Type - MDL 2179 Trial Docs · Type: GoM DxC E&P - GoM Deepwater - GoM Deepwater Production Full ......

Gap Analysis Lead:Exported On:

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GoM DxCE&P - GoM Deepwater - GoM Deepwater ProductionFull

Webster Mark (BP1\websteme)6/16/2009

Assessment Data ExportAssessment:Organisational Unit:

GoM DC OMS Gap Assessment Webster, Rev.0, 6/16/09

ID Element Sub-Element Sub-Element SPA Statement Conformance Rating

Risk Ranking Evidence Comments Gap comment Gap Title Aggregated Gap Gap Risk Broad Corrective Action Specific Corrective Action(s) SPA Target Date Date, Status Closed

1.1.1 Leadership Operating Leaders Vice President Define and then annually review and communicate to the workforce an entity vision that includes details of how the application of OMS will enable continuous risk reduction and performance improvement and safe, responsible and reliable operating.

Level 4 4-Moderate to High

1) D&C Vision Statement with Values 2) Business Plan updated annually 3) Leadership Performance contracts and Individual Objectives 4) HSE Annual Plan and frequent LT and townhall reviews 5) D&C People Agenda 6) DCLT Collective Priorities

1.1.2 Leadership Operating Leaders Vice President Demonstrate management commitment to compliance with legal and regulatory requirements, to the application of OMS and to conformance with BP requirements. 1.1.2.1 Conduct periodic and planned leadership site reviews.


1) High-level Risk Register captures requirements 2) DWOP and ETPs 3) MMS Subpart O Plan 4) Compliance Management System 5) BP Engineering Authorities manage GDP compliance 5) Internal and External inspections 6) Field Self-Verification System audits 7)Regulatory Expertise assigned 8) BP Team Leads review compliance procedures 9) D&C Procedures are peer-reviewed and undergo approval process 10) APD and APM approval by MMS 11) MMS on-site inspection 12) OSHA requirements in Safe Practices Manual 13)Bridging documents to Contractor Program 14) EMS 15) BtB 16) INCs, etc. are recorded in scorecards and are routinely monitored 17) Periodic meetings with VPDC to discuss compliance 18) HSE Regulatory monitors and communicates changes 1.1.2.1: [no data]

Lack of understanding of OMS OMS Understanding OMS 3-Basics/BP Implement OMS Develop broad audience communication prior to and during organization move to OMS.

Jassal 12/30/09 11/20: Complete. Four newsletter articles to date. Poster's staged on D&C floors. Initial communication at engineer Lesson Learned meeting. Staged communication packs for team meetings delivered on OMS, D&C specifics, Navigator.

y

1.1.3 Leadership Operating Leaders Vice President Model behaviours by personal example that reinforce continuous risk reduction and performance improvement. 1.1.3.1 Verify that operations integrity risks are systematically identified, understood and managed: verify understanding of risks with key stakeholders; review risk mitigation plans periodically, know the key elements, and communicate to stakeholders as needed.

Level 4 5-High 1) AFEs 2) Decision Support Packages 3) BtB 4) Risk Assessments 5) Stop the Job participation 6) Stage Gate Reviews 7) Leadership visits to the field with safety focus 8)Risk Management Plan document (draft) including leaderships' roles 9) Major Accident Risk Mitigation plans with VP sign-off 10) Tech Limit process 11) Benchmarks 12) Weekly Progress Report 13) Bi-weekly Ops Meeting 14) Weekly SPU LT Ops meetings that include Performance and Risk 15) Recognition of Employees 16) SOC Conversations 1.1.3.1: [no data]

Visibility of the Risk Management Plan RMP Visibility Risk Management 5-Sig Risk Develop and implement comprehensive Risk Management Plan

Develop Risk Plan including regular updates on progress. Key deliverables include: (Kal need these 10?)

Rich 2/30/10 11/19 -- On track. The Risk Plan has been developed, there will be regular updates on progress. To date (November), 9 of the 10 key deliverables have been met. Progress on the plan has is regularly communicated to key D&C individuals accountable for implementation. Three outstanding elements are: Develeopment of D&C Risk Guidelines; Frame up implementation plan; Frame up training plan. Risk Guidelines still being developed. 1/21/10 -- Thierens to Rich. Target date from 12/30/09 to 2/30/10. RMP and BPRAT rolled out to LT, and Risk Leader established. Need to fully embed in organization

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1.1.4 Leadership Operating Leaders Vice President Seek feedback on their leadership behaviour, and reflect it in their personal development.

Level 3 5-High 1) 360 Feedback 2) Leadership Training, e.g., 7 Habits 3) 1-on-1 Leader Feedback 4)Zoomerang Surveys and PAS 5) Communication and visibility of Leadership Framework, including meeting reviews and challenges to hold ELT accountable 6) Performance Review process/form 7) Use of Leadership Framework

Not all ELT seek feedback actively on a routine basis

ELT Seek Feedback People 3-Basics/BP Set expectations for supervisor upward feedback.

Launch of the new 360 feedback system. Launch GoM Development for All website in September/October 2009. Zoomerang is complete, followup on action items. Continue with quarterly town hall meetings.

Nahman 10/30/09 10/26/09 -- New system as been launched effective October 1, 2009. Working with the LT to develop a 360 schedule by month to complete 360's on those who need it. Development for All website is almost ready. Expect Launch to occur in first 2 weeks of November 2009.

y

1.2.1 Leadership Operating Strategy Director Incorporate a strategy for continuous risk reduction and operating performance improvement into the entity business strategy.

Level 2 5-High 1) SPU Risk Management Policy 2) OMS Implementation Plan, which contains a continuous improvement process 3) SPU Business Strategy is in place with D&C components

Biases for decision-making exist, and strategy needs to be documented

Risk Decision Strategy Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Complete RAT Enhancement phase; complete trial before roll-out.

Rich 12/30/09 9/19/09 -- The RAT Enhancemenrt phase is complete and rolled out.

y

1.2.2 Leadership Operating Strategy Director Maintain and communicate to the workforce a local operating policy consistent with the entity vision and OMS, and that includes the BP Commitment to Health, Safety, Security and Environmental Performance.

Level 3 2-Low to Moderate

1) Documented at the SPU Level 2) D&C follows the SPU's lead, and communicates this out from SPU VP 3) Posters describe/illustrate BP HSE policy

Need to tie D&C Operating Policy and OMS to SPU policy

Intgrte D&C Op/OMS w/SPU Policy

OMS 2-Effeciency Implement OMS Include tie in D&C LOMS Manual and Website. Jassal 10/30/09 11/20: Included with LOMS manual. y

1.2.3 Leadership Operating Strategy Director Develop and annually review a statement of intent aligned to the entity vision and operating policy, explaining the objectives and scope of the local OMS.

Level 1 1-Low Work in progress Develop local OMS Develop OMS OMS 3-Basics/BP Implement OMS OMS development in progress. Jassal 12/30/09 12/18: MoC complete, approved by Leary/Joslin/Skelton/Lacy/Dupree.

y

1.2.4 Leadership Operating Strategy Director Monitor the external environment and update the strategy for continuous risk reduction and performance improvement in response to changing business needs.

Level 3 3-Moderate 1) DWOG 2) Rushmore External Benchmarking 3) Regulatory Team linked into MMS focus 4) Weather updates, especially during hurricane season 5) Monitor rig market via Segment accountability

No systematic process or documented written strategy

Doc Systematic Op Strategy

Learnings/Tracking 2-Effeciency Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Leary and Sprague to discuss. Sharpoint site exists.

Sprague 10/30/09 1/21/10 -- The FM best practices considers external benchmarking to enter our learning process and performance conversations. Closed per Sprague

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1.3.1 Leadership Planning and Controls

Director Identify and document risks and opportunities to be addressed in a prioritised way through the local OMS and include them in the annual planning process.


1) Local OMS will include an Annual Plan 2) BtB 3) Annual Planning Process 4) Environmental Risk Assessments by asset 5) D&C Annual Plan is driven by assets 6) D&C VP Annual Contract forms the basis of Annual Plan 7) Annual Transformation Agenda incorporates HSE, Well Control, etc. 8) Rig Schedule is largely the output of prioritization exercise 9) Working toward formalizing the Rig Schedule Hopper Process 10) Goals are assigned in Individual Performance Contracts

Rig Schedule Hopper Process is incomplete

Rig Schedule Hopper Organization Management 3-Basics/BP Jassal





Risk assessments are heavily weighted to risks, rather than Opportunity

Opportunity Risk Asmnts Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Make all risks visible in the Enhanced BP RAT to allow opportunity decisions to be taken at the right levels of management. Desig tool to highlight opportunities as well as mitigate risk.

Rich 12/30/09 11/19/09 -- On track. Enhanced features include the the assessment and ranking of risk on a continuous basis.

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Local OMS is not yet built Develop OMS OMS 2-Effeciency Implement OMS OMS development in progress. Jassal 12/30/09 11/20: Complete. Local OMS Handbook completed.

y





Director Incorporate objectives, targets, actions and accountabilities into the annual plan to manage operating risk, to deliver the requirements of OMS, and to close gaps against the Group Essentials.

Level 4 3-Moderate 1) BtB 2) Annual Planning Process 3) Environmental Risk Assessments by assets 4) D&C Annual Plan is driven by assets 5) D&C VP Annual Contract forms basis of Annual Plan and then assignments are made in the Individual Performance Contracts 6) Annual Transformation Agenda incorporates HSE, Well Control, etc. 7) Rig Schedule contains the output of Prioritization Exercise 8) Formalizing Rig Schedule Hopper Process

OMS is not fully implemented Implement OMS OMS 3-Basics/BP Implement OMS OMS development in progress. Jassal 12/30/09 12/18: MoC complete, approved by Leary/Joslin/Skelton/Lacy/Dupree.

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Director Establish control mechanisms to address risks to the delivery of the annual plan and assess performance against the plan.


1) Annual Planning Process 2) GFO Process 3) Bi-weekly Ops meetings 4) Weekly SPU LT Ops meetings 5) Monthly Scorecards 6) Semi-weekly DC Wells Operations ELT meeting

Substantial duplication of financial controls between assets and D&C

Duplicate Asset/D&C Fin Control

Financial Control 2-Effeciency Jassal





Lack of consistent process to summarize financial data and to control Plan vs. Actual

Incon Fin$ Data, Plan vs. Actual






Unclear responsibilities for $$ (in asset plan, but is D&C accountable?)

D&C/Asset $$ accountability






No consistent schedule for financial data cut-off

Incon Financial Data Schedule






All of the "people costs" are not covered between assets/central

Asset/D&C People Costs Asgnmnt


1.4.1 Leadership Resource and Implementation

Director Communicate the relevant parts of the annual plan and targets to the workforce and other identified stakeholders, and translate and include them in annual team and personal objectives.

Level 4 5-High 1) Rig Schedule 2) Resource Plan 3) LTP 4) GFO updates 5) Numbers 1-4 all are cascaded to Individual Performance Objectives 6) Townhalls

Not enough rigor around creating achieveable targets (developed before fully understanding the work)

Achievable Targets Organization Management 3-Basics/BP Develop and embed process for creating achievable performance targets.

Finalization of two process standards will accomplish: LTP process refresh , and AFE process

Jassal 6/30/10 9/20/09: Will review the GFO "0" inputs with the D&C LT on 30 September. GFO"0" will form the basis of what we will be measured against next year. Need to schedule a refresh of the LTP process as well as establish dates and accountabilities for the AFE process development. 14 Jan 10 - The D&C LT met on 12 Jan 10 to discuss driving performance in the SPU. Plan an engagement session with the ELT in early Feb to further push this into the organization along with implementation of a D&C SPU standard technical limit process will serve to futher drive performance improvements. THe LTP process will be reviewed and updated as necessary in front of this year's LTP cycle.

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Director Identify the resources needed to implement the annual plan. If resource constraints are identified modify the annual plan consistent with the need to maintain safe, responsible and reliable operating.

Level 4 5-High 1) People, rig and monetary resources are identified in Annual Plan (people through RPD, rigs through Rig Schedule) 2) Interface through SDDN annually 3) Central D&C Reorganization has allowed more reprioritizing of resources

Some resources that impact D&C are not under D&C control (e.g., subsurface, PSCM)

Resources Outside D&C Organization Management 3-Basics/BP Develop and embed process for assessing and realigning organizational resources.

Leadership behaviors reinforcement integration skills

Rich 12/30/09 10/22/09 -- Core management accountability to review resources and allocate appropriately. Leadership meets regularily to review priorities and adjust resources as needed. 1/21/10 -- The BtBcp requiring integrated multi-discipline teamwork to deliver wells now covers this (WRM); complete per Rich

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Director Identify the resources needed to implement the annual plan. If resource constraints are identified modify the annual plan consistent with the need to maintain safe, responsible and reliable operating.

Level 4 5-High 1) People, rig and monetary resources are identified in Annual Plan (people through RPD, rigs through Rig Schedule) 2) Interface through SDDN annually 3) Central D&C Reorganization has allowed more reprioritizing of resources

Although resouce plans are identified up front, not always allowed to resource; therefore, some projects underesourced

Underresourced teams Organization Management 2-Effeciency Develop and embed process for assessing and realigning organizational resources.

Develop cultures that utilize dedicated scheduling to resource load work.

Rich 12/30/09 10/22/09 -- Closed out. Team resourcing is the responsibilty of management. Team leaders need to continuially monitor expected activities and inform senior leadership of requirements. Rig scheduling and LTP support this effort

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Director Implement the annual plan mobilising identified resources. Level 5 5-High 1) Delivery track record 2) Performance Scorecards on all metrics


Director Apply control mechanisms to identify shortfalls against the annual plan, and put in place corrective actions.


1) Resourcing Model (people, rigs, monies) is applied against schedule so that gaps are identified and corrected 2) Weekly Ops meetings 3) Daily Rig calls 4) Stage Gate meetings 5) Long Lead Forecast meetings 6) Rig Schedule meetings 7) Project Team meetings 8) SPU LT Weekly Ops meetings

1.5.1 Leadership Accountability Vice President Appoint Engineering and Marine Authorities Level 5 5-High 1) D&C EAs 2) Engineering and Marine Authorities (external to D&C but within SPU) have been identified

1.5.2 Leadership Accountability Vice President Work with their Segment and/or SPU Engineering, Marine and Operating Authorities to support the delivery of safe, responsible and reliable operating activities.

Level 4 5-High 1) Annual Engineering Plan held by SPU EA 2) EAs' own implementation of ETPs 3) ETPs are auditable at Group level 4) Dispensations and design approval through D&C EAs with endorsement of Technical Strategy 5) Marine and Riser Assurance plans for rigs 6) Some teams do self-verification

1.5.3 Leadership Accountability Vice President Assign accountabilities and delegations to deliver BP requirements.

Level 4 3-Moderate 1) RACI 2) DOA 3) R&Rs and Annual Objectives 4) Individual Performance Contracts

Minor organizational changes remain from D&C Reorganization

Reorg Changes Remain Organization Management 1-Excellence Develop and embed process for assessing and realigning organizational resources.

Organization changes need to be made more decisively by leadership

Rich 12/30/09 10/22/09 -- Closed out. Organizational readjustments are managed by the LT dictated by the needs of the SPU. While minimizing change is desired adjustment is inevitable. Major organizational changes are managed by the MoC process

y

1.5.4 Leadership Accountability Vice President Provide BP employees with clearly defined and documented accountabilities. Set performance standards, goals and objectives which are aligned with their performance contracts and reward mechanisms. .5.4.1 Document and communicate the local progressive discipline policy and apply it consistely across the organization, including a description of the consequences for: Non-compliance with legal and regulatory requirements; Unsanctioned deviations from local operating procedures and policies.

Level 5 3-Moderate 1) Individual Performance Contracts for all, which include R&R 2) Semi-annual Performance reviews 3) Question on this issue was included in the latest Zoomerang survey 1.5.4.1: [no data]

1.6.1 Leadership Communication and Engagement

Technology Manager

Communicate business context and plans for risk reduction and performance improvement to the workforce.


1) Quarterly townhalls with all staff 2) Periodic LT and ELT offsite meetings, wherein performance is reviewed 3) New quarterly newsletter includes performance highlights 4) Frequently request ELT to pass on important issues with their teams 5) Performance Agenda, which is aligned with scorecards for assets, SPU and wells, is provided weekly/monthly via email and via portal

Risk reduction communication is not targeted

Target Risk Reductn Comms

Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Regularly and consistenly illuminate risk reduction to (where necessary) the entire D&C community.

Rich 2/30/10 11/19/09 -- On track. Roll out of the completed Plan will allow risks to be regularly and consistenly illuminated to ( where necessary ) the entire D&C community. More imnportantly, the risk plan will allow for value opportunities, not just mitigation. 1/21/10 -- Thierens to Rich. Target date from 12/30/09 to 2/30/10. RMP and BPRAT rolled out to LT, and Risk Leader established. Need to fully embed in organization.

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Technology Manager

Communicate to BP employees the process that enables them to report, in confidence, operating concerns and concerns relating to legal compliance or conformance with BP requirements.


1) Open Talk 2) ELT discussions with staff 3) Compliance issues all handled by GoM Controller 4) Ombudsman process 5) Compliance Audit and annual Ethics Certification includes Code of Conduct discussion 6) Gift register 7) STOP cards 8) SOC 9) Monthly Westlake Campus reporting system


Technology Manager

Apply reward and disciplinary programmes to reinforce and reward behaviours consistent with legal and regulatory requirements and BP requirements


1) D&C follows HR's policies and procedures 2) Performance Contracts reviewed 2X/year 3) Performance Improvement Process is implemented where needed 4) 360 Feedback for leaders takes place @ 18 months 5) Competency Frameworks 6) Career Atlases by discipline 7) Reward process assesses performance 8) Disciplinary process available 9)Spot Bonus Program 10) Recognition events

Cultural reluctance to provide frank and candid feedback (performance feedback) to drive performance upward

Frank Performance Feedback

People 3-Basics/BP Enhance supervisor to employee performance management process.

The importance of open feedback was discussed/communiated to the LT and ELT before the mid year review process. Formal training needs to be offered in December/January to prepare team leaders to give open, objective and performance driven feedback to employees. Select TL's will also be participating in the managing essentials program for 2009/2010.

Nahman 12/30/09 10/26/09 -- Informal audit of the LT and ELT validated that mid year reviews were complete by September 2009. We currently do not collect mid year documentation. Training/tools still on schedule to be delivered in December/January addressing the need for candid, quality feedback. Managing essentials nominations have been submitted for 2010 based on need and followup from PDP conversations. The Managing Essentials courses go into greater detail about the enhanced process of giving honest feedback to drive performance within the organization.

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Technology Manager

Not tolerate retaliatory action against any member of the workforce for reporting in good faith, to line management or in confidence via any available BP process, operating concerns or concerns relating to legal compliance or conformance to BP requirements.

Level 5 3-Moderate 1) SPU and D&C LT communicate and adhere to the policy of no toleration of retaliatory action for reporting issues 2) HR monitors and will objectively follow-up on any breaches 3)D&I Agenda/People Agenda sets tone 4) Open Talk program is available/in-place


Technology Manager

Implement and maintain a process to consult with the workforce to identify continuous risk reduction and performance improvement opportunities.


1) D&C performs an annual anonymous Zoomerang survey 2) For the past two years we have set up a committee of staff to review and group the survey results for presentation back to LT 3) Zoomerang survery results are posted on Sharepoint site 4) JSAs at worksite 5) Informal ELT discussions with staff 6) Crew Engagements 7) Line-by-line procedure reviews 8) After-Action Reviews 9) Lessons Learned discussions 10) Risk Reduction and Performance Improvement Opportunity discussions 11) Peer Assists/Peer Reviews 12) HAZIDs 13) BtB Process

Since the tools are not standard, it is unclear which tool to use at which time

Clarity of Feedback Tools People 2-Effeciency Set expectations for supervisor upward feedback.

New 360 degreem feedback tool rolled out. Leadership team to sign up for the process.

Nahman 12/30/09 10/26/09 -- 360 tool rolled out October 1, 2009. Developing a schedule for all LT and ELT to complete the 360 feedback in the next year. The new 360 program mandates 360 feedback every 2 years instead of every 18 months.

y


Technology Manager

Develop a Local Operating Management System Handbook and communicate the contents to the workforce.


1) D&C LOMS Handbook will be developed prior to move to MOC (transition to OMS) 2) D&C already has a "Way We Work" document

No D&C LOMS Manual has been developed

Develop LOMS Manual OMS 3-Basics/BP Implement OMS LOMS Manual development in progress. Jassal 10/30/09 11/20: Complete. Local OMS Handbook completed.

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Technology Manager

Require leaders to seek feedback at defined intervals on their communication and engagement activities and modify them as needed.


1) Verbal encouragement from LT to ELT and staff 2) Zoomerang surveys 3) 360 Surveys done every 18 months 4) Coaching engagements available 5) Formal coaching/mentoring programs 6) "BP's Behavioral Expections" brochure discusses behaviors for receiving feedback about management style 7) "Managing Essentials" 8) Performance Reviews

Not all team leaders complete 360 reviews every 18 months as required

All TLs Conduct 360 People 3-Basics/BP Set expectations for supervisor upward feedback.

Schedule all team leaders to complete 360 reviews ASAP once the process opens in October

Nahman 12/30/09 10/26/09 -- 360 tool rolled out October 1, 2009. Developing a schedule for all LT and ELT to complete the 360 feedback in the next year.

y

1.7.1 Leadership Culture HR Advisor Define and communicate the desired operating culture and behaviours to the workforce; address behaviours that are inconsistent with the desired culture, and encourage and recognise behaviours that support it.


1) BP Leadership Model 2) Behavioral Expectations brochure 3) Performance Management Process, including mid-year and annual discussions 4) Performance Improvement plans 5) 360 Feedback 6) Career Atlases 7) Competency Framework 8) LT and HR meetings 9) SDDM 10) PDP reviews and feedback for individuals 11) Succession planning 12) Safety standdowns 13) Stop the Job 14) Townhalls 15) Communications from Neil Shaw 16)Reward processes in place 17) Quarterly telecoms from Andy Ingalls 18) D&C Vision Statement

Lack of consistent, high-quality PDP discussions

Inconsistent PDP Discussions


Launch Development for All. Address PDP issues, communicate the employee and TL responsibility within the process. Develop a consistent PDP process. Audit/check randomly to insure employees feel the process is helpful, effective and informative.

