guidance on meeting expectations of ei process safety management framework element 5 communication...

Guidance on meeting expectations of EI Process safety management framework

Element 5: Communication with stakeholders

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK ELEMENT 5:

COMMUNICATION WITH STAKEHOLDERS

1st edition

January 2014

Published byENERGY INSTITUTE, LONDON

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK ELEMENT 5: COMMUNICATION WITH STAKEHOLDERS

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CONTENTSPage

Publications in this series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.1 Communication with stakeholders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.2 Expectations for element 5: Communication with stakeholders . . . . . . . . . . . . . . . . . 7

2 Arrangements for meeting expectations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.1 Descriptions of actions for each step in the logical flow diagram . . . . . . . . . . . . . . . 11

3 Suggested compliance checks and performance measures . . . . . . . . . . . . . . . . . . . . 20 3.1 Performance measure 1: Element compliance and implementation status (EIPSS rating) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 3.2 Performance measure 2: Stakeholder engagement and communication programme status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.3 Performance measure 3: Stakeholder engagement and communication programme – outstanding issues . . . . . . . . . . . . . . . . . . . . 24 3.4 Performance measure 4: Number of complaints received . . . . . . . . . . . . . . . . . . . . . 25 3.5 Performance measure 5: Complaints follow-up and outstanding issues . . . . . . . . . . 26 3.6 Performance measure 6: Communication with stakeholders – observed non-compliances . . . . . . . . . . . . . . . . . . . . . . 27 3.7 Performance measure 7: Overdue field observations . . . . . . . . . . . . . . . . . . . . . . . . 28 3.8 Performance measure 8: Incident root causes which are failures of element 5 . . . . . 29

Annexes

Annex A References and bibliography. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 A.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 A.2 Further resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Annex B Glossary of acronyms and abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Annex C Mapping of steps to EI PSM framework expectations . . . . . . . . . . . . . . . . . . . 32

Annex D Example report template: Management and supervisory field observation. . 33



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PUBLICATIONS IN THIS SERIES

Guidance on meeting expectations of EI Process safety management framework

− Element 1: Leadership, commitment and responsibility

− Element 2: Identification and compliance with legislation and industry standards

− Element 3: Employee selection, placement and competency, and health assurance

− Element 4: Workforce involvement

− Element 5: Communication with stakeholders

− Element 6: Hazard identification and risk assessment

− Element 7: Documentation, records and knowledge management

− Element 8: Operating manuals and procedures

− Element 9: Process and operational status monitoring, and handover

− Element 10: Management of operational interfaces

− Element 11: Standards and practices

− Element 12: Management of change and project management

− Element 13: Operational readiness and process start-up

− Element 14: Emergency preparedness

− Element 15: Inspection and maintenance

− Element 16: Management of safety critical devices

− Element 17: Work control, permit to work and task risk management

− Element 18: Contractor and supplier, selection and management

− Element 19: Incident reporting and investigation

− Element 20: Audit, assurance, management review and intervention



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FOREWORD

Process safety management (PSM) is vital to ensuring safe and continued operations in major accident hazard (MAH) organisations. However, PSM is a multifaceted process, and a number of high profile incidents since 2005 have suggested that without a holistic understanding of the various factors required for effective PSM it can be difficult and inefficient to ensure, and measure, performance.

In 2010 the Energy Institute (EI) published High level framework for process safety management ('PSM framework'), which aimed to define what PSM should involve. Divided into four focus areas (process safety leadership, risk identification and assessment, risk management, and review and improvement) and sub-divided into 20 'elements', it sets out a framework of activities MAH organisations should undertake to ensure PSM. Each element lists a number of high level activities organisations should meet (expectations).

EI Guidance on meeting expectation of EI Process safety management framework is a series of 20 publications ('guidelines') that build on the PSM framework. Commissioned by the EI Process Safety Committee (PSC) each guideline captures and presents current industry good practices and guidance on how organisations can meet the expectations set out in each element of the PSM framework. Each guideline includes:

− A logical flow diagram of activities ('steps') the organisation should undertake to manage that element.

− Descriptions of those steps. − Example performance measures (PMs) to measure the extent to which key steps have

been undertaken. − A list of further resources to help undertake key steps. − A table mapping the steps against the expectations in the PSM framework. − Annexes of useful information.

Readers implementing the guidance in this publication should be aware of the PSM framework and the other publications in this series, particularly if they are a manager with oversight of the wider implementation of PSM.

The information contained in this publication is provided for general information purposes only. Whilst the EI and the contributors have applied reasonable care in developing this publication, no representations or warranties, express or implied, are made by the EI or any of the contributors concerning the applicability, suitability, accuracy or completeness of the information contained herein and the EI and the contributors accept no responsibility whatsoever for the use of this information. Neither the EI nor any of the contributors shall be liable in any way for any liability, loss, cost or damage incurred as a result of the receipt or use of the information contained herein.

