Adnoc Hsems Guidelines

Contents

HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM I HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY......... POLICY ......... 9 1. POLICY ON ENVIRONMENTAL PROTECTION:.............................................................13 2. POLICY ON EMPLOYEE AND FACILITY SAFETY AND OCCUPATI OCCUPATIONAL ONAL HEALTH: HEALTH:................ ................................. .................................. .................................. .................................. ..............................15 .............15 3. POLICY ON PRODUCT SAFETY STEWARDSHIP: STEWARDSHIP: .................. ......... .................. ................... ................... .................. ............17 ...17 4. POLICY POLICY ON MINIMIZATION OF EMISSIONS, EMISSIONS, EFFLUENTS AND WASTES: WASTES: ............19 ......... ...19

II ADNOC HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM ............................................................. 21 INTRODUC INTRODUCTION: TION: .................................. ................................................... .................................. .................................. .................................. .................................2 ................23 3 1. SCOPE: SCOPE: ................................. ................................................... ................................... .................................. .................................. .................................. ..............................23 .............23 2. DEFINITION DEFINITIONS:................... S:.................................... .................................. .................................. .................................. .................................. .................................2 ................24 4 3. HSE MANAGEMENT MANAGEMENT:: .................................. ................................................... .................................. .................................. .................................. ......................29 .....29

3.1. POLICY:................................ :................................................. .................................. ................................... ................................... .................................. ...........................29 ..........29 3.1.1. Health, Safety And Environment (HSE) Policy: .............................................................29 3.1.2. Policy on Environmental Protection: ................... ......... ................... .................. .................. ................... ................... .................. ............30 ...30 3.1.3. Policy on Employee and Facility Safety and Occupational Health:................................31 3.1.4. Policy on Product Safety Stewardship:...........................................................................31 3.1.5. Policy on Minimization of Emissions, Effluents and Wastes:..........................................32 3.1.6. HSE Vision, Mission, Values: ........................................................................................33 3.2. REQUIREMENTS: .................................. ................................................... .................................. .................................. .................................. ..............................3 .............34 4 Element 1: Policy, Leadership And And Responsibility:.................... Responsibility:........... ................... ................... .................. .................. .................34 ........34 Element 2: Safety: ................... ......... ................... .................. .................. ................... ................... .................. .................. ................... ................... .................. ............34 ...34 Element 3: Occupational Health Protection: Protection: ................... ......... ................... .................. .................. ................... ................... .................. .........35 35 Element 4: Product Safety:............ Safety:... .................. .................. ................... ................... .................. .................. .................. ................... ................... ...............35 ......35 Element 5: Environmental Environmental Protection:................... Protection:.......... .................. .................. ................... ................... .................. .................. ................... ...........35 .35 Element 6: Risk Management:........... Management:.. .................. .................. ................... ................... .................. .................. ................... ................... .................. ............36 ...36 Element 8: Incident Reporting And Investigation: Investigation: .......................... ................ ................... .................. .................. ................... ..............36 ....36 Element 9: Training And Competency: Competency: .................. ......... ................... ................... .................. .................. ................... ................... .................. .........36 36 Element 10: Community And Public Relations: Relations: ................... .......... .................. .................. .................. ................... ................... ...............37 ......37 Element 11: Legal Requirements: Requirements:......... .................. .................. ................... ................... .................. .................. ................... ................... .................. .........37 37 3.3. ROLES AND RESPONSIBILITIES : ................................. .................................................. ................................... ................................... ........................37 .......37 3.4. ESTABLISHING HSE OBJECTIVES AND TARGETS:................................................ :................................................................. ...................38 ..38 3.5. IMPLEMENTING HSE PLANS: ................................. ................................................... ................................... .................................. ...........................39 ..........39 3.6. IMPROVEMENT INCENTIVES: .................................. .................................................... ................................... .................................. ...........................39 ..........39 3.7. HSE MANAGEMENT SYSTEM AUDITS:.................................... :..................................................... .................................. ..............................4 .............40 0 3.8. MANAGEMENT REVIEW: ................................ ................................................. .................................. .................................. .................................. ...................41 ..41 3.9. COMMUNICATIONS AND INFORMATION SHARING:................................................ :................................................................4 ................42 2

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Health, Safety & Environment Management System

III.A.

DEVELOPMENT DEVELOPMENT AND APPLICATION APPLICATION GUIDELINES GUIDELINES ... 43

INTRODUC INTRODUCTION: TION: .................................. ................................................... .................................. .................................. .................................. .................................4 ................46 6 1. BACKGROUND:.......... BACKGROUND:........................... .................................. .................................. .................................. .................................. .................................. ......................46 .....46 2. PURPOSE PURPOSE AND SCOPE: SCOPE: .................................. ................................................... .................................. .................................. .................................. ...................46 ..46 3. THE HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT MANAGEMENT SYSTEM SYSTEM MODEL: MODEL: ................................. .................................................. .................................. .................................4 ................47 7 4. STRUCTUR STRUCTURE E OF THE DOCUMENT DOCUMENT:: .................................. ................................................... .................................. ..............................48 .............48 5. TERMINOLOGY TERMINOLOGY:: ................................. .................................................. .................................. .................................. .................................. ..............................48 .............48 EXECUTIVE SUMMARY OF THE HSEMS MODEL: .................. ........ ................... .................. .................. ................... ..............48 ....48 1. LEADERSHI LEADERSHIP P AND COMMITMENT COMMITMENT:: .................................. ................................................... .................................. ..............................49 .............49 2. POLICY AND STRATEGIC OBJECTIVES:........................................................................50 3. ORGANIZATION, RESOURCES AND DOCUMENTATION: DOCUMENTATION:......... .................. ................... ................... ...............51 ......51

3.1. ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES : ................................. .................................................. ........................51 .......51 3.2. MANAGEMENT REPRESENTATIVE(S):...................................... ):....................................................... .................................. ..............................5 .............52 2 3.3. RESOURCES:................................................ :................................................................. .................................. .................................. .................................. ......................52 .....52 3.4. COMPETENCE: .................................. ................................................... .................................. .................................. .................................. .................................5 ................52 2 3.4.1. 3.4.1. General: General: ................................. .................................................. .................................. .................................. .................................. .................................. ...................52 ..52 3.4.2. 3.4.2. Training: Training: ................................... .................................................... .................................. .................................. .................................. .................................5 ................53 3 3.5. CONTRACTORS : ................................... .................................................... .................................. .................................. .................................. ..............................5 .............54 4 3.6. COMMUNICATION:.......................................... :........................................................... .................................. .................................. .................................. ...................54 ..54 3.7. DOCUMENTATION AND ITS CONTROL :................................................ :................................................................. .................................. ...................55 ..55 3.7.1. 3.7.1. HSEMS Documenta Documentation:.................... tion:..................................... .................................. ................................... ................................... ........................55 .......55 3.7.2. 3.7.2. Document Document Control: Control: .................................. ................................................... .................................. .................................. .................................. ...................56 ..56 4. EVALUATIO EVALUATION N AND RISK MANAGEMEN MANAGEMENT: T: ................................. .................................................. .................................. ...................57 ..57

4.1. HAZARD MANAGEMENT : ................................ ................................................. .................................. .................................. .................................. ...................57 ..57 4.2. IDENTIFICATION OF HAZARDS AND EFFECTS :...................................... :....................................................... .................................. ...................58 ..58 4.3. EVALUATION:........................................... :............................................................ .................................. ................................... ................................... ........................59 .......59 4.4. RECORDING OF HAZARDS AND EFFECTS : ................................. .................................................. .................................. ..............................6 .............60 0 4.5. STRATEGY REQUIREMENTS: .................................. ................................................... .................................. .................................. ..............................6 .............60 0 4.6. OBJECTIVES AND PERFORMANCE CRITERIA:............................................... :................................................................ ...........................60 ..........60 4.7. RISK REDUCTION MEASURES: ................................. ................................................... ................................... .................................. ...........................60 ..........60 MPLEMENTATION 4.8. I :............................... :................................................ .................................. .................................. .................................. ..............................6 .............61 1 5. PLANNING:. PLANNING:.................. .................................. .................................. .................................. .................................. .................................. .................................. ......................62 .....62

5.1. GENERAL: .................................. ................................................... .................................. .................................. .................................. .................................. ......................62 .....62 5.2. ASSET INTEGRITY: ................................. .................................................. ................................... ................................... .................................. ...........................63 ..........63 5.3. PROCEDURES AND WORK INSTRUCTIONS : ................................. .................................................. .................................. ...........................63 ..........63 5.3.1. Developing Procedures: ................................................................................................63 5.3.2. Issuing Work Instructions: .................. ........ ................... .................. .................. ................... ................... .................. .................. ................... ...........63 .63 5.4. MANAGEMENT OF CHANGE:.......................................... :........................................................... .................................. .................................. ......................63 .....63 5.5. CONTINGENCY AND EMERGENCY PLANNING: ................................. .................................................. .................................. ......................64 .....64

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III.A.

DEVELOPMENT DEVELOPMENT AND APPLICATION APPLICATION GUIDELINES GUIDELINES ... 43

INTRODUC INTRODUCTION: TION: .................................. ................................................... .................................. .................................. .................................. .................................4 ................46 6 1. BACKGROUND:.......... BACKGROUND:........................... .................................. .................................. .................................. .................................. .................................. ......................46 .....46 2. PURPOSE PURPOSE AND SCOPE: SCOPE: .................................. ................................................... .................................. .................................. .................................. ...................46 ..46 3. THE HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT MANAGEMENT SYSTEM SYSTEM MODEL: MODEL: ................................. .................................................. .................................. .................................4 ................47 7 4. STRUCTUR STRUCTURE E OF THE DOCUMENT DOCUMENT:: .................................. ................................................... .................................. ..............................48 .............48 5. TERMINOLOGY TERMINOLOGY:: ................................. .................................................. .................................. .................................. .................................. ..............................48 .............48 EXECUTIVE SUMMARY OF THE HSEMS MODEL: .................. ........ ................... .................. .................. ................... ..............48 ....48 1. LEADERSHI LEADERSHIP P AND COMMITMENT COMMITMENT:: .................................. ................................................... .................................. ..............................49 .............49 2. POLICY AND STRATEGIC OBJECTIVES:........................................................................50 3. ORGANIZATION, RESOURCES AND DOCUMENTATION: DOCUMENTATION:......... .................. ................... ................... ...............51 ......51

3.1. ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES : ................................. .................................................. ........................51 .......51 3.2. MANAGEMENT REPRESENTATIVE(S):...................................... ):....................................................... .................................. ..............................5 .............52 2 3.3. RESOURCES:................................................ :................................................................. .................................. .................................. .................................. ......................52 .....52 3.4. COMPETENCE: .................................. ................................................... .................................. .................................. .................................. .................................5 ................52 2 3.4.1. 3.4.1. General: General: ................................. .................................................. .................................. .................................. .................................. .................................. ...................52 ..52 3.4.2. 3.4.2. Training: Training: ................................... .................................................... .................................. .................................. .................................. .................................5 ................53 3 3.5. CONTRACTORS : ................................... .................................................... .................................. .................................. .................................. ..............................5 .............54 4 3.6. COMMUNICATION:.......................................... :........................................................... .................................. .................................. .................................. ...................54 ..54 3.7. DOCUMENTATION AND ITS CONTROL :................................................ :................................................................. .................................. ...................55 ..55 3.7.1. 3.7.1. HSEMS Documenta Documentation:.................... tion:..................................... .................................. ................................... ................................... ........................55 .......55 3.7.2. 3.7.2. Document Document Control: Control: .................................. ................................................... .................................. .................................. .................................. ...................56 ..56 4. EVALUATIO EVALUATION N AND RISK MANAGEMEN MANAGEMENT: T: ................................. .................................................. .................................. ...................57 ..57

4.1. HAZARD MANAGEMENT : ................................ ................................................. .................................. .................................. .................................. ...................57 ..57 4.2. IDENTIFICATION OF HAZARDS AND EFFECTS :...................................... :....................................................... .................................. ...................58 ..58 4.3. EVALUATION:........................................... :............................................................ .................................. ................................... ................................... ........................59 .......59 4.4. RECORDING OF HAZARDS AND EFFECTS : ................................. .................................................. .................................. ..............................6 .............60 0 4.5. STRATEGY REQUIREMENTS: .................................. ................................................... .................................. .................................. ..............................6 .............60 0 4.6. OBJECTIVES AND PERFORMANCE CRITERIA:............................................... :................................................................ ...........................60 ..........60 4.7. RISK REDUCTION MEASURES: ................................. ................................................... ................................... .................................. ...........................60 ..........60 MPLEMENTATION 4.8. I :............................... :................................................ .................................. .................................. .................................. ..............................6 .............61 1 5. PLANNING:. PLANNING:.................. .................................. .................................. .................................. .................................. .................................. .................................. ......................62 .....62