Nahman 12/30/2009 10/26/09 -- Site will be launched in November. There is a module on PDP discussions. We also have a separate tool kit that another HR Advisor will roll out in 1Q 2010 with more formal training on the process. In our recent employee feedback survey we did solicit feedback on the quality of PDP discussions to give us a baseline for continuous improvement in the future.

y




Succession planning process not standard/inconsistent

Inconsistent Succession Plng

Organization Management 3-Basics/BP Develop and embed process for assessing and realigning organizational resources.

Sprague and Rich to use existing process, formilize and communicate. Leaders to hold other accountable for behaviors.

Rich 3/30/10 10/22/09 -- D&C LT will conduct a formal succession planning and critial skills assessment annually as part of its people process. Plans are to hold a session before the end of 1Q 2010. Target date changed from 10/30/09 to 3/30/10. 1/21/10 -- The new organization will include an organization capability lead to manage this process.

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Lack of consistent performance management process

Inconsistent Perf Management


Adhere to ranking guidelines per the annual compensation cycle. Train team leaders on effective written and verbal feedback. Complete PIP's as necessary. Communicate behavioural and perfornance expectations clearly and in a timely manner for employees.

Nahman 12/30/09 10/26/09 -- Ongoing, ratings for 2009 due November 11th. We will stay within the guidelines. Effective written and verbal feedback will continue to part of team leader training. A number of D&C employees have been through the Managing Essentials program to provide Effective Performance Feedback, additional managers have been nominated for the 2010 program. Oue expectation is that all TL's complete ME course or demonstrate the competency.

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Inconsistent objective setting and feedback for employees

Inconsistent Objective Setting


Communication, training, audite of goals and objectives to insure consistency.

Nahman 2/30/10 10/26/09 -- Future goal, audit objective setting for 2010.

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1.7.2 Leadership Culture HR Advisor Assess the operating culture and behaviours at defined intervals and develop improvement plans as needed.


1) 360 Feedback 2) PAS Pulse Checks 3) Zoomerang 4) Yearly interval of Code of Conduct/Ethics Certification 5) People Agenda 6) Lacy breakfast or lunch with employees 7) Safety Pulse Checks 8) OMS Gap Assessment process 9) One LT visit per rig per month 10) SOC trending to assess culture 11) In-town reviews 12) Bi-weekly meetings with rig from office to discuss safety via telecom

Inconsistent applications of tools and action plans

Incon Culture Asmnt Tools Organization Management 2-Effeciency Jassal




2.1.1 Organization Organization Structure

Drilling Engineering Manager

Document and implement an organization structure aligned to manage entity business and operating processes.

Level 4 5-High 1) Contained within: D&C Organization Transition White Paper, the "Way We Work" document, 2008 Organizational MoC's 2) All are accessible via D&C Sharepoint Sites 3) R&R 1-pagers 4) Rollouts to different assets/teams 5) Posters with photos 6) 2008 Reorg. of D&C from asset-based to function-based organization 7) RACI chart for all in new organization 8) Transitioning to new SAP people system

Current process does not consider future organization transitions and changes

Org Changes in Resource Plng

Organization Management 2-Effeciency Develop and embed process for assessing and realigning organizational resources.

Rich



Establish clear line reporting relationships ensuring leaders have a manageable span of control, and BP employees have a clear understanding of their roles, accountabilities and objectives.

Level 4 5-High 1) Contained within: D&C Organization Transition White Paper, the "Way We Work" document, 2008 Organizational MoC's 2) 1-pager of R&Rs for each position 3) Individuals' annual performance contracts 4) RACI charts

Potential span of control risk Span of Control Organization Management 2-Effeciency Develop and embed process for assessing and realigning organizational resources.

Sprague and Rich to establish Span of Control and communicate.

Rich 10/30/09 10/22/09 -- Closed out. Team leader will review and realign teams to meet span of control recommendations as part of their core responsibility.

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Some resources that impact D&C are not under D&C control (e.g., Subsurface, PSCM)

Resources Outside D&C Organization Management 2-Effeciency Develop and embed process for assessing and realigning organizational resources.

Rich





Still some confusion and poor communication around responsibilities

Responsibility Confusion Organization Management 2-Effeciency Develop and embed process for creating achievable performance targets.

Finalization of two process standards will accomplish: LTP process refresh , and AFE process

Jassal 6/30/10 9/20/09: Will review the GFO "0" inputs with the D&C LT on 30 September. GFO"0" will form the basis of what we will be measured against next year. Need to schedule a refresh of the LTP process as well as establish dates and accountabilities for the AFE process development. 14 Jan 10 - D&C LT met on 1 Dec to review the plan for 2010. Another session including the new D&C VP is planned for 15 December to review the 2010 GFO "0" and agreee and assign priorities and milestones for 2010. Updated and aligned AFE process is being drafted along with a standard fgor one papgers for items going to RCM for approval.

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Allow functional experts access to entity leaders and independent access to their functional leadership to discuss operating risk concerns.


1) The D&C Risk Management Plan, in conjuction with the yet-to-be-implemented Wells Advisory Meeting (WAM), will facilitate transparency of risk from top to bottom and across the organization. 2)EA-TA structure in place and ensures access between SPU and funct. 3) MCPC has mandatory reviews at segment level through Discipline VPs on Cat. 1 projects and self-verification on Cat. 2 projects. 4) Wells Director and Wells VP meet quarterly with Segment LTP (Annual Wells Mgrs. meetings and bi-monthly teleconferences). 5)Organizational structure w/ engineer mgrs and operations mgrs provides independent risk verification. 6) Open Talk mechanism, Ombudsman program available to employees

D&C Risk Management Plan is not finalized

Finalize Risk Mgt Plan Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Allow access of completed plan and risk information.

Rich 8/30/09 8/14/09 -- In place per Thierens. Plan is subject to scrutiny from Segment Risk Authority for D&C ( Hugh Williamson ). There is a very well established internal (to SPU) and external (Segment) review protocol in place and being used and documented for critical and non critical D&C projects where risks are clearly identified. Segment ( TVP for D&C ) has asked for a demonstration of the GOM Risk Management plan in November 2009.

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Allow functional experts access to entity leaders and independent access to their functional leadership to discuss operating risk concerns.


1) The D&C Risk Management Plan, in conjuction with the yet-to-be-implemented Wells Advisory Meeting (WAM), will facilitate transparency of risk from top to bottom and across the organization. 2)EA-TA structure in place and ensures access between SPU and funct. 3) MCPC has mandatory reviews at segment level through Discipline VPs on Cat. 1 projects and self-verification on Cat. 2 projects. 4) Wells Director and Wells VP meet quarterly with Segment LTP (Annual Wells Mgrs. meetings and bi-monthly teleconferences). 5)Organizational structure w/ engineer mgrs and operations mgrs provides independent risk verification. 6) Open Talk mechanism, Ombudsman program available to employees

WAM has not been implemented Implement WAM Organization Management 3-Basics/BP Jassal



Identify activities to be carried out by contractors and other parties and provide BP resources to manage the interfaces.

Level 4 3-Moderate 1) Contained within the "Way We Work" document and supported by the Well Services Organization 2) Clear accountability exists with Ops Managers to manage rig contractors 3) Ops managers and TLs in office manage office-based contractors 4) PSCM 5) Functional reviews 6) Oversight by an account manager

Inconsistency in CAM process/sector specialists

Inconsistent CAM/SS Process

Contractor Interface 2-Effeciency Rich

2.2.1 Organization People and Competence

Performance Manager

Implement and maintain a people resourcing strategy to meet the current and anticipated needs of the business and which assigns accountabilities for recruitment, selection and retention of personnel.

Level 2 3-Moderate 1) Functional organization and the existence of a healthy contract population are hugely helpful in managing uncertainty in strategic business plans 2) While Resource Accountabilities are fairly clear, they are not clearly documented or communicated 3) LTP includes People Forecast populated in the RPD, refreshed annually. 3) Managed move process within function supported by DoC. 3) PDPs inform candidate pool. 4) Have RPD for tracking headcount. 5) The Way we Work document addresses organization.

No resourcing strategy written or communicated

People Resourcing Strategy Organization Management 3-Basics/BP Develop and embed process for assessing and realigning organizational resources.

Finding is inocrrect -- strategy exists reference DE and CE Staffing Strategy Document.

Rich


Performance Manager

Define required competencies and training for roles to be filled by BP employees, including any legally required training. 2.2.2.1 Identify posts where jobholder competencies and proficiency can significantly impact HSE or operating integrity ("critical jobs"). Develop and maintain a register of those jobs.

Level 3 3-Moderate 1) Well Site Leader competencies defined (some work left for "Completions WSLs") 2) CE and DE are progressing well with plans to roll out globally in fall 2010 through D&C function. GoM is supporting; but will need implementation plan 3) "Competency On Line" - to be updated with new competency criteria. COL is being used by Challengers and by Well Site Leaders of the Future. Definitions are being used, but the scoring or grading typically is not useful and needs to be updated 4) Challenger process robust through DAPS, structured program, well-used 5) Also Well Site Leaders of the Future program is robust, structured and well-used 2.2.2.1: a) EAs and TAs identified and in place, reviewed, formal process in place b) Well Site Leaders in place, competency testing, considered safety critical c) D&C Engineering competencies being refreshed d) Specific training requirements for jobs are identified e) VTA identifies and tracks individuals' training status, e.g., well control

2.2.2.1: No single register for D&C critical jobs exists

Single Critical Job Register People 1-Excellence Publish the training registry in VTA. Plan courses. Communicate requirements and train employees in a timely manner.

Nahman 12/30/10





Performance Manager



The refresh of segment-level competency framework is incomplete

Competency Frmwrk Refresh

People 1-Excellence Implement Segment Competency Assurance Framework

Link the competency framework to the new Development for All Website.

Nahman 6/30/10 10/26/09 -- Initially the Development for All site will have links to Functional Leaders, SDDM contacts and the basics around D&C competencies. As the function develops more sophisticated tools, these may be linked to the Development for all site.

n


Performance Manager



Completions Well Site Leader competencies not defined and integrated with existing programs

Compl WSL Competencies People 3-Basics/BP Implement Segment Competency Assurance Framework

Work with Ken Tucker, Keith Daigle and John Smart to formalize the program.

Nahman 3/30/2010 10/26/09 -- This is a function deliverable. Jennifer to work with the discipline to insure these things are complete. Ken Tucker and Mike Wise have completed extensive work in this area on competencies and the 10 year plan.

y


Performance Manager

Assess BP employees on entry into safety and production critical roles, and at defined intervals thereafter, against the required competencies for their role, record assessments, identify any gaps, and take identified training and development action to close them. 2.2.3.1 Base training offers on recommended curricula from the function and involve the team leader in defining specific additional training necessary to achieve required competency and proficiency levels.

Level 2 3-Moderate 1) See 2.2.2 comments 2) Competencies need to be defined and in place prior to plans to close gaps 3) Most DE and CE roles assumed "production-critical" 4) D&C Organization is in good shape with safety critical roles and training - particularly for Well Site Leaders 5) Performance Appraisals done semi-annually 2.2.3.1: a) Production maps, training catalogs exist and are being refreshed to be a curriculum b) Team Leaders are required to attend Managing Essentials c) Career Atlas is being refreshed and will be rolled out soon d) Open PDP discussions with DoC, HR, LT involvement e) Verification comes from presenting PDP to the LT

2.2.3.1: Learning Progression Maps and D&C Curriculum not yet refreshed

Lrng Progrssn Map Refresh People 1-Excellence Enhance supervisor to employee performance management process.

Work with the organization capability tags and the training group to develop a training plan.

Nahman 6/30/10 10/26/09 -- Will work with Tucker to make sure this is complete.

n


Performance Manager

Assess BP employees on entry into safety and production critical roles, and at defined intervals thereafter, against the required competencies for their role, record assessments, identify any gaps, and take identified training and development action to close them. 2.2.3.1 Base training offers on recommended curricula from the function and involve the team leader in defining specific additional training necessary to achieve required competency and proficiency levels.

Level 2 3-Moderate 1) See 2.2.2 comments 2) Competencies need to be defined and in place prior to plans to close gaps 3) Most DE and CE roles assumed "production-critical" 4) D&C Organization is in good shape with safety critical roles and training - particularly for Well Site Leaders 5) Performance Appraisals done semi-annually 2.2.3.1: a) Production maps, training catalogs exist and are being refreshed to be a curriculum b) Team Leaders are required to attend Managing Essentials c) Career Atlas is being refreshed and will be rolled out soon d) Open PDP discussions with DoC, HR, LT involvement e) Verification comes from presenting PDP to the LT

No standard process for initial assessment of new employees except for EA and TA roles

Initial Competency Assessment

People 2-Effeciency Implement Segment Competency Assurance Framework

Audit the training requirements against individual training history. Plan for annual, required training to occur.

Nahman 12/30/10 10/26/09 -- Will work with Tucker to make sure this is complete.

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Performance Manager

Perform induction training covering HSSE and emergency procedures for new or transferred BP employees, contractor employees and visitors. 2.2.4.1 Include the local OMS as part of new employee orientation.


1) Offshore rigs and facilities have rigorous induction in place 2) New Employee Induction Process at Westlake is required before new hires get a badge 3) Experienced hires go through "Discover BP" program 4) Visitors to be escorted while in building 5) HSE info on badge 6) STOP, SOC used at office 2.2.4.1: N/A to D&C, as OMS not yet in place

2.2.4.1: OMS not included as part of new employee orientation

OMS New Emp Orient OMS 1-Excellence Webster to include local OMS as part of new employee induction

Jassal 3/30/10 1/21/10 -- process document modified and posted at 2.2.4.1


Performance Manager

Maintain training materials and records, evaluate training effectiveness at defined intervals, and implement identified improvements as needed. 2.2.5.1 Implementa CMAS-ican when migrating or upgrading the local business to an electronic competency assurance system.


1) VTA Training records are maintained, but non-VTA training records are up to the individual 2) Evaluation of training effectiveness likely to be done for BP at Function level with GoM support 3) Good job with Challenger population 4) BP training courses require feedback at end of course 5) DTA courses audited by BP advisors 6) Performance conversations, assessments of skills, evaluating performance 2.2.5.1: N/A, as D&C does not use CMAS in GoM

No clear process for documenting non-VTA training

Document non-VTA training People 2-Effeciency Track and enter all training into VTA Nahman 12/30/10


Performance Manager

Maintain training materials and records, evaluate training effectiveness at defined intervals, and implement identified improvements as needed. 2.2.5.1 Implementa CMAS-ican when migrating or upgrading the local business to an electronic competency assurance system.


1) VTA Training records are maintained, but non-VTA training records are up to the individual 2) Evaluation of training effectiveness likely to be done for BP at Function level with GoM support 3) Good job with Challenger population 4) BP training courses require feedback at end of course 5) DTA courses audited by BP advisors 6) Performance conversations, assessments of skills, evaluating performance 2.2.5.1: N/A, as D&C does not use CMAS in GoM

Training/follow-up gaps exist for post-Challenger level engineers

Post-Challenger Training People 2-Effeciency Enhance supervisor to employee performance management process.

Partner with training and the organizational capability group to get non-VTA into the VTA training/tracking system.

Nahman 6/30/10 10/26/09 -- Will work with Tucker and Kathryn Connor to make sure this is complete.

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Performance Manager

Implement and maintain performance management and career development processes to monitor and improve individual performance and enhance contribution.


1) Performance Management processes in place and adhered to 2) Very good job with PDP fest and feedback to engineers 3) Challenger Program structured and in place 4) SDDM ensures the Business Performance Management of people, succession planning, employing and developing staff. 5) PAS, SPU, D&C Zoomerang




2.3.1 Organization Operating Discipline

Director Require members of the workforce to stop work that they consider unsafe or likely to cause loss of containment causing damage to the environment. 2.3.1.1 Implement a local policy which defines the expectations to stop work that is unsafe, non-compliant with environmental regulations or not conforming to BP requirements.

Level 4 5-High 1) SPM Control of Work C1.L discusses stop work authority 2) Short-service employee training has an element of Stop Work Authority 3) Drilling contractors also have as part of their core management systems the mandate to stop the job if unsafe 4) Stop the job issuess are reviewed at safety meetings, recognizing individuals for taking the time to stop unsafe work 5) Bridging documents for SPM 6) Rig calls in the mornings 7) STOP card observation process in place (office) 2.3.1.1: We comply with the SPU process addressed in 2.3.1


Director Define and communicate to the workforce the consequences of non-compliance with legal and regulatory requirements, BP requirements and local operating procedures and practices.


1) Code of Conduct 2) Annual Code of Ethics Certification 3) Contract language requires contract employees to follow all laws and company policies 4) Rig meetings/reviews include consequences of noncompliance 5) Contractors have their own programs and policies 6) Included in offshore orientation program (onboarding; BP license to go offshore program)


Director Monitor workforce understanding and observance of legal and regulatory requirements, BP requirements and local operating procedures and practices. Apply defined consequences for non compliance.


1) Compliance Management System 2) D&C HSSE self-assessments 3) SOC 4) Periodic CPET audits 5) "Compliance Minute" featured on whiteboard on rig 6) MMS, USCG audits 7) S&O audits 8) Group Defined Practice audits 9) D&C follows Progressive discipline 10) JSEA, Operating Procedures

2.4.1 Organization Organizational Learning

Completions Engineering Manager

Share high value learnings and other lessons learned from incident or other local operating investigations and good operating practices with other members of BP Group.


1) Bi-weekly Barnyard, and Team meetings 2) Well Site Leader meetings 3) Annual Contractor HSE meetings 4) Engineer mobility between teams 5) Wells Managers Telecom 6) Semi-weekly Ops meetings 7) D&C networks probably a bit better connected with lessons sharing globally through Com Ex Network 8) Good job with HSSE reports and distribution, e.g. GoM LL sharing http://gom.bpweb.bp.com/operationsandhsse/hsse/lessonslearned/Pages/IncidentsandLearning.aspx 9) Bi-monthly HSE performance reviews with drilling contractors 10) GoM D&C has in place a Post Well Review Recommended Practice that captures variances and Lessons Learned 11) Implementation plans are identified 12) Team Link is used as a D&C standard tool for capturing Lessons Learned 13) Technical Limit process and workshops are part of the standard D&C BtB process 14) Use output from PWR

No systemmatic process for including new employees in the sharing network, e.g., how to find out about/sign up to be on specific, job-related e-mail lists

Orient to Sharing Tools Learnings/Tracking 2-Effeciency Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Prepare comprehensive lists of meetings for new employees.

Sprague 2/28/10 1/21/10 -- The onboarding process pulls in new employees to understand sharing networks; TL's include this in their induction. Closed per Sprague

y



Benchmark good operating practices from across the BP Group and/or external sources to identify opportunities for risk reduction and operating performance improvement.


1) D&C function using global benchmarks (days/10K, day/completion) 2) Intervention uses WETS 3) Widely distributed reports and metrics for HSSE 4) Purple Book is a performance benchmarking book 5) D&C networks 6) DWOG, CWOG 7) Rushmore Benchmarking



Prioritise and incorporate into the local OMS specific improvement opportunities identified through self assessments, audits, annual management reviews, project reviews, incident investigations, high value learnings and benchmarked good practice.


1) Embedding HSSE Lessons Learned through formal process 2) Global high-value HSSE learnings 3) LT has developed collective priorities for 2009

No process exists to prioritize opportunities and learnings universally across the broader organization

Prioritize Learnings Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Handoff to Tink HSSE Committee. Need to enable ELT collective priorities/review at Townhall HSE plan

Tink 10/30/09 1/18/10 -- responsibility to Tink from Sprague per Rich

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2.5.1 Organization Working with Contractors

Rigs and Wells Services Manager

Designate BP employee and contractor employee roles which have accountability for the management of contracts, the safety of the contractor employees and the safety of their work activity.


1) Employee Roles and Responsibilites documents for PSCM and D&C personnel are established 2) Each contract is assigned to a specific PSCM 3) Some D&C subsector specialists are assigned 4) Supplier Business Plans (under development) 5) GoM D&C Sharepoint Site on Well Services/PSCM (Contract Briefings) 6) Per NAWS Master contract - see Section 2, General Conditions of Contract, Definitions (responsibilities delineated) 7) PSCM Contract Specialists have responsibility to issue and maintain current contracts 8) Wells Team Leaders and BP field personnel monitor contractor employee work safety activity 9) CPET Committee audits the safety management systems of contractors to ensure documentation and implementation of programs 10) Contractors are explained the HSSE requirements before execution of contracts 11) Drilling Contractors' HSSE Steering Committee manages ongoing HSE peformance of operations 12) BP's Code of Conduct is applied which covers: health, safety, security and the environment; employees; business partners; governments and communities; company assets and financial integrity



Implement a process to screen and select contractors based on a combination of their capability, contractor employee competency, financial viability and HSSE performance, taking into account the technical, commercial and HSSE risks of the specific work.

Level 4 5-High 1) NAWS Project RFPs (T&Cs, Scope of Work documents) and Bid Evaluation Sheets 2) GoM Prequalification Process 3) BP lead interviews of potential contractors 4) CVs of Contractors 5) Use of SPM, GWSI Scorecards 6) Semi-annual Performance Reviews 7) Contractor Performance Evaluation Team (CPET) Process is utilized to review contractors to verify existence and implementation of safety management systems programs 8) Sampling of contractor training records is taken to verify that required training is taking place to complete competencies 9) Contractor's industry and BP GoM TRIR are reviewed to compare to minimum thresholds 10) Scope of Work is rated to determine level of risk that is being created 11) Contracts tracked via red-yellow-green system, and monthly reports are generated for PSCM leadership 12) BP's Code of Conduct is applied, which covers: health, safety, security and the environment; employees; business partners; governments and communities; company assets and financial integrity






Define contractually and inform contractors of the entity’s HSSE requirements for the services and equipment to be provided, the scope of work of the contract and identified boundary conditions.