Suggested revisions are invited and should be submitted through the Technical Department, Energy Institute, 61 New Cavendish Street, London, W1G 7AR. e: [email protected]



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ACKNOWLEDGEMENTS

EI Guidance on meeting expectations of EI Process safety management framework was commissioned by the Energy Institute (EI) Process Safety Committee (PSC) and prepared by Martin Ball (Bossiney Consulting). During this project, PSC members included:

Martin Ball Bossiney ConsultingDavid Bleakley ConocoPhillipsJohn Brazendale Health and Safety ExecutiveJohn Briggs Kuwait Petroleum InternationalJonathan Carter MarshJames Coull TotalKenny Crighton NexenPeter Davidson UKPIAGraeme Ellis ABBDr David Firth Chilworth GroupPeter Gedge (Chair) BPJohn Henderson CB&I Lummus (BCECA)Bob Kilford EDF EnergyKing Lee (Vice-chair) Lloyd’s RegisterKeith Lewis Total E&P UK LtdPaul McCulloch E.ONSreeRaj Nair ChevronPeter O’Toole Tullow OilJohn Pond ConsultantDr Niall Ramsden Resource Protection InternationalToby St.Leger ConocoPhillipsDr Mark Scanlon (Secretary) Energy InstituteDon Smith Eni UK

The following additional individuals are acknowledged for commenting on the draft for consultation of this series of publications:

Lee Allford European Process Safety CentreMike Beanland ABBAmanda Cockton Health and Safety ExecutiveEdwin Ebiegbe E.ONAllan Ormond ABB

Technical editing was carried out by Stuart King (EI).

Affiliations are correct at the time of contribution.



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1 INTRODUCTION

1.1 COMMUNICATION WITH STAKEHOLDERS

This guideline sets out good practices for communication with stakeholders in health, safety and environment (HS&E) and process safety. Establishing and maintaining stakeholders’ confidence is an important factor in maintaining an organisation’s licence to operate. Management should identify key stakeholder groups and develop and maintain a good working relationship with them, understanding and addressing their issues and concerns.

The focus of this element and this guideline is primarily on developing and maintaining effective communication with external stakeholders. Communication with internal stakeholders is addressed by both this guideline and Guidance on meeting expectations of EI Process safety management framework Element 1: Leadership, commitment and responsibility. The identification of relevant stakeholders and the specific approaches or agendas for communication with them should be cognisant of the organisation’s HS&E and process safety policies and required leadership attributes as defined in element 1. This guideline focuses on the development of systematic HS&E and process safety communication and engagement programmes which should be in place in order to establish and maintain the confidence of stakeholders in the organisation’s ability to manage the HS&E and process safety risks associated with its activities.

1.2 ExPECTATIONS FOR ELEMENT 5: COMMUNICATION WITH STAKEHOLDERS

Element 5 of EI High level framework for process safety management (PSM framework) describes six expectations – arrangements and processes that organisations should (to an appropriate degree) have in place in order to ensure they are managing this aspect of PSM appropriately:'Overview: Establishing and maintaining stakeholders’ confidence is a key factor in

maintaining an organisation’s licence to operate. Management must identify key stakeholder groups and develop and maintain

a good working relationship with them, understanding and addressing their issues and concerns.

5.1 A defined communications system supports the organisation to identify, develop and maintain a good working relationship with the statutory and non-statutory stakeholders about its activities, including emergency response communications.

5.2 Organisations ensure and demonstrate that the consultation process with statutory and non-statutory stakeholders is appropriate and proportionate, and follows a defined process.

5.3 Appropriate HS&E and process safety information is published in the public domain to demonstrate the organisation’s commitment to continually improving its performance.



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5.4 Effectiveness of programmes for communication with stakeholders is regularly reviewed by specified levels of management.

5.5 Arrangements for communication with stakeholders are understood and followed; understanding of arrangements and compliance with them is regularly tested.

5.6 Compliance and performance trends are reviewed by specified levels of management.'

This guideline provides a process, along with guidance, to help organisations meet these expectations. It also suggests a number of compliance checks and performance measures (PMs) to measure the extent to which key activities involved in meeting these expectations have been or are being undertaken.



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2 ARRANGEMENTS FOR MEETING ExPECTATIONS

Figure 1 provides a logical flow diagram for the activities that should be in place to meet the expectations in element 5, to effectively manage communication with stakeholders. It covers activities (steps) which should be undertaken by the organisation, across three phases: set-up (preparations to manage the element); operate (management of the element); and monitor, review and intervene (monitoring and reviewing the management of the element, and making appropriate interventions if the element is not being managed effectively).