5.1. GENERAL: .................................. ................................................... .................................. .................................. .................................. .................................. ......................62 .....62 5.2. ASSET INTEGRITY: ................................. .................................................. ................................... ................................... .................................. ...........................63 ..........63 5.3. PROCEDURES AND WORK INSTRUCTIONS : ................................. .................................................. .................................. ...........................63 ..........63 5.3.1. Developing Procedures: ................................................................................................63 5.3.2. Issuing Work Instructions: .................. ........ ................... .................. .................. ................... ................... .................. .................. ................... ...........63 .63 5.4. MANAGEMENT OF CHANGE:.......................................... :........................................................... .................................. .................................. ......................63 .....63 5.5. CONTINGENCY AND EMERGENCY PLANNING: ................................. .................................................. .................................. ......................64 .....64

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Contents

6. IMPLEMENTA IMPLEMENTATION: TION: ................................ ................................................. .................................. ................................... ................................... ........................66 .......66

6.1. ACTIVITIES AND TASKS:............................... :................................................ .................................. .................................. .................................. ......................66 .....66 6.2. MONITORING :........................................... :............................................................ .................................. ................................... ................................... ........................67 .......67 6.3. RECORDS: .................................. ................................................... .................................. .................................. .................................. .................................. ......................67 .....67 6.4. NON-COMPLIANCE AND CORRECTIVE ACTION: .................................. ................................................... .................................. ...................68 ..68 6.5. INCIDENT REPORTING : ................................. .................................................. .................................. .................................. .................................. ......................68 .....68 6.6. INCIDENT FOLLOW-UP: ................................ ................................................. .................................. .................................. .................................. ......................69 .....69 7. AUDIT AND REVIEW: REVIEW: ................................. .................................................. .................................. .................................. .................................. ......................70 .....70

7.1. AUDIT: ................................. .................................................. .................................. ................................... ................................... .................................. ...........................70 ..........70 7.2. REVIEW:..................................... :...................................................... .................................. .................................. .................................. .................................. ......................71 .....71 SUPPLEME SUPPLEMENTAR NTARY: Y: ................................. .................................................. .................................. .................................. .................................. ..............................72 .............72 S1. LEADERSHIP LEADERSHIP AND COMMITMENT:.......................... COMMITMENT:........................................... .................................. .................................. ...................72 ..72 S2. POLICY AND STRATEGIC OBJECTIVES:......................................................................73 S3. ORGANIZATION, RESOURCES AND DOCUMENTATION:.........................................73

S3.1. ORGANIZATIONAL STRUCTURE AND RESPONSIBILITIES :.......................................................73 S3.2. MANAGEMENT REPRESENTATIVE(S): ................................ ................................................. .................................. .................................7 ................74 4 S3.3. RESOURCES:...................................... :....................................................... .................................. .................................. .................................. ..............................7 .............74 4 S3.4. COMPETENCE: ................................... .................................................... .................................. .................................. .................................. ..............................7 .............74 4 S3.5. CONTRACTORS : ................................. .................................................. .................................. .................................. .................................. ..............................7 .............76 6 S3.6. COMMUNICATION:............................... :................................................ ................................... ................................... .................................. ...........................76 ..........76 S3.7. DOCUMENTATION AND ITS CONTROL: .................................. ................................................... .................................. ..............................7 .............77 7 S4. EVALUATION AND RISK MANAGEMENT:...................................................................77

S4.1. IDENTIFICATION OF HAZARDS AND EFFECTS : ................................ ................................................. .................................. ......................77 .....77 S4.2. EVALUATION :................................. :.................................................. .................................. .................................. .................................. .................................7 ................77 7 S4.3. RECORDING OF HAZARDS AND EFFECTS :.......................................... :........................................................... .................................. ...................80 ..80 S4.4. OBJECTIVES AND PERFORMANCE CRITERIA: ................................. .................................................. .................................. ......................80 .....80 S4.5. RISK REDUCTION MEASURES:................................................. :.................................................................. .................................. ...........................81 ..........81 S5. PLANNING: PLANNING: ................................ ................................................. .................................. .................................. .................................. .................................. ......................82 .....82

S5.1. GENERAL: ................................ ................................................. .................................. .................................. .................................. .................................. ......................82 .....82 S5.2. ASSET INTEGRITY: .................................. ................................................... .................................. ................................... ................................... ........................82 .......82 S5.3. PROCEDURES AND WORK INSTRUCTIONS: ................................. ................................................... ................................... ........................83 .......83 S5.4. MANAGEMENT OF CHANGE:................................ :................................................. .................................. .................................. ..............................8 .............83 3 S5.5. CONTINGENCY AND EMERGENCY PLANNING:........................................... :............................................................ ...........................84 ..........84 S6. IMPLEMENT IMPLEMENTATION ATION AND MONITORING MONITORING:: ................................. .................................................. .................................. ...................85 ..85

S6.1. ACTIVITIES AND TASKS: .................................. ................................................... .................................. .................................. .................................8 ................85 5 S6.2. MONITORING :................................. :.................................................. .................................. .................................. .................................. .................................8 ................85 5 S6.3. RECORDS: ................................ ................................................. .................................. .................................. .................................. .................................. ......................85 .....85 S6.4. NON-COMPLIANCE AND CORRECTIVE ACTION:............................................ :............................................................. ........................86 .......86 S6.5. INCIDENT REPORTING: .................................. ................................................... .................................. .................................. .................................. ...................86 ..86 S6.6. INCIDENT FOLLOW-UP:............................... :................................................ .................................. .................................. .................................. ......................87 .....87 S7. AUDIT AUDIT AND REVIEW: REVIEW: .................................. ................................................... .................................. .................................. .................................. ...................87 ..87

S7.1. AUDIT: .................................. ................................................... .................................. .................................. ................................... ................................... ........................87 .......87 S7.2. REVIEW: .................................. ................................................... .................................. .................................. .................................. .................................. ......................88 .....88 S7.3. LEVELS OF AUDIT:................................................ :.................................................................. ................................... .................................. ...........................89 ..........89

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III. B. AUDIT PROGRAM ................................................................... 91 INTRODUCTION: ......................................................................................................................93 1. AUDIT PROGRAM OVERVIEW:.........................................................................................93

1.1. PROGRAM RESPONSIBILITY:..................................................................................................93 1.2. PROGRAM OBJECTIVES: ........................................................................................................93 1.3. PROGRAM SCOPE:.................................................................................................................93 1.4. PROGRAM ELEMENTS: ..........................................................................................................94 1.5. PROGRAM PARTICIPANTS:.....................................................................................................96 1.5.1. ADNOC Group HSE Committee:...................................................................................96 1.5.2. ADNOC HSE Audit Manager: .......................................................................................96 1.5.3. Audit Team:...................................................................................................................97 1.6. DOCUMENT RETENTION PROCEDURE: ...................................................................................97 2. PRIORITISATION AND SELECTION OF SITES:..............................................................98 3. PRE-SITE VISIT ACTIVITIES: ............................................................................................98

3.1. AUDIT TEAM SELECTION: .....................................................................................................98 3.2. TEAM LEADER RESPONSIBILITIES :.........................................................................................98 3.3. TEAM MEMBER RESPONSIBILITIES : .......................................................................................99 3.4. TEAM TRAINING:..................................................................................................................99 3.5. SITE NOTIFICATION: .............................................................................................................99 3.6. THE PRE-AUDIT QUESTIONNAIRE:.........................................................................................99 3.7. DATA REVIEW:...................................................................................................................100 3.8. CHECKLIST UPDATE:...........................................................................................................100 3.9. AUDIT TEAM MEETING: ......................................................................................................101 4. THE ON-SITE AUDIT:.........................................................................................................101

4.1. ENTRANCE BRIEFING AND TOUR: .......................................................................................101 4.2. FILE AND DATA REVIEW: ...................................................................................................102 4.3. SITE INSPECTION: ...............................................................................................................102 4.4. INTERVIEWS: ......................................................................................................................102 4.5. MANAGEMENT SYSTEMS REVIEW: ......................................................................................102 4.6. EVALUATION :.....................................................................................................................103 4.7. EXIT BRIEFING: ..................................................................................................................103 5. POST-SITE VISIT ACTIVITIES: ........................................................................................103

5.1. REPORT PREPARATION AND DISTRIBUTION : ........................................................................103 5.2. CORRECTIVE ACTION PLAN PREPARATION: .........................................................................104 5.3. CORRECTIVE ACTION PLAN IMPLEMENTATION: ...................................................................104 5.4. FOLLOW-UP REVIEWS: .......................................................................................................105 6. QUALITY ASSURANCE PROCEDURES: .........................................................................105

6.1. ANNUAL REPORT:...............................................................................................................105 6.2. MANAGEMENT REPORTING: ................................................................................................105 6.3. NETWORKING OF FINDINGS AND SOLUTIONS: .....................................................................106 6.4. UPGRADING AUDIT PROGRAM: ...........................................................................................106

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Contents

III C. AUDIT CHECKLIST................................................................ 107 INTRODUCTION: ....................................................................................................................109 1. LEADERSHIP: ....................................................................................................................109 2. PERSONNEL:......................................................................................................................110 3. PROJECT MANAGEMENT:.............................................................................................110 4. OPERATIONS INTEGRITY:.............................................................................................110 5. CONTRACTORS AND SUPPLIERS:................................................................................111 6. MANAGEMENT OF CHANGE:........................................................................................111 7. ENVIRONMENTAL PROTECTION: ...............................................................................112 8. INCIDENT MANAGEMENT:............................................................................................112 9. EMERGENCY PREPAREDNESS / CRISIS MANAGEMENT: ......................................112 10. LEGAL REQUIREMENTS AND STANDARDS: .............................................................113 11. CONTINUOUS IMPROVEMENT:....................................................................................113 12. FIELD REVIEW AND VISUAL INSPECTION:...............................................................113 13. SITE PROFILE: ..................................................................................................................113

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Foreword

MANAGEMENT SYSTEM HEALTH, SAFETY AND ENVIRONMENT ADNOC believes it to be in the best interest of the Directorates and Group Companies to have a comprehensive Policy and Guidelines for Health, Safety and Environmental programs. ADNOC further believes that by working together, each of the Directorates and Group Companies will have a stronger, more efficient and cost effective program. Costs can be reduced and efficiencies improved by shifting our approach on Health, Safety and Environmental (HSE) issues to one that aligns and builds systematic processes for continuous improvement in business and HSE performance. A Health Safety and Environmental Management System (HSEMS) approach based on Total Quality Management principles will provide this. The goal of this HSEMS is to develop and implement business processes that will help line management to: •

• • • •

Prevent major incidents resulting in injuries, environmental damages, business interruptions or loss of assets Reduce operating costs Reduce instances of non-compliance with ADNOC HSE Guidelines Continuously improve HSE performance Maintain ADNOC reputation

This HSEMS will enable ADNOC through its Directorates and Group Company General Managers and operating officers to drive the HSE Management process throughout all operations. ADNOC has policies to help ensure that business is conducted with full concern for preserving the Environment and the Health and Safety of our workforce, neighboring community and customers. To carry out these policies, the traditional approach has been based on an array of directives, controls and programs for compliance with emerging regulations, standards, rules and procedures. Our performance has been very good, and this approach served ADNOC and the Group Companies well in the past; but it cannot easily keep pace with the current speed or complexity of our changing business, technical and organizational needs or the increase in laws, regulations, and international standards. Proposed UAE and Abu Dhabi Emirate regulations provide for stricter HSE controls. Traditional HSE approaches fostered incremental compliance responses and "end of pipe" solutions when innovation and breakthroughs were needed; they provided little clarity or flexibility; they did not support prioritisation based on risk and they provided very few valid measures of performance. In essence, they did not provide a supporting framework to enable our leaders and workforce to manage this part of the business the same way they manage the rest of their business issues and in a way that enables continuous improvement. Many commendable initiatives have been undertaken to better control some individual HSE costs and issue drivers in each Directorate or Group Company. We must now take a look at all our processes and develop integrated management solutions. Major integrated petroleum companies have recognized this need and are developing systematic approaches for addressing HSE issues and compliance. We must do likewise if we are to remain competitive in the world market and be perceived as a good environmental citizen. This HSEMS must and will be a tool to improve our business and our HSE performance.