1) The HSSE requirements contract exhibit is attached to contract and signed off by contractor 2) Additional HSSE requirements, those that apply due to scope of work, are accepted by contractor by initialing next to that specific HSSE requirement 3) Contractors are required to hold subcontractors to same BP HSSE requirements followed by contractor 4) There are specific training requirements for specific required training, tracked by Operations personnel and VTA training department 5) (Section 7-HSSE), Joint Buisness Plans address HSSE Requirements/Goals 6) http://gom.bpweb.bp.com/operationsandhsse/hsse/safety/cpet/Pages/default.aspx 7) BP's Code of Conduct is applied which covers: health, safety, security and the environment; employees; business partners; governments and communities; company assets and financial integrity



Contractually require contractors to communicate the entity’s HSSE requirements to their employees and subcontractors and demonstrate that they follow them. 2.5.4.1 Confirm that contractor and subcontractor personnel receive a site or project-specific induction that highlights BP's HSSE expectations, site hazards, and compliance tasks to be accomplished by them. Require contractor and subcontractor personnel to confirm in writing that they have received and accept their obligations. Assign accountability to a BP representative to confirm that the contractor satisfactorily completes compliance tasks.


1) BP contracts stipulates per Exhibit "D" HSSE & Environmental requirements 2) Bridging documents established with drilling contractors that define which requirements apply (BP's or contractor's) 3) CPET audits confirm demonstration 4) HSSE Requirements Contract Exhibit states that contractors must meet HSSE requirements and contractor shall ensure that any subcontractor it employs also meet these requirements 5) Audit report checks to ensure that contractor is communicating HSSE requirements to employees and to subcontractor employees 6) Audit reports check to see that contractor HSSE staff is communicating contractor HSSE goals to employees 7) BP employees check onsite activities of contractor employees to stress adherence to safety rules 2.5.4.1: a) BP - License to go offshore (6-in-1), TWIC and Safe-Gulf required for all, and screened for at helibase b) Facility (onsite) induction c) DWOPs and CWOPs prior to project



Contractually require contractors to confirm at defined intervals that their employees are competent and their equipment is fit for service, and their work is carried out in compliance with entity requirements.


1) Under the audit clause in BP's MSA, company can request, inspect, and audit financial information, technical documents, performance records, etc. 2) Implement IM Accountability in Contract per Section 5, rev. D document 3) Wells Team Leaders and BP field personnel monitor contractor employee work activity safety 4) Periodic reviews by CPET are via HSSE audits on a three-year cycle and a twelve-month cycle when there are audit findings that need to be followed to closure



Evaluate contractor performance at defined intervals to provide feedback, lessons learned and a basis for improving future contractor selection and performance.

Level 4 5-High 1) Currently hold Performance Reviews twice a year 2) Done intentionally for 80% of our spend 3) Utilize GWSI scorecard system to provide job performance feedback for local and Global reviews 4) CPET process audit review is the system used to document contractor compliance with BP HSSE requirements 5) Safety performance is reviewed weekly by CPET to see if any contractors have experienced any safety incidents, HIPOs, or have been involved in any major incident announcements 6) Audit report grading scale ranges from 1 to 5 (5 being the best score), and audit report and findings are presented at CPET meetings that are attended by personnel from Operations, PSCM and HSSE 7) Based on audit results, TRIR safety performance and Sector Leader input, a HSSE status is assigned to the contractor that was audited

Currently, the GWSI system is inefficient and inconsistent; working to refresh SPM system

GWSI Inefficient Contractor Interface 2-Effeciency Rich



Evaluate contractor performance at defined intervals to provide feedback, lessons learned and a basis for improving future contractor selection and performance.

Level 4 5-High 1) Currently hold Performance Reviews twice a year 2) Done intentionally for 80% of our spend 3) Utilize GWSI scorecard system to provide job performance feedback for local and Global reviews 4) CPET process audit review is the system used to document contractor compliance with BP HSSE requirements 5) Safety performance is reviewed weekly by CPET to see if any contractors have experienced any safety incidents, HIPOs, or have been involved in any major incident announcements 6) Audit report grading scale ranges from 1 to 5 (5 being the best score), and audit report and findings are presented at CPET meetings that are attended by personnel from Operations, PSCM and HSSE 7) Based on audit results, TRIR safety performance and Sector Leader input, a HSSE status is assigned to the contractor that was audited

Suppliers don't own our NPT to meet our requirements

Supplier NPT Ownership Contractor Interface 2-Effeciency Rich

3.1.1 Risk Risk Assessment and Management

Director Develop and then update at least annually an entity level risk register which considers hazards and risks relating to operating performance. The risk register shall include the assessed impact and probability for each identified entity level risk and identify plant, process, people and performance risk reduction measures that are in place to manage those risks. 3.1.1.1 Document and implement a major hazards risk management policy.

Level 3 5-High 1) D&C teams produce risk registers either using BP-RAT or using one of a number of different Excel-based spreadsheets 2) Registers do include risks associated with operating performance, risk reduction measures and pre-response impacts and probabilities for each identified risk 3) Some registers also include post-response impacts 4) Registers are updated regularly by the teams and part of the CVP stage-gate process with the process facilitated by the common process coordinators 5) Annual reporting to London by SPU - D&C will feed into that reporting 3.1.1.1: We are following the SPU major risk management policy

There are inconsistencies across the teams/CPOL Coordinators in the way risk registers are produced and managed, e.g. formats, variety of different tools

CPOL Coord Inconsistency Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Create a standard risk register format. Standardize the risk management process and the risk management tool throughout the D&C function.

Rich 12/30/09 11/19/09 -- On track. The Risk Management Plan will provide the guidance. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place for consistency. Closed per Rich

y







There is limited (to no) aggregation of risks

Aggregation of Risk Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Develop and incorporate aggregation feature within BP RAT to support the aggregation of risks across projects and assets.

Rich 12/30/09 11/19/09 -- On track. Aggregation feature has been developed and will be incorporated within BP RAT. Developed but further review planned (qualitative vs. quantitative assessments). 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to aggregate risk. Closed per Rich

y




Not all risks are captured or addressed, e.g., IM, MAR

All Risks Captured Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Assure evaluation of all risks and capture as necessary within the new risk management plan. Use Standard Risk to help ensure all risk types are considered.

Rich 12/30/09 11/19/09 -- on track. Standard risks developed. All risks are being captured within the new RMP. Guidance document is being worked now. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to address all risk. Closed per Rich

y




No common standard benchmark for risk comparison/levelling; no standard guideline exists

Standard Risk Comparison Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Address leveling and comparison of risks and their aggregated impact on the SPU within the new risk tool and management process.

Rich 12/30/09 11/19/09 -- On track. Mechanism incorporated in process and tool. Guidance document is being worked now. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to address levelling/consistency. Closed per Rich

y




Nonexistent D&C common risk register (bottoms up)

Common Risk Register Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Develop D&C risk register to capture high level D&C risks

Rich 12/30/09 11/19/09 -- on track. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to capture high level risks. Closed per Rich

y



Level 2 5-High 1) Communication of risk reduction measures is achieved through a number of methods ranging from stage gate meetings during the planning process, regular project team meetings, one-on-one meeting between the risk champion and the risk owner to sending out risk updates to the teams 2) BowTies have been used to communicate MAR risks to the drilling contractor operating the rigs on BP platforms 3) Root Cause Failure Analysis - putting standards around risks (e.g., lessons learned one-pagers; incident reports; ad hoc task groups; RCFAs)

There are inconsistencies across the teams on how risks and risk reduction measures are communicated to the various levels of the organization, e.g. offshore teams, limited use of BowTies, not all risks captured by teams (MAR) and MODU Operations, engagement of drilling contractor

Risk Communication Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Communicate risks to all stakeholders through enhancements to the BP RAT tool and through the use of BowTies for MARs.

Rich 12/30/09 11/19/09 -- Complete. Transparency of risks is achieved through BP RAT.

y


Director At least annually communicate the importance of the risk reduction measures put in place to manage the identified entity level risks, and the reasons for them, to those members of the workforce who apply them and to those members of the workforce who may be affected by the identified entity level risks.


The communication of risk reduction methods is not clear and there is no guideline in place

Risk Reduction Comm Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Enhance the BP RAT tool and use new standardized reports to achieve communication of risk reduction.

Rich 12/30/09 11/19/09 -- complete. Capability of mapping on 8x8 matrix and the 4x4 matrix.

y


Director At least annually communicate the importance of the risk reduction measures put in place to manage the identified entity level risks, and the reasons for them, to those members of the workforce who apply them and to those members of the workforce who may be affected by the identified entity level risks.


The tools used to communicate risk and risk reduction measures are not conducive to collabrative environments

Collaborative Risk Comm Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Enhance the BP RAT tool and use new standardized reports to achieve communication and collaboration of risk reduction.

Rich 12/30/09 11/19/09 -- complete. Capability of mapping on 8x8 matrix and the 4x4 matrix.

y


Director At least annually update a gap assessment of the entity’s operating activities against the Group Essentials, GDPs and segment, SPU and entity requirements. The gap assessment against the Group Essentials requires a full assessment with a facilitator who is external to the entity when first transitioning to OMS and thereafter every 3 years.


1) This is the first go-around for a gap assessment of the D&C's operating activities against the group essentials, GDPs and segment requirements 2) Each group within D&C has its own set of requirements and conducts periodic assessments against these as/when a need arises

D&C is still operating as decentralized vs. a central organization

Still Operating Decentralized

Organization Management 3-Basics/BP Jassal





Director Use the gap assessment results to identify and prioritise opportunities for risk reduction and performance improvement that can be delivered through improvements to both the specification and application of the plant, process, people and performance risk reduction measures that constitute the local OMS.


1) Gap assessments results identified against the entity requirements are captured and recorded in Lessons Learned sessions 2) These lessons are incorporated into the future project phases by updating existing plans, procedures or equipment requirements or they are incorporated into new projects right away There are a variety of processes in place: 1. Some teams use Teamlink, 2. Some teams have their own database, 3. Lesson Learned sessions and record items while other teams may not

There are inconsistencies across the D&C function in the way opportunities for risk reduction are identified, recorded and prioritized

Inconsistent Risk Red. Process


Provide consistency across the function for managing, recording and prioritizing risks in the enhancements to BP RAT and the Risk Management Plan.

Rich 12/30/09 11/19/09 -- complete per OMS, BtB and MPcp. y


Director Use the gap assessment results to identify and prioritise opportunities for risk reduction and performance improvement that can be delivered through improvements to both the specification and application of the plant, process, people and performance risk reduction measures that constitute the local OMS.


1) Gap assessments results identified against the entity requirements are captured and recorded in Lessons Learned sessions 2) These lessons are incorporated into the future project phases by updating existing plans, procedures or equipment requirements or they are incorporated into new projects right away There are a variety of processes in place: 1. Some teams use Teamlink, 2. Some teams have their own database, 3. Lesson Learned sessions and record items while other teams may not

There are no common guidelines that teams can follow, nor is there a standard tool to manage this process

Incon Risk Asmnt Process Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Provide the tools to maintain common approaches in the enhanced BP RAT and the Risk Management Plan.

Rich 12/30/09 11/19/09 -- BP rat complete. Working on recommended practice now. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place. Closed per Rich

y


Director Identify and apply tools to assess operating risks commensurate with the particular types of risk presented


1) Btb, MPcp are two main procedures used within each D&C team to identify, assess and manage operating risk 2) Each procedure contains its own matrix for determining impacts and probabilities, which are different from the OMS 3.1 matrix

Application of BtB and MPcp is varied across the teams, mainly in the way registers are developed

Incon BtB and MPCP Registers


Support the common application of BtB and MPcp through a standard register.

Rich 12/30/09 11/19/09 -- complete. Standard registers and process in place.

y





Risk assessment and prioritization is not in alignment with OMS 3.1

Align Risk Asmnt to OMS Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Support the compliance to OMS 3.1 within the risk management plan and the enhanced tool.

Rich 12/30/09 11/19/09 -- complete. In conformance with 3.1. Continuous improvement will include roles/responsibility, budget process and aggregation feature.

y





No common set of reviewers for every well (project) risk (levelling)

Cnsistnt Team Risk Levelling

Risk Management 2-Effeciency Develop and implement comprehensive Risk Management Plan

Cover guidance in the new risk management plan.

Rich 12/30/09 11/19/09 -- recommended practice is being drafted. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to cover reviewers. Closed per Rich

y


Director Document risk assessments and risk management control measures and include them in project approval documentation. 3.1.6.1 Document and manage residual risk throughout the project cycle; Record and communicate residual risk carried from one stage gate to another; Assign accountabilities for recording and communicating residual risks at each stage gate; Confirm that projects document and communicate hazards, residual risks and safeguards to be managed by operations in the Operate stage of a project, prior to handover to operations.


1) Risk assessments and risk management controls measures are documented by all teams 2) Within the projects group, these are presented at each stage gate for approval prior to proceding to the next phase 3) Within operations, these are reviewed on a regular basis by the teams 3.1.6.1.: Residual risk can be carried throughout stage gates, and from engineers who go from design to operate

There are inconsistencies across the teams on how these items are documented and reviewed. There is a need for a consistent procedure and toolset

Incon Risk Asmnt Process Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Create consistency in the documenting and reviewing of risks in the enhanced BP RAT, the risk management plan and the use of standard reports.

Rich 12/30/09 11/19/09 -- recommended practice is being drafted. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to create consistency. Closed per Rich

y


Director Document risk assessments and risk management control measures and include them in project approval documentation. 3.1.6.1 Document and manage residual risk throughout the project cycle; Record and communicate residual risk carried from one stage gate to another; Assign accountabilities for recording and communicating residual risks at each stage gate; Confirm that projects document and communicate hazards, residual risks and safeguards to be managed by operations in the Operate stage of a project, prior to handover to operations.


1) Risk assessments and risk management controls measures are documented by all teams 2) Within the projects group, these are presented at each stage gate for approval prior to proceding to the next phase 3) Within operations, these are reviewed on a regular basis by the teams 3.1.6.1.: Residual risk can be carried throughout stage gates, and from engineers who go from design to operate

No common reviewers for validation/characterization of risks (levelling)

Cnsistnt Team Risk Levelling


Cover guidance in the new risk management plan.

Rich 12/30/09 11/19/09 -- recommended practice is being drafted. 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to address levelling/consistency. Closed per Rich

y

3.2.1 Risk Personal Safety HSSE Manager Systematically identify personal safety hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Personal safety hazards include but are not limited to breaking containment, working at heights, confined space entry, energy isolation, ground disturbance, power tools, electrocution, cranes and other lifting devices. 3.2.1.1 Engage the workforce in the identification, assessment and mitigation of safety-related hazards through a documented process; Assess the engagement process at a frequency set by the local business and implement corrective actions as appropriate.

Level 4 5-High 1) D&C rig-based operations follow the drilling contractors' safety management system which is bridged to the GoM Safe Practices Manual (SPM) and safety requirements of DWOP 2) Contractors have risk assessment process procedures that are tiered according to risk of the operation 3) D&C intervention operations use the policies and procedures within the SPM and safety requirements of DWOP 4) A self-verification process is in place to assess contractors' compliance with their management system and the additional requirements mandated in the bridging document 5) This is our first run-through for this 6-month cycle, and adjustments will be made as necessary 6) "8 Golden Rules" are visible at rig and at safety meetings 3.2.1.1 a) JSEAs or equivalent - contractors and BP each have process b) "Hazard Hunt" processes on rigs c) Some rigs use safety committees with broad representation d) Local and external Lessons Learned are reviewed during weekly safety meetings

3.2.2 Risk Personal Safety HSSE Manager Implement and maintain a behaviour-based safety process to continually improve operating behaviours through observation, recording and coaching. 3.2.2.1 Implement the Safety Observations & Conversations (SOC) program.

Level 4 5-High 1) Each drilling operation has a behavioral-based safey process established 2) Observations are documented, actions are acted on and trending established 3) BP personnel on drilling rigs use the BP Safety Observation Conversation process 4) Observation/conversation are input into Tr@ction, trends are reviewed 5) Quarterly, a GoM-wide analysis with actions is shared with D&C leadership 6) Field and HSSE advisors are trained as SOC coaches 3.2.2.1 - Ditto. SOC is the BP process

Inconsistent trending review of various BBS processes on a regular basis with GoM-wide sharing

BBS Trending Learnings/Tracking 1-Excellence Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Handoff to Tink HSSE Committee. Make SOC, etc. visible to wider organization.

Tink 10/30/09 1/18/10 -- responsibility to Tink from Sprague per Rich

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3.3.1 Risk Process Safety Rigs and Operations/IM Assurance Manager

Systematically identify process safety hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Process safety hazards include but are not limited to sources of ignition, explosions, fires, and uncontrolled releases of hydrocarbons, toxic chemicals, high or low temperature materials and stored energy.

Level 3 5-High 1) D&C uses the GoM Major Hazard & Risk Mgmt Policy and the SPUs efforts in PS identification, classification, and mitigation 2) D&C also uses MPcp and BtBcp guidelines to govern risk reviews; however, both processes have different matrices 3) D&C Teams implement the guidelines within these processes in different fashions. Legacy risk matrices will be replaced by the single 8x8 OMS matrix 4) BP-RAT is planned for entity use and process simplification 5) RPs exist in the form of Well Control Manual, Safe Practices Manual, Safe Lifting Guidelines, etc. 6) Casing Design Manual, Integrity Mgmt book, BP FLUX Guidelines 7) Equipment maintenance/frequency/testing 8) Control of Work 9) Contractors' Control of Work 10) Open Water Lift Guidelines 11) Marine pieces such as stationkeeping, SIMOPS, riser inspections/ops/maintenance; etc. 12) Process Safety Definition for D&C (Porter)

Need to simplify and clarify PS risk review process, communicate across teams, and implement. (The MAR review was the first of its kind for GoM under the new IM Standard (OMS) requirement. The process seemed somewhat dysfunctional and strenuous, leaving room for ongoing improvements in both the process and volume of PS hazards considered.)

Simplify PS Risk Process Risk Management 3-Basics/BP Develop and implement comprehensive Risk Management Plan

Update MAH risk mitigation plans. Provide feedback to process safety group to improve annual revalidation exercise.

Rich 12/30/09 11/19/09 -- major hazards mitigation plans updated for 2009/10. Provided feedback to PS group to imrove MAH mitigation plan refresh.

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Identify whether there is a potential for a major accident, and if so, complete an assessment of the major accident risks; use identified major accident risks as input to the entity level risk register.

Level 5 5-High 1) D&C participated in the SPU & Asset MAR assessments in 2008, resulting in owning four of the top 24 SPU identified risks 2) Three of those risks relate to loss of well control (LoWC) on the three BP-owned rigs, and one relates to damage to infrastructure from dropped objects on TH. These were included in the SPU register and MAR roll-up to Segment and Group 3) Have an agreed Risk Mitigation Plan in place for LoWC 4) Have an Asset RMP in place for the TH damage to infrastructure by dropped objects

Mitigation Plan lacks visibility Risk Mitigation Visibility Risk Management 1-Excellence Develop and implement comprehensive Risk Management Plan

Assure MAR plan is in place and updated annually (owner Dave Porter ).

Rich 8/30/09 8/14/09 -- In place per Thierens. The uncontrolled flow of hydrocarbon through loss of containment is the single major accident exposure for D&C. A clearly defined Risk Mitigation Plan for MAR is in place. This addresses Competencies, Potential Risk and Consequence, Robustness of Barriers, Contingency planning.

y


Define, based on entity risks, the level of process safety and operating integrity expertise needed to design, construct and operate safely. Provide BP employees with access to this expertise through available internal or external resources.


1) Have affirmed nine new Technical Authorities in ten roles within Organization, which has considered the level of expertise needed, with two Engineering Authorities, and communicated these new positions and roles across Teams 2) Organization is beginning to recognize and access TA expertise 3) Also identified and communicated the 18 segment TA roles 4) Identified Advisors (segment advisors - 148 roles)

3.4.1 Risk Health and Industrial Hygiene

HSSE Manager Systematically identify hazards including human factors in the work environment that could harm health. These include chemical, physical, biological, ergonomic hazards and psychosocial factors. 3.4.1.1 Assign Industrial Hygiene (IH) competent personnel to conduct hazard identification within the local business. 3.4.1.2 Document and regularly review hazards under normal operating conditions and for emergency scenarios.

Level 2 3-Moderate 1) Employee Health Risk and Exposure Assessment Plan 2) Procedure in Safe Practices Manual 3) GoM is required to go through a HealthMap exercise annually 4) D&C - uses a bridging document 5) Well Site Leader participated in a HealthMap workshop in Houma this year, which included drilling health risks 6) Audit-able information about D&C's participation available on website 7) Workstation ergonomic assessment is part of the Plan; managed by WL campus program 3.4.1.1: CIH on staff 3.4.1.2: HealthMap, IH Review Process include normal operating conditions and also emergency response

Unsure how drilling contractors are implementing IH Programs (exposure assessment, respiratory protection)

Contractor IH Programs Industrial Hygiene/Health 3-Basics/BP Review Contractor IH programs for adequacy.

Tink


HSSE Manager Assess exposures and risks from identified health hazards, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage them. Use this as an input to the entity risk register. 3.4.2.1 Document applicable occupational exposure limits (OELs) for identified IH hazards. 3.4.2.2 Conduct quantitative workplace monitoring where potential exposure levels are uncertain relative to occupational exposure limits for identified IH hazards. 3.4.2.3 Assess exposure for compliance and maintain records in accordance with local business standards and the Group Reporting Practice. 3.4.2.4 Document and implement IH nazard control programs when there is the potential for exposures above applicable exposure limits. 3.4.2.5 Report actual or potential exposures in excess of established exposure limits in accordance with local business reporting procedures: Conduct a management review upon identification of actual or potential exposures in excess of established limits; Involve medical staff in evaluating the need for medical surveillance in the event of actual or potential exposures in excess of established limits. 3.4.2.6 Communicate via local leadership the results of monitoring, and applicable related recommendations, to those that are potentially impacted.