The flow diagram provides an example of the logical arrangement of necessary activities. The reader should take cues from the arrangement and relationships between steps when determining the appropriate flow design for their own organisation. The flow diagram also shows interfaces with other elements, where this element may be dependent upon activities that are addressed by other elements – e.g. step 2 relies on there being an effective competence management system in place, as described in Guidance on meeting expectations of EI Process safety management framework Element 3: Employee selection, placement and competency, and health assurance.

At specific points in the flow diagram process, PMs are suggested. These PMs are predominantly leading indicators designed to enable the measurement of the outputs from the element and the level of operational compliance with the expectations. Suggested PMs are described further in section 3.

2.1 provides guidance on the actions involved for each step, the deliverables that should result from those actions, the frequency at which the step should be undertaken. It also provides more detailed guidance notes.

These steps have been mapped against element 5 expectations in Annex C. Note that some expectations are fulfilled through several steps, and some steps help fulfil several expectations, however all steps should be undertaken. As such, Annex C is for reference purposes only, to demonstrate that the arrangements outlined in this guideline enable the organisation to work towards fulfilling the requirements set out in element 5 of the PSM framework.



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01

Identify and appointresponsible persons,

define delegated authorities for decision making

02

Ensure competence of appointed

responsible persons

04

Prepare listing of stakeholders

05

Assign responsibility for each stakeholder

06

Gap analysis and identify stakeholder interests and

issues

11

Develop complaint handling process

12

Implement complaint handling process

13

Follow-up on complaints

07

Develop stakeholder engagement plan

08

Implement stakeholder engagement plan

10

Review outcomes from stakeholder engagement

14

Performance measurement and

compliance checking

17

Management review and control

meetings

16

Annual review of effectiveness and suitability of element arrangements

15

Performance and compliance trend

analysis

Monitor, review and intervene

03

Prepare list of typical stakeholder groups

09

Prioritise and follow-up on issues from stakeholder engagement

and communication

Set-up

Operate

HS&E and process safety policy; required leadership attributes; legislative requirements

Element 19

Element 3

2

3

4

5

Performance measures

1

6

7

8 8

4

Figure 1: Logical flow diagram



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2.1 DESCRIPTIONS OF ACTIONS FOR EACH STEP IN THE LOGICAL FLOW DIAGRAM

Step Actions Deliverables Frequency

01 Identify and appoint responsible persons; define delegated authorities for decision making

Identify and appoint persons who will have defined roles and responsibilities for each aspect of the arrangements for communication with stakeholders.

Defined roles and responsibilities.

Agreed list of responsible persons who will:

− act as element owner, and

− carry out each aspect of the arrangements for the element.

Defined delegated authorities for decision making.

Agreed list of delegated authorities for each identified responsible person/position.

During implementation; then as required.

Guidance notes:

The senior accountable person, typically a director, business unit (BU) leader or site manager should ensure that accountabilities and responsibilities are assigned for each step in the process. Typically this can be achieved by appointing an element owner who will work with line managers to agree and assign these accountabilities and responsibilities.

Typically, the element owner should be a senior line manager.

During the implementation phase the element owner should coordinate the implementation of the element across the organisation, BU or site on behalf of the senior accountable person, working with other senior line managers to ensure that the implementation is appropriately planned and resourced and that any issues are resolved.

The element owner should also ensure that delegated authorities for decision making within the element are defined and approved.

Following implementation, during the operational phase the element owner should work with other senior line managers to ensure that the element continues to operate as intended. In effect the element owner should act as a coach to the management team, building their understanding and confidence in the use of the element.

02 Ensure competence of appointed responsible persons

Training material.

Competency assessment.

Training schedule.

Competent persons.

During implementation; then as required



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02 cont...

Define required HS&E and process safety attributes and example behaviours for each level and integrate into the organisation’s competency framework (see Guidance on meeting expectations of EI Process safety management framework Element 3: Employee selection, placement, competency and health assurance).

Guidance notes:

The element owner should ensure that the required competencies are defined and agreed for all persons with assigned roles and responsibilities within the element and that each of these people is trained and coached appropriately to develop these required competencies.

They should also ensure that training and development programmes and routine personnel performance appraisals take into account these required competencies. This should be accomplished by means of Guidance on meeting expectations of EI Process safety management framework Element 3: Employee selection, placement, competency and health assurance.

03 Prepare a list of typical stakeholder groups

Prepare a list of typical stakeholders for each segment and location within the organisation.

Take into account legislative requirements, HS&E and process safety policy, and required leadership attributes.

Identify reason why stakeholders should be on the list.

Approved list of typical stakeholders for each segment and location within the organisation.

Identified reason why each typical stakeholder is included on the list.

Approved guidelines for communication and engagement with each identified typical stakeholder.