7


The HSEMS will provide the following: •

HSE goals and targets will be clarified. Business process analysis techniques will be used to identify important HSE processes associated with supporting and improving key activities and business performance. Targeted are the HSE processes and activities that, if done well, will help us consistently meet our business goals, objectives and legal requirements at less cost, and with greater efficiency. This process will highlight which HSE related processes and activities should be emphasised for continuous improvement.

•

Roles, responsibilities and expectations will be clarified. This will be accomplished through a systematic process to identify who, at each level of the organization, is responsible for implementation and improvement of each relevant HSE related process and activity.

•

Innovation will be fostered. This will be accomplished by providing a high degree of flexibility in how key HSE related processes and activities are implemented to deliver improved business performance, improved risk exposure and liability management, and cost effective regulatory compliance.

•

Improved measurement and feedback mechanisms will be provided. This will help management better assess individual, departmental, organizational, Directorate and Group Company progress and to initiate appropriate action to achieve desired results. It will facilitate more consistent recognition for improvement of results.

•

Participation and mobilisation of our leaders and workforce will be improved. This improvement will be gained by providing clarity regarding which HSE related processes and activities to emphasise and who is responsible for maintaining or improving each of those processes or activities. This will provide a clearer link between personal HSE related responsibilities and the business.

•

Teamwork in HSE related activities will be enhanced. This enhancement will come from establishing a systematic framework for better defining expectations, priorities, key processes and technologies. This will also strengthen support for decision making through improved analysis of HSE risks, exposures, liabilities, costs and benefits.

This Health, Safety and Environmental Management System has been prepared by ADNOC Environment & Safety Division under direction of the ADNOC Group HSE Committee. This document consists of three separate tiers or sections. Tier one is the ADNOC HSE Policy Declaration statement. Tier II is the ADNOC Health, Safety and Environmental Management System. Tier III contains guidance on preparing an individual company HSEMS and how to use the Audit process to ensure continuous improvement.

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HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY

9

ADNOC HSE Policy

I

HEALTH, SAFETY AND ENVIRONMENT (HSE) POLICY

It is Abu Dhabi National Oil Company “ADNOC” Group Policy to conduct activities in a manner designed to minimize HSE risks, protect health and safety of employees, contractors, customers, the community at large and the environment in which the Group activities are conducted. ADNOC, through active participation of all employees and contractors, will strive to manage HSE risks with the goal of preventing accidents, injuries and occupational illnesses, progressively minimizing environmental impact by reducing discharges and using energy efficiently and producing safe, quality products. ADNOC and the Group Companies believe that good HSE performance will contribute/determine the success of the business and will treat HSE issues on par with all other primary business objectives.

On General HSE Issues, ADNOC Group will: • •

•

• •

• • •

• •

Commit to meet defined, measurable HSE targets. Comply with all applicable laws and regulations and apply internationally recognized standards where local laws and regulations do not exist. Hold all levels of line management accountable for HSE issues and for the development of positive attitudes in themselves and those whom they supervise. Require contractors to apply same or similar HSE standards, practices and procedures. Undertake appropriate reviews and evaluations to measure HSE performance against defined standards and to ensure compliance with this policy. Provide appropriate HSE training to employees and contractors. Develop and maintain HSE emergency procedures. Periodically audit and review application of process control and management measures to ensure compliance with the HSE Guidelines. Manage all risks to a level which is ‘As Low As Reasonably Practicable’ (ALARP). Openly report HSE performance (good and bad).

On Health Issues, ADNOC Group Will: •

•

Control and manage all chemical, physical, biological, mechanical and psycho-social factors which contribute to health risks, based on established guidelines and standards, applying best available technology consistent with good industry practice. Strive to protect and promote the health of all employees and contractors.

On Safety Issues, ADNOC Group Will: •

• •

Design facilities, establish procedures, provide training and conduct operations in a manner that minimizes risks and hazards to workers, property and the community at large, applying best available technology consistent with good industry practice. Ensure all operations are conducted with the safety of the employee and community as a primary objective. Practice good product stewardship to ensure products are properly evaluated and provide As Low As Reasonably Practicable (ALARP) impacts to the environment and can be used safely by customers.

On Environment Issues, ADNOC Group Will: • •

•

•

Progressively reduce emissions, effluents and wastes and improve efficient use of natural resources and energy. Minimize the impact of ADNOC Group activities on the environment and protect endemic fauna and flora at all sites of operations. Provide products and services supported with practical documented advice which, when used and practised in accordance with this advice, will not cause undue effects on the environment. Preserve and protect all locations of archaeological, historical and natural interest in the areas of operation.

ADNOC and the Group Companies will, through a documented Health, Safety and Environment Management System, implement this policy and ensure contractors apply similar systems. All employees and contractors are required to be committed to and perform their duties according to this general HSE Policy and the individual policies on Environmental Protection, Employee and Facility Safety and Occupational Health, Product Safety Stewardship, and Minimization of Emission, Effluents and Wastes.

H. E. Yousef Omair Bin Yousef Secretary General of SPC & General Manager of ADNOC

11

ADNOC HSE Policy

1.

POLICY ON ENVIRONMENTAL PROTECTION: It is the policy of ADNOC to ensure that the activities of ADNOC Directorates and Group Companies are conducted with full concern for safeguarding employee and public health, for protection of the physical environment and to comply with relevant environmental laws and regulations. ADNOC policy is to establish and implement effective compliance programs, including systems and procedures, for informing employees of the policy and their continuing obligation to conduct all activities in compliance with this policy and all applicable legal requirements. Where ADNOC becomes aware of a hazard representing a risk not covered by existing laws or regulations, where appropriate, ADNOC will develop its own environmental standards and practices to provide for adequate protection of employees, public health and the environment. In establishing timing, priorities, and levels of control, careful consideration will be given to benefits in relation to costs and technological feasibility. Particular attention will be given to achieving a reasonable balance between environmental goals and those for energy, jobs and the economy. Environmental laws and regulations will be periodically reviewed to comprehend changes in laws and regulations, national goals, new scientific and technical information and resource availability.

1

ADNOC HQ Building

ADNOC will co-operate with industry and government in identifying environmental goals and in developing effective, reasonable and equitable control programs. It is the responsibility of Directorate, Group Company Managers and Supervisors to ensure adherence to ADNOC environmental policy. Further, all employees are expected to be guided by this policy in forming plans, setting objectives and conducting their day-to-day activities. Contractors are to be made aware, of and are expected to comply with, ADNOC environmental policy and standards.

13

ADNOC HSE Policy

2.

POLICY ON EMPLOYEE AND FACILITY SAFETY AND OCCUPATIONAL HEALTH: It is the Policy of ADNOC to ensure that the activities of its Directorates and Group Companies are conducted with full concern for the safety of its facilities in order to protect the safety and health of employees, communities adjacent to our operations and the general public. ADNOC will comply with all applicable legal requirements pertaining to occupational safety, health, process safety and fire protection. ADNOC Guidelines, based upon scientific knowledge, established engineering practice and appropriate industry standards, will be developed when existing laws and regulations do not provide for adequate protection. ADNOC Directorates and Group Companies will carry out the objective of this policy by developing and maintaining safety management systems and procedures which ensure that process and employee safety and health considerations receive priority in design, operation, maintenance and decommissioning of facilities. ADNOC also will require appropriate safety and health training and will require strict adherence to safety rules and procedures.

2

3

ADNOC will hold each Manager, Supervisor and Employee accountable for the safe performance of their job and will measure their achievement in preventing occupational injuries, illness and accidental losses. ADNOC will provide qualified safety and health staff and appropriate equipment to support management in carrying out their objectives and goals in these areas. The same high standards are expected of contractors.

4

15

ADNOC HSE Policy

3.

POLICY ON PRODUCT SAFETY STEWARDSHIP: ADNOC will comply with applicable laws, regulations and international standards on product safety. In addition, ADNOC will: evaluate its products; identify reasonably foreseeable potential hazards to health and the environment; provide procedures and controls to avoid unreasonable risk; and assess the product safety compliance of its operations. Also, where appropriate, ADNOC will inform employees, customers, users, government agencies and the public concerning product safety. ADNOC will work with government and trade associations to develop and implement product safety regulations that protect employees, transportation personnel, customers and the public, taking into account scientific, economic and social factors. ADNOC Directorates and Group Companies are responsible for the development, manufacture and marketing of products in a manner consistent with applicable laws and ADNOC's high standards of safety, health, and environmental protection. In the absence of adequate local government requirements, ADNOC will maintain standards of safety and health protection that consider scientific knowledge, international standards and established practices in more developed countries. All hazardous purchased products transiting, stored or used on ADNOC properties will be accompanied by a material safety data sheet (MSDS) or its equivalent. Appropriate management, employees and contractors will be made aware of the product and proper precautions on transport, storage, use and disposal.

17

ADNOC HSE Policy

4.

POLICY ON MINIMIZATION OF EMISSIONS, EFFLUENTS AND WASTES: ADNOC, in addition to complying with all applicable environmental laws and regulations, is committed to reduce overall discharges (emissions to air, effluents to surface water, ground water and land surface and solid waste) from its operations wherever technically and economically feasible. This is part of ADNOC's commitment to safeguarding and protecting the physical environment. Although proper management of wastes, including environmentally sound treatment, storage and disposal, is important in protecting the physical environment, eliminating their generation through source reduction and recycling is encouraged. Source reduction can be accomplished in many ways, including input substitution, product reformulation, process modification, operational changes and improved housekeeping. Recycling includes the use, reuse, and reclamation of residues both on-site and off-site. ADNOC Directorates and Group Companies will be responsible for developing, implementing and maintaining programs at their facilities aimed at minimizing and preventing the generation of emissions, effluents and wastes. These programs will include the establishment of goals, encouragement of technology development and transfer and review of accomplishments. ADNOC Directorates and Group Companies will operate plants and facilities and handle raw materials and products in a manner that protects the environment. ADNOC will work with suppliers, customers and the public, where appropriate, to resolve problems created by handling and disposal of hazardous substances from its operations. ADNOC employees and contractors will be informed of this policy and directed to strive for the minimization and prevention of emissions, effluents and wastes in formulating plans, setting objectives and conducting their daily activities.

5

19


ADNOC HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT SYSTEM

21

ADNOC Health, Safety & Environment Management System

II

ADNOC HE HEA ALT LTH, H, SAFE SAFETY TY AND ENV ENVIRON IRONME MEN NT MANAGEMENT SYSTEM

INTRODUCTION The ADNOC HSE Management System (HSEMS) is a quality-based, structured, process for managing HSE activities. Through this process, process, ADNOC management wishes to clearly communicate the minimum level of HSE performance it expects Directorates and Group Companies to meet, and its desire for continuous improvement of HSE performance. Personnel are to establish establish objectives and targets to meet or exceed these minimum levels of HSE performance, implement plans to achieve those objectives and targets, periodically measure their progress, then readjust the objectives and targets accordingly to provide continuous improvement. ADNOC HSE policies (Section 3.1) provide the foundation for the HSEMS. To these are added HSE Vision, Mission and Value Statements (Section 3.1) to provide the philosophical cornerstone for the HSEMS by articulating where we are going as an organization, what we believe and how we conduct our business regarding HSE. In addition, the HSE Values provide a code of conduct to guide employees as they assume greater responsibility and accountability in the conduct of business. ADNOC Management states its minimum levels of HSE performance as a set of Expectations (Section 3.2), which are to be used by the Directorates and Group Companies to translate ADNOC HSE Policies, Vision, Mission and Values into Systems, Programs and Procedures. These Expectations are grouped into eleven HSE areas called Elements. The Expectations focus on maximizing the effectiveness of ADNOC and Group Company Management and Staff to achieve desired HSE performance and improve the return from our assets. While the Expectations indicate WHAT level of HSE performance is required, people at the Directorate and Group Company and facility level are empowered to determine HOW to meet or exceed that level of performance. They are expected to develop the Systems, Programs and Procedures best suited to their needs, after considering operating conditions and requirements, best practices, experience of other Group Companies, major international petroleum companies and international standards. A Library of HSE Systems, Programs and Procedures will be maintained by ADNOC E&S Division. Division. This will allow for effective sharing of best practices practices and will assist assist in this process. Nevertheless, each Company will be free to achieve the HSEMS Expectations as it chooses. This HSE Management System includes a description of roles and responsibilities for implementing and maintaining the system (Section 3.3), procedures for establishing HSE objectives and targets (Section 3.4) and for implementing HSE programs (Section 3.5). After the initial implementation of the HSEMS, ADNOC's goal is to establish a continuous improvement process to ensure that the HSEMS will be an integral part of each business (Section 3.6). The HSEMS includes HSE audit (Section 3.7) and management review (Section 3.8) procedures. Finally, the success of the HSEMS depends on there being clear, two-way communications and information exchange among and between all levels of the ADNOC Directorates and Group Companies organizations (Section 3.9).