Level 4 3-Moderate 1) Fit for Duty Program for offshore positions 2) U.S. Drug and Alcohol Policy 3) GoM Drug and Alcohol Policy 4) Employee Assistance 5) DOT-compliant D&A programs 6) USCG- compliant D&A programs 7) Bphit Wellness Program 8) Case Management Process 9)Westlake Wellness Center 10) Group Health & Hygiene System 11) Safe Practices Manual 12) Employee Health Risk and Exposure Assessment Plan 13) Handling of Radioactive Sources Protection Program 14) Hazard Communication Program 15) Hearing Conservation Program 16) Potable Water Procedure 17) Respiratory Protection Program 18) Bloodborne Pathogens Exposure Control Plan 19) Sewage and Blackwater Treatment Procedure 20)Benzene Program 21) BP-owned rigs include IH monitoring for all rig employees 22) MODUs conduct periodic monitoring on an ad hoc basis 23) Onshore uses the Westlake ergonomic program 3.4.2.1: All reports include OELs 3.4.2.2: a) Audits performed every three years utilizing quantitative monitoring b) Additional ad hoc requests (as needed) 3.4.2.3: Every report's exposure results are maintained in Global Health and Hygiene System and filing system 3.4.2.4: Examples of documented control problems: H2S contingency plans; hearing protection program; ammonia in mud on Bob Palmer; radioactive tracer management procedure 3.4.2.5: a) Report through Traction b) Global Health and Hygiene System document exposure c) 3.4.3 Risk Health and

Industrial HygieneHSSE Manager Implement and maintain exposure assessment programmes

to monitor the effectiveness of risk reduction measures to eliminate or manage exposures to identified health hazards.

Level 4 3-Moderate 1) Employee Health Risk and Exposure Assessment Plan 2) Handling of Radioactive Sources Protection Program 3) Hazard Communication Program 4) Hearing Conservation Program 5) Potable Water Procedure 6) Group Health and Hygiene System 7) Noise is controlled and monitored systematically as it is a key risk for drilling 8) Risk-based programs are systematic


HSSE Manager Define fitness for task requirements for identified tasks where fitness is needed for the safety and health of the individual or to deliver safety and production critical operating activity. Assess BP employees against the fitness for task requirements for their role, record assessments, identify any gaps, and take action to close them.

Level 4 3-Moderate 1) Fit for Duty Program for offshore positions 2) Bphit Wellness Program 3) Case Management Process 4) Westlake Wellness Center


HSSE Manager Implement and maintain risk based programmes to promote and monitor that individual performance of members of the workforce is not impaired by drugs and alcohol.


1) U.S. Drug and Alcohol Policy 2) GoM Drug and Alcohol Policy 3) Employee Assistance 4) DOT-compliant D&A programs 5) USCG-compliant D&A programs





HSSE Manager Implement and maintain health surveillance programmes to monitor the health of BP employees who may be exposed to known work place health risks.

Level 4 3-Moderate 1) Group Health and Hygiene System 2) Respiratory Protection Program 3) Hearing Conservation Program 4) Pulmonary Function Testing 5) Emergency Evacuation Plan (offshore) 6) Medics onboard rigs that engage with the people before emergencies happen 7) Bphit wellness program for all offshore and onshore personnel 8) Medic collects medical information about BP personnel upon arrival at the rig, including medications and current health status per Medicines and Reporting Policy 9)http://docs.bpweb.bp.com/dkgom/custom/dk/dk_view_content.jsp?strFunction=hse&objectid=0900a8858004d204&path=/us_wl_dk_gom_hse:/content/hssems/gom_unified/UPS-US-SW-GOM-HSE-DOC-00109-2


HSSE Manager Develop expertise in conjunction with Group Health that provides ready access to BP employees to health and industrial hygiene advice and support required to effectively manage risk and promote health and wellness.

Level 4 3-Moderate 1) Group Health and Hygiene System 2) Bphit Wellness Program 3) Westlake Wellness Center 4) Case Management Process 5) Nurse 6) IH specialist 7) Dr. in the SPU 8) Clinic available in WL1 9) Medics offshore 10) HSE professionals work with Challengers' development 11) Monthly Wellness Newsletter - Bphit newsletter

3.5.1 Risk Security HSSE Manager Systematically identify security hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Security hazards include but are not limited to criminal conduct, intimidation, violence, sabotage, unauthorised access or damage to BP property, and unauthorized access to, alteration, use or disclosure of information.

Level 3 3-Moderate 1) GSR Assessment to identify risks and provide a process for risk mitigation - annual 2) BP Security Compliance Program meets MTSA regulatory requirements, with a 5-year assessment/update cycle 3) Code of Conduct 4) Open Talk, Fraud Reporting System, and Tr@ction system for reporting security incidents are systems used for tracking/trending, assessing, security issues

Security incidents not consistently being reported in Tr@ction

Tr@ction Security Incidents Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Handoff to Tink HSSE Committee. Tink 10/30/09 1/18/10 -- responsibility to Tink from Sprague per Rich

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Lack of understanding D&C security systems on MODUs

MODU Security Understanding

Security 3-Basics/BP Enhance D&C Security Expertise Sims



WPV awareness program has not been rolled out

Rollout Security WPV Security 3-Basics/BP Sims

3.5.2 Risk Security HSSE Manager Develop, implement and update at least annually a security management plan based on the results of the hazard evaluation and risk assessment.

Level 3 3-Moderate 1) GoM SPU GSR Assessment and SMP completed 2007/8 2) MTSA regulated GoM SPU OCS facilities possess Facility Security Plans (FSP) as required. The FSPs are audited annually and updated every five years 3) Non-regulated facilities also maintain FSPs that are updated every five years 4) The FSPs complement the GoM SPU’s SMP 5) D&C follows SPU facility security plans

3.5.3 Risk Security HSSE Manager Develop internal security expertise in conjunction with Group Security and designate individuals as subject matter experts and security advisors to entity management.

Level 4 3-Moderate 1) GoM SPU has an embedded Business Security Manager (BSM) 2) GoM SPU is further supported at Group level by a Regional Security Advisor (RSA) 3) GoM SPU assets have an assigned Business Security Representative (BSR) that helps support the security program. The BSR role is filled by someone with other job responsibilities

Lack of D&C security expertise Lack of D&C Security Expertise

Security 2-Effeciency Enhance D&C Security Expertise Sims

3.5.4 Risk Security HSSE Manager Implement and maintain processes for the workforce to securely handle valuable and sensitive information in all forms, including Confidential and Secret information.


1) Information of Security Standard 2) Digital Security Standard 3) Code of Conduct 4) Privacy & Employee Confidentiality 5) Digital systems and security 6) Insider Trading 7) D&C control of sensitive information, e.g., DIMS, rig schedule 8) Access control on file shares and servers 9) Follow Security of Information Standard 10) Highly confidential projects require additional confidentiality agreements 11) Bldg. floors controlled via badge access (secure floors) 12) Rolled out Information Security Awareness campaign in 2008

3.5.5 Risk Security HSSE Manager Design and operate IT and digital process control systems to manage risk to system and information integrity, availability and confidentiality.


1) Digital Security Standard https://digitalsecurity.bp.com/securefiles/topicpage2.aspx?pagetag=ss_userstand_eng 2) Exploration's confidential documents and data are rigidly controlled 3) D&C follows Segment/Group/GoM processes 4) Check with German

No document register assigning level of confidentiality for each controlled document

Document Confidentiality Register

Data Management 2-Effeciency Embed use of GoM document control procedure (revise as necessary to close OMS gaps)

Jassal

3.6.1 Risk Environment HSSE Manager Systematically identify environmental hazards, assess risks and opportunities to minimise environmental impact, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risks and use as an input to the entity risk register. Environmental risks include but are not limited to emissions to air, discharges to water and land and the handling and disposal of waste.


1) Aspect/Impact identification and prioritization 2) Aspect/Impact Matrix 3) HSE Risk identification and ranking/matrix 4) O&T and EMPs 5) Operational controls (SOPs/STPs) 6) Compliance matrices and associated controls 7) Audits (BP and Contractors) 8) Regular meetings with main contractors to review functioning of C-EMSs

Inconsistent implementation of risk ID and management practices

Incon Enviro Risk ID and Mgt


Rich 1/21/10 -- Thierens to Rich. RMP/BPRAT process now in place to cover environmental risks. Closed per Rich

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Reduction targets for spills, but lack of Greenhouse Gas/air emissions, discharge, and waste reduction targets

GHG, Water, Waste Targets

Environmental 2-Effeciency Tink




The GoM Waste Management Program was not being followed as written (2008 S&O audit finding #022)

Waste Mgt Program Use Environmental 2-Effeciency Tink




3.6.2 Risk Environment HSSE Manager Identify the potential environmental, health and social impacts of projects, designing them to avoid or mitigate adverse impacts and reduce use of natural resources.


1) Drilling a well as a project 2) Screening and categorization 3) Compliance reports p/CVP phase 4) Environmental STP 5) BtB, DWOP, ETPs 6) Environmental Impact Statement - APD, DOCD, POE

3.6.3 Risk Environment HSSE Manager At Major operating sites, maintain external ISO14001 certification and produce an externally verified environmental statement at least every three years.


1) SPU (major operating site) certified to ISO 2) VES produced every 3 years (next due on 1010 for the reporting period '06-'09)

3.7.1 Risk Transportation E&A Wells Operations Manager

Systematically identify transportation hazards, assess risk, and implement and maintain plant, process, people and performance risk reduction measures identified as necessary to manage the risk, and use as an input to the entity risk register. Transportation hazards include but are not limited to road vehicle, bicycles, rail, ship, fixed-wing aircraft and helicopter travel.

Level 5 5-High 1) Aviation – Risk Register at Asset Level 2) Mitigation Bow Ties at Asset Level 3) GoM Contract Aircraft Guidelines. 4) Shore base – CMID Audit Process (Common Marine Inspection Document). 5) Marine - DP Trials (Dynamic Positioning). 6) Structural Review (for vessel > 25 yrs old). 7) Aviation - audits for compliance to standard. 9) Travel - flights preapproved by BP Aviation. 10) Group Recommended Practice on Aviation. 11) Shore base – BP GMAS (Global Marine Standard) Element 14 & 15. 12) Marine - CMID based on IMCA (International Marine contractor association). 13) Vessel Operating Instructions

Flying staff to Devon - unsure if approved

Flights to Devon Logistics 3-Basics/BP Verify flights to Devon are approved

Verify flights to Devon are approved Holt 8/30/09 Only fly staff via Approved PHI per Holt 8/4/09 y


Require that all vehicles operated by members of the workforce while on BP business are operated and maintained to a defined standard, have fully functional seat belts installed, and that the seat belts are worn by all occupants at all times whenever the vehicle is in motion.


1) Safe Practices Manual Chapter 9 (Driving Safety) contains all elements of this driving standard 2) Travel guidelines on rental cars 3) Defensive Driving training

No periodic assessment of compliance (SPU issue)

Periodic Asmnt of Driving Cmplnce

Vehicle Safety 3-Basics/BP Develop and embed vehicle safety assessment program.

Tink


Require that all vehicles operated by members of the workforce while on BP business are operated and maintained to a defined standard, have fully functional seat belts installed, and that the seat belts are worn by all occupants at all times whenever the vehicle is in motion.


1) Safe Practices Manual Chapter 9 (Driving Safety) contains all elements of this driving standard 2) Travel guidelines on rental cars 3) Defensive Driving training

Infrequent non-compliance through rental vehicles (direct rental through CWT prevents non-compliance) (SPU issue)

Vehicle Rental Cmplnce Vehicle Safety 3-Basics/BP Develop and embed vehicle safety assessment program.

Tink


Require that members of the workforce while operating a vehicle on BP business do not use mobile phones or other two-way communication devices.


Safe Practices Manual Chapter 9 (Driving Safety) contains this element


Periodic Asmnt Drvng Cmplnce


Tink





Not systematic - need refresher on group standard/RP - present defensive driving training in SPU does not cover GRP

Mobile Phone Driving Reqs Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink





New hire induction may not cover GRP on cell phone use while driving (SPU issue)

Mobile Phone Driving Reqs Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink


Require that motorcycles are not used on BP business unless a documented risk assessment is completed to support the advantages of their use rather than automobiles.

Level 3 3-Moderate 1) Safe Practices Manual Chapter 9 (Driving Safety) contains this element 2) Motorcycle use for company business is prohibited by our policy


Period Asmnt MC Driving Comp


Tink




Need refresher on group standard/RP - present defensive driving training in SPU does not cover GRP (SPU issue)

MC Driving Refresher Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink




New hire induction may not cover GRP on motorcycles (SPU issue)

MC Driving Orientation Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink


Require that in higher risk countries journey risk management plans must be in place.

n/a n/a 1) No high-risk journeys in GoM (although is covered in Safe Practices Manual Chapter 9 [Driving Safety]) 2) When GoM employees travel to high-risk countries, they follow the local plan


Require that members of the workforce driving on BP business be appropriately assessed, licensed, trained and fit to operate the vehicle, be rested and alert, and do not operate any vehicle when fatigued.

Level 3 3-Moderate Safe Practices Manual Chapter 9 (Driving Safety) contains all elements of this driving standard


Period Asmnt Driver Fitness


Tink




Need refresher on group standard/RP - present defensive driving training in SPU does not cover GRP (SPU issue)

Driver Fitness Refresher Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink




New hire induction may not cover GRP on driving (SPU issue)

Driver Fitness Orientation Vehicle Safety 3-Basics/BP Provide training/refresher training on vehicle safety standards.

Tink


Verify that all aircraft contracted or chartered to move the workforce for BP purposes, are operated and maintained to a defined standard, and that their use is in accordance with BP Requirements.

n/a n/a 1) Aviation – Contract Aircraft Guidelines 2) OGP Aircraft Management Guidelines 3) FAA Approved Operator Manuals and Guidelines 4) GOM CAG 5) Shore base – BP GMAS (Global Marine Standard) Element 14 & 15/Marine CMID based on IMCA (International Marine contractor association) 6) Vessel Operating Instructions


Implement and maintain a process to deliver safe, secure, timely and cost-effective BP employee business travel.


BP Travel Website use (which delivers this element) is required per BP Travel Policy


Period Asmnt of Travel Compliance

Vehicle Safety 2-Effeciency Develop and embed vehicle safety assessment program.

Tink

4.1.1 Procedures Procedures and Practices


Develop, implement and maintain local OMS procedures and practices for human resources, HSSE, engineering, operations, maintenance, inspection and projects. Require that operations procedures cover normal operating conditions as well as start up, shut down, upset and emergency conditions.

Level 4 5-High 1) Local and Segment D&C procedures exist which cover all requirements 2) Operations procedures cover normal conditions, start-up, shut down, upset and emergency conditions 3) Refer to Navigator (in future) for procedures list 4) Buckets include: Industry standards/procedures/maintenance/acceptance,etc.; Well Plans; Recommended Practices; Defined Practices; Equipment Ops Procedures (Maintenance and Inspection Procedures); Contractor Ops Procedures; Standard Ops Procedures; Emergency/Crisis Plans; Installation Procedures owned by others within BP; SIMOPS (held by assets); Rig Movement; STPs 4.1.1.1: DWOP 3.3.4 requires procedures be applied to all inspection, maintenance and operations

Processes are not standardized (Have identified redundancies - begun work, about 80% done - still discovering a few gaps along the way - in the process of creating STPs/ETPs. We have identified the different ways of doing processes and are working on standardizing these.)

Standardize Procedures Operations Procedures 2-Effeciency Standardize operating procedures. Ongoing -- DWOP rollout action plan to close ETP gaps

Rich 2/30/10



Define which procedures and practices are applicable to identified BP employees or contractors, and make these procedures and practices available to them. Require contractors to follow these procedures or practices unless they have their own comparable procedures and practices.


1) GoM D&C staff (including contractors) have access to, understand applicablity of, and follow these procedures 2) Refer to Navigator (in future) for procedures list 3) Well-specific and rig-specific plans are readily accessible

Some industry standards and RPs are not always readily accessible

Industry Standard/RP Access

Wells Procedures 2-Effeciency Identify and communicate access to relevant standards

Sprague and Rich to setup Sharepoint for accessibility.

Rich 12/30/10 10/22/09 -- Waiting on finalization of an SPU document control process. Leary should be able to help with close out date. Target date changed from 10/30/09 to 12/30/10

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Define which procedures and practices are applicable to identified BP employees or contractors, and make these procedures and practices available to them. Require contractors to follow these procedures or practices unless they have their own comparable procedures and practices.


1) GoM D&C staff (including contractors) have access to, understand applicablity of, and follow these procedures 2) Refer to Navigator (in future) for procedures list 3) Well-specific and rig-specific plans are readily accessible

The locations of some standard Ops procedures are not well understood by all

SOP Location Understanding


Establish Sharepoint site. Rich 3/30/10 10/22/09 -- Sharepoint site established. Navigator will also link to practices. Need to get all relevant practices established on the sites per Sprague/Rich direction. Target date changed from 10/30/09 to 3/30/10.

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Monitor that entity procedures and practices are up to date, understood and consistently followed and take corrective action when gaps are identified.

Level 4 5-High 1) Many procedures are for specific operations 2) Pre-spud meetings, JSEAs, etc. help make sure things are understood prior to executing 3) Tech limit meetings, team leaders/ wellsite leaders/wells communications provide oversight

BP Global RPs - getting explicit about which ones will be used

Define Applicable RPs Wells Procedures 2-Effeciency Identify and communicate access to relevant standards

Sprague, Chester, Rich to define in Drilling Engineering Procedures Guide.

Rich 12/30/09 10/22/09 -- need to define/develop/communicate Drilling Engineering Procedure Guide

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Review and update entity procedures and practices at defined intervals confirming that they are sufficient to control the related risks.

Level 4 5-High 1) Procedures are reviewed and updated before each well 2) Contractor procedures are reviewed through the rig audit process 3) DWOP and BtB are updated at regular frequencies 4) SOPs are now becoming controlled and will be updated regularly

GoM D&C RPs, STPs and SOPs currently are not set up for regular reviews

Regular Procedure Review Wells Procedures 3-Basics/BP Establish regular review process for standards

Plan to Rollout regular procedure review. Rich 12/30/10 10/22/09 -- D&C will develop this process as part of its document control process. Review dates to be included in creation/revision of standards beginning now. Date target date changed from 10/30/09 to 12/30/10.

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After each update communicate any changes or additions to entity procedures and practices to the affected BP employees and contractors.

Level 4 5-High 1) MoC (BP and Contractor) 2) Drilling Team Leader communicates at Tech Limit and Pre-Spud meetings 3) JSEA is used pre-task 4) Sharepoint maintains latest versions of documents

Communications sometimes are not clear throughout the organization

Procedure Comms Wells Procedures 5-Sig Risk Develop and Embed Procedural Change Communications

Leadership needs to consistently emphasize need to communicate

Rich 12/30/09 10/22/09 -- Standardized procedures/RPs/SOPs have been established across the organization. Changes are managed by the MoC process. Document control is in place for RP and SOPs. 1/18/10 -- closed per Rich.

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4.2.1 Procedures Management of Change

Performance Manager

Implement and maintain a Management of Change (MOC) process for temporary and permanent changes.


1) GoM D&C Recommended Practice for Management of Change (2200-T2-PM-PR-000001) 2) GoM Drilling and Completion Quick Reference Guide, version 1.0 3) Management of Change Wiki on GoM D&C Sharepoint Site 4) BizFlow MoC tool and D&C workflow 5) Training session ongoing for teams (Level 4 conformance when rollouts complete) 4.2.1.1: [no data]

Rollout not complete Implement MOC MOC 3-Basics/BP Rollout and embed MOC process. Jassal


Performance Manager

Monitor legal and regulatory requirements and BP requirements so as to be aware of changes in these that might necessitate changes to the entity operating activity. 4.2.1.1 Adopt eMOC when migrating the local business to an electronic MoC system.


1) Scherie Douglas (BP Sr. Regulatory Specialist) is the D&C tag for reviewing Regulatory requirements 2) The GoM Regulatory Notice Practice (currently being circulated for review) defines the process 3) This document is expected to be authorized by end of 2Q 2009

Process not complete - finalize and communicate procedure by end 2Q09

Regulatory Notice Process Compliance Program 1-Excellence Develop and embed Regulatory Change procedure

Develop a GoM Regulatory Notice Practice document that defines the process (Scherie Douglas).

Tink 10/30/09 Document completed 2Q 09' per Tink. 9/22/09 Jim Grant considering rollout options for SPU - if no rollout by SPU, will execute D&C rollout. 10/21/09 - Jim Grant Rolled out to D&C LT. Complete - Tink.

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Performance Manager

Specify criteria for determining which proposed changes to entity operating activity require application of the MOC process, paying particular attention to those affecting plant, material, equipment, technology, process, products, services, procedures, practices, people and organization. 4.2.3.1 Define criteria for determining the applicable MoC type (i.e. technical, organizational or administrative).


Reference GoM D&C Recommended Practice for Management of Change (2200-T2-PM-000001), Section 3.2, "Types of Changes," which specifies changes and gives examples of changes that require a formal MoC 4.2.3.1: [no data]

Rollout not complete - current rollout of Rec Practice and BizFlow should take D&C Organization to Conformance Rating 4 by end of May09

Implement MOC MOC 3-Basics/BP Rollout and embed MOC process. Jassal


Performance Manager

Include in the MOC process: risk assessment, identification and application of risk reduction measures; the required level of management approval; application of a review prior to implementing the change to verify that identified risk reduction measures are in place and identified training completed; and updating of relevant documents.


Reference GoM D&C Recommended Practice for Management of Change (2200-T2-PM-000001), Section 5, "Process Detail, BizFlow DCMOC Workflow, and Roles"

Rollout not complete (current rollout of Rec Practice and BizFlow should take D&C Organization to Conformance Rating 4 by end of May09. Additionally, the Recommended Practice on Risk Management currently being worked should better define Risk Assessment requirements when doing an MoC.)

Integrate Risk Asmnt w/MOC


Complete and assure use of MOC via Bizflow. Assure risk is addressed in the process.

Rich 8/30/09 8/14/09 -- In place per Thierens y


Performance Manager

Communicate the details of the proposed change to affected members of the workforce.