During implementation; then as required (review annually).



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03 cont...

Prepare generic guidelines for communication and engagement approach for each identified typical stakeholder.

The list and guidelines should be reviewed and approved by persons with the authority to do so.

Guidance notes:

The element owner should ensure that a list of typical stakeholders is prepared for each segment and location within the business. When developing this list cognisance should be taken of the organisation’s HS&E and process safety policies and relevant legislative requirements. The following groups should be considered for inclusion in the list:

− neighbours; − legislative bodies; − local authorities; − planning authorities; − emergency services; − local opinion formers; − local councillors and politicians (e.g. Members of Parliament (MPs)) − industry bodies; − insurers; − financiers; − shareholders; − customers; − suppliers, and − contractors.

The element owner should ensure that generic guidelines for the communication and engagement approach for each identified typical stakeholder are prepared. In developing these generic guidelines the required leadership attributes and behaviours defined in Guidance on meeting expectations of EI Process safety management framework Element 1: Leadership, commitment and responsibility should be taken into account.

The guidelines should set out how the organisation will interact with the identified stakeholders, defining the scope, communication pathways and tools.

The guidelines should consider what information (if any) about HS&E and process safety performance the organisation will publish and release into the public domain.

It should be recognised that communication with stakeholders is a two-way process, interacting both with groups the organisation may wish to influence and groups from which the organisation would wish to receive information. The guidelines should define the scope and boundaries for these interactions, together with advice on how to set delegated authorities to represent the organisation’s position with these outside bodies.



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Guidance notes cont...

The guidelines should also provide advice on how authority to represent the organisation’s position on industry bodies and committees should be set.

The list and guidelines should be reviewed and approved by persons with the authority to do so.

04 Prepare listing of stakeholders

Develop specific stakeholder listing for each segment of the organisation.

List all stakeholders who will be included in the communication and engagement programme.

The list should be reviewed and approved by persons with the authority to do so.

Approved list of named stakeholders for each segment of the organisation, who will be included in the communication and engagement programme.


Guidance notes:

The element owner should ensure that the management teams in each segment and location within the business develop and approve a list of named stakeholders, who will be included in the communication and engagement programme. For local populations, the named stakeholder could be the emergency services; however, communication may still be required directly with the public (e.g. through regular meetings, mail drops, etc.).

05 Assign responsibility for each stakeholder

Identify persons who will manage communication and engagement with each identified stakeholder.

Agreed assigned responsibilities for managing communication and engagement with each of the identified stakeholders.


Guidance notes:

The element owner should ensure that responsibilities for managing communication and engagement with each of the identified stakeholders are assigned.

They should also ensure that the assigned persons are appropriately trained, understand what is expected of them, their authority level and that they have the necessary time and resources to carry out what is required of them.



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06 Gap analysis and identify stakeholder interests and issues

Assess current communication and engagement with stakeholders compared with the defined guidelines developed in step 3.

Identified interests and issues for each identified stakeholder.

Identified communication and engagement gaps which need to be closed.


Guidance notes:

The responsible persons in each segment of the organisation should ensure that a gap analysis is carried out to identify any deficiencies in the communication with each of the identified stakeholders, compared with the guidelines defined in step 3.

The responsible persons should also identify the specific interests and issues for each of the identified stakeholders.

07 Develop stakeholder engagement plan

Annual plan for communication and engagement with each identified stakeholder.

The plan should be reviewed and approved by persons with the authority to do so.

Approved comprehensive annual communication plan for all identified stakeholders covering:

− proposed approach; − topics to be addressed;

− schedule, and − resource requirements.

During implementation; then updated periodically (quarterly) as required.

Guidance notes:

The responsible persons in each segment of the organisation should ensure that a comprehensive communication plan is developed, incorporating all of the identified stakeholders and covering:

− the proposed approach; − topics to be addressed; − schedule, and − resource requirements.

The plan should be reviewed and if necessary updated on a periodic (quarterly) basis taking into account any changes to stakeholders, topical issues and feedback from the communication and engagement programme.



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08 Implement stakeholder engagement plan

In full, on schedule delivery of the engagement and communication plan.

Effective engagement and communication and constructive relationships with stakeholders.

Understanding of stakeholders’ issues and concerns.

Stakeholder confidence in organisation’s ability to manage the HS&E and process safety risks associated with its activities.

As required by the schedule.

Guidance notes:

The responsible persons in each segment should ensure that communication and engagement with stakeholders are carried out in line with the agreed plan and that the required feedback and reporting are carried out.

09 Prioritise and follow-up on issues from stakeholder engagement and communication

Issues identified as a result of stakeholder engagement and communication systematically prioritised and followed up on a timely basis.


Guidance notes:

Issues identified as a result of the communication and engagement programme should be prioritised and followed up on a timely basis.