1.

SCOPE: The HSEMS has been developed to provide direction to the ADNOC Business Line Directorates and Group Companies and to ensure that the management of HSE throughout the organization is aligned with ADNOC HSE Policy, Vision, Mission and Values. The HSEMS should also be considered for all contractors.

23


2.

DEFINITIONS: For the purposes of these HSEMS Guidelines, the following definitions apply: •

Accident: See ‘Incident’

•

ADNOC: Refers to ADNOC and its General Manager and Directorates responsible for Policies and Guidelines for the operating entities described as ‘Company’ below.

•

As Low As Reasonably Practicable (ALARP): To reduce a risk to a level which is ‘as low as reasonably practicable’ involves balancing reduction in risk against the time, trouble, difficulty and cost of achieving it. This level represents the point, objectively assessed, assessed, at at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained.

•

Audit Finding: An Audit Finding is the identification of a situation which either does not satisfy applicable legal requirements or does not conform with the HSEMS.

•

Company: Means ADNOC Directorates and Group Companies and may also include contractors, facilities and entities responsible to the ADNOC General Manger.

•

Crisis:

A Crisis is an incident or series of incidents that affect, or could affect, people, property, or the environment, and pose a serious threat to the company's ability to conduct business. •

Crisis Management: Crisis Management is a system of plans and procedures which prepares the organization to respond to and recover from crisis situations.

•

Discharges: Discharges include releases to the air, surface water, groundwater, or land of any material which can have an adverse effect on human health or the environment, be it of gaseous, liquid, or solid nature or a combination thereof. Any discharges fall into one of three categories: emission a discharge into the atmosphere

•

effluent

a discharge of liquid

waste

any other type of discharge

Element:

An Element is a part of the HSEMS system and represents a grouping of actions and/or expectations on key HSE focus areas, e.g., Safety, Risk Management, Training, etc.

24


•

Environment:

The surroundings and conditions in which a company operates and upon which it may have an effect. effect. This includes non-living non-living systems (air, water, earth) earth) and living systems (human, plant and animal) and social/cultural systems. •

Environmental Effect:

A direct or indirect impingement of the activities, products and services of a company upon the environment, whether adverse or beneficial. •

Environmental Effects Evaluation:

A documented evaluation of the environmental significance of the effects of a company's activities, products products and services, both existing and planned. (This may also be termed an "Environmental Impact Assessment" or EIA.) •

Expectation:

An Expectation is a statement of the minimum level for HSE performance expected for any element of the HSEMS. •

Explanatory Notes:

Explanatory Notes provide additional information about the Expectations, but do not add to their requirements. While they may discuss how the Expectation should be met, they do not require a specific approach to meet the Expectation. •

Facility:

Any single piece of equipment or structure, either standing alone, such as a well head, or grouped, such as a refining or gas plant, that has a potential to impact the environment. •

Gap:

A Gap is a finding that an Expectation is not being met. •

Gap Analysis: A process that identifies a Gap, i.e., those areas of the HSE Management system that can or need need to be improved. This “Gap Analysis” Analysis” becomes part part of the initial evaluation or subsequent audit report and consequently part of the cycle of planning and implementation for continuous improvement.

•

Hazard: This includes anything with the potential to cause harm, ill health or injury, damage to property, plant, products or the environment, production losses or increased liabilities. liabilitie s. Hazards may be physical, chemical or biological. biological .

•

Health Protection:

Health Protection encompasses the practices, procedures, equipment and training necessary for the prediction of health risk and protection of the health of persons working at company facilities. Providing health protection requires recognition, evaluation, control and management of the physical, chemical, biological and ergonomic hazards associated with processes and operations.

25


•

Health, Safety and Environmental Critical - (HSE Critical):

Designates activities, personnel or measures that have been identified as vital to ensure asset integrity, prevent incidents and/or to mitigate adverse HSE effects. •

Health, Safety and Environmental (HSE) Management Audit:

An independent, systematic and documented process of objectively obtaining and evaluating verifiable evidence to determine: Whether the HSEMS and its results conform to the audit criteria Whether the system is implemented effectively Whether the system is suitable to achieve the health, safety and environmental policy and objectives n n n

•

Health, Safety and Environmental (HSE) Management:

Those aspects of the overall management function (including planning) that develop, implement and maintain the HSE policy. •

Health, Safety and Environmental (HSE) Policy:

A statement endorsed by the General Manager of ADNOC and ADNOC’s Directorates and Group Company Senior Management of the intentions and principles of actions regarding the health, safety and environmental effects and which gives rise to strategic and detailed objectives. •

Health, Safety and Environmental (HSE) Management Documentation:

The documentation describing the overall health, safety and environmental management system, which makes reference to the systems and procedures for implementing the health, safety and environmental management plan. •

Health, Safety, and Environmental (HSE) Management Plan:

A description of the means of achieving health, safety and environmental objectives. •

Health, Safety and Environmental (HSE) Management Review:

The formal review by senior management of the status and adequacy of the health, safety and environmental management system and its implementation in relation to health, safety and environmental issues, policy, legal requirements, Codes of Practice and new objectives resulting from changing circumstances. •

Health, Safety and Environmental Management System (HSEMS):

The structure, responsibilities, guidelines, practices, procedures, processes, systems and resources for implementing HSE management. •

Health, Safety and Environmental (HSE) Strategic Objectives:

The broad goals, arising from the HSE policy, that a company sets for itself to achieve. These should be quantified wherever practicable.

26


•

Incident:

An event or chain of events which has caused or could have caused injury, illness and/or damage (loss) to assets, the environment or third parties. (The word ‘accident’ is used by some writers and organizations to denote an incident which has caused injury, illness and/or damage, but the term also has connotations of ‘bad luck’ in common speech, and is therefore avoided by others. In these Guidelines, only the term ‘Incident’ has been used, which in the above sense embraces the concept of ‘accident’.) •

Incident Reporting and Investigation:

Incident Reporting and Investigation are procedures undertaken to communicate the occurrence and to understand the root cause(s) of an incident. •

Legal Requirement:

Legal refers to UAE and/or Abu Dhabi Laws, Regulations, Decrees and any Guidelines or Codes of Practice adopted by ADNOC under or because of these laws, regulations or decrees. It also refers to any international standards or treaties to which the UAE, Abu Dhabi Emirate or ADNOC is a signatory, or under which they have agreed in principle to operate. •

Maintain (Procedures):

The term ‘Maintain’ as used in these Guidelines should be understood to mean ‘establish and maintain’ if the procedure which is to be maintained does not yet exist. •

Monitoring Activities:

All inspection, test and monitoring work related to health, safety and environmental management. •

Performance Criteria:

Performance criteria describe the measurable standards set by management to which an activity or system element is to perform. (You may also think of performance criteria as ‘goals’ or ‘targets’.) •

Practice:

Accepted methods or means of accomplishing stated tasks. •

Procedure:

A Procedure is a written description of how a specific task should be accomplished. •

Product Safety:

Product Safety is the recognition, evaluation, control and communication of the potential health hazards of products and the materials used in their production. •

Program: A Program is a management tool for meeting an established objective which is less comprehensive than a System. It is composed of two steps: plan and implement. It usually addresses issues that have either limited scope or limited time frame.

27


•

Risk:

This is the product of the chance that a specified undesired event will occur and the severity of the consequences of the event. •

Risk Management: Risk Management is the systematic process of: Identifying potential hazardous events and their potential consequences (hazard analysis) Assessing the probability of the hazardous event occurring (risk analysis) Reducing the risk by reducing the probability of a hazardous event occurring or mitigating its potential consequences. n

n n

•

Safety:

Safety encompasses the Systems, Programs, Procedures and Practices required for the prevention of incidents. •

Screening Criteria: These are the values or standards against which the significance of the identified hazard or effect can be judged. They should be based on sound scientific and technical information and may be developed by ADNOC, Standards Organizations, Industry Associations or Government Agencies.

•

Self-Assessment: A Self-Assessment is a process whereby a check is carried out by a unit or facility to determine how well its programs and procedures satisfy legal requirements and conform with the Expectations of the HSEMS.

•

System: A System is a management tool for meeting an established objective made up of four steps: plan, implement, measure and adjust.

•

Training: Training encompasses the steps necessary to ensure that employees and contractors have the knowledge, skills and values necessary to fulfil their environmental, health and safety responsibilities.

•

Waste Management: Waste Management encompasses the assessment and disposal of wastes generated by facilities, with the goal of minimizing and preventing the generation of waste.

When reference is made for actions to be taken, the intent of the following words is:

28

Shall, Will, Must

means that an action is compulsory

Should, Would If possible

means that an action is not compulsory but is recommended

May

means that an action is optional and no recommendation is made as to whether or not it is carried out.


3.

HSE MANAGEMENT: 3.1.

Policy: ADNOC has adopted the following Policies covering Health, Safety and Environmental activities. The Expectations of ADNOC's HSEMS state these standards for all Directorate and Group Company operations.

3.1.1. Health, Safety And Environment (HSE) Policy: It is Abu Dhabi National Oil Company (ADNOC) Group Policy to conduct activities in a manner designed to minimize HSE risks, protect health and safety of employees, contractors, customers, the community at large and the environment in which the Group activities are conducted. ADNOC, through active participation of all employees and contractors, will strive to manage HSE risks with the goal of preventing accidents, injuries and occupational illnesses, progressively minimizing environmental impact by reducing discharges and using energy efficiently, and producing safe, quality products. ADNOC and the Group Companies believe that good HSE performance will contribute/determine the success of the business and will treat HSE issues on par with all other primary business objectives. On General HSE Issues, ADNOC Group will: • •

•

•

•

• • •

•

•

Commit to meet defined, measurable HSE targets. Comply with all applicable laws and regulations and apply internationally recognized standards where local laws and regulations do not exist. Hold all levels of line management accountable for HSE issues and for the development of positive attitudes in themselves and those whom they supervise. Require contractors to apply same or similar HSE standards, practices and procedures. Undertake appropriate reviews and evaluations to measure HSE performance against defined standards and to ensure compliance with this policy. Provide appropriate HSE training to employees and contractors. Develop and maintain HSE emergency procedures. Periodically audit and review application of process control and management measures to ensure compliance with the HSE Guidelines. Manage all risks to a level which is ‘As Low As Reasonably Practicable’ (ALARP). Openly report HSE performance (good and bad).

On Health Issues, ADNOC Group Will: •

•

Control and manage all chemical, physical biological, mechanical and psycho-social factors which contribute to health risks, based on established guidelines and standards, applying best available technology consistent with good industry practice. Strive to protect and promote the health of all employees and contractors.

29


On Safety Issues, ADNOC Group Will: •

•

•

Design facilities, establish procedures, provide training and conduct operations in a manner that minimizes risks and hazards to workers, property and the community at large, applying best available technology consistent with good industry practice. Ensure all operations are conducted with the safety of the employee and community as a primary objective. Practice good product stewardship to ensure products are properly evaluated and provide As Low As Reasonably Practicable (ALARP) impacts to the environment and can be used safely by customers.

On Environment Issues, ADNOC Group Will: •

•

•

•

Progressively reduce emissions, effluents and wastes and improve efficient use of natural resources and energy. Minimize the impact of ADNOC Group activities on the environment and protect endemic fauna and flora at all sites of operations. Provide products and services supported with practical documented advice which, when used and practiced in accordance with this advice, will not cause undue effects on the environment. Preserve and protect all locations of archaeological, historical and natural interest in the areas of operation.

ADNOC and the Group Companies will, through a documented Health, Safety and Environment Management System, implement this policy and ensure contractors apply similar systems. All employees and contractors are required to be committed and perform their duties according to this general HSE Policy and the individual policies on Environmental Protection, Employee and Facility Safety and Occupational Health, Product Safety Stewardship and Minimization of Emissions, Effluents and Wastes.

3.1.2. Policy on Environmental Protection: It is the policy of ADNOC to ensure that the activities of ADNOC Directorates and Group Companies are conducted with full concern for safeguarding employee and public health, for protection of the physical environment and to comply with relevant environmental laws and regulations. ADNOC policy is to establish and implement effective compliance programs, including systems and procedures, for informing employees of the policy and their continuing obligation to conduct all activities in compliance with this policy and all applicable legal requirements. Where ADNOC becomes aware of a hazard representing a risk not covered by existing laws or regulations, where appropriate, ADNOC will develop its own environmental standards and practices to provide for adequate protection of employees, public health and the environment. In establishing timing, priorities, and levels of control, careful consideration will be given to benefits in relation to costs and technological feasibility. Particular attention will be given to achieving a reasonable balance between environmental goals and those for energy, jobs and the economy. Environmental laws and regulations will be periodically reviewed to comprehend changes in laws and regulations, national goals, new scientific and technical information and resource availability.