1) Reference GoM D&C Recommended Practice for Management of Change (2200-T2-PM-000001), Section 5.9, "MoC Post-Approval Action Items and MoC Close-out" 2) BizFlow tool provides communication to those reviewing and approving MoC, and provides reminders in close-out of an MOC to communicate to all affected parties and update documentation

Rollout not complete (current rollout of Rec Practice and BizFlow should take D&C Organization to Conformance Rating 4 by end of May09)



Performance Manager

Track MOC actions to closure. 4.2.6.1 MoC Workflow Process (see table in E&P OMS Manual).


1) Reference GoM D&C Recommended Practice for Management of Change (2200-T2-PM-000001), Section 5.9, "MoC Post-Approval Action Items and MoC Close-out" 2) BizFlow tool tracks actions

Rollout not complete (current rollout of Rec Practice and BizFlow should take D&C Organization to Conformance Rating 4 by end of May09)



Performance Manager

Verify the original scope and duration of temporary changes are not exceeded without review and approval.

Level 2 3-Moderate BizFlow tool can be utilized for review of MOCs No audit or system process to identify or to prevent deadline creep

MOC Deadline Creep MOC 4-Moderate to High

Implement MOC review process. Work with Vani Rao to create a fit for purpose process to identify overdue MOC actions and subsequent management review (Jordan)

Jassal 12/30/09 9/20/09: Need to schedule one of the CP coordionators to pull the open temporary MoCs on a quarterly basis and review any with the LT. 14 Jan 10 - Are setting the calendar for the D&C LT for the year. Will review any overdue MoC actions on a quarterly basis with the D&C LT.

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4.3.1 Procedures Information Management and Document Control

Performance Manager

Define and implement an information management and document control process to control the approval, publication, transmission, storage, change, retention and disposal of controlled documents. 4.3.1.1 Identify document owners for controlled documents.

Level 2 3-Moderate 1) Use of the GoM Document Management Procedure 2020-T2-DM-PR-000002 is starting to be followed by some of the teams within D&C 2) GoM Document Register 3) Some guidance on GoM D&C Sharepoint site 4.3.1.1 - D&C Organization is beginning to get document owners

Existing document not widely vetted/implemented (no approved document - GoM D&C Leadership needs to confirm this is the approved Procedure for all of GoM, and if so, communicate this to the GoM D&C team. GoM D&C needs to develop a specific recommended practice for Document Management)

Document Control Procedures

Wells Procedures 3-Basics/BP Identify and communicate access to relevant standards

Rich 3/30/10 10/22/09 -- Sharepoint site established. Navigator will also link to practices. Need to get all relevant practices established on the sites as defined by Rich/Sprague. Date changed from 10/30/09 to 3/30/10

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Performance Manager

Define and implement an information management and document control process to control the approval, publication, transmission, storage, change, retention and disposal of controlled documents. 4.3.1.1 Identify document owners for controlled documents.

Level 2 3-Moderate 1) Use of the GoM Document Management Procedure 2020-T2-DM-PR-000002 is starting to be followed by some of the teams within D&C 2) GoM Document Register 3) Some guidance on GoM D&C Sharepoint site 4.3.1.1 - D&C Organization is beginning to get document owners

SPU Gap: Lack of documented process and consistent, simplified use of the systems in place

Use Document Control Proced

Data Management 3-Basics/BP Embed use of GoM document control procedure (revise as necessary to close OMS gaps)

Jassal


Performance Manager

Specify the types of information, documents and records that are to be controlled documents and maintain formal registers of these controlled documents. 4.3.2.1 As a minimum, include the following as controlled documents: Local OMS; Drawings; Policies; Internal standards; Procedures and practicts (i.e. operating and maintenance procedures); Regulatory compliance records; Design data; Training records.

Level 2 3-Moderate Some guidance given in SPU GoM Document Management Procedure 2020-T2-DM-PR-000002 4.3.2.1: [no data]

Same as 4.3.1 Use Document Control Proced


Jassal


Performance Manager

Provide ready and secure access to controlled documents, removing obsolete information and documentation from circulation.


Documentum, GoM D&C Sharepoint, CPOL, File Servers all have controlled access

No formalized procedures exist for a systematic review and removal process. (Formalized procedures for these tools needs to be established. Consolidation of tools would improve efficiency. Improvemements in compatibility between Documentum and other tools would help, or replace Documentum with a compatible tool for document storage.)

Document Control Procedures


Jassal





Performance Manager

Maintain and retain BP employee health and medical records as medical confidential and occupational exposure records as confidential.

Level 4 3-Moderate Records kept by BP medical The organization may not know what it needs to know about confidentiality, etc.

Med Rcrds Conf People 4-Moderate to High

Communicate medical information confidentiality

Confirm with medical that all records are kept confidential .

Nahman 8/30/09 08/17/2009. All medical information is confidentially maintained within the medical group Per Nahman 8/17/09. The medical department collects all documentation and it does not go to the team leader at all. Medical will also not release any medical details to the team leader or HR for that matter. Will also send a note to all team leaders reminding them that if they do receive any medical information on an employee (ie the employees tells them) that they are not to share that data with anyone else.

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4.4.1 Procedures Incident Management

HSSE Manager Develop and maintain an incident reponse capability. 4.4.2.1 Implement systems, processes and procedures to report, investigate, and analyze HSSE incidents, non-conformances to BP requirements and regulatory non-compliances, based on risks faced by the local business. 4.4.2.2 Use the E&P Segment incident reporting tool (Tr@ction) to record incidents. 4.4.2.3 Investigate HSE incidents and non-conformances per table 4.4.2.3, using the more sever of the actual and potential outcome classifications.


1) BP and contractor rigs maintain emergency medical and fire response personnel 2) MMS inspections and drills 3) The GoM Safe Practices Manual "Incident Notification, Reporting and Investigation" procedure is used within D&C 4) D&C maintains experienced and designated on-call investigation leaders and root cause specialists 5) HSE management reviews quality of investigations post-accident investigation


HSSE Manager Report and investigate incidents to establish immediate and system causes. Identify action plans to address identified causes with due dates for completion and track to completion..


1) The GoM Safe Practices Manual "Incident Notification, Reporting and Investigation" procedure is used within D&C 2) Tr@ction is used for initial incident information and reporting; all incident Recordable/HiPo and higher also apply formal root cause investigation and corrective actions 3) Resulting actions are tracked in Tr@ction, which include completion dates and accountabilities 4) Periodic closure reports are run to track completion 4.4.2.1: Same as above 4.4.2.2: Tr@ction used by BP and contractors 4.4.2.3: BP Investigation procedure meets the severity matrix requirement

4.4.2.1 Contractors' systems for investigations: unclear whether their application quality will meet BP expectations

Contractor Inc Inv Quality Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Handoff to Tink HSSE Committee. Tink 10/30/09 1/18/10 -- responsibility to Tink from Sprague per Rich

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HSSE Manager Report and investigate incidents to establish immediate and system causes. Identify action plans to address identified causes with due dates for completion and track to completion..


1) The GoM Safe Practices Manual "Incident Notification, Reporting and Investigation" procedure is used within D&C 2) Tr@ction is used for initial incident information and reporting; all incident Recordable/HiPo and higher also apply formal root cause investigation and corrective actions 3) Resulting actions are tracked in Tr@ction, which include completion dates and accountabilities 4) Periodic closure reports are run to track completion 4.4.2.1: Same as above 4.4.2.2: Tr@ction used by BP and contractors 4.4.2.3: BP Investigation procedure meets the severity matrix requirement

4.4.2.1 Contractors don't use ABC analysis

Contractor Inc Inv ABC Analysis

Learnings/Tracking 1-Excellence Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Sprague 10/30/09 1/21/10 -- We require contractors to thoroughly investigate and review with BP leadership. We don't consider a gap to exist here, and consider this closed per Sprague/Rich

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HSSE Manager Analyse collective results of incident investigations at defined intervals to identify trends in immediate and system causes. Develop action plans to address identified trends with due dates for completion and track to completion.


1) Trends are analyzed on an event-driven basis 2) GoM trending analysis via Tim Church 2007 analysis 3) Field/office safety advisor analysis 4) D&C has HSSE Performance Management System that includes a Management Steering Committee, Performance Reviews, and Well Site Leader Engagement Sessions 5) During those, we review collective results of incidents, Lessons Learned, action plans, improvement options 6) Embedding of key learnings 7) Process began in 1Q09 and is becoming systematic

No systematic process beyond Meeting Minutes to ensure completion of actions that result from the Management Steering Committee meetings

Track Mgt HSE Rev Actions


Sprague 10/30/09 1/21/10 -- Sharepoint process now exists for each team, including management, to track their actions within sharepoint. Closed per Sprague.

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4.5.1 Procedures Control of Work HSSE Manager Implement and maintain a process to plan work, identify hazards, assess risk and put in place risk reduction measures to allow work tasks to be completed safely and without unplanned loss of containment causing environmental damage. 4.5.1.1 Define types of hazardous work that require a work permit. 4.5.1.2 Document and communicate the roles, responsibilities and accountabilities within the permit to work (PTW) system, including any that are specific to hazardous work: Assign roles and responsibilities as set out in Table 4.5.1.2; Check that individuals assuming the roles know their responsibilities; Assign the roles of Performing Authority and Issuing Authority (or other rolese responsibile for issuing the permit) to different individuals for any given permit; Define criteria and circumstances under which individuals can perform multiple roles without compromising the integrity of the PTW system; Identify and document those roles in the PTW system that are exclusive to BP employees. 4.5.1.3 Execute the PTW process described in the requirements listed in Table 4.5.1.3.

Level 4 5-High 1) BP-Owned Rigs 2) Safe Practices Manual Control of Work: ISSOW system, PTW training records, Energy Isolation 3) CMAS assessments 4) ISSOW training provided to contractors serving as Performing Authority and to new employees 5) "GOM Offshore Orientation" awareness level overview of PTW/ISSOW system and requirements 6) Contractor-specific JSEAs, SIMOPS PTW meetings 7) Control of Work assessments/audits performed 8) Contractor-owned rigs 9) Transocean risk assessment or Think Process (HQS-HSE-PP-01 Section 4, Subsection 2.1) 10) PTW process, TOI (Health & Safety HQS-HSE-PP-01, Section 4, Subsection 2.2) 11) Rowan has documented program 9) Contractor CoW process has been verified through the use of the BP CoW Self Assessment Process to BP's SPM CoW process and is reflective in bridging documents 4.5.1.1: Defined as above 4.5.1.2: Refer to 4.5.1: RRs defined/assigned. Control of Work assessments/audits performed 4.5.1.3: We follow the BP Control of Work process

No clear determination, based on risk assessment, as to whether boat-to-rig mud transfers should require a permit

Boat to Rig Trans Permit Logistics 3-Basics/BP Risk assess and determine permitting requirements for boat-to-rig mud transfers.

Will confirm with current practices with wells team leaders and correct as necessary

Holt 8/30/09 Confirmed with all the Ops Team Leaders…DDII, PDQ, Enterprise, and Horizon. All use PTW for SBM (and Diesel transfers); DDIII will be when they arrive. Holstein was doing everything but the permit; rig now to cold stacked; will do permits for Diesel near term. Marianas was not doing a PTW, they will start the same this week. Now all rigs are doing PTW for SBM and Diesel transfers…gap is closed -- per Holt 8/6/09

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4.5.1 Procedures Control of Work HSSE Manager Implement and maintain a process to plan work, identify hazards, assess risk and put in place risk reduction measures to allow work tasks to be completed safely and without unplanned loss of containment causing environmental damage. 4.5.1.1 Define types of hazardous work that require a work permit. 4.5.1.2 Document and communicate the roles, responsibilities and accountabilities within the permit to work (PTW) system, including any that are specific to hazardous work: Assign roles and responsibilities as set out in Table 4.5.1.2; Check that individuals assuming the roles know their responsibilities; Assign the roles of Performing Authority and Issuing Authority (or other rolese responsibile for issuing the permit) to different individuals for any given permit; Define criteria and circumstances under which individuals can perform multiple roles without compromising the integrity of the PTW system; Identify and document those roles in the PTW system that are exclusive to BP employees. 4.5.1.3 Execute the PTW process described in the requirements listed in Table 4.5.1.3.

Level 4 5-High 1) BP-Owned Rigs 2) Safe Practices Manual Control of Work: ISSOW system, PTW training records, Energy Isolation 3) CMAS assessments 4) ISSOW training provided to contractors serving as Performing Authority and to new employees 5) "GOM Offshore Orientation" awareness level overview of PTW/ISSOW system and requirements 6) Contractor-specific JSEAs, SIMOPS PTW meetings 7) Control of Work assessments/audits performed 8) Contractor-owned rigs 9) Transocean risk assessment or Think Process (HQS-HSE-PP-01 Section 4, Subsection 2.1) 10) PTW process, TOI (Health & Safety HQS-HSE-PP-01, Section 4, Subsection 2.2) 11) Rowan has documented program 9) Contractor CoW process has been verified through the use of the BP CoW Self Assessment Process to BP's SPM CoW process and is reflective in bridging documents 4.5.1.1: Defined as above 4.5.1.2: Refer to 4.5.1: RRs defined/assigned. Control of Work assessments/audits performed 4.5.1.3: We follow the BP Control of Work process

No D&C-wide analysis of Control of Work audit/assessment results

D&Cwide COW Asmnt Results


Tink Traction Sprague 10/30/09 1/21/10 -- D&C participates in functional reviews of COW results. New D&C COW practice exists segment wide is also being developed. Closed per Rich/Sprague

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4.6.1 Procedures Crisis and Continuity Management and Emergency Response

Atlantis Wells Operations Manager

Identify crisis and continuity management scenarios utilising the entity risk register, the output of the entity’s Major Accident Risk assessment and other information.

Level 5 5-High 1) Utilize a common template for crisis response (BART), including major accident risks, environmental, and security risks 2) SPU has a business continuity plan in place, including tracking all personnel



Implement and maintain crisis and continuity management plans to manage the scenarios identified. These will include procedures from initiation to response and recovery. At site level these plans shall include arrangements for evacuation and, where needed, for initial shelter-in-place.

Level 5 5-High 1) Crisis and business continuity plans are in place and managed by the CMER efforts, including offshore site-specific emergency response and evaluation plans 2) All plans are shared with government, state, and local agencies 3) Oil Spill Response Plan 4) ERP - each facility 5) Pandemic Response Plan (refreshed) 6) MMS drills (unannounced) 7) USCG participates in drills 8) BP drills



Validate the plans through exercising them at defined intervals. Review the plans at least annually to reflect changes in hazards, risks, organisation or contact details, and implement identified improvements.

Level 5 5-High 1) Crisis management plans are reviewed on a quarterly basis via the CMER team 2) At least two drills take place each year 3) All IMT personnel are trained and tracked 4) Drills and incidents are reviewed for Lessons Learned 5) Improvements are incorporated into new drills, and then actual responses are tracked via the CMER team



Provide access to trained personnel, resources, medical emergency and other facilities needed to implement and execute the crisis and continuity management plans.

Level 5 5-High 1) Incident Commander for each drill and response is delegated by position; the authority and responsibility to execute the plans is via DOA 2) Financial authority 3) IMT system 4) Fixed rotation 5) Contracts in place with service providers for emergency response 6) TRG, etc.



Implement, maintain and exercise a documented process for accounting for personnel during and after an emergency evacuation.


1) GoM SPU POB reporting 2) Phone Tree system, including mapping of affected personnel 3) Tracking during actual response by the Resouce Section Leader 4) City of Houston-required fire drills 5) Emergency Response booklets 6) Orientation at office inlcudes ER plans/muster points

5.1.1 Assets Project Management

Projects Manager Implement and maintain a documented system for managing projects which provides for five stages of project development (Appraise, Select, Define, Execute and Operate) with approval at each stage-gate by an identified gatekeeper.

Level 5 5-High 1) Documented in MPcp, BtB, locally for GoM D&C in "Way We Work" and "MPcp for D&C Major Projects" 2) http://epsegmentcommonprocess.bpweb.bp.com/Default.aspx?tabid=56; http://epsegmentcommonprocess.bpweb.bp.com/Default.aspx?tabid=60 3) BP Internal audit on 3-year cycle

Orientation system is in place but not defined for new hires coming into the business

Project Stages Orientation Project Management 2-Effeciency Harland


Projects Manager Identify legal and regulatory and BP requirements applicable to the design, procurement, construction, commissioning, start-up and handover of the project facilities.

Level 4 5-High 1) Regulatory Well Design requirements documented in MMS Code of Federal Regulations Title 30, Section 250 2) Validation that BP is meeting these requirement demonstrated through MMS approval of APDs, APMs, EPs, etc. 3) BP requirements documented in Equipment Integrity Assurance (EIA) document for GoM required by TA 4) Have an ESOR system in place to feed administration and workflow out of TIAPs 5) DWOP 6) Rig Construction Manual

Codes/standards are not utilized uniformly across the globe

Global Code Proj Standards Project Management 3-Basics/BP Develop and embed global Projects codes/standards

Raise awareness of existing codes and regulations

Harland 3/30/10 10/25-08 -- no progress; 1/18/10 -- target date to 3/30/10 from 12/30/09 per Kirton

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Projects Manager Document the project objectives in a statement of requirements and have them agreed by the identified gatekeeper.


1) Requirement documented in MPcp and BtB and applied locally as documented in "MPcp for D&C Major Projects" 2) http://gomdnc.bpweb.bp.com/docs/Documents/Processes/Stage Gated/DnC MPcp/MPCP reduction ver 3.doc


Projects Manager Develop and implement a documented project execution plan which covers concept selection through to handover.


1) Requirement documented in MPcp is project-level that contains a section for D&C 2)http://epsegmentcommonprocess.bpweb.bp.com/Default.aspx?tabid=56 3) PEP reviewed/ signed by AGM and Project Manager plus discipline leads


Projects Manager Implement and maintain a comprehensive Quality Assurance/Quality Control process for project design, procurement, construction, commissioning, start up and handover.

Level 3 5-High 1) QA/QC of engineered equipment documented in Equipment Integrity Assurance (EIA) program covers equipment design, procurement, manufacturing, and acceptance 2) EIA is being rolled out to GoM, and engineers are beginning to use the ESOR process 3) We have QA/QC plans in place 4) Will be a Conformance Rating 4 at some point, may not be there yet 5) http://eia.bpweb.bp.com/ 6) Acceptance: Each producing asset has a handover document in Well Integrity Mgmt Program for GoM: http://eia.bpweb.bp.com/ 7) Each GoM Project develops a Project Quality Plan that describes the Quality Management System used for project design, procurement, construction, commissioning, startup, and handover 8) The Quality Management System is designed to follow the MPcp Engineering and Quality Management Guidelines and the ETP 50 and 32 series (DWGOM GP 50-20, 50-10, 32-10 to 19) 9) Various supporting quality-related documents are used, including Quality Requirements for Request for Quotations (RFQ), Quality Requirements for Construction Contractors, etc. 10) Refer to the Mad Dog Rig Repair Project quality documents as evidence

ESOR system in place, but still in growing phase in that its level of detail is unclear, and inconsistencies exist

Embed ESOR System Project Management 2-Effeciency Rich 1/21/10 -- ESOR and ETP 1050 now part of all well design. Complete per Rich

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Projects Manager Implement and maintain a comprehensive Quality Assurance/Quality Control process for project design, procurement, construction, commissioning, start up and handover.

Level 3 5-High 1) QA/QC of engineered equipment documented in Equipment Integrity Assurance (EIA) program covers equipment design, procurement, manufacturing, and acceptance 2) EIA is being rolled out to GoM, and engineers are beginning to use the ESOR process 3) We have QA/QC plans in place 4) Will be a Conformance Rating 4 at some point, may not be there yet 5) http://eia.bpweb.bp.com/ 6) Acceptance: Each producing asset has a handover document in Well Integrity Mgmt Program for GoM: http://eia.bpweb.bp.com/ 7) Each GoM Project develops a Project Quality Plan that describes the Quality Management System used for project design, procurement, construction, commissioning, startup, and handover 8) The Quality Management System is designed to follow the MPcp Engineering and Quality Management Guidelines and the ETP 50 and 32 series (DWGOM GP 50-20, 50-10, 32-10 to 19) 9) Various supporting quality-related documents are used, including Quality Requirements for Request for Quotations (RFQ), Quality Requirements for Construction Contractors, etc. 10) Refer to the Mad Dog Rig Repair Project quality documents as evidence

Unfamiliarity of all teams with Well Handover Process and documentation (not engineered equipment)

Embed Well Handover Process


Set up workshop to educate D&C. Waters 6/30/09 10/22/09 -- Set up new IM team with responsibility to work with SS&W to finalize and communicate process. 1/21/09 -- SPA Rich to Waters. Documented Well Handover best practice now in place. Planning roll-out.

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Projects Manager Integrate operations, maintenance, HSSE and, where applicable, marine expertise during concept selection, definition of engineering scope, and design, construction, commissioning and handover of facilities.


1) A requirement of MPcp, this is done formally through HAZOPs and HAZIDs involving D&C participation on multi-disciplinary review teams 2) Formal D&C discipline-specific reviews occur during various stage gates and include "No Drilling Surprise" workshops, Drill/Complete "Well on Paper" sessions with rig crews, rig team pre-tour meetings, and pre-job JSAs 3) This is also done informally as a result of having a central D&C organization 4) Peer Assists and Peer Interaction occurs routinely where well designs being considered for Major Projects are reviewed with peers in Operations 5) Marine Ops and Assurance are involved in the development of SIMOPS strategies and plans 6) Rig Audit 7) Marine Assurance plans for new-build rigs

Lack of operations and interventions interface early in projects and assets

Integrate Interventions w/Projects

Project Management 3-Basics/BP Operations-don’t agree Interventtuiob Harland 10/25-08 -- no progress


Projects Manager Identify and assess the risks associated with the project interfaces to existing operations and implement plans to manage the identified risks.