Relevant stakeholders should be kept up-to-date with progress on any issues they have raised.

10 Review outcomes from stakeholder engagement

Identified issues and opportunities are prioritised to include updates of stakeholder communication and engagement plan.


Guidance notes:

Feedback and outcomes from the communication and engagement programme should be routinely reviewed in order to identify:

− developing issues which need to be addressed; − what is going well with the programme, and − what needs to be improved with the programme.



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Guidance notes cont...

It may be useful to carry out periodic opinion surveys to assess the opinions and perceptions of the organisation which are held by the identified stakeholders and the local community.

11 Develop complaint handling process

Develop a complaint handling process. The process should be reviewed and approved by persons with the authority to do so.

Approved complaint handling process:

− defined process; − defined roles and responsibilities;

− required competencies, and

− required resources.

During implementation; then updated as required (review annually).

12 Implement complaint handling process

Fully implemented complaint handling process.


13 Follow-up on complaints

Prioritise complaints and ensure that they are followed up and closed out on a timely basis.

Complaints systematically prioritised, followed up and closed out on a timely basis.

As required.

Guidance notes:

The element owner should ensure that effective complaint handling processes are developed and implemented for all of the organisation’s segments and operating locations.

The complaint handling process should be easily accessible by the local community and other stakeholders. Complaints should be categorised to identify the most significant issues so that they can be appropriately prioritised for follow-up.

Response to complainants should be timely and they should be kept briefed on progress by following up on their complaint.

The more significant complaints should be considered as incidents, and investigated accordingly, to identify the root causes and appropriate recommendations to address them. This should be done in line with Guidance on meeting expectations of EI Process safety management framework Element 19: Incident reporting and investigation.

14 Performance measurement and compliance checking

Establish and implement PMs.

Defined PMs.

PMs generated in line with the schedule.




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14 cont...

Establish regular management and supervisory compliance checks (see Annex D for an example management and supervisory field observation form).

Compliance checking programme.

Completed compliance checks.

Identified necessary interventions.

Guidance notes:

A systematic set of PMs should be defined in order to enable each BU or site to monitor and confirm compliance with the element and to draw attention to any areas of non-compliance.

In order to maintain effective control the element owner should ensure that accountability for performance against each PM is clearly identified and that the accountable person understands the interventions that need to be made to correct deviations in performance against the PM.

The element owner should ensure that PMs are reviewed by an appropriate level of management on a routine scheduled basis.

The suggested PMs are defined in Section 3.

15 Performance and compliance trend analysis

PMs and findings from compliance checks are analysed to identify any emerging underlying trends.

A report on trends identified, for review:

− at appropriate management meetings;

− by BU executive, and − by company executive.

Monthly.

Guidance notes:

This guideline defines suggested PMs which will allow the BU or site to monitor compliance with the element. This is an important aspect of management control but it does not provide the whole picture. Findings from compliance checking and performance monitoring should be reviewed and analysed in order to identify any underlying trends. The trends which should be monitored and analysed should also be adapted according to performance and the issues being managed during any particular time period. However, the key issue is to ensure that resource is assigned to carry out this monitoring and analysis and that this trend analysis is carried out on a routine basis and presented for review at appropriate management meetings.

16 Annual review of effectiveness and sustainability of element arrangements

A report identifying: − issues requiring resolution, and

− opportunities to enhance the arrangements.

Annually.



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16 cont...

Review of the arrangements to check that they are functioning as intended and are still fit for purpose.

Guidance notes:

The element owner should initiate an annual review of the element in order to check that it is still functioning as intended and that it is still fit for purpose, identifying any issues requiring resolution or any opportunities to enhance the implementation of the element.

The element owner should ensure that appropriate employees and employees’ representatives are involved in developing input to this review.

17 Management review and control meetings

Management review and control meetings by the appropriate levels of management.

Systematic review of defined PM sets.

Review emerging issues identified by the analysis of trends.

Manage issues and opportunities identified by an annual review of the process.

Appropriate interventions.

PMs and trend analysis reviewed at appropriate management meetings by:

− local line management;

− BU executive, and − company executive.

Appropriate interventions to correct deviations from required performance.

Initiation of appropriate actions to address findings from the annual review.

Monthly.

Guidance notes:

The element owner should ensure that the review of the PMs is incorporated into appropriate management control meetings. It is likely that it will be necessary to incorporate the PMs into meetings at a number of different levels. For example, they may need to be incorporated into executive meetings and into senior management team meetings. The scope of any PMs should be matched to the area of the business which is being reviewed at each meeting.

The management control meetings should focus on deviations from the required performance, identifying necessary interventions to correct performance.

The PMs and the output from these management control meetings may provide input to appropriate health and safety committees.