30


ADNOC will co-operate with industry and government in identifying environmental goals and in developing effective, reasonable and equitable control programs. It is the responsibility of Directorates, Group Company Managers and Supervisors to ensure adherence to ADNOC environmental policy. Further, all employees are expected to be guided by this policy in forming plans, setting objectives and conducting their day-to-day activities. Contractors are to be made aware of, and are expected to comply with, ADNOC environmental policy and standards.

3.1.3. Policy on Employee and Facility Safety and Occupational Health: It is the Policy of ADNOC to ensure that the activities of its Directorates and Group Companies are conducted with full concern for the safety of its facilities in order to protect the safety and health of employees, communities adjacent to our operations and the general public. ADNOC will comply with all applicable legal requirements pertaining to occupational safety, health, process safety and fire protection. ADNOC Guidelines, based upon scientific knowledge, established engineering practice and appropriate industry standards, will be developed when existing laws and regulations do not provide for adequate protection. ADNOC Directorates and Group Companies will carry out the objective of this policy by developing and maintaining safety management systems and procedures which ensure that process and employee safety and health considerations receive priority in design, operation, maintenance and decommissioning of facilities. ADNOC also will require appropriate safety and health training and will require strict adherence to safety rules and procedures. ADNOC will hold each Manager, Supervisor, and Employee accountable for the safe performance of their job and will measure their achievement in preventing occupational injuries, illness and accidental losses. ADNOC will provide qualified safety and health staff and appropriate equipment to support management in carrying out their objectives and goals in these areas. The same high standards are expected of contractors.

3.1.4. Policy on Product Safety Stewardship: ADNOC will comply with applicable laws, regulations and international standards on product safety. In addition, ADNOC will: evaluate its products; identify reasonably foreseeable potential hazards to health and the environment; provide procedures and controls to avoid unreasonable risk; and assess the product safety compliance of its operations. Also, where appropriate, ADNOC will inform employees, customers, users, government agencies and the public concerning product safety. ADNOC will work with government and trade associations to develop and implement product safety regulations that protect employees, transportation personnel, customers and the public, taking into account scientific, economic and social factors. ADNOC Directorates and Group Companies are responsible for the development, manufacture and marketing of products in a manner consistent with applicable laws and ADNOC's high standards of safety, health, and environmental protection. In the absence of adequate local government requirements, ADNOC will maintain standards of safety and health protection

31


that consider scientific knowledge, international standards and established practices in more developed countries. All hazardous purchased products transiting, stored or used on ADNOC properties will be accompanied by a material safety data sheet (MSDS) or its equivalent. Appropriate management, employees and contractors will be made aware of the product and proper precautions on transport, storage, use and disposal.

3.1.5. Policy on Minimization of Emissions, Effluents and Wastes: ADNOC, in addition to complying with all applicable environmental laws and regulations, is committed to reduce overall discharges (emissions to air, effluents to surface water, ground water and surface and solid waste) from its operations wherever technically and economically feasible. This is part of ADNOC's commitment to safeguarding and protecting the physical environment. Although proper management of wastes, including environmentally sound treatment, storage and disposal, is important in protecting the physical environment, eliminating their generation through source reduction and recycling is encouraged. Source reduction can be accomplished in many ways, including input substitution, product reformulation, process modification, operational changes and improved housekeeping. Recycling includes the use, reuse, and reclamation of residues both on-site and off-site. ADNOC Directorates and Group Companies will be responsible for developing, implementing and maintaining programs at their facilities aimed at minimizing and preventing the generation of emissions, effluents and wastes. These programs will include the establishment of goals, encouragement of technology development and transfer and review of accomplishments. ADNOC Directorates and Group Companies will operate plants and facilities and handle raw materials and products in a manner that protects the environment. ADNOC will work with suppliers, customers and the public, where appropriate, to resolve problems created by handling and disposal of hazardous substances from its operations. ADNOC employees and contractors will be informed of this policy and directed to strive for the minimization and prevention of emissions, effluents and wastes in formulating plans, setting objectives and conducting their daily activities.

32

6


3.1.6. HSE Vision, Mission, Values: ADNOC HSE Vision: ADNOC will strive to be recognized as responsible, cost-effective and innovative in our approach to health, safety and the environment. Our performance will be a source of pride to our employees, ADNOC, the Emirate of Abu Dhabi and the UAE.

ADNOC HSE Mission: ADNOC will identify the needs of the Emirate of Abu Dhabi, our customers, our employees and the physical environment. We will strive to deliver the highest quality of service and products while protecting the environment, employees and public health.

ADNOC HSE Values: ADNOC values the health and well-being of our employees, contractors, neighbouring communities, customers and the natural environment. ADNOC believes that: • • •

•

•

•

•

•

All accidents and incidents are preventable Line management is responsible for HSE performance Every employee and contractor is responsible for working safely and in an environmentally responsible manner Leadership and commitment of all employees and contractors is vital to successful HSE performance Demonstrating innovative and competent HSE management is a prime tool for gaining and retaining employee, community, public and customer preference Measuring and communicating performance is key to achieving continuous improvement Profitability and reputation will be enhanced by continuously improving HSE performance Proper HSE management will protect employees our neighbors, our operations and facilities

ADNOC is committed to: •

•

•

•

•

Conducting our business with full concern for protecting the environment and the health and well-being of our employees, contractors, customers and the communities in which we operate Integrating environmental, health and safety priorities into our business activities Managing HSE risks of our business and being prepared to respond to emergency situations Seeking opportunities to cost-effectively and continuously improve our HSE performance Working with customers, suppliers, contractors, trade associations and government, to address HSE concerns and participate in the development of legal requirements, standards and Codes of Practice

33


•

• •

3.2.

Involving our employees in the development and achievement of HSE goals and objectives Enhancing our HSE reputation Conducting our business in compliance with legal requirements, standards and codes of practice

Requirements: The requirements of the HSEMS are defined by the system Elements and Expectations. For each of these elements either a specific document or system must be in place to ensure the Expectation is met. These are listed below. A guide on how to prepare Directorate or Group Company HSEMS systems is appended as Development and Application Guidelines.

Element 1: Policy, Leadership And Responsibility: 1.1. Policies are established, communicated, and periodically updated. 1.2. Business Units establish and implement HSE Management Systems that are consistent with ADNOC HSEMS. 1.3. Clarity, definition and documentation of HSE roles and responsibility assignments for relevant employees and contractors are provided. 1.4. Managers demonstrate commitment to improved HSE performance through leadership and active, visible HSE participation. 1.5. Employees are encouraged to communicate opportunities for improved HSE performance. 1.6. Managers plan for the future by reviewing operations, evaluating risks/opportunities, setting measurable objectives, developing action plans and reporting annual achievements. 1.7. HSE performance indicators are established and measured. 1.8. Individual and team contributions to HSE performance are recognized and considered during employee performance reviews. 1.9. Procedures exist at all levels to encourage the transfer of good HSE systems, programs, procedures, practices and technology. 1.10. Contractor selection includes review of contractor HSEMS and HSE performance. 1.11. Management reviews HSE success and incorporates improvements to the HSEMS. Element 2: Safety: 2.1. General Safety rules and a Permit-to-Work system are in place, communicated, documented, and enforced for each site to address identified hazards. 2.2. Safety rules and procedures are in place, communicated, documented and enforced for off-site work-related activities, including vehicle operation. 2.3. A self-audit ensures the adequacy and enforcement of the facility's safety rules and procedures. 2.4. A procedure to ensure that facilities, vehicles, and equipment are maintained in a safe and operable condition. 2.5. Purchasing and warehousing procedures consider HSE requirements. 2.6. Ensure that appropriate safety equipment and hardware are provided and properly inspected and maintained.

34


2.7.

2.8. 2.9. 2.10.

2.11. 2.12. 2.13.

Ensure that the safety implications of operation and facility changes both temporary and permanent are assessed, documented, communicated to employees and contractors, and properly managed. (This is often called a “Management of Change” system.) Ensure that contractors manage HSE issues in a manner compatible with the ADNOC HSE Management System. Employees are involved in the development and implementation of safety systems. Identify and communicate personal protective equipment (PPE) requirements and train personnel to ensure that the PPE requirements are properly implemented and enforced. Ensure that design data, drawings and operating manuals are up-to-date and available. Purchasing and warehousing procedures and contracts include HSE requirements. Ensure safety and environmental control equipment and systems are tested and maintained.

Element 3: Occupational Health Protection: 3.1. Protect the occupational health and well being of employees and contractors. 3.2. Ensure for camps, housing, food supply and sanitation the health protection of employees and contractors from infectious disease. 3.3. Evaluate and improve workplace ergonomic factors during design and implementation. 3.4. Ensure employees and contractors are fit for duty. 3.5. Identify, assure and manage occupational health risks. 3.6. Ensure adequate communication to employees and contractors of the hazards associated with jobs. Element 4: Product Safety: 4.1. Product safety information is appropriate, accurate and available. 4.2. Ensure that the product safety aspects of new and reformulated products are evaluated by a proper, qualified professional prior to commercialization. Element 5: Environmental Protection: 5.1. Ensure that all discharges generated at facilities are managed to control their potential impacts on human health, the local environment, business operations and costs. 5.2. Definitions of hazardous and toxic waste are established and the disposal of hazardous and toxic waste is documented. 5.3. Continually reduce discharges whenever technically and economically feasible and beneficial to the environment. 5.4. Ensure that the control and the minimization of discharges are evaluated in the design, operation and maintenance of facilities. 5.5. Systems are implemented to prevent and deal with spills and leaks. 5.6. Identify and manage instances of soil, ground water or surface water contamination resulting from facility operation.

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5.7.

Efficient use of energy and natural resources is a key consideration in the design, development and optimization of field operations, plants and products.

Element 6: Risk Management: 6.1. Identify hazardous activities and events and their potential consequences as part of on-going business operations. 6.2. Assess and prioritize risks, manage them in a cost effective manner, and document and communicate risk management decisions. 6.3. Ensure that the design of new and modified facilities incorporates appropriate environmental, health and safety protection measures. (This is often called a “HAZOP” review.) 6.4. Ensure that appropriate HSE assessments are conducted as part of the acquisition or disposal of assets. 6.5. Manage HSE hazards as part of equipment or facility decommissioning. Element 7: Crisis Management: 7.1. Ensure that assessments of potential emergency situations, including transportation accidents, and their potential impacts are periodically conducted. 7.2. Ensure that emergency response and crisis management plans are in place for each facility, are kept up-to-date and are understood by those who may be affected and those who will respond. 7.3. Ensure that the resources necessary to respond to emergency situations are defined, available, ready to use and periodically tested. 7.4. Exercises are conducted to ensure applicability of the emergency response plan and the readiness of resources. 7.5. The relative roles, responsibilities and capabilities of ADNOC, contractors and emergency response agencies are understood and incorporated into emergency response plans. Element 8: Incident Reporting And Investigation: 8.1. An incident reporting system is in place which, at a minimum, includes the types of incidents to be reported, the level of management to be informed and the time frame for reporting. 8.2. Ensure that incidents are investigated to determine root causes, costs and the corrective actions necessary to prevent their recurrence. 8.3. Ensure that corrective actions are implemented, documented and periodically assessed. 8.4. Ensure lessons learned are shared. Element 9: Training And Competency: 9.1. Procedures ensure that HSE training and experience pre-requisites for relevant assignments are defined and documented. 9.2. Provide training to meet HSE job requirements. 9.3. A competency evaluation system is implemented to evaluate staff in HSE critical assignments.

36


Element 10: Community And Public Relations: 10.1. A procedure for maintaining community contact and addressing concerns is established and maintained. 10.2. Contact with appropriate local HSE authorities is established and maintained. 10.3. Public Relations are knowledgeable of HSE in relation to operations, projects, incidents and crisis management and ensures the facts are appropriately communicated to concerned parties, government agencies and the media. 10.4. Local concerns about ADNOC or its business units should be identified and addressed. Element 11: Legal Requirements: 11.1. Ensure that all applicable HSE legal requirements are known and compliance is incorporated into relevant programs. 11.2. Monitor emerging HSE legal requirements and international standards development. 11.3. Identify opportunities for participating in the development of new legal requirements, where appropriate.

