Divestitures: Preserving Process Safety Information (PSI)

Divestitures represent a moment of strategic realignment—but they also pose a significant risk if Process Safety Information (PSI) is not managed with rigor. The successful transition of IT systems must go hand-in-hand with the secure preservation and transfer of PSI and corporate records. By taking a holistic and disciplined approach, organizations can safeguard operational continuity, uphold compliance, and lay a stable foundation for the future success of the newly independent business unit.
Divestitures: Preserving Process Safety Information (PSI)

Divestitures—whether in the form of a business unit sale, spin-off, or asset carve-out—trigger substantial transformations across an organization’s operational landscape. Among the most impacted areas is the Information Technology (IT) landscape. As a business unit is separated from its parent organization, one of the top priorities is establishing an independent IT infrastructure tailored to the specific needs of the acquiring entity. This shift often involves replacing legacy enterprise platforms with modern systems optimized for the new business context.

IT Transition: Balancing Agility with Stability

The transition from shared IT environments to independent platforms must be handled with precision. Seamless cutover planning is essential to avoid operational disruptions, protect data integrity, and ensure cybersecurity. From enterprise resource planning (ERP) to plant control systems, each application and interface must be carefully migrated or replaced. IT leaders must collaborate closely with business units, cybersecurity teams, and compliance officers to ensure the new infrastructure is resilient and compliant with regulatory and contractual obligations.

Key considerations include:

  • Data migration and validation: Ensuring all critical business data is accurately transferred and remains usable post-transition.
  • Security controls: Implementing robust cybersecurity measures to protect sensitive information during and after the migration.
  • Operational continuity: Avoiding downtime in critical systems through parallel testing, phased rollouts, and fallback procedures.

Process Safety Information: A Non-Negotiable Priority

While much of the divestiture conversation focuses on IT systems and financial implications, the secure retention and transfer of Process Safety Information (PSI) is equally critical—particularly in highly regulated sectors like oil and gas, petrochemicals, energy and life sciences.

PSI encompasses the design basis, safety evaluations, chemical hazards, process technology, and mechanical integrity of equipment—data that is legally required to be preserved for the life of a facility. This information forms the backbone of compliance with standards such as OSHA’s Process Safety Management (PSM) or similar regulations in other jurisdictions.

During a divestiture, losing access to or compromising the accuracy of PSI can have serious implications:

  • Regulatory non-compliance: Failure to maintain adequate PSI can result in fines or sanctions.
  • Operational risk: Incomplete safety data can lead to accidents or equipment failures.
  • Knowledge loss: Historical design decisions and incident learnings must be preserved to inform future maintenance and modifications.

Best Practices for Retaining Institutional Knowledge

Effective divestiture management includes not only IT and safety data transfer, but also institutional knowledge continuity. This requires:

  • Comprehensive data mapping: Identifying all sources of PSI and ensuring they are included in the transition plan.
  • Document control protocols: Maintaining version control, metadata, and audit trails during the transfer process.
  • Stakeholder engagement: Involving engineers, safety professionals, legal counsel, and records managers early and often.
  • Post-transition accessibility: Ensuring that all critical documents remain searchable, usable, and protected in the new system.

PSI Preservation – Action Plan

1. Initiate a PSI Initial Study

Engage an experienced consulting team such as Gateway Consulting Group to lead a comprehensive discovery process. The purpose is to inventory all existing PSI sources, evaluate their accessibility, and define the scope of the migration.

Key Activities:

  • Conduct stakeholder interviews (e.g., Operations, Engineering, HSE, Document Control).
  • Review corporate systems (EDM system, CAD, legacy PSM and QA databases)
  • Identify PSI-relevant documents and records such as:
    • P&IDs and process drawings
    • Operating procedures and manuals
    • MOCs and associated follow-ups
    • Incident investigations and lessons learned
    • Hazard analyses (PHAs, LOPA, HAZOP)
    • Equipment specifications and maintenance history
    • Environmental permits and compliance records

2. Map PSI Silos and Define Extraction Complexity

Create a data inventory that includes:

  • Source system
  • Document volume (e.g., number of files, pages, or GB)
  • Format (PDF, scanned image, Word, CAD, etc.)
  • Storage location (cloud, network drive, legacy EDMS)
  • Metadata quality and completeness
  • Extraction difficulty score (e.g., Easy, Moderate, Hard)

This step provides a clear picture of what data exists, where it lives, and how hard it is to retrieve before the corporate platforms are decommissioned.

3. Estimate Level of Effort (LOE): Time and Cost

Based on the complexity map, develop a detailed LOE model to define:

  • Estimated hours or days per category or data source
  • Consulting fees for analysis, migration scripting, validation
  • Licensing or tool costs for data extraction and transformation
  • Internal resource requirements (SMEs, document owners, IT support)
  • Timeline to complete the migration before separation or platform retirement

This will inform divestiture leadership on budget, staffing, and scheduling needs.

4. Prioritize PSI Migration Efforts

Using a risk-based prioritization model, rank PSI elements according to:

Priority TierCriteria Examples
HighRegulatory requirement, operational criticality, no alternate source
MediumImportant for maintenance or improvement, but may be recreated or retrieved later
LowLegacy data with minimal current operational use

Apply these tiers to the dataset to sequence migration efforts appropriately.

5. Design a Migration Plan and Archive Strategy

Work with Gateway Consulting Group to:

  • Select target platforms (PSI vault, PSM platform, cloud hosting, etc.)
  • Define document control standards and retention policies
  • Ensure searchability via metadata tagging and OCR (for scans)
  • Validate completeness and integrity post-migration

Set up governance checkpoints for quality assurance and define handover plans for the new operating entity.

Conclusion

This structured approach ensures PSI isn’t lost in the chaos of divestiture. A methodical discovery and migration strategy—led by a trusted consulting partner—enables regulatory compliance, preserves institutional knowledge, and supports ongoing safe operations.

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