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3 SUGGESTED COMPLIANCE CHECKS AND PERFORMANCE MEASURES

This guideline provides a set of suggested implementation and operational PMs.The suggested implementation PMs can be used during the implementation phase to

measure and monitor progress with the implementation of the arrangements for leadership, commitment and responsibility.

The suggested operational PMs can be used to measure compliance with the element as part of normal operation. The reader should refer to Figure 1 to indicate which PMs are relevant to which steps.

The suggested measures identify aspects of performance that should be controlled in order to assure the integrity of the operation. In order to be controlled they should be measured by someone in the organisation – if they aren’t measured they are unlikely to be controlled.

The measurement regime should be appropriate for the business, taking into account the risk to the business associated with each parameter being out of control.

The required frequency of measurement and checking may vary according to the level of demonstrated performance; if the performance of a parameter is demonstrated to be under control, then the measurement and checking interval may be extended. However, if the performance of the parameter is shown to be unacceptable the interval should be reduced. It should be ensured that there is a frequency of measurement and checking which assures an appropriate level of control.

Table 1: Performance measures for element 5

No. Type Performance measure

1 Compliance and implementation Element compliance and implementation status (EIPSS rating)

2 Operational Stakeholder engagement and communication programme status

3 Operational Stakeholder engagement and communication programme –outstanding issues

4 Operational Number of complaints received

5 Operational Complaints follow-up and outstanding issues

6 Operational Communication with stakeholders – observed non-compliances

7 Operational Overdue field observations

8 Outcome Incident root causes which are failures of element 5



21

3.1 PERFORMANCE MEASURE 1: ELEMENT COMPLIANCE AND IMPLEMENTATION STATUS (EIPSS RATING)

This PM enables management to monitor the implementation and compliance of this element of the EI PSM framework. It makes use of the EI Process Safety Survey (EIPSS) to enable the business to carry out a systematic self-assessment of their compliance with the expectations of element 5.

The EIPSS can be used for a baseline assessment of compliance, which can then be updated as those responsible close each of the individual identified gaps. In this way it provides management with an easily developed continuously updated assessment of implementation and compliance.

The line manager accountable for implementation should make a corrective intervention if the actual progress falls below plan. It is likely the required interventions would be either to adjust priorities to create space to allow this work to be done, to make additional resource available or to reset the schedule to reflect what can be achieved realistically with the assigned resource.

Table 2: Element compliance and implementation status (EIPSS rating) – PM overview

Type Required data Representation

Compliance and implementation

By month: − current element 5, target EIPSS overall rating;

− current element 5, actual EIPSS overall rating;

− current element 5, EIPSS documented arrangements rating, and

− current element 5, EIPSS implementation rating.

Line and bar graph: − target overall element rating (line);

− overall element rating (bar);

− documented arrangements rating (line), and

− implementation rating (line).



22

Overall status Implementation Documented arrangements Target overall status

Figure 2: Suggested presentation of PM 1: Element 5 compliance and implementation status (EIPSS rating)

4

3.5

3

2.5

2

1.5

1

0.5

0

EIPS

S ra

ting

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec



23

3.2 PERFORMANCE MEASURE 2: STAKEHOLDER ENGAGEMENT AND COMMUNICATION PROGRAMME STATUS

This PM enables management to monitor the stakeholder engagement and communication programme, tracking actual against scheduled engagement with stakeholders.

The graphical representation of this PM is likely to be supplemented by a listing of the overdue engagements, together with the responsible line manager, reasons and plans to address the failure to complete the scheduled engagements

The line manager accountable for the stakeholder engagement and communication programme should make a corrective intervention if the actual number of engagements completed falls below schedule. It is likely the required interventions would be either to adjust priorities to create space to allow this work to be done, to make additional resource available or to reset the schedule to reflect what can be achieved realistically with the assigned resource.

Table 3: Stakeholder engagement and communication programme status – PM overview


Operational By month: − scheduled number of stakeholder engagements;

− number of stakeholder engagements completed, and

− number of stakeholder engagements overdue.

Line/stacked bar: − number scheduled (line); − number completed (bar), and

− number overdue (bar).

02468

10121416


Stak

ehol

der e

ngag

emen

ts

Completed Overdue Scheduled

Figure 3: Suggested presentation of PM 2: Stakeholder engagements



24

3.3 PERFORMANCE MEASURE 3: STAKEHOLDER ENGAGEMENT AND COMMUNICATION PROGRAMME – OUTSTANDING ISSUES

This PM enables management to monitor the status of follow-up actions to issues identified during the engagement and communication programme, tracking outstanding major and minor issues.

The graphical representation of this PM is likely to be supplemented by a listing of the outstanding issues, together with the responsible line manager, plan and schedule to resolve the issue and any assistance required.