3.3.

Roles and Responsibilities: Responsibilities for implementation of the HSEMS are as follows: 1) The ADNOC Directors are responsible for the implementation of the HSEMS within their Directorates and accountable for achieving the Expectations 2) The Group Company General Managers are responsible for adopting the HSEMS, establishing Procedures for its implementation within their companies, and for achieving the Expectations 3) The Senior Line Manger at each facility is responsible for ensuring that the HSEMS is implemented at his facility and that appropriate resources and training are made available to understand the HSEMS and to achieve its Expectations 4) Directorate and Group Company HSE Staff are responsible for providing support to Line Management in implementing and overseeing the HSEMS. This function can be accomplished by developing, reviewing and periodically updating the necessary HSE Systems, Programs and Procedures, and by assisting Line Management in implementing appropriate self-assessment and audit systems 5) The Directorate or Group Company HSE Manager is responsible for: Maintaining and enhancing the HSEMS, including development of Procedures • to facilitate comments and advice from the field on suggested revisions to the system, and for obtaining the necessary Line Management approval for any proposed changes • Maintaining an HSE audit function to assure Line Management that the operations are in compliance with legal requirements, Codes of Practice and in conformance with the Expectations of the ADNOC and Directorate or Group Company HSEMS Coordinating, on an annual basis, the development of a report summarising • HSE performance for submission to the ADNOC Group HSE Committee who shall provide a combined HSE performance report of all Directorate and Group Company actions to ADNOC Management Establishing and maintaining with ADNOC HSE function a “Library” to • facilitate sharing HSE “Best Practices” and Systems, Programs and

37


•

3.4.

Procedures needed to meet the Expectations of the HSEMS. Participating in a network for transferring HSE technology and “lessons learned” as an aid to continuous improvement Establishing a document control system for communicating and distributing the HSEMS and associated HSE Systems, Programs and Procedures. The document control system includes a process for issuing all HSEMS information through line channels, a mechanism to acknowledge receipt of documents, and reports to users highlighting any changes in Expectations along with a description of the reasons for the changes

Establishing HSE Objectives and Targets: Diagram 1 is a depiction of the HSE Management System process as it would function at the Directorate, Group Company or facility level. The term “facility” can refer to either a single facility, such as a refinery or a production unit, gas plant, port or it can refer to a set of similar facilities, aggregated together. CONTINUOUS IMPROVEMENT CYCLE Procedures

Diagram 1 As shown at the top of Diagram 1, HSE policies provide the basic input for the HSE Vision, Mission and Values statement and for the Elements and Expectations of the HSEMS. Legal requirements define the regulatory boundaries in which the Directorates or Group Companies operate. Facility management reviews its HSE performance and the requirements of the HSEMS and develops a set of HSE Business Objectives to improve HSE performance, which should be integrated with the overall business objectives process. To facilitate this process, the business planning cycle should incorporate guidelines requesting a brief discussion of the overall HSE strategy and HSE objectives. Once HSE Business Objectives have been set, a Self-Assessment should be conducted. Since compliance with legal requirements, Guidelines and Codes of Practice are a critical part of the HSEMS, the Self-Assessment should include a careful review of these requirements and whether they are being met by the facility. The review should also examine the Systems in place to ensure that such requirements are identified and kept up-to-date.

38


Any Expectation which is not being met by existing Systems, Programs and Procedures constitutes a Gap. In evaluating whether a Gap exists, it is important to consider the documentation and review requirements in the HSEMS. Clear assignment of responsibility, provision of adequate resources and documentation are required for all Systems, Programs and Procedures. In addition, Systems must include provisions for measuring results and for management review. At the completion of the Self-Assessment, the facility may have a list of Gaps which require filling. These Gaps should be prioritised, with Gaps which represent a threat to health, safety or the environment, or non-compliance with laws, regulations and Codes of Practice, having immediate priority, while Gaps which are caused by lack of proper documentation or management review have lower priority. Line Management should then develop its HSE plans, taking into account and establishing a balance between the following three considerations: • •

•

3.5.

Filling Gaps in priority order Seeking opportunities to reduce HSE cost without compromising HSE performance Capturing operations, production and marketing opportunities created by improved HSE performance

Implementing HSE Plans: Once the HSE Business Objectives have been established, facility personnel should develop specific plans including targets and timetables to achieve those objectives. As part of this process, Key Performance Indicators (KPI's) can be identified to help the facility track its performance. Resources should then be allocated, Systems, Programs and Procedures developed, and the plans implemented. Periodically operations personnel should measure the results of HSE programs and compare them with the targets set for those programs. Management should then review: • •

•

The results of these measurements Findings of self assessments and independent audits of the HSEMS (discussed in section 3.7) Any other pertinent information, such as changes in HSE laws, regulations and codes of practice, business conditions or incentives for exceeding the expectations of the HSEMS

HSE targets should be adjusted as necessary. Any capital requirements generated by these new targets are to be integrated into the business objectives for that facility. The adjustment of HSE targets ends one continuous improvement cycle and begins the next.

3.6.

Improvement Incentives: Evaluation of the incentives to improve HSE should be an on-going process. These incentives can include: • • • • • •

Reduced accidents Reduced emissions, effluents and waste Lower cost Improved reliability Reduced potential liability Improved reputation with regulators, the public and customers

39


•

Enhancement of employee pride

In some cases it may be possible to quantify an economic incentive for exceeding the Expectations of the HSEMS by comparing The Price Of Non-Conformance (PONC) with the Price Of Conformance (POC). Examples of PONC include the costs of cleaning up spills, repairing the damage caused by accidents, carrying out incident investigations, dealing with the greater regulatory or public scrutiny which results from a poor performance record, etc. Examples of POC include the costs of additional control equipment, additional staff, additional training, etc. If PONC is greater than POC, an economic incentive may exist for exceeding Expectations. As part of its consideration of continuous improvement, facility management should evaluate incentives for obtaining ISO 9000 and ISO14000 and/or similar certifications. If such incentives exist, the facility will be required to implement a document control system and other appropriate procedures to meet certification requirements. Facilities which do not find incentives for ISO standards or similar certifications, should consider whether there are incentives for establishing document control systems independent of certification.

3.7.

HSE Management System Audits: ADNOC shall establish and maintain an HSE Audit Program to determine the effectiveness of the HSEMS in fulfilling ADNOC HSE policies and overall business objectives. HSE performance, assessed by this Audit Program, will be reviewed with Directorate and Group Company Management. Conducting HSEMS Audits will be the responsibility of the ADNOC Group HSE Committee, who will report annually to ADNOC management on HSEMS performance. A fundamental principle of ADNOC's approach to HSE auditing is a recognition of the prime importance of periodic HSE Self-Assessments at the facility or business unit level. Such Self-Assessments are an essential tool for setting objectives and sustaining continuous improvement in HSE processes, HSE results and business performance and should be conducted on a regular schedule. Any finding of non-compliance with legal requirements or non-conformance with the Expectations of the HSEMS should be documented, and Action Plans developed to correct the situation. A business unit should carry out a Self-Assessment prior to an independent audit directed by ADNOC Group HSE Committee or ADNOC Internal Auditors. Independent HSE audits will be conducted on a periodic basis as directed by ADNOC Group HSE Committee and/or Internal Audit staff to verify compliance with applicable legal requirements, to ensure conformance with the Expectations of the HSEMS and to confirm the effectiveness of the facility or business unit's SelfAssessments. Directorates and Group Companies will develop and maintain a written HSE audit protocol based on self-assessment, and consistent with state-of-the-art criteria for use in carrying out independent HSE audits. These audit protocols will be document-controlled and may serve as guidance for the development of selfassessments and audit protocols for use by facility staff. (ADNOC HSEMS Audit Program and the HSEMS Audit Checklist are Annexures to this Document.)

40


ADNOC Group HSE Committee directed auditors will use the HSE audit protocol to develop an understanding of Directorate or Group Company HSEMSs. The audit team will also assess the effectiveness of the Management System by reviewing relevant documentation, inspecting operating sites and facilities, and interviewing employees and contractors. Audits will be scheduled on the basis of the strategic importance of the business activity concerned, considering such factors as risk, environmental sensitivity, the results of previous HSE audits, and the HSE performance of the facility or business unit. Audit findings will be recorded and reviewed with local Line Management at the conclusion of the audit. Subsequently, audit findings and recommendations must be documented and reported to those Senior Line Managers responsible for the activity and/or area audited. The responsible Line Managers must develop an Action Plan to address audit findings and recommendations. For self audits, the Senior Line Manager will be responsible to communicate annually a summary of the audit results and the success of the corrective Action Plan implementation through line channels to the ADNOC Group HSE Committee appointed Audit Manager. The Directorate and Group Companies will develop and maintain an HSE audit system to track the status of HSE audit findings and recommendations to ensure that timely follow-up action is implemented and to facilitate and document the follow-up process. For ADNOC Group HSE Committee directed audits the ADNOC Group HSE Committee will maintain through Internal Audit an HSE audit data base to track the status of HSE audit findings, recommendations and implementation. The ADNOC Group HSE Committee appointed Audit Manager shall, in conjunction with ADNOC HSE, ensure that independent HSE audits are led by personnel who: •

•

Have professional experience and a thorough understanding of the activity, area and business sector being audited Have been trained in quality auditing principles with a particular focus on HSE systems, programs and procedures

Personnel to serve on the ADNOC audit teams will be drawn on an ad hoc basis from various departments within the ADNOC organizations as needed to meet audit objectives and provide HSE training opportunities for Directorate and Group Company staff. Contractors may also be used to staff audit teams.

3.8.

Management Review: Directorates and Group Company Management will review the HSEMS at least biennially to ensure its continuing suitability and effectiveness. The review shall be documented. Management Review must address the HSE performance of facilities, the commitment to continuous improvement in HSE performance and the status of HSE audit findings. The Management Review must also address the potential need for change in ADNOC HSE policies or in Directorate and Group Company HSE Systems and Objectives in light of emerging HSE trends and changes in the business.

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3.9.

Communications AND Information Sharing: Communications and information sharing are critical to the success of the HSEMS. Communication is specifically required: •

•

With employees, government agencies, customers, communities, and the public Between facilities and units at the same level within a Directorate or Group Company and with their counterparts in the rest of the ADNOC organization

7

The Expectations of the HSEMS address the first type of communication and information-sharing. The requirements for communication between various levels of the management on HSE matters are the same as the communication requirements for other aspects of our business. However, the HSEMS creates new opportunities and new incentives to communicate and share information horizontally throughout the ADNOC Directorates and Group Companies. By creating a common set of requirements for operations, the HSEMS facilitates the sharing of HSE Systems, Programs and Procedures. The emphasis that the HSEMS places on continuous improvements should create an even greater incentive for this information sharing. ADNOC E&S Division will maintain a “Library” of HSE Systems, Programs and Procedures, to facilitate sharing of “Best Practices” across all of ADNOC.

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III A.

DEVELOPMENT AND APPLICATION GUIDELINES

43

HSEMS Development & Application Guidelines

Authors:

These Guidelines have been styled by the ADNOC Group HSE Committee after those proposed by the E&P Forum. The E&P Forum Safety, Health and Personnel Competence and Environmental Quality Committees formed a special ad hoc Health, Safety and Environmental Management Systems (HSEMS) task force to develop these guidelines. This same basic structure has been adopted by the International Standards Organization for the Environmental Management System (EMS) Standard Series 14000 (ISO 14000) and was used for the ISO 9000 standard services setting forth the Safety Management System (SMS) The following petroleum and service companies participated in the development of the E&P Forum and/or ISO 9000 and ISO 14000 guidelines: Agip Amoco British Gas British Petroleum Exxon

Halliburton Kuwait Oil Company Mobil Pertamina Philips

Shell Statoil UNOCAL

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III.a.

DEVELOPMENT AND APPLICATION GUIDELINES

INTRODUCTION 1.

BACKGROUND: Petroleum and chemical activities are subject to extensive local and international legislation and regulation concerning Health, Safety and the Environment (HSE). Operators have HSE strategies to satisfy their own operating and regulatory requirements. For most, Safety Management Systems (SMS) are a principal component of such strategies. SMS guidelines have been developed both by individual companies and by national and international bodies. There is wide recognition of the benefits of objective or goal-setting approaches to safety. This is a fundamental principle of British Standard 5750 (BS 5750) and the SMS approach which draws on the management principles of the International Standard on Quality Systems, ISO 9000. Similarly, environmental aspects are subject to extensive regulation and Environmental Management Systems (EMS) (BS 7750 and ISO 14000) are used to control and manage environmental impacts. Further, BS 8800 Occupational Health and Safety Management System, has been implemented to include occupational health into this overall management scheme. Although there are differences in the detailed handling of Health, Safety and Environmental Issues, safety and environmental management are converging towards the systems model of ISO 9000. It is upon the ISO 9000 system that ISO 14000 builds Environmental Management Systems. The requirements of health, safety and environmental protection are not always in harmony. For example, measures necessary to safeguard personnel in emergencies may have adverse environmental effects, and vice versa. However, joint consideration of health and safety and environmental matters provides a framework within which such issues can be resolved, and an appropriate balance struck.