Level 3 5-High 1) Documented in MPcp, BtB 2) Documented locally for GoM D&C in the "Way We Work" and "MPcp for D&C Major Projects"

Project interface risks exist within D&C, and between D&C and other functions, especially when there is no designated Wells Team Leader or Interface Manager

Project Interfaces Project Management 3-Basics/BP Develop and embed process to provide operational interface within Projects.

Identify specific interface risks as opposed to Projects/Engineering Risks that have already been identified and implement mitigation plans


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Projects Manager Conduct documented HSSE reviews, pre-start up safety reviews and operational readiness reviews for projects, including projects on existing facilities, and close out agreed actions.

Level 5 5-High 1) Documented in MPcp, BtB 2) Documented locally for GoM D&C in the "Way We Work" and "MPcp for D&C Major Projects" 3) A requirement of MPcp, this is done formally through HAZOPs and HAZIDs involving D&C participation on multi-disciplinary review teams 4) Formal D&C discipline-specific reviews occur during various stage gates and include "No Drilling Surprise" workshops, Drill/Complete "Well on Paper" sessions with rig crews, rig team pre-tour meetings and pre-job JSAs 5) This is also done informally as a result of having a centralized D&C organization 6) Peer Assists and Peer Interaction occurs routinely where well designs being considered for Major Projects are reviewed with peers in Operations 7) Marine Ops and Assurance are involved in the development of SIMOPS strategies and plans 8) Project EDR/PHSSER


Projects Manager Conduct documented post-project reviews to identify lessons for future projects.

Level 3 3-Moderate 1) Requirement documented in MPcp, BtB 2) Documented locally for GoM D&C in the "Way We Work" and "MPcp for D&C Major Projects" 3) Lessons capture happens on a number of levels and venues including bi-weekly meetings, global network teleconferences, completions monthly barnyard meetings, post-well reviews, etc. 4) Horn Mountain post-project review was well-inclusive 5) First-Year Operability Reviews are conducted consistently (driven at Segment level)

Asset-level post-well reviews are inconsistent

Incon Asset Post Well Review


BtB Action Item is being addressed with Comp. Eng. Mgr taking the lead.

Waters 3/30/10 1/18/10 -- from Sprague to Waters per Rich. Being worked by Keck with SS&W. Closure driven by the re-organization and getting key stakeholders re-engaged and aligned with the revised plan for post well reviews.

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5.2.1 Assets Design and Construction

Projects Manager Establish the basis of design following BP requirements and considering new technology, business requirements, performance improvement, normal and abnormal operating conditions, start-up, shut down, ramp-up, turndown and decommissioning.

Level 4 5-High 1) Well construction and delivery is governed by BtBcp and supported by GoM Well Integrity Management Program (http://dwwi.bpweb.bp.com/default.htm), Element 1—Sub Element, Design Codes, Standards and Regulations Compliance, and Element 2—Well Operating Procedures 2) Segment Defined Operating Practices (DWOP) 3) D&C Defined operating practices (18 ETP s + BtB) 4) D&C Recommended Practices (Surveying, Tubular Design, Well Control, and Cementing) 5) D&C Guidance (BHA Design and Downhole Tool Reliability, Well Bore Stability, Organizational Guidelines, Sidetracking, Fluids Management, Perforating, Cavings Field Guide, Stuck Pipe Library, Well Cost Estimating, Wellsite Checklists, etc.) 6) Further supported by BP Common Processes: Exploration cp (Ecp); Major Projects cp (MPcp); Beyond the Best cp (BtBcp); Base Management cp (BMcp); Integrated Field Planning cp (IFPcp); Production Efficiency Improvement cp (PEIcp); Supplier Performance Management cp (SPMcp)


Projects Manager Design plant, assets, facilities and floating structures (including engineered systems, marine systems, structures and protective systems) in accordance with inherently safer design principles and BP requirements.

Level 4 5-High 1) Design in accordance to: a) GoM Well Integrity Management Program (http://dwwi.bpweb.bp.com/default.htm) b) Segment Defined Operating Practices (DWOP) c) D&C Defined operating practices (18 ETPs + BtB) 2) Functional Assurance provided by EAs (D&C)

Lack of understanding of GP 48-03 applicability

GP 48-03 Applicability Project Management 1-Excellence Develop and embed global Projects codes/standards

Embed D&C checklist in Select Phase to ensure Process Safety Review has been accomplished


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Projects Manager Procure and construct plant, assets, facilities and floating structures in accordance with the design.


1) Functional assurance for procurement is in place and supported by PSCM team 2) Design Basis for well construction is documented 3) Quality plans are in place with suppliers 4) Procurement and well construction is also governed by additional BP Common Processes: Exploration cp (Ecp); Major Projects cp (MPcp); Beyond the Best cp (BtBcp); Base Management cp (BMcp); Integrated Field Planning cp (IFPcp); Production Efficiency Improvement cp (PEIcp); Supplier Performance Management cp (SPMcp)


Projects Manager Develop and maintain a Marine Assurance Plan, to encompass the specification, design, construction and commissioning of the marine structure and systems of all floating production and storage units, in conjunction with BP Shipping and the Segment Marine Authority.

Level 5 5-High 1) Marine Assurance plans have been developed for DDIII and PS1 & 2 2) "BP (GoM) does not design, construct or commission MODUs. The boats we use are all third party owned. Also we chose not to delegate to BPS. I did the MAP for D&C and GOM accountabilities and assurance as requested by Harry and Kevin after we decided that GoM would not delegate anything to BPS.” --quote by Neil Cramond, BP Marine Authority 3) Local marine group is led by Marine Authority, Neil Cramond. Processes, procedures, inspection plans, etc. can be located at the following: http://gomtools.bpweb.bp.com/One%20Touch/Marine/VA_v2/Pages/default.aspx. 4) Rig Acceptance Audits cover marine assurance. Local marine group lead by Marine Authority, Neil Cramond. Processes, procedures, inspection plans, etc. can be located at the following: http://gomtools.bpweb.bp.com/One%20Touch/Marine/VA_v2/Pages/default.aspx


Projects Manager Delegate the supervision of the specification, design, construction and commissioning of all Marine Vessels to BP Shipping.

Level 4 3-Moderate 1) “BP (GoM) does not design, construct or commission MODU's. The boats we use are all third party owned. Also we chose not to delegate to BPS. I did the MAP for D&C and GOM accountabilities and assurance as requested by Harry and Kevin after we decided that GoM would not delegate anything to BPS.” --quote by Neil Cramond, Marine Authority 2) Local marine group lead my Marine Authority, Neil Cramond. Processes, procedures, inspection plans, etc. can be located at the following: http://gomtools.bpweb.bp.com/One%20Touch/Marine/VA_v2/Pages/default.aspx


Projects Manager Manage and control deviations from design standards, entity practices and procedures through a deviation process. Manage subsequent changes through the MOC process.

Level 5 5-High 1) As previously defined in DWOP, all deviations shall be handled via Dispensation Process as detailed in Addendum 3 2) Future deviations from standards (ETPs) on a local basis will be managed via STPs or Deviation Process as described in DWOP Addendum 3 & 4; all subsequent changes will follow MoC process 3) Reference MoC process (RP for D&C MoC)


Projects Manager Identify safety and production critical equipment and systems. Define and set safe operating envelopes, alarm parameters and required levels of inspection and maintenance.

Level 4 5-High 1) As previously defined in DWOP, all deviations shall be handled via Dispensation Process as detailed in Addendum 3 2) Future Deviations from standards (ETPs) on a local basis will be managed via STPs or Deviation Process as described in DWOP Addendum 3 & 4; all subsequent changes will follow MoC process 3) Reference MoC process (RP for D&C MoC)


Projects Manager Develop and implement a commissioning, start-up, handover and operating plan including a post start up review to confirm that construction is in accordance with design, all required verification testing is complete and all deviation and MOC actions are complete..


GoM Well Integrity Management Program (http://dwwi.bpweb.bp.com/default.htm), Element 2—Well Operating Procedures; Integrated Acceptance Test (rigs) 5.2.8.1: a) GoM Well Integrity Management Program (http://dwwi.bpweb.bp.com/default.htm), Element 2—Well Operating Procedures b) Post-well review c) MoC close-out process d) Full life-cycle integrity strategy documents in place for wells and BP-owned rigs along with maintenance, inspection and testing (MIT) plans for their implementation for wells. Rating: Level 4, High

5.3.1 Assets Asset Operation Thunder Horse Wells Operations Manager

Operate plant, assets, facilities, floating structures and transport equipment within defined safe operating envelopes, in accordance with documented operating procedures and taking due account of manufacturers’ recommendations. 5.3.1.1 Define safe operating limits (SOL) and operating envelopes for equipment covered by operating procedures or inspection plans: Identify critical operating parameters (e.g. pressure, temperature, flow, level, vibration) that, if exceeded, may compromise equipment integrity (see Figure 5.3.1.1); Specify upper and lower limits within which the equipment/process/system can operate safely. 5.3.1.2 Establish accountabilities for defining and updating equipment safe operating limits, including but not limited to the following: (see Table 5.3.1.2).

Level 3 5-High 1) All GoM BP-owned rigs operate each piece of equipment as per OEM Manuals with no deviations 2) There are also Equipment Operating Procedures available for the TH PDQ Rig equipment 3) Any potential excursion would require a MoC and/or Control of Work 4) Service Co. updates or bulletins are used to modify the equipment operating procedures 5) IM Audit in 2008 checked against Element 6 5.3.1.1: a) Ditto above b) Wells: Specify operating limits and tech limits regularly and at handover c) Re-visit and revise through MoC as needed 5.3.1.2: a) Safe Operating Limits are defined by manufacturers of rig equipment b) If we needed to deviate, would go through BP TA or EA and use MoC c) Integrity Management Manual - annual risk reviews to manage changing well conditions

No definition of the minimum requirements for EOPs for BP-owned rigs (in process now)

Owned Rig Procedures Operations Procedures 3-Basics/BP Define and apply minimum requirements for BP-owned rig equipment operating procedures.

Dan Welch to complete and issue document specifying minimum requirements.

Harder 8/30/09 9/11/09 -- 2200-T2-IM-RP-000005, Minimum Requirements for BP Owned Rigs Site Operating Procedures was issued 7/20 per Sullivan.

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Monitor, investigate and document excursions outside safe operating envelopes and unexpected failures of structures, materials and equipment. Identify and implement corrective actions.

Level 4 5-High 1) We do not deviate from maximum operating parameters recommended by the OEM 2) Any potential excursion would require a MoC 3) Incident Reporting procedure requires us to investigate and report as appropriate for accidental excursions 4) Override Log monitored weekly on Pride rigs (BP-owned)


At defined intervals review safety and production critical equipment and upgrade them as necessary to continue to achieve safe, responsible and reliable operation and competitive performance.


1) Vendor product information bulletins are part of this process along with recommendations from the drilling contractor 2) As for maintenance efforts, critical path maintenance efforts are worked into the SIMOPs plan 3) Two safety critical lists: one of BP, one of Pride. We use Pride's list 4) Maximo tracks equipment and inspection frequencies 5) Bi-weekly Pride report of KPIs and overdue safety critical equipment 6) For Wells: SEC equipment into Maximo, worked on priority basis, KPIs reported 7) Managed at asset level, not D&C





Verify both the adequacy and accuracy of production metering instrumentation at defined intervals.

n/a n/a N/A


Measure, report and investigate performance shortfall, and develop a prioritised plan to reduce such shortfall and address identified immediate and system causes.

Level 4 5-High 1) We hold bi-weekly meetings with the Pride Drilling O&M Team to discuss KPIs 2) Pride also presents their HSSE and operational performance data quarterly

5.4.1 Assets Inspection and Maintenance

Thunder Horse Wells Operations Manager

Develop and implement an inspection, maintenance and turnaround strategy to manage identified risks and deliver availability in line with the entity business strategy. Include inspection, maintenance and turnaround actions in the annual plan. 5.4.1.1 Implement a risk-based inspection, maintenance and reliability management system with tools developed and outputs documented. 5.4.1.2 Apply the Capital Value Process for Turnarounds (CVP-TAR) for full facility outages and for major TAR.


1) The rigs use Maximo to manage maintenance on the rig systems 2) Intervals for maintenance follow recommendations from the OEM 3) We follow Pride maintenance policy along with BP-owned rig equipment maintenance strategy document 4) 5-year plans follow OEM and API guidelines 5.4.1.1: Done regularly on a frequency basis, but not risk-based inspections - driven by MMS and USCG regulations for those systems 5.4.1.2: N/A



Implement and maintain an inspection programme to determine the condition of safety and production critical equipment and systems, and verify and document they are fit for service. Verify that deficiencies identified from the inspection programme are investigated and corrected on a timely basis. 5.4.2.1 Track critical equipment failures and apply appropriate defect elimination techniques.

Level 3 5-High 1) Maximo Maintenance System is used and SCE is monitored within this system and flagged when due 2) Work orders are issued according to equipment repair needs and/or OEM or API recommended intervals 3) Bi-weekly Pride overdue safety critical reviews 4) D&C In-service rig audits take place every two years per GP 10-40 5.4.2.1: a) Equip. failure reports b) Contractors document failure well c) IM-related equip. failures are put into Tr@ction program

Repair/conclusion of equipment failure reports is lacking per 5.4.2.1

Failure Report Conclusions Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Handled by Sullivan's Group. Sprague to engage.

Harder 10/30/09 1/18/10 -- from Sprague to Sullivan per Rich. n



Implement and maintain an inspection programme to determine the condition of safety and production critical equipment and systems, and verify and document they are fit for service. Verify that deficiencies identified from the inspection programme are investigated and corrected on a timely basis. 5.4.2.1 Track critical equipment failures and apply appropriate defect elimination techniques.

Level 3 5-High 1) Maximo Maintenance System is used and SCE is monitored within this system and flagged when due 2) Work orders are issued according to equipment repair needs and/or OEM or API recommended intervals 3) Bi-weekly Pride overdue safety critical reviews 4) D&C In-service rig audits take place every two years per GP 10-40 5.4.2.1: a) Equip. failure reports b) Contractors document failure well c) IM-related equip. failures are put into Tr@ction program

Failure reports are not well communicated per 5.4.2.1, e.g., passing on lessons learned and applying lessons learned

Failure Report Comm Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Sullivan's Group is SPA. We do not implement M&I programs, we assure them. Use BtB process and Sharepoint to monitor and post failure report.




Implement and maintain a maintenance management system to plan, schedule, resource and record the results of inspection and maintenance work. 5.4.3.1 Adopt Maximo when upgrading the local business electronic work management system.

Level 4 5-High 1) Maximo is used for this 2) Records are maintained in keeping with BP and regulatory requirements 5.4.3.1: GoM D&C uses Maximo

5.4.3: Inspection reporting results are not always documented in Maximo - difficult to do trending reports - can't access reports in Maximo

Document Inspection Reports


Sullivan's Group is SPA. We do not implement M&I programs, we assure them. Use BtB process and Sharepoint to monitor and post failure report. Need to discuss with Rig Audit process.




Evaluate inspection programme results and maintenance regimes, and modify the programmes to take account of the risk of equipment and system failure. 5.4.4.1 Assess, evaluate and utilize inspection and condition monitoring data when making risk-based decisions on scope of equipment repair and program optimization.

Level 5 5-High The Maximo System is constantly being updated with learnings, product information bulletin information, and when work is performed on each piece of equipment 5.4.4.1: Handled as part of business plan



Implement and maintain a process to verify that equipment replacement or modification maintains operating integrity.

Level 5 5-High 1) BizFlow MoC System is used on all rigs 2) TAs advised when needed 3) Reviewed by EAs and TAs 4) Control of Work Process 5) Commissioning and inspection



Verify equipment that has been out of service is fit-for-service prior to use. 5.4.6.1 Develop and utilize quality assurance/quality control processes, performance acceptance criteria and/or certified testing prior to putting equipment back into service after repair. 5.4.6.2 Confirm that operating parameters of equipment returned to service remain valid.

Level 5 5-High 1) Any rig system out of service for a length of time such as warm and or cold stack will be re-commissioned 2) Pre-startup review 3) HSSE checklist 5.4.6.1: a) Part of re-commissioning process b) Pre-operational checklist c) Pre-startup checklist d) Third-party verification 5.4.6.2: Ditto

5.5.1 Assets Decommissioning and Remediation

E&A Wells Operations Manager

Identify and consider decommissioning and remediation needs during project concept selection and design approval, updating them as needed over the lifecycle of the asset. 5.5.1.1 Incorporate regulatory and BP requirements for local businesses pertaining to decommissioning and remediation activities: Include the requirements for addressing soil and groundwater contamination and waste.


1) BP ETP, STP, and Policy documents are aligned with updated MMS regulatory requirements 2) Decommissioning and abandonment cost for end-of-life wells are comprehended in cost model during concept selection and updated throughout the life of projects 3) ETP (GP10-60) Zonal Isolation, etc. 4) Rig decommissioning 5) ISD GP 48-04 5.5.1.1: Ditto



Develop a risk based plan prior to decommissioning, long term shutdown, demolition or remediation and implement when required.


1) Risk Management as part of BtBcp for Wells P&A operations 2) Risk Management Processes and tools are being updated in alignment with OMS



Identify and manage HSSE impacts of decommissioning and remediation on existing operations, neighbours and the local community.


1) Section 26 of the Drilling and Well Operations Practice (DWOP) book (https://epti.bpglobal.com/C17/C4/GlobalDocLib/Document%20Library/NEW%20DWOP%20REV%206.pdf) 2) ETP (GP 10-60), Zonal Isolation Requirements during Drilling Operations and Well Abandonment and Suspension (http://etplib.bpweb.bp.com/login/IntegratedLogin.jsp?docNumber=GP%2010-60&docType=etp) 3) Regional Oil Spill Plan (http://docs.bpweb.bp.com/us_wl_dk_gom_hse:/website/custom/ims_vol2/index.htm) 4) Following MMS standards and 2003 DWOP 5) Updated 2008 DWOP will be rolled-out to GoM D&C in Oct. 6) MSDS sheets 7) GoM Safe Practices Manual

5.6.1 Assets Marine Operations Thunder Horse Wells Operations Manager

Recognise BP Shipping’s sole accountability for marine activity related to the transportation of cargo by bulk, with particular reference to the execution of the chartering, purchasing, leasing, selling and recycling of cargo carrying marine vessels and the provision of manning and technical management, voyage operation (including non customer facing scheduling), and vetting services for all cargo carrying marine vessels.

n/a n/a 1) Handled by BP Shipping 2) Documents that address these requirements Global Marine Standard (elements 14 & 15) 3) Recognized - Logistics Group handles that activity for D&C


Procure, charter, select, contract, operate and maintain marine vessels used in exploration, development and production to a defined standard.

Level 5 5-High 1) Handled by Marine Assurance 2) Documents that address these requirements include Global Marine Standard (elements 14 & 15) 3) GRP on marine operations 4) Segment-defined practice 5) ETP - DWOP - rig audit, acceptance, addresses GRP relating to MODUs 6) Reported quarterly 7) ETP is fully implemented 8) Local marine activity handled by Logistics


Conduct the scheduling of customer facing hydrocarbon transportation to a defined standard.

n/a n/a N/A to D&C





Operate and maintain Marine Terminals to a defined standard. Implement and maintain procedures that specify the requirements of a ship/shore interface.

n/a n/a N/A to D&C


Require that any marine vessel contracted for use by the BP entity meets a defined standard, fit for purpose and is vetted and approved by a defined process.

Level 5 5-High 1) Handled by Marine Assurance 2) Documents that address these requirements include Global Marine Standard (elements 14 & 15) 3) GRP on marine operations 4) Segment-defined practice 5) ETP - DWOP - rig audit, acceptance, addresses GRP relating to MODUs 6) Reported quarterly 7) ETP fully implemented 8) Local marine activity handled by Logistics


Produce an annual marine report on the scale of marine activity within the entity identifying associated marine risks.

n/a n/a 1) Handled by Marine Assurance 2) Documents that address these requirements include Global Marine Standard (elements 14 & 15) N/A to D&C

6.1.1 Optimization Plant Optimization Technology Manager

Identify and evaluate operating improvements and put prioritised plans in place to implement them.


1) DIMS (moving to OpenWells) is standard D&C tool for archiving operational records and to evaluate performance 2) A standard probabalistic risk and cost forecasting tool is used: MWE & SWE (https://epti.bpglobal.com/C0/Well%20Cost%20Estimating/default.aspx) 3) Standard KPIs of Days/10K and Days/Completion 4) D&C has operating envelope for Depth & Departure 5) These tools and processes are verified as projects go through MPcp/BtB Stage Gate Reviews 6) EOW Reports capture improvement ideas 7) GoM rig performance is monitored and reported in weekly standardized score cards 8) If operating conditions require a deviation from approved procedures, then an MoC is required 9) Track downtime for rigs (monthly) 10) Safe Operating Limits for all equipment - SORA for deviations (or MoC) 11) Track equipment performance in Maximo w/ work orders, inspection plans (BP-owned rigs) 12) Reliability - maintenance plans - condition-based maintenance, ongoing in Maximo 13) Reliability of systems contributes to maintenance plans 14) Product quality of rig fleet team and Pride - close relationships w/ vendors, equipment failure reports/feedback to vendors 14) Financial-commercial: monitor pricing/invoicing for third party work done on rig 15) Monitored/challenged costs 16) Monitor spills 17) SBM and spill containment 18) Air emissions monitoring 19) Technical Limit 20)

No clear written process describing the opportunity hopper of ideas for improvement for rigs

Rig Imprvmnt Op Hopper Process


Need to discuss with Sullivan. Consider management with Sharepoint.

Sprague 10/30/09 1/21/10 -- All contractors now participate periodically in operating improvement planning process reviews. Closed per Sprague/Rich

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Some equipment failure reports don't always address conclusions, or end up in Tr@ction, or are actioned (wells and rigs)

Address, Track Equip Failure


Being addressed in NPT Sharepoint Site Sprague 10/30/09 1/18/10 -- NCR system rolled out to LT; Revised NPT process; Skelton to review and finalize process for NPT & NCR and roll out; per Rich.

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Not common knowledge where some tools are located, e.g., MWE, SWE

MWE, SWE Tool Awareness


Will clarify in Drilling Engineering Procedures Guide.