The line manager accountable should make a corrective intervention if there is an adverse trend with an increasing backlog of unresolved issues. It is likely the required intervention would be either to adjust priorities to create space to allow this work to be done, or to make additional resource available. It is unlikely that it would be acceptable to tolerate an increasing backlog of issues to be resolved.

Table 4: Stakeholder engagement and communication programme – outstanding issues – PM overview


Operational By month: − number of major issues outstanding, and

− number of minor issues outstanding.

Stacked bar: − number of major issues, and

− number of minor issues.

02468

10121416


No.

of i

ssue

s

Minor issues Major issues

Figure 4: Suggested presentation of PM 3: Stakeholder engagement – outstanding issues



25

3.4 PERFORMANCE MEASURE 4: NUMBER OF COMPLAINTS RECEIvED

This PM enables management to monitor the number and significance of complaints being received, tracking the number of major and minor complaints.

The graphical representation of this PM is likely to be supplemented by a listing of the major complaints received, together with the accountable line manager.

The accountable line manager should make a corrective intervention if there is an adverse trend with an increasing number of complaints being received. It is likely the required intervention would be to assign resource to identify any common underlying sources and causes for the complaints, in order to focus efforts to resolve the most frequent root causes of the complaints and correct the trend.

Table 5: Number of complaints received – PM overview


Operational By month: − number of major issue complaints received, and

− number of minor issue complaints received.



02468

1012141618


No.

of c

ompl

aint

s


Figure 5: Suggested presentation of PM 4: Number of complaints received



26

3.5 PERFORMANCE MEASURE 5: COMPLAINTS FOLLOW-UP AND OUTSTANDING ISSUES

This PM enables management to monitor the status of the follow-up to issues identified by the received complaints, tracking outstanding major and minor issues.

The graphical representation of this PM is likely to be supplemented by a listing of the outstanding issues, together with the responsible line manager, plan and schedule to resolve the issue and any assistance required.

The accountable line manager should make a corrective intervention if there is an adverse trend with an increasing backlog of unresolved issues. It is likely the required intervention would be either to adjust priorities to create space to allow this work to be done, or to make additional resource available. It is unlikely to be acceptable to tolerate an increasing backlog of unresolved issues.

Table 6: Complaints follow-up and outstanding issues – PM overview


Operational By month: − number of major issues outstanding, and

− number of minor issues outstanding.



02468

101214161820


No.

of i

ssue

s


Figure 6: Suggested presentation of PM 5: Complaints – outstanding issues



27

3.6 PERFORMANCE MEASURE 6: COMMUNICATION WITH STAKEHOLDERS – OBSERvED NON-COMPLIANCES

This PM enables management to monitor whether the required communication arrangements with stakeholders are being implemented satisfactorily, tracking the number of major and minor non-compliances whilst implementing the arrangements.

The graphical representation of this PM is likely to be supplemented by analysis of the root causes of the non-compliances and proposed corrective actions.

The accountable line manager should make an intervention if there is a prolonged increasing trend in the number of non-compliances. It is likely that the intervention would be to question what additional support or resources would be required to correct the trend.

Table 7: Communication with stakeholders – observed non-compliances – PM overview


Operational By month: − number of major non-compliances with required arrangements, and

− number of minor non-compliances with required arrangements.

Stacked bar graph: − major non-compliances, and

− minor non-compliances.

0

1

2

3

4

5

6

7


No.

of n

on-c

ompl

ianc

es


Figure 7: Suggested presentation of PM 6: Observed non-compliances with communication agreements with stakeholders



28

3.7 PERFORMANCE MEASURE 7: OvERDUE FIELD OBSERvATIONS

This PM enables management to monitor whether the scheduled field observations have been carried out, tracking the number of management and supervisory field observations overdue.

The graphical representation of this PM is likely to be supplemented by a listing of the supervisors with overdue field observations and their line manager.

The accountable line manager should make an intervention if there are any overdue supervisory observations. It is likely that the intervention would be to question what has prevented the field observations from being done and possibly to adjust priorities in order to make time, or to provide additional resource to enable the required supervisory observations to be completed.

Table 8: Overdue field observations – PM overview


Operational By month: − number of overdue supervisory field observations.

Bar graph: − overdue field observations.

0

1

2

3

4

5

6

7


No.

ove

rdue

Figure 8: Suggested presentation of PM 7: Overdue field observations



29

3.8 PERFORMANCE MEASURE 8: INCIDENT ROOT CAUSES WHICH ARE FAILURES OF ELEMENT 5

This PM enables management to monitor the trend of the number of times a failure of some aspect of element 5 is identified as a root cause of an incident. (Guidance on meeting expectations of EI Process safety management framework Element 19: Incident reporting and investigation, provides guidance on how root causes should be aligned to failures of EI PSM framework elements). This information should assist line managers to understand whether their arrangements for meeting the expectations of element 5 are achieving the required outcome.