2.

PURPOSE AND SCOPE: These Health, Safety and Environmental Management System Guidelines are designed to: • • • • •

Cover relevant Health, Safety and Environment (HSE) issues in a single document Be adaptable to different types of operations Recognize, and be applicable to, the role of contractors and sub-contractors Facilitate operation within the framework of statutory requirements Facilitate evaluation of operations to international standards

These Guidelines describe the main elements necessary to develop, implement and maintain a Health, Safety and Environmental Management System (HSEMS). They do not dictate specific performance requirements, but instead allow each Directorate or Group Company to set Policies and Objectives taking into account information about the significant health and safety hazards and environmental effects of their operations. The Guidelines are templates for ourselves and our contractors that help assure us and others (such as government agencies, neighbors, partners, clients, insurers and the public) of compliance with stated HSE policies within an objective-setting management system. Furthermore, the guidelines are intended to build upon existing sound, workable and effective company systems and practices.

46


The HSE criticality of a given operation or situation dictates whether it warrants a formally documented and controlled procedure. In many instances the existing company practices will be less formal but nevertheless fully acceptable. Assuring the suitability of all aspects of the HSEMS remains the responsibility of each Directorate, Group Company and facility. These Guidelines should be read in the context and spirit of self regulation.

3.

THE HEALTH, SAFETY MANAGEMENT SYSTEM MODEL:

AND

ENVIRONMENTAL

The model Health, Safety and Environmental Management System which forms the basis of these Guidelines is shown schematically in Diagram 2. Although this indicates a sequence of the HSEMS elements, many of the stages will in practice be addressed at the same time or revisited at different times. Likewise, this is only one depiction of the interrelation of these elements. The HSEMS is not intended to be a stand alone exercise. It is to be merged into and become an integral part of the overall management system . THE MODEL HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT SYSTEM (HSEMS)

Policy & Strategic Objectives

Organization, Resources & Documentation

Review

Leadership and Commitments

Evaluation & Risk Management

Implementation & Monitoring Monitoring

Planning Diagram 2

Audit

47


4.

STRUCTURE OF THE DOCUMENT: The ADNOC HSEMS GUIDE has two main sections: ‘Guidelines’ and ‘Supplementary Information’. The Guidelines describe the elements of the HSEMS model and their interrelationships. These elements may also be thought of as ‘performance standards’. [This term should not however, be confused with ‘performance criteria’, which are lower-level specifications for the performance of operations.] The Supplementary section contains additional advisory material under the same headings, including examples of the manner in which the Guidelines may be applied. The sections are numbered as in the Guidelines, but with the prefix ‘S’.

5.

TERMINOLOGY: Particular attention should be paid to the definition and usage in these Guidelines of the terms ‘risk’, ‘hazard’, ‘performance criteria’, ‘audit’ and ‘review’. References in the Guidelines to a ‘Company’ may be taken to refer to the ADNOC Directorates, Group Companies, facilities, contractors, and other operations under the purview of ADNOC and/or of the Abu Dhabi Supreme Petroleum Counsel.

EXECUTIVE SUMMARY OF THE HSEMS MODEL KEY ELEMENTS OF THE HSEMS MODEL:

The Guidelines describe a management system, shown in Diagram 2 of this section, for setting and implementing ADNOC Policy and Objectives on Health, Safety and the Environment. Key elements of the HSEMS are shown in the table below. HSEMS Element

Addressing

Leadership and commitment

Top-down commitment and culture, essential to the success of the system.

Policy and strategic objectives

ADNOC intentions, principles of action and aspirations with respect to health, safety and environment.

Organization, resources and documentation

Organization of people, resources and documentation for sound HSE performance.

Evaluation and risk management

Identification and evaluation of HSE risks, for activities, products and services, and development of risk reduction measures.

Planning

Planning the conduct of work activities, including planning for changes and emergency response.

Implementation and monitoring

Performance and monitoring of activities, and how corrective action is to be taken when necessary.

Auditing and reviewing

Periodic assessments of system performance, effectiveness and fundamental suitability.

Additional advisory material on each element is given in the Supplementary section.

48


1.

LEADERSHIP AND COMMITMENT: .

This section addresses the top down commitment and culture necessary for the success of an HSEMS system

Policy & Strategic Objectives Organization, Resources & Documentation

Review


Evaluation & Risk

Implementation & Monitoring

Management Planning

Diagram 3

Audit

Senior Management must provide strong, visible leadership and commitment, and ensure that this commitment is translated into the necessary resources to develop, operate and maintain the HSEMS and to attain the Policy and Strategic Objectives. Management should ensure that full account is taken of HSE Policy requirements and should provide support for local actions taken to protect health, safety and the environment. ADNOC must create and sustain a culture that supports the HSEMS, based on: • • • • •

Belief in ADNOC's desire to improve HSE performance Motivation to improve personal HSE performance Acceptance of individual responsibility and accountability for HSE performance Participation and involvement at all levels in HSEMS development Commitment to an effective HSEMS

Employees of both ADNOC and its contractors must be involved in the creation and maintenance of a culture that supports HSEMS.

49


2.

POLICY AND STRATEGIC OBJECTIVES:

This section addresses ADNOC intentions, principles of action and aspirations with respect to health, safety and environment and the aim of improved HSE performance

Policy & Strategic Objectives Organization, Resources &

Review

Documentation Leadership and Commitments


Implementation & Monitoring Planning

.

Audit Diagram 4 Company management will define and document its HSE Policies and Strategic Objectives and ensure that they: • • • • • • • • •

•

Are consistent with those of ADNOC Are relevant to its activities, products and services, and their effects on HSE Are consistent with other policies Have equal importance with other policies and objectives Are implemented and maintained at all organizational levels Are available to ADNOC, government agencies and the public Commit the company to meet or exceed all relevant regulatory and legislative requirements Apply responsible standards of its own where laws and regulations do not exist Commit to reduce the risks and hazards to health, safety and the environment of activities, products and services to levels which are as low as reasonably practicable Provide for the setting of HSE objectives that commit continuous efforts to improve HSE performance

Strategic HSE Objectives will be established and periodically reviewed. Such objectives will be consistent with both ADNOC and the company's policy and reflect the activities, relevant

50


HSE hazards and effects, operational and business requirements, regulations and the views of employees, contractors and customers.

3.

ORGANIZATION, RESOURCES AND DOCUMENTATION:

This section addresses the organization of people, resources and documentation for sound HSE performance

Policy &Strategic Objectives Organisation, Resources & Documentation

Review


.



Diagram 5

3.1.

Audit

Organizational Structure and Responsibilities: Successful handling of HSE matters is a line responsibility, requiring the active participation of all levels of management and supervision; this should be reflected in the organizational structure and allocation of resources. The company will define, document and communicate - with the aid of organizational diagrams where appropriate - the roles, responsibilities, authorities, accountabilities and inter-relations necessary to implement the HSEMS, including but not limited to: •

• • •

•

•

Provision of resources and personnel for HSEMS development and implementation Initiation of action to ensure compliance with HSE Policy Acquisition, interpretation and provision of information on HSE matters Identification and recording of corrective actions and opportunities to improve HSE performance Recommendation, initiation or provision of mechanisms for improvement, and verification of their implementation Control of activities while corrective actions are being implemented

51


•

Control of emergency situations

It will be stressed to all employees their individual and collective responsibility for HSE performance. The company will also ensure that personnel are competent (see section 3.4) and have the necessary authority and resources to perform their duties effectively. The organizational structure and allocation of responsibilities will reflect the responsibility of line managers at all levels for developing, implementing and maintaining the HSEMS in their particular areas. The structure should describe the relationships between: • •

• • •

3.2.

Different operating units or facilities Operating and supporting services (whether the services are provided on the same facility or from a larger corporate organization) Onshore and offshore organizations Employees and contractors Partners in joint activities

Management Representative(s): Management representative(s) will be assigned responsibility, authority and accountability for coordinating implementation and maintenance of the HSEMS. The representative(s) will be accountable to senior Group Company, Directorate and ADNOC management. However, the appointment(s) should not reduce the responsibility of individual line managers for implementing the HSEMS in their particular areas.

3.3.

Resources: Senior management will allocate sufficient resources to ensure the effective operation of the HSEMS, taking account of advice from the management representative(s), line management and HSE specialists. Resource allocation should be reviewed regularly as part of the review of the HSEMS (see section 7.2), of management of change (see section 5.4) and of risk management (See section 4).

3.4.

Competence: 3.4.1. General: Procedures will be maintained for ensuring that personnel performing specific assigned HSE-critical activities and tasks are competent on the basis of appropriate: Personal abilities Skills developed through experience Acquired knowledge • • •

Systems for competence assurance should apply both to initial recruitment and to selection for new activities, and to both staff and contractors. The continuing competence of personnel to perform their duties should be regularly reviewed and assessed, including appropriate consideration of personal development and training required to achieve competence for changing activities and technologies (see section 3.4.2). Procedures for competence assurance include, among others: • •

52

Systematic analysis of requirements for tasks Assessment of individuals' performance against defined criteria


• •

Documented evidence of individual competence Programs for periodic re-assessment Identify manner in which tasks are to be performed

Identify competencies (abilities/skills/knowledge)

Select appropriate staff

Provide training if necessary

Diagram 6

Review performance

3.4.2. Training: The company will maintain procedures to ensure and increase competence through identification of training needs and provision of appropriate training for all personnel. Training must be sufficient to ensure achievement of the company's policy and objectives, and meet or exceed that required by legislation and regulations. Appropriate records of training should be maintained (see section 6.3) and refresher training scheduled as required. Consider tasks and individuals

Identify type/extent/frequency of training needed

Prepare training course/material

Record training conducted

Obtain participants feedback

Diagram 7

Evaluate effectiveness

Systems to monitor the effectiveness of training programs and to introduce improvements where necessary should be developed.

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3.5.

Contractors: Procedures must be developed to ensure contractors operate a management system that is consistent with the requirements and provisions of ADNOC Policy and are compatible with the HSEMS of the company to which it is providing services. Procedures should facilitate interfacing of contractors' activities with those of the company and with those of other contractors, as appropriate. [This may be achieved by means of a specific interface document between company and contractor so that any differences may be resolved, and procedures agreed, before work commences]. Particular attention should be paid to the following: •

Selection of contractors, including (among other considerations) specific assessment of their HSE policy, practices and performance and the adequacy of their HSEMS, commensurate with the risks associated with the services to be provided

•

Effective communication (see section 3.6) of the key elements of the company's HSEMS, and of the standards of worker and environmental protection expected from the contractor, including agreed HSE objectives and performance criteria

•

Sharing by company and contractor of relevant information which may impact on the HSE performance of either

•

The requirement that each contractor has an effective and relevant training program which includes records and procedures for assessing the suitability of staff or a particular individual and the need for further training

•

3.6.

Definition of methods for monitoring and assessing contractor performance against agreed HSE objectives and performance criteria

Communication: Procedures are to be developed to ensure that company employees and those of contractors and partners, at all levels, are aware of the: •

•

• •

Importance of compliance with the HSE Policy and Objectives, and their individual roles and responsibilities in achieving it HSE risks and hazards of their work activities and the preventative and mitigation measures (see section 4) and emergency response procedures that have been established (see section 5.5) Potential consequences of departure from agreed operating procedures Mechanisms for suggesting to management improvements in the procedures by which they and others operate

Maintaining means of external communication in times of emergency is especially important and special contingency arrangements should be in place (see section 5.5). The company should maintain procedures for communication of HSE information, consistent with its policy and with applicable legal requirements. The company should, while protecting confidential information, make available its HSE experience to employees, contractors, customers and other companies engaged in similar activities to facilitate improvements in industry HSE performance.

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customers

regulators

shareholders

media

banks C O M P

AN Y

ADNOC

neighbors

insurers

Management representatives All employees

interest groups supreme petroleum council

Diagram 8

emergency services suppliers

contractors

Procedures should be developed for receiving and responding to communications from employees, contractors, customers, government agencies and the public concerning HSE performance and management. Community awareness and consultation programs will be maintained where appropriate. Methods to measure the effectiveness of these communication procedures should be developed.