Sprague 4/30/10 10/22/09 -- Need to develop and communicate to Drilling Engineering Procedures Guide. 1/21/10 -- SPA Rich to Sprague.

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Analyze production variances and put prioritised plans in place to reduce them.

n/a n/a N/A to D&C





Monitor the impact of changes to feedstocks and operating conditions on maintenance and inspection activities.

n/a n/a N/A to D&C Operational Feedstock Comment: Muds, brines, and chemicals used in drilling and completing wells are monitored by fluid engineers on the rigs.

6.2.1 Optimization Energy NA Include energy usage in the entity business strategy and annual plan.

n/a n/a N/A to D&C

6.2.2 Optimization Energy NA Assess, prioritise and implement technologies and other systems for improving energy usage.

n/a n/a N/A to D&C

6.3.1 Optimization Feedstock and Product Scheduling and Inventory

NA Develop and implement a logistics, inventory and production scheduling process to meet business needs.

n/a n/a N/A to D&C

6.3.2 Optimization Feedstock and Product Scheduling and Inventory

NA Review the effectiveness of this scheduling process at defined intervals and implement identified improvements.

n/a n/a N/A to D&C

6.4.1 Optimization Quality Assurance NA Establish feedstock, intermediates and product specifications based on customer and business needs and operational considerations.

n/a n/a N/A to D&C

6.4.2 Optimization Quality Assurance NA Implement and maintain quality assurance programmes to assure BP, contractor or supplier activities that are material to operating performance.

n/a n/a N/A to D&C (covered in 6.6.1)

6.4.3 Optimization Quality Assurance NA Monitor that products sold by BP meet product specifications. Respond to variances, identify immediate and system causes and take corrective action.

n/a n/a N/A to D&C

6.5.1 Optimization Technology Technology Manager

Identify opportunities for application of new or existing technologies consistent with the business entity strategy.

Level 4 3-Moderate 1) We have a GoM D&C Technology Plan that includes drilling, completions, and interventions for high-value technologies that apply across the SPU 2) Each of the producing assets and projects also have technology plans for their individual needs 3) The Wells Plan is integrated with the SPU technology strategy and plans to ensure alignment with the SPU business strategy 4) The GoM technology manager coordinates input from the assets and functions as part of the annual LTP process 5) The functional technology SPAs meet quarterly to update alignment and address common issues 6) We also interface with EPT to seek alignment with them on the GoM D&C technology needs 7) The GoM D&C technology manager hosts detailed annual project reviews with the EPT D&C flagship projects 8) We present our needs and issues, and they present their current projects and proposed new projects 9) Front End Loading considers technology enhancements (short-term) 10) MPcp has a technology readiness level component (longer view)

No consistent Technology governance process

Technology Gvrnance Process

Technology 1-Excellence Keck


Identify opportunities for application of new or existing technologies consistent with the business entity strategy.

Level 4 3-Moderate 1) We have a GoM D&C Technology Plan that includes drilling, completions, and interventions for high-value technologies that apply across the SPU 2) Each of the producing assets and projects also have technology plans for their individual needs 3) The Wells Plan is integrated with the SPU technology strategy and plans to ensure alignment with the SPU business strategy 4) The GoM technology manager coordinates input from the assets and functions as part of the annual LTP process 5) The functional technology SPAs meet quarterly to update alignment and address common issues 6) We also interface with EPT to seek alignment with them on the GoM D&C technology needs 7) The GoM D&C technology manager hosts detailed annual project reviews with the EPT D&C flagship projects 8) We present our needs and issues, and they present their current projects and proposed new projects 9) Front End Loading considers technology enhancements (short-term) 10) MPcp has a technology readiness level component (longer view)

Re: Assets and Projects - D&C technology plans may overlap, conflict or overlook

D&C/Asset Technlgy Plan Overlap

Technology 1-Excellence Keck


Evaluate, select and apply preferred technologies. Level 4 3-Moderate 1) We evaluate major technology projects both from EPT and assets 2) Since most technology projects are funded by the assets, the assets usually help select and apply the projects themselves 3) The D&C function does select cross-SPU projects, usually with EPT, and helps get them implemented 4) Minor technologies are evaluated routinely via well review process 5) Four TLs in D&C looking at technologies 6) Each asset submits a technology plan as part of their LTP

Resource sharing commitments from assets are difficult to help implement technology broadly

Technlgy Resource Sharing Technology 1-Excellence Keck

6.6.1 Optimization Procurement Rigs and Wells Services Manager

Implement and maintain a procurement process for materials and services that defines specifications and standards; establishes a supplier selection process based on criteria that include HSSE considerations; meets delivery requirements; considers life-cycle cost; and provides clear procedures for changes to suppliers, materials and services.

Level 4 5-High 1) PO's for casing and tubing, wellheads, trees specify the BP GIS standards for quality manufacturing 2) D&C LT approves with selection based on capabilities and HSSE 3) Quality Audits done to ensure suppliers maintain the required standards 4) Change to suppliers goes through pre-qualification audit for mfg ability 5) From engineering perspective, have IM program and QA program that apply to goods and services 6) Line oversight prior to PO (requisition approval) 7) Deviations from GIS standards by supplier go through formal approval/acceptance within BP 8) Financial: Comprehensive viability assurance for major suppliers and contractors 9) Integrity Assurance Specification for the Procurement of Critical Equipment for Drilling & Completions (excluding Tubular Products) (AKA ETP10-50) 10) Integrity Assurance Specification for the Procurement of Tubular Products and Connection Manufacturing Services (for use in Wells) 11) Establishing BP Global QCPs Process for the Production of BP Global QCPs and associated Documents 12) Design Review Process for Drilling, Completions, and Subsea Equipment 13) Equipment Integrity Assurance Guidelines 14) Procedures for Auditing Suppliers for Drilling & Completions 15) Drilling & Completions Equipment Surveillance

Our quality and reliability efforts have been focused on BP-owned equipment. Less focus has been given on rental equipment (additional global integrity assurance specifications are forthcoming for rental equipment later in '09)

Rental Equip QA Contractor Interface 3-Basics/BP Develop and embed Rental Equipment quality and reliability assurance program

Actions underway to cover rental equipment. Rich/Sprague 10/30/09 1/18/10 -- Completed through IASO 3 implementation per Rich

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6.6.2 Optimization Procurement Rigs and Wells Services Manager

Review the effectiveness of the procurement process at defined intervals and implement identified improvements.

Level 3 1-Low 1) PSCM - Common Process sets the standard 2) Coaches exist within PSCM to assist with implementation 3) Internal control audit conducted periodically to verify compliance with BP internal controls for procurement 4) Financial audits of suppliers produce comprehensive report identifying areas of improvement in procurement process 5) Periodic quality audits based on specific material being made 6) KPIs used during SPM - market intelligence for U.S. and also global 7) Marketing Intelligence/Contracting Excellence Groups embedded in PSCM (http://epsegmentcommonprocess.bpweb.bp.com/Default.aspx?tabid=83)

Don't have a defined interval documented in Common Process document [M. Gonzalez to confirm]

Prcurmnt Effectivenss Rev Timng

Contractor Interface 2-Effeciency Rich

6.7.1 Optimization Materials Management


Identify and maintain the material inventories required to deliver operating performance.


1) Detailed information related to this sub-element can be found on GoM’s Materials Management website including the following: a) GoM materials and equipment visibility lists b) Links to MAETrax tool and Legacy MMS c) Houma Preservation and Maintenance Facility (PMF) site information and processes d) GoM Logistics procedures, aviation/boat schedules, and shorebase contacts e) Materials management training and support information f) All evidence is located in the MMG Website: http://mmg.bpweb.bp.com/ 2) Materials Management has material control personnel embedded inside all D&C operations



For stored materials, implement and maintain a system to identify, inspect and protect them from deterioration, paying particular attention to those that form part of safety and production critical equipment.


1) Detailed information related to this sub-element can be found on GoM’s Materials Management website including the following: a) GoM materials and equipment visibility lists b) Links to MAETrax tool and Legacy MMS c) Houma Preservation and Maintenance Facility (PMF) site information and processes d) GoM Logistics procedures, aviation/boat schedules, and shorebase contacts e) Materials management training and support information f) All evidence is located in the MMG Website: http://mmg.bpweb.bp.com/



Review materials management performance at defined intervals and implement identified improvements.

Level 5 3-Moderate 1) Detailed information related to this sub-element can be found on GoM’s Materials Management website including the following: a) GoM materials and equipment visibility lists b) Links to MAETrax tool and Legacy MMS c) Houma Preservation and Maintenance Facility (PMF) site information and processes d) GoM Logistics procedures, aviation/boat schedules, and shorebase contacts e) Materials management training and support information 2) All evidence is located in the MMG Website: http://mmg.bpweb.bp.com/ 3) Continuous improvement teams 4) Monthly KPIs

6.8.1 Optimization Continuous Improvement


Engage the workforce to build continuous improvement culture and behaviours.


1) Quarterly Performance Reviews 2) Peer Assists 3) Peer Reviews 4) Rig Crew Engagement Meetings 5) Bi-Weekly Lessons Learned sharing meetings 6) Townhall meetings 7) Project Stage Gate Reviews 8) Weekly Team Meetings 9) Annual Performance reviews



Systematically identify defects in the plant, process, people and performance elements of the entity’s operating activity and implement improvements utilising continuous improvement methodologies and tools. 6.8.2.1 Identify gaps and build plans to act on specific opportunities for eliminating defects in the local business in a systemetic manner. 6.8.2.2 Include resources for local CI activities in the annual business plan, including process evaluation and standardization, implementation of lessons learned/best practices, and capability development.


1) After Action Reviews 2) BP Internal Audits 3) End of Well Reports 4) Incident (Safety, Non-Productive Time) Investigations 5) EIAG 6) PIPs 7) Performance Reviews 8) KPIs 9) Rig audit 6.8.2.1: a) Continuous improvement plans across the D&C b) Rig Audit action plans c) Closeout plans in Tr@ction d) Completion Excellence plans e) DWOPs, CWOPs 6.8.2.2: a) D&C Excellence Teams b) D&C Engineering advisors c) Sector specialists d) Performance Team e) PDPs f) Bi-weekly Lessons Learned meetings g) Ops meetings h) WEPF i) Completions Excellence, Drilling, Ops, Intervention Networks

DEIP not rolled out DEIP not Rolled Out Wells Procedures 2-Effeciency Roll out DEIP Rich 8/30/09 Has been rolled out per Sprague 8/18/09 y






Inconsistent Tech Limit process Incon Tech Limit Process Learnings/Tracking 2-Effeciency Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

BtB Audit findings being worked by Jake Skelton.

Sprague 12/30/09 1/21/10 -- Tech limit guidance document now complete and process initiated. Closed per Sprague.

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Inconsistent Well reviews (IBR) Incon Well Review Process Organization Management 2-Effeciency Jassal






6.8.2.1 Lack of situational awareness (unknown unknowns) and decision-making

Lack of Situational Awareness


Sprague/Thierens developing training program for D&C in Excellent Execution.

Sprague 12/30/10 1/21/10 -- target date from 12/30/09 to 12/30/10. In progress per Sprague.

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Implement and maintain a process to capture learnings and sustain performance improvements in the local OMS.

Level 3 3-Moderate 1) Beyond the Best Process 2) Major Project Common Process 3) Team Link 4) Tr@ction 5) Continuous Improvement Plans 6) Performance Scorecards 7) Benchmarking 8) Purple Book

D&C doesn't have a structured and specific, standardized CI plan

Standardized Cont Imp Plan


Use BtB CIP Process -- Leary to own. Use OMS and BtB. Need D&C Ops & Engr CIP Plan documented.

Rich 12/30/09 1/18/10 -- Sprague to Rich per Rich. n





OMS not implemented yet, and we have not yet been through the Continuous Improvement cycle

Implement OMS OMS 3-Basics/BP Implement OMS OMS development in progress. Jassal 12/30/09 12/18: MoC complete, approved by Leary/Joslin/Skelton/Lacy/Dupree.

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No process in place to utilize data collected

Capture Learnings Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Use BtB CIP Process -- Leary to own. Need D&C Ops & Engr CIP Plan documented.


7.1.1 Privilege to Operate

Regulatory Compliance

Director Identify applicable legal and regulatory HSSE requirements, determining how these apply to the entity’s projects, operations, maintenance, inspection, marine, decommissioning and remediation activities, and products and services. 7.1.1.1 Develop and maintain a compliance matrix of HSSE regulatory and other legal HSSE requirements applicable to the local business: List obligations for HSSE permits and authorizations associated with local business; Assign specific accountability for the development and management of the local HSSE compliance matris; Make the HSSE compliance matrix readily available across the organization.

Level 5 5-High 1) Compliance Management System (CMS) covers all legal and regulatory requirements 2) Each facility has a CMS Matrix which identifies all compliance tasks that are required 3) The tasks were developed by BP Compliance and verified by the rig for applicability 7.1.1.1: a) Compliance Management System (CMS) covers all legal and regulatory requirements b) Each facility has a CMS Matrix which identifies all compliance tasks that are required c) The tasks were developed by BP Compliance and verified by the rig for applicability



Director Put a process in place to identify and where necessary implement an MOC for changes to applicable legal and regulatory HSSE requirements.

Level 3 5-High 1) GoM Regulatory Notice Process manages changes to requirements 2) Document Number: CD # UPS-US-SW-GOM-HSE-DOC-000xx-2 3) This process is in practice; however, the document is in draft stage

The current process to ensure compliance with changes is not fully implemented because the document is still in draft

Reg Change Proc Compliance Program 5-Sig Risk Develop and embed Regulatory Change procedure

Dvelop a GoM Regulatory Notice Process that manages changes to regualtory requirements (Scherie Douglas).

Tink 10/30/09 Document completed 2Q 09' per Tink. 9/22/09 Jim Grant considering rollout options for SPU - if no rollout by SPU, will execute D&C rollout. 10/21/09 - Jim Grant Rolled out to D&C LT. Complete - Tink.

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Director Identify and document specific compliance tasks to meet applicable legal and regulatory HSSE requirements.

Level 5 5-High 1) CMS Compliance Matrices for each drilling facility identifies tasks necessary for compliance 2) Process is systematic 3) The CMS team audits the process annually, and changes tasks as necessary



Director Establish and implement operational controls needed to accomplish the identified compliance tasks to meet applicable legal and regulatory HSSE requirements.

Level 3 5-High 1) Operational controls are identified in the compliance matrices for each task 2) The tasks are currently being conducted but not systematically (each site completes tasks differently, and there is no completion status report)

No systematic way to ensure task completion due to complexity of dealing with different contractors and processes. (Develop operational controls document to ensure tasks are completed and roll out to D&C)

Compliance Task Completion

Compliance Program 3-Basics/BP Develop and embed Compliance Program to D&C Organization

Develolp a Compliance Management System Process document.

Tink 12/30/09 1/15/10 Tink - Document approved and posted on the HSSE Website

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Director Assign and document accountabilities for the identified compliance tasks to meet applicable legal and regulatory HSSE requirements, and communicate these to the accountable individuals.

Level 3 5-High Compliance Management System (CMS): 1) Each facility has a CMS Matrix which identifies all compliance tasks that are required 2) The Matrix identifies a person who is responsible for the task

The accountable individuals perform their tasks, but are not clear about their accountability within the Compliance Management System per the CMS requirement

Clear CMS Accountability Compliance Program 4-Moderate to High

Develop and embed Compliance Program to D&C Organization

Develop compliance system rollout roles and responsibilities and rollout to affect employees.

Tink 4/30/10 9/22/09 - still on track for end of 1Q 10' delivery, Tink. 1/15/10 Material developed - rollout plan currently being worked, Tink. Moved completion date back to April so rollout can be done at WLS Meetings - Tink 3/9/10

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Director Verify completion of the identified compliance tasks to meet applicable legal and regulatory HSSE requirements, report and investigate instances of non-compliance and take action to prevent recurrence.

Level 2 5-High 1) Each facility tracks the completion of tasks and identify suspected deviations independently 2) CMS “Best Practices Recommendation” for completion tracking are those tasks that require reporting to an Agency should be electronically tracked 3) MMS and EPA noncompliances are entered into Tr@ction and investigated per GoM incident processes

No current system used to verify completion of all identified HSSE compliance tasks on all drilling rigs

Compliance Task Completion


Evaluate and select a compliance tracking tool. Tink 10/30/09 9/22/09 - have completed rig by rig assessment of current tracking methods. Still on track to deliver by end of October, Tink. 10/28/09 - A tracking tool has been chosen and accepted by Harry Thierens. Complete -Tink.

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Director Verify completion of the identified compliance tasks to meet applicable legal and regulatory HSSE requirements, report and investigate instances of non-compliance and take action to prevent recurrence.

Level 2 5-High 1) Each facility tracks the completion of tasks and identify suspected deviations independently 2) CMS “Best Practices Recommendation” for completion tracking are those tasks that require reporting to an Agency should be electronically tracked 3) MMS and EPA noncompliances are entered into Tr@ction and investigated per GoM incident processes

Not all BP-requirements (non-regulatory) task failures are entered into Tr@ction

Traction for Rqrmnt Failure Learnings/Tracking

3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Tink Tink 10/30/09 1/18/10 -- Sprague to Tink per Rich. n



Director Implement and maintain a programme for verifying compliance with other (non HSSE) legal and regulatory requirements.

Level 3 5-High 1) CMS requirements meet the requirements for the program but it has not been fully implemented [await response from Tammy - SPU]

We lack an operational controls document that would include non-compliance tasks, and would be rolled out to D&C

Compliance Control Doc Compliance Program 3-Basics/BP Develop and embed Compliance Program to D&C Organization

Develolp a Compliance Management System Process document.

Tink 12/30/09 1/15/10 Tink - Document approved and posted on the HSSE Website

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Director Communicate to the workforce the existence and importance of these compliance programmes.

Level 1 5-High 1) No formal rollout 2) Initial communication to WSLs and HSE advisors prior to program implementation

Lack of understanding among D&C organization of the compliance programs

Compliance Proc Understanding


Rollout Compliance Management System program to the D&C organization

Tink 4/30/10 9/22/09 - still on track for end of 1Q 10' delivery, Tink. Material developed - rollout plan currently being worked, Tink. Moved completion date back to April so rollout can be done at WLS Meetings - Tink 3/9/10

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Community and Stakeholder Relationships

NA Identify key communities and stakeholders involved in or affected by its operating activities and designate accountabilities for managing the relationships with them.

n/a n/a N/A to D&C



NA Build relationships with identified key communities and stakeholders through early engagement, listening and responding to their expectations and concerns about its operations, projects and products.

n/a n/a N/A to D&C



NA Record external commitments made by the entity to the identified key communities and stakeholders and take action with respect to these commitments.

n/a n/a N/A to D&C



NA Establish and implement a process to receive communications from key communities and stakeholders; and document responses.

n/a n/a N/A to D&C



NA Identify and manage the environmental, health and social impacts of changes to operating activities on key communities and stakeholders.

n/a n/a N/A to D&C


Social Responsibility

NA Identify whether there are social responsibility issues associated with their operating activities, and manage the associated impacts.

n/a n/a N/A to D&C


Customer Focus Atlantis Wells Operations Manager

Manage BP customer relationships consistent with the entity business strategy and annual plan.


1) Participate with assets to develop LTP and GFO's, including monthly cost reconciliation, Monthly Performance Scorecards, Leadership PC's roll up to SPU objectives 2) D&C organization principle is to maintain a strong relationship with the assets 3) Deliver well to the SOR. 4) Asset approval of AFEs. 5) RLG survey of Asset VPs in 2008 - evaluated and took actions from this. 6) Handover for every well - robust process.



Implement and maintain a process to make relevant members of the workforce aware of the importance of maintaining BP customer relationships.

Level 4 1-Low 1) Townhalls 2) Roles and Responsibilities 3) Asset D&C Performance Reviews 4) Annual Code of Conduct certification






Implement and maintain a process to receive and respond to BP customer feedback on HSSE, service and quality issues.

Level 4 3-Moderate 1) Asset D&C performance reviews 2) Participation in asset HSSE steering committees 3) Wells Scorecards, including production rates, skin factors, well time and costs reviews 4) Asset post-well reviews 5) SIMOPS meetings 6) First year operability reviews 7) Feedback mechanisms, such as Open Talk

No ongoing, formal feedback loop to ensure these activities or relationships are good

Ongoing Customer Feedback

Organization Management 1-Excellence Jassal



Implement and maintain a process for managing or assuring all BP supervised activities involved in the safe transportation, storage and delivery of products to BP customers.

n/a n/a N/A to D&C


Product Stewardship

NA Maintain a register of products, and systematically assess them for HSSE hazards and risks and the legal and regulatory HSSE requirements applicable to BP in relation to the products from development through to end user for anticipated conditions of storage and use, and reassess when changes occur.

n/a n/a N/A to D&C


Product Stewardship

NA Inform the workforce, BP’s customers and other identified stakeholders about the relevant identified HSSE hazards and risks relating to products through the provision of material safety data sheets, warning labels or other communication media.

n/a n/a N/A to D&C


Product Stewardship

NA Implement and maintain a process to record, investigate and learn from product related HSSE effects and incidents reported to BP by other parties.

n/a n/a N/A to D&C


Product Stewardship

NA Implement and maintain a product recall procedure and emergency response procedure for product related HSSE effects and incidents reported to BP by other parties. Exercise the procedures at defined intervals.

n/a n/a N/A to D&C


Product Stewardship

NA At defined intervals assess, document, and implement opportunities that are consistent with the entity business strategy, to replace chemical constituents or products that may present a significant risk to health or the environment, with chemical constituents or products that present a lesser risk.

n/a n/a N/A to D&C

8.1.1 Results Metrics and Reporting

Performance Manager

Use leading and lagging indicators to monitor progress against the objectives and targets in the annual plan.