A constant or increasing number of root causes associated with a failure of this element would indicate that there is a need to review the effectiveness of the arrangements and their implementation.

Table 9: Incident root causes which are failures of element 5 – PM overview


Outcome (lagging indicator)

By month: − number of incident root causes which are failures of element 5, categorised as root causes of:

− very serious incidents; − serious incidents, and − incidents.

Stacked bar: − very serious incidents; − serious incidents, and − incidents.

0

2

4

6

8

10

12

14


No.

of I

ncid

ents

Incidents Serious incidents Very serious incidents

Figure 9: Suggested presentation of PM 8: Incident root causes which are failures of element 5



30

ANNEx AREFERENCES AND BIBLIOGRAPHY

A.1 REFERENCES

EI, High level framework for process safety management,http://www.energyinst.org/psm-framework

A.2 FURTHER RESOURCES

This section contains a non-exhaustive list of further resources to help organisations implement element 5. Resources include pertinent guidance publications, codes of practice, standards, and practical tools.

Description Step

Advice Services Alliance

A practical guide to writing a stakeholder communications strategy,

http://www.asauk.org.uk/fileLibrary/pdf/A_practical_guide_to_writing_a_stakeholder_communications_strategy.pdf

03,04, 06,07

HSE HSG254, Developing process safety indicators: A step-by-step guide for the chemical and major hazard industries,

http://books.hse.gov.uk/hse/public/saleproduct.jsf?catalogueCode=9780717661800

14,15

HSE HSE and the Environment Agency generic design assessment (GDA): stakeholder engagement plan, October 2010,

http://www.hse.gov.uk/newreactors/joint-strategy-action-plan.pdf

(This is an example of a stakeholder engagement plan)

07



31

ANNEx BGLOSSARY OF ACRONYMS AND ABBREvIATIONS

BU business unitEIPSS Energy Institute Process Safety SurveyHSE Health and Safety ExecutiveHS&E health, safety and environmentMAH major accident hazardMP Member of ParliamentPM performance measurePSC Process Safety CommitteePSM process safety management


GU

IDA

NC

E ON

MEETIN

G EX

PECTA

TION

S OF EI PRO

CESS SA

FETY M

AN

AG

EMEN

T FRAM

EWO

RK

ELEMEN

T 5: CO

MM

UN

ICA

TION

WITH

STAK

EHO

LDERS

32

ANNEx CMAPPING OF STEPS TO EI PSM FRAMEWORK

Table C1: Mapping of steps to EI PSM framework expectations for element 5

Expectation Step number

01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17

5.1 A defined communication system supports the organisation to identify, develop and maintain a good working relationship with statutory and non-statutory stakeholders about its activities, including emergency response communications.

5.2 Organisations ensure and demonstrate that the consultation process with statutory and non-statutory stakeholders is appropriate and proportionate, and follows a defined process.

5.3 Appropriate HS&E and process safety information is published in the public domain to demonstrate the organisation’s commitment to continually improve its performance.

5.4 Effectiveness of programmes for communication with stakeholders are regularly reviewed by specified levels of management.

5.5 Arrangements for communication with stakeholders are understood and followed, understanding of arrangements and compliance with them is regularly tested.

5.6 Compliance and performance trends are reviewed by specified levels of management.



33

ANNEx DExAMPLE REPORT TEMPLATE: MANAGEMENT AND SUPERvISORY FIELD OBSERvATION

Management and supervisory field observation report

Communication with stakeholders

Location: Date:

Work group leader: Observer:

Rating Comments

1 2 3 4 n/a

Is there a comprehensive and up to date list of stakeholders?

Are there comprehensive and effective stakeholder engagement plans in place?

Has responsibility for each stakeholder been assigned appropriately?

Are assigned personnel aware of and understand their responsibilities for communication with stakeholders?

Is there evidence that stakeholder engagement plans are implemented?

Is there evidence that stakeholder engagement is effective?

Is there evidence that stakeholder concerns are followed up appropriately?

Is the complaint handling process effective?

Is there evidence that complaints are followed up systematically and appropriately?

1 = Major deficiency identified

3 = Meets expectations

2 = Minor deficiency identified

4 = Exceeds expectations

Note: Organisations should define what will be considered as major and minor deficiencies; the use of the risk matrix may assist with this.


This publication has been produced as a result of work carried out within the Technical Team of the Energy Institute (EI), funded by the EI’s Technical Partners and other stakeholders. The EI’s Technical Work Programme provides industry with cost effective, value adding knowledge on key current and future issues affecting those operating in the energy sector, both in the UK and beyond.

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