1) Weekly Operations reports provide some leading indicators 2) Monthly cost forecasting 3) Monthly performance scorecards 4) GFO updates 5) Ad-hoc presentations 6) LTP process identifies resourcing, budget management 7) BtB Common Process front-end loading scores 8) Indexes that assess project execution readiness at each stage gate 9) HSSE scorecards - leading lag indicators, conformance with Annual Plan 10) Check AFEs, FMs when compared to what was assumed in the plan 11) AFE Cost Report across D&C

Material Mgmt Group: accountabilities not clear for physical, cost forecast

MM Group Frcst Accountabilities

Financial Control 3-Basics/BP Jassal


Performance Manager




Lacking emphasis on leading indicators and lower level metrics that influence the lagging indicators. GoM D&C Key Milestones and improvement objectives lacking visibility and communication (too much emphasis on Days/10k & Completion days which are outputs); emphasis and refining of the leading indicators vs the output; e.g., achieving 100% cementing success on production casing; visibility of actions on performance improvement target areas or NPT reduction

Lack of Leading Indicator Use

Performance Management 2-Effeciency Jassal


Performance Manager




Lack of systematic processes around GFO-1; CAPEX and OPEX that the assets hold

Incon GFO-1, CAPEX, OPEX



Performance Manager

Provide employee access to operating performance indicator information to support delivery of the annual plan.

Level 3 3-Moderate 1) Monthly Performance Scorecards on GoM D&C Sharepoint site 2) Townhalls by LT discussing performance 3) Team meetings discussing performance 4) GFO updates 5) Time depth/cost depth charts (teams) 6) Bi-weeky Lessons Learned meeting 7) Cost meetings/monthly for assets, projects, finance across D&C

Lack consistency on where data is kept Perf Metrics Storage Data Management 3-Basics/BP Enhance operating performance metrics use

Jassal


Performance Manager



Employee surveys indicate mixed views on data availability, accessibility, relevance, consistency

Perf Metrics Use Performance Management 3-Basics/BP Jassal


Performance Manager



Orientation doesn't adequately cover business information/measures/accessibility

Perf Metrics Orientation Performance Management 3-Basics/BP Jassal


Performance Manager

Report operating performance data in accordance with BP requirements.

Level 4 5-High 1) Systematic use of Tr@ction, SAP, DIMS 2) Long Term Plan and GFO forecasts, updates 3) Monthly financial updates 4) Code of Conduct communicated annually 5) Employees and contractors encouraged to openly report 5) Purple Book feeds, Orange Book feeds, etc. 6) Partner audits and internal BP audits (CETs, PWC) 7) Reporting requirements - rig commitments (LTCCs)

Potential for errors in data still exists Data Error in Reporting Systms

Data Management 2-Effeciency Enhance operating performance metrics use

Jassal




8.2.1 Results Assessment and Audit


Implement and maintain a risk-based internal self assessment programme to monitor that operating activities are being carried out in accordance with the local OMS, this shall include auditing of procedures and processes to validate they are operating as intended. 8.2.1.1 Include leaders in the monitoring of operating activities through systematic self-verification, and in the follow-up of corrective actions. 8.2.1.2 Define and document the key competencies required for team members participating in self-assessments, according to the type of self-assessment.


Cross-GoM Processes as follows: 1) Leadership site visits 2) KPIs 3) Internal audits 4) Audit Plan 5) Audit Guidelines 6) Audit Schedule 7) SOCs (targets developed) 8) EMS Management Review 9) GoM communication tools 10) Presentations 11) S&O audit protocols 12) GoM Field Checklists 13) GoM Action Tracking procedure 14) GoM Drilling HSSE Self-Assessment System - monthly on a 6-month cycle 15) GoM BP-owned Rig IM audit/review scheduled with Pride summer '09 (ad hoc) 16) GoM BtBcp audit scheduled May/June 2009 - 3-year cycle 17) Rig Audits conducted every two years 18) Marine Audits - 2-year cycle (?) 19) DWOP dispensations are reviewed annually for continued justification for risk reduction/performance improvements 8.2.1.1: Leaders are engaged in all of these processes, and in the corrective actions, and action closures (level 4) 8.2.1.2: a) HSE undergoing competency assessments now b) External audit teams are professional-level (level 2) (risk level: low/mod)

8.2.1.2 Key competencies for assessment participants is not defined or documented for GoM D&C self-assessment

Leader Asmnt Competencies

Performance Management 2-Effeciency Jassal



Plan and prepare for audits by Group S&O as per the S&O audit programme.

Level 3 1-Low 1) S&O Audit - Steve Haden and David Saul have had further discussion with S&O (Jim O'Brien) 2) In time, S&O will make arrangements to audit Wells Teams as part of SPU S&O audits 3) When they do, they will focus on three main areas: a) DWOP Conformance, with focus on Part B "Shalls" - use the spreadsheet tracker to record where you are b) Rig Audit - S&O will accept the rig audits we do ourselves using Norman Wong's Team - emphasis on action close out c) Well Integrity - WIMS conformance will be important (SETA working on protocol) 4) S&O audits of Wells teams not expected to take place in 2009 due to pre-existing commitments. Once suitable protocols in place expect audits from 2010 onwards 5) Management is committed to preparation and applying lessons from previous other audits

No single point of contact assigned S&O Audit Single POC Compliance Program 3-Basics/BP Assign Single Point of Contact for S&O Audit

Tink



Identify and implement corrective actions with due dates for completion to address the findings of these self assessments and audits, and track to completion.

Level 3 5-High GoM Action Tracker Tool is functional for this, at: http://gomtools.bpweb.bp.com/One%20Touch/SOI%20Action%20Items/Action%20Items/GOMActionTracker/Pages/default.aspx

Action items not always followed up (need to assign an Action Item Coordinator (AIC) role to 1) log actions, dates, responsible party, etc. in tool 2) validate inclusion of requisite supporting documentation in tool 3) verify timely closeout of actions)

Corrective Action Followup Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Should reside in Project Services -- involve Leary. Action Tracking in Sharepoint. Need to identify Action Tracker coordinator.

Sprague 10/30/09 n





HSE self-assessments are not being tracked (pilot stage)

Track HSE Self Assmnts Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Should reside in Project Services -- involve Tink. Action Tracking in Sharepoint.

Tink 10/30/09 1/18/10 -- Sprague to Tink per Rich. n





Gaps in D&C action tracking - no consistent process to define which methodology is to be used to track all corrective actions

Action Tracking Process Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Action Tracking in Sharepoint. Need to identify Action Tracker coordinator.

Sprague 10/30/09 n



Assess at defined intervals the results from self assessments and audits to identify trends, emerging risks, opportunities to improve risk reduction measures and identify local OMS improvement opportunities.


1) "Way We Work" - Year-end Cycle of Performance Management: look at NPT, Completions performance, gaps, collective priorities, people, cost management, HSE, technology, etc. 2) Annual Planning Process

Need to establish frequency-driven assessments to evaluate trends, emerging risks, and CRR opportunities

Establish Asmnt Frequencies

Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Action Tracking in Sharepoint. Need to identify Action Tracker coordinator.

Sprague 10/30/09 n



Assess at defined intervals the results from self assessments and audits to identify trends, emerging risks, opportunities to improve risk reduction measures and identify local OMS improvement opportunities.


1) "Way We Work" - Year-end Cycle of Performance Management: look at NPT, Completions performance, gaps, collective priorities, people, cost management, HSE, technology, etc. 2) Annual Planning Process

No scheduled D&C comprehensive and systematic review

Systemic Asmnt Reviews Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Need to work into LT Meeting agenda. Sprague to visit with Thierens. Staff meeting review: Action Tracker.


8.3.1 Results Performance Review

Vice President Conduct formal documented Management Reviews at least annually of the local OMS to determine its overall effectiveness in delivering continuous risk reduction and performance improvement across the Elements of Operating.

Level 3 5-High 1) Leadership Team held review workshop to develop 2009 Priorities, but not using the OMS system 2) Formal Management Review - annual 3) Annual Plan in place - reviewed on established schedule - modifications made as needed 4) IPCs, annual objectives tied to Annual Plan

OMS not implemented in D&C, yet Implement OMS OMS 3-Basics/BP Implement OMS OMS development in progress. Jassal 12/30/09 12/18: MoC complete, approved by Leary/Joslin/Skelton/Lacy/Dupree.

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Vice President Implement and maintain a process to revise the local OMS with learnings identified at Management Reviews and in response to updates to Group, Segment and SPU requirements.

Level 2 5-High 1) OMS not in place yet 2) Management Reviews of Annual Plan - monthly and at GFO cycles 3) Weekly review of progress against Plan targets 4) Teams review progress daily in morning meetings

OMS not in place; have not gone through a cycle yet

Implement OMS OMS 3-Basics/BP Implement OMS OMS development in progress. Jassal 12/30/09 12/18: MoC complete, approved by Leary/Joslin/Skelton/Lacy/Dupree.

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Vice President Track to completion improvement action items resulting from Management Reviews, reporting overdue action items to entity management at defined intervals.


1) Action items captured and tracked by individual teams by various processes 2) Annual Plan milestones - tracked at SPU LT level 3) LT focus areas for D&C (cost, CE, HSE) 4) Projects track milestones, actions, risks - monthly (rotated among projects) 5) Stage Gates - wells

No formal action tracking system for management reviews

Track Mgt Rev Actions Learnings/Tracking 3-Basics/BP Develop and embed comprehensive event and/or best practice evaluation, learning, sharing and tracking process to systematically embed improvements.

Need to work into LT Meeting agenda. Sprague to visit with Thierens.

Sprague 10/30/09 1/18/10 -- Scorecard insights discussed at LT per Rich.

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8.4.1 Results Budget Management

Performance Manager

Develop the annual budget to provide resources to deliver the activities in the annual plan.


1) CAPEX-OPEX - major processes; general GFO process a) LTP (http://gomdnc.bpweb.bp.com/drlgengr/LTPAAR/Shared%20Documents/Forms/AllItems.aspx) b) GFO Zero c) GFO One Processes d) RACI Charts 2) PxO (cost center budgets) 3) Headcount (resource planning database)

Disconnect between GFO1/IPC development and LTP/GFOZero processes

GFO1/IPC and LTP/GFO0 disconnect






Performance Manager

Monitor and control costs and record reasons for any variances against the annual budget. Report to the budget approver new or changing risks which may cause significant variances.


1) Monthly Forecast Process http://gomdnc.bpweb.bp.com/docs/Documents/Processes/Process%20-%20Forecastin%20GFO/Forecasting_Timeline_v4.ppt 2) AFE Cost Tracker (http://gomdnc.bpweb.bp.com/docs/Documents/Processes/Process%20-%20Cost%20Tracking%20for%20Wells/EOWR_05.pdf) 3) Timewriting Process (http://gomdnc.bpweb.bp.com/bam/BP/Wiki%20Pages/Process%20-%20Timewriting%20-%20Time%20Sheet.aspx) 4) D&C One-Pager and RACI Charts (http://gomdnc.bpweb.bp.com/docs/Project%20Services/Forms/AllItems.aspx?RootFolder=%2fdocs%2fProject%20Services%2f%5fGOM%20Wide%2f2009%20%2d%20VOWD%20%2d%20Forecast&FolderCTID=&View=%7b7BD4960A%2dC98C%2d4804%2d8E51%2d8B4F56BE94F7%7d) 5) Nonfield lifting reports provided to cost center BRO's (budget responsiblity owners) monthly; VP-level review w/ each GFO 6) Headcount - reviewed monthly by D&C Perf Mgr. and reconciled with Resource Planning Database; RPD reconciled quarterly with HR

Inconsistent purchase to pay process Incon PtP Process Financial Control 3-Basics/BP Jassal


Performance Manager




Inconsistent accountability for cost control

Incon Cost Control Accntablty

Financial Control 3-Basics/BP Jassal


Performance Manager




Lack of a standard and phased COPAS plus equipment cost forecast on a monthly basis from GoM Material Management group

Standard Eqpt Cost Forecast



Performance Manager




Lack of clarity around AFE Process Unclear AFE Process Financial Control 2-Effeciency Jassal

ELT Seek Feedback Rental Equip QABBS Trending Underresourced teams Risk Decision Strategy Compliance Task Completion Clear CMS Accountability Procedure Comms

Risk Mitigation Visibility Org Changes in Resource Plng Achievable Targets Compliance Task Completion Reg Change ProcD&Cwide COW Asmnt Results Span of Control Resources Outside D&C Traction for Rqrmnt Failure RMP Visibility

GP 48-03 Applicability Resources Outside D&C CPOL Coord Inconsistency Compliance Control DocResponsibility Confusion Aggregation of Risk Compliance Proc Understanding

GWSI Inefficient All Risks Captured Corrective Action FollowupSupplier NPT Ownership Standard Risk Comparison Track HSE Self AssmntsStandardize Procedures Common Risk Register Action Tracking ProcessDefine Applicable RPs Risk Communication Implement OMS

Project Stages Orientation Risk Reduction Comm Implement OMSEmbed ESOR System Collaborative Risk Comm

Embed Well Handover Process Simplify PS Risk ProcessDocument Inspection Reports Flights to Devon

Data Error in Reporting Systms Regular Procedure ReviewBoat to Rig Trans Permit

Global Code Proj StandardsProject Interfaces

Owned Rig ProceduresFailure Report Conclusions

OMS Understanding Periodic Asmnt Drvng CmplnceOMS New Emp Orient Develop OMS Lack of Leading Indicator Use Rig Schedule Hopper Mobile Phone Driving Reqs

Regulatory Notice Process Clarity of Feedback Tools Incon GFO-1, CAPEX, OPEX Develop OMS Mobile Phone Driving ReqsContractor Inc Inv ABC Analysis Incon Culture Asmnt Tools Leader Asmnt Competencies Target Risk Reductn Comms Implement MOC

MWE, SWE Tool Awareness Orient to Sharing Tools GFO1/IPC and LTP/GFO0 disconnect Frank Performance Feedback Implement MOCCnsistnt Team Risk Levelling Standard Eqpt Cost Forecast Develop LOMS Manual Integrate Risk Asmnt w/MOCCnsistnt Team Risk Levelling Unclear AFE Process All TLs Conduct 360 Implement MOC

Document Confidentiality Register Inconsistent PDP Discussions Implement MOCIncon Enviro Risk ID and Mgt Inconsistent Succession Plng Document Control ProceduresGHG, Water, Waste Targets Inconsistent Perf Management Contractor Inc Inv Quality

Waste Mgt Program Use Inconsistent Objective Setting Integrate Interventions w/ProjectsPeriod Asmnt of Travel Compliance Finalize Risk Mgt Plan Incon GFO-1, CAPEX, OPEX

Track Mgt HSE Rev Actions Implement WAM Establish Asmnt FrequenciesMWE, SWE Tool Awareness Prioritize Learnings Systemic Asmnt ReviewsAddress, Track Equip Failure Still Operating Decentralized Track Mgt Rev Actions

Incon Tech Limit Process Inconsistent Risk Red. Process Standard Eqpt Cost ForecastIncon Well Review Process Incon Risk Asmnt Process Unclear AFE Process

DEIP not Rolled Out Incon BtB and MPCP Registers Lack of Situational Awareness Align Risk Asmnt to OMS

Incon Risk Asmnt Process

Reorg Changes Remain Doc Systematic Op Strategy Implement OMS Implement OMS Med Rcrds ConfCompetency Frmwrk Refresh Inconsistent CAM/SS Process People Resourcing Strategy Perf Metrics Storage MOC Deadline CreepCompl WSL Competencies Lrng Progrssn Map Refresh Single Critical Job Register Perf Metrics Use

Initial Competency Assessment Lack of D&C Security Expertise Contractor IH Programs Perf Metrics OrientationTechnology Gvrnance Process Incon Asset Post Well Review Tr@ction Security Incidents

D&C/Asset Technlgy Plan Overlap Capture Learnings MODU Security UnderstandingTechnlgy Resource Sharing Rollout Security WPV

Ongoing Customer Feedback Period Asmnt MC Driving CompMC Driving RefresherMC Driving Orientation

Period Asmnt Driver FitnessDriver Fitness RefresherDriver Fitness Orientation

Document Control ProceduresUse Document Control ProcedUse Document Control Proced

Standardized Cont Imp Plan

Intgrte D&C Op/OMS w/SPU PolicyDuplicate Asset/D&C Fin ControlIncon Fin$ Data, Plan vs. ActualIncon Financial Data Schedule

Asset/D&C People Costs AsgnmntDocument non-VTA training

Industry Standard/RP AccessSOP Location Understanding

Post-Challenger Training

Prcurmnt Effectivenss Rev Timng Develop OMS

S&O Audit Single POC

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Gap Relative RiskExcellence Efficiency Basics & BP Requirements Legal Compliance Significant Risk Mitigation

Contractor Interface (5) 4Q09Learnings/Tracking (26) 4Q09 Compliance Program (8) 1Q10

Logistics (2) 3Q09 Risk Management (24) 4Q09OMS (10) 4Q09 Wells Procedures (9) 4Q09

Operations Procedures (2) 3Q09Org Management (16) 2Q10

Project Management (6) 4Q09

Environmental (2) Data Management (6) MOC (5) 4Q09Performance Management (4) Financial Control (12)

Vehicle Safety (12)

Technology (3) IH/Health (1) People (15) 4Q09Security (3)

Excellence Efficiency Basics & BP Requirements Legal Compliance Significant Risk

Mitigation

Note: ranking priority given to Gap Relative RiskGap Relative Risk

Gap Priority Matrix -- Worst Case Gap Aggregate (# gaps) Closure Date Highest Priority Gaps

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Contractor Interface (5 4)Learnings/Tracking (26 19) 1Q10 Compliance Program (8 3) 1Q10 Risk Management (24 2) 1Q10

Wells Procedures (9 7) 4Q10Operations Procedures (2 1) Org Management (16 12) 2Q10

Project Management (6 5) 1Q10

OMS (10 1) Environmental (2) Data Management (6) MOC (5) 4Q09Performance Management (4) Financial Control (12)

Vehicle Safety (12)People (15 7)

Technology (3) IH/Health (1)Security (3)

Excellence Efficiency Basics & BP Requirements Legal Compliance Significant Risk

Mitigation

Note: ranking priority given to Gap Relative RiskGap Relative Risk

Dynamic Gap Priority Matrix -- Worst Case Gap Agg. (# gaps) Closure Date Highest Priority Gaps

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1.1 Operating Leaders 1.1.1 1.1.2 1.1.3 1.1.41.2 Operating Strategy 1.2.1 1.2.2 1.2.3 1.2.41.3 Planning and Controls 1.3.1 1.3.2 1.3.31.4 Resource and Implementation 1.4.1 1.4.2 1.4.3 1.4.41.5 Accountability 1.5.1 1.5.2 1.5.3 1.5.41.6 Communication 1.6.1 1.6.2 1.6.3 1.6.4 1.6.5 1.6.6 1.6.71.7 Culture 1.7.1 1.7.22.1 Organization Structure 2.1.1 2.1.2 2.1.3 2.1.42.2 People and Competence 2.2.1 2.2.2 2.2.3 2.2.4 2.2.5 2.2.62.3 Operating Discipline 2.3.1 2.3.2 2.3.32.4 Organizational Learning 2.4.1 2.4.2 2.4.32.5 Working with Contractors 2.5.1 2.5.2 2.5.3 2.5.4 2.5.5 2.5.63.1 Risk Assessment and Management 3.1.1 3.1.2 3.1.3 3.1.4 3.1.5 3.1.63.2 Personal Safety 3.2.1 3.2.23.3 Process Safety 3.3.1 3.3.2 3.3.33.4 Health and Industrial Hygiene 3.4.1 3.4.2 3.4.3 3.4.4 3.4.5 3.4.6 3.4.73.5 Security 3.5.1 3.5.2 3.5.3 3.5.4 3.5.53.6 Environment 3.6.1 3.6.2 3.6.33.7 Transportation 3.7.1 3.7.2 3.7.3 3.7.4 3.7.5 3.7.6 3.7.7 3.7.84.1 Procedures and Practices 4.1.1 4.1.2 4.1.3 4.1.4 4.1.54.2 Management of Change 4.2.1 4.2.2 4.2.3 4.2.4 4.2.5 4.2.6 4.2.74.3 Information Management and Document Control 4.3.1 4.3.2 4.3.3 4.3.44.4 Incident Management 4.4.1 4.4.2 4.4.34.5 Control of Work 4.5.14.6 Crises and Continuity Management and Emergency Response 4.6.1 4.6.2 4.6.3 4.6.4 4.6.55.1 Project Management 5.1.1 5.1.2 5.1.3 5.1.4 5.1.5 5.1.6 5.1.7 5.1.8 5.1.95.2 Design and Construction 5.2.1 5.2.2 5.2.3 5.2.4 5.2.5 5.2.6 5.2.7 5.2.85.3 Asset Operation 5.3.1 5.3.2 5.3.3 5.3.4 5.3.55.4 Inspection and Maintenance 5.4.1 5.4.2 5.4.3 5.4.4 5.4.5 5.4.65.5 Decommissioning and Remediation 5.5.1 5.5.2 5.5.35.6 Marine Operations 5.6.1 5.6.2 5.6.3 5.6.4 5.6.5 5.6.66.1 Plant Optimization 6.1.1 6.1.2 6.1.36.2 Energy 6.2.1 6.2.26.3 Feedstock and Product Scheduling and Inventory 6.3.1 6.3.26.4 Quality Assurance 6.4.1 6.4.2 6.4.36.5 Technology 6.5.1 6.5.26.6 Procurement 6.6.1 6.6.26.7 Materials Management 6.7.1 6.7.2 6.7.36.8 Continuous Improvement 6.8.1 6.8.2 6.8.37.1 Regulatory Compliance 7.1.1 7.1.2 7.1.3 7.1.4 7.1.5 7.1.6 7.1.7 7.1.87.2 Community and Stakeholder Relationships 7.2.1 7.2.2 7.2.3 7.2.4 7.2.57.3 Social Responsibility 7.3.17.4 Customer Focus 7.4.1 7.4.2 7.4.3 7.4.47.5 Product Stewardship 7.5.1 7.5.2 7.5.3 7.5.4 7.5.58.1 Metrics and Reporting 8.1.1 8.1.2 8.1.38.2 Assessment and Audit 8.2.1 8.2.2 8.2.3 8.2.48.3 Performance Review 8.3.1 8.3.2 8.3.38.4 Budget Management 8.4.1 8.4.2M

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