3.7.

Documentation and its control: 3.7.1. HSEMS Documentation: The Company will maintain controlled documentation to: • • • •

• • •

•

Record the HSE policy, objectives and plans Record and communicate key roles and responsibilities Describe HSEMS elements and their interactions Cross-reference related documentation and describe links with other aspects of the overall management system Record the results of HSE evaluation and risk management Record relevant legal requirements Record, where necessary, procedures and work instructions for key activities and tasks Describe emergency plans and responsibilities, and the means of responding to incidents and potential emergency situations

Such documentation will cover: • • •

•

ADNOC Directorates and Group Companies Individual functions and operations (e.g., facility design and construction, exploration, drilling, process operations, shipping, ports, etc.) Contractors and partners

55


3.7.2. Document Control: Procedures for controlling HSEMS documents will ensure that: • •

• •

They can be identified with the appropriate company, unit or activity They are periodically reviewed, revised as necessary and approved for adequacy by authorised personnel prior to issue Current versions are available at those locations where they are needed When obsolete, they are promptly removed from all points of issue and points of use

Documentation will be legible, (with dates of revision), readily identifiable, numbered (with a version number), maintained in an orderly manner and retained for a specified period. Policies and responsibilities will be established for the modification of documents, and their availability to employees, contractors, government agencies and the public. Documentation may be made available on electronic media but at least one printed copy shall be available and easily accessible at major facilities.

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4.

EVALUATION AND RISK MANAGEMENT:

. Risk is present in all human endeavours. This section addresses the identification of HSE hazards and evaluation of HSE risks, for all activities, products and services, and development of measures to reduce these risks. The essential steps of Hazard Management are shown in diagram 10

Policy &Strategic Objectives Organisation, Resources & Documentation

Review


Evaluation & Risk

Management


Audit

Diagram 9

4.1.

Hazard Management: Risk reduction is related to the reduction of hazards and is itself a TQM process as depicted below. Hazards must be identified and their possible effects evaluated. This allows the proper operations precautions or engineering design out steps to be taken to prevent hazards. However, when an incident does occur damage mitigation and recovery must be addressed through pre-planned procedures

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THE ESSENTIAL STEPS OF HAZARD MANAGEMENT

Evaluate

Identify

Prevent

Recover

Diagram 10

4.2.

Mitigate

Identification of hazards and effects: Procedures will be developed to identify systematically the hazards and effects which may affect or arise from operations and activities, and from the materials which are used or encountered in them. The scope of the identification should cover activities from project inception through to abandonment and restoration of sites. The concept being to “design out” HSE possible problems from day one. Identify hazards and effects

Establish screening criteria

Establish hazards and effects

significant hazards and effects and statutory requirements

Set detailed objectives and performance criteria

Identify and evaluate risk reduction measures

Diagram 11

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Implement selected risk reduction measures

Identify applicable statutory requirements


This includes consideration of: •

•

•

Planning, construction and commissioning (i.e., asset acquisition, development and improvement activities) Routine and non-routine operating conditions, including shut-down, maintenance and start-up Incidents and potential emergency situations, including those arising from: Product/material containment failures Structural failure Climatic, geophysical and other external natural events Sabotage and breaches of security Human factors including breakdowns in the HSEMS

n n n n n

• •

Decommissioning, abandonment, dismantling, disposal and restoration Potential hazards and effects associated with past activities

Personnel at all organizational levels should be appropriately involved in the identification of hazards and effects.

4.3.

Evaluation: Procedures will be developed to evaluate (assess) risks and effects from identified hazards against screening criteria, taking account of probabilities of occurrence and severity of consequences for: • • •

8

People Environment Assets

It should be noted that any evaluation technique provides results which themselves may be subject to a range of uncertainties. Therefore, formal risk evaluation techniques will be used in conjunction with the judgement of experienced personnel. Where appropriate, advice of regulators and surrounding community should also be considered. Risk evaluation should: Include effects of activities, products and services • Address effects and risks arising from both human and hardware factors • Solicit input from personnel directly involved with the risk area • Be conducted by qualified and competent personnel • Be conducted according to appropriate and documented methods • Be updated at specified intervals • Evaluation of health and safety risks and effects should include, where appropriate, consideration of: • • • • •

Fire and explosion Impacts and collisions Drowning, asphyxiation and electrocution Chronic and acute exposure to chemical, physical and biological agents Ergonomic factors

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Evaluation of acute and chronic environmental effects should include, where appropriate, consideration of: •

• • • • •

4.4.

Controlled and uncontrolled emissions of matter and energy to land, water and the atmosphere Generation and disposal of solid and other wastes Use of land, water, fuels and energy, and other natural resources Noise, odour, dust, vibration Effects on specific parts of the environment including ecosystems Effects on archaeological and cultural sites and artefacts, natural and conservation areas and sensitive marine areas.

Recording of hazards and effects: The company will maintain procedures to document those hazards and effects (chronic and acute) identified as significant in relation to health, safety and the environment, outlining the measures in place to reduce them (see sections 4.6) and identifying the relevant HSE - critical systems and procedures.

4.5.

Strategy Requirements: The company should maintain procedures to record statutory requirements and codes applicable to the HSE aspects of its operations, products and services and to ensure compliance with such requirements.

4.6.

Objectives and Performance Criteria: The company will maintain procedures to establish detailed HSE objectives and performance criteria at relevant levels. Such objective and performance criteria should be developed in the light of policy, strategic HSE objectives, HSE risks, and operational and business needs. They should be quantified, wherever practicable, and identified with defined time scales while being realistic and achievable. As a follow-up to risk evaluation (see section 4.3), the company should develop procedures to set performance criteria for HSE - critical activities and tasks, which stipulate in writing the acceptable standard for their performance. It should also, at specified intervals, review the continuing relevance and suitability of the criteria.

4.7.

Risk Reduction Measures: The company will have procedures to select, evaluate and implement measures to reduce risks and effects. Risk reduction measures include both those to prevent incidents (i.e., reducing the probability of occurrence) and to mitigate chronic and acute effects (i.e., reducing the consequences). Preventive measures such as ensuring asset integrity (see section 5.2) should be emphasised wherever practicable. Mitigation measures should include steps to prevent escalation of developing abnormal situations, lessen adverse HSE effects and ensure emergency response measures for recovery (see section 5.5). Effective risk reduction measures and follow-up require visible commitment of management and on-site supervision, as well as the understanding and ownership of operations personnel.

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4.8.

Implementation: In all cases consideration will be given to reducing risk to a level deemed ‘As Low As Reasonably Practicable’ (ALARP) reflecting among other factors, local conditions and circumstances, the balance of cost and benefits and the current state of scientific and technical knowledge. Procedures are needed to: •

•

•

•

•

•

Identify prevention and mitigation measures for particular activities, products and services which pose potential HSE risks Re-appraise activities to ensure that the measures proposed do reduce risks, or enable relevant objectives to be met Implement, document and communicate to key personnel interim and permanent risk reduction measures, and monitor their activities Develop relevant measures such as plans for emergency response (section 5.5) to recover from incidents and mitigate their effects Identify hazards arising from risk prevention and mitigation and recovery measures Evaluate the tolerability of consequent risks and effects against the company screening criteria

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5.

PLANNING: .

This section addresses the firm planning of work activities, including the risk reduction measures (selected through the evaluation and risk management process). This includes planning for existing operations, managing change and developing emergency response measures

Policy & Strategic Objectives Organisation, Resources & Documentation

Review


Evaluation & Risk

Management Implementation & Monitoring

Planning

Audit

Diagram 12

5.1.

General: There must be within overall work programs, plans for achieving HSE objectives and performance criteria. These plans should include: • •

• • • •

• •

•

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A clear description of the objectives Designation of responsibility for setting and achieving objectives and performance criteria at each relevant function and level of the organization The means by which they are to be achieved Resource requirements Time scales for implementation Programs for motivating and encouraging personnel toward a suitable HSE culture Mechanisms to provide feedback to personnel on HSE performance Processes to recognize good personal and team HSE performance (e.g., safety award schemes) Mechanism for evaluation and follow-up


5.2.

Asset Integrity: Procedures must be in place to ensure that HSE - critical facilities and equipment which the company designs, constructs, procures, operates, maintains and/or inspects are suitable for the required purpose and comply with defined criteria. Preprocurement and pre-construction assessment of new facilities and equipment must include explicit assessment of appropriateness to meet HSE requirements and should emphasise design as the best preventive measures to reduce risk and adverse HSE effects. Procedures and systems for ensuring asset integrity must address (among other factors) structural integrity, process containment, ignition control and systems for detection, shutdown, emergency response, life-saving, exposure reduction and environmental protection. Deviation from approved design practices and standards are permitted only after review and approval by designated personnel and/or authorities (as appropriate). The rationale for the deviation should be documented.

5.3.

Procedures and Work Instructions: 5.3.1. Developing Procedures: Activities for which the absence of written procedures could result in infringement of HSE policy, breaches of legal requirements, performance criteria, Guidelines, or Codes of Practice should be identified. Documented procedures or standards should be prepared for such activities, defining how they are to be conducted - whether by the company's own employees, or by others acting on its behalf - to ensure technical integrity and to transfer knowledge effectively. State written procedures simply, unambiguously and understandably, and indicate the persons responsible, methods to be used and, where appropriate, performance standards and criteria to be satisfied. Procedures are required for procurement and contracted activities, to ensure that suppliers and those acting on the company's behalf comply with the company's policy requirements that relate to them.

5.3.2. Issuing Work Instructions: Work instructions define the manner of conducting tasks at the work-site level, whether conducted by our own employees or by others acting on our behalf. In the case of HSE - critical tasks, which have the potential for adverse HSE consequences if incorrectly performed, these work instructions should be documented and communicated to relevant personnel.

5.4.

Management of Change: Procedures must be in place for planning and controlling changes, both permanent and temporary, in people, plant, processes and procedures, to avoid adverse HSE consequences.

9

63


The procedures must be suitable to address the HSE issues involved, according to the nature of the changes and their potential consequences, and should address: • •

•

Identification and documentation of the proposed change and its implementation Responsibility for reviewing and recording the potential HSE hazards from the change or its implementation Documentation of the agreed change and implementation procedure, including: Measures to identify HSE hazards and to assess and reduce risks and effects Communication and training requirements Time limits, if any Verification and monitoring requirements Acceptance criteria and action to be taken if breached Authority for approval to implement the proposed change n n n n n

•

Procedures will include how new, amended or revised legal requirements will be assessed and incorporated in the HSEMS. Separate plans should be established for the HSE management of new operations (relating, for example, to acquisitions, developments, divestments, products, services or processes), or of modified operations where the modification introduces significantly different HSE concerns. These separate plans should define at least: • • • • •

5.5.

HSE objectives to be attained Mechanisms for their achievement Resource requirements to achieve HSE objectives Procedures for dealing with changes and modifications as projects proceed Corrective mechanisms to be employed should the need arise, how they will be activated and how their adequacy can be measured

Contingency and Emergency Planning: Procedures will be devised to identify foreseeable emergencies by systematic review and analysis. A record of such identified potential emergencies should be made, and updated at appropriate intervals in order to ensure effective response to them. The company should develop, document and maintain plans for responding to these potential emergencies, and communicate such plans to: • •

• • •

Command and control personnel Employees and contractors who may be affected Emergency services Local government units Others likely to be impacted

10

The emergency plans should cover: •

•

•

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Organization, responsibilities, authorities and procedures for emergency response and disaster control, including the maintenance of internal and external communications Systems and procedures for providing personnel refuge, evacuation, rescue and medical treatment Systems and procedures for preventing, mitigating and monitoring environmental effects of emergency actions


•

•

•

•

Procedures for communicating with authorities, relatives and other relevant parties Systems and procedures for mobilising company equipment, facilities and personnel Arrangements and procedures for mobilising third party resources for emergency support Arrangements for training response teams and for testing the emergency systems and procedures

To assess the effectiveness of response plans, procedures must be maintained to test emergency plans by scenario drills and other suitable means, at appropriate intervals, and to revise the response plans as necessary in the light of the experience gained. Procedures must be in place for the periodic assessment of emergency equipment needs and the maintenance of such equipment in a ready state.

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6.

IMPLEMENTATION:

This section addresses how activities are to be performed and monitored, and how corrective action is to be taken when necessary.


Review




Audit

Diagram 13

6.1.

Activities and Tasks: Activities and tasks should be conducted according to procedures and work instructions developed at the planning stage or earlier, in accordance with HSE policy: •

•

•

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At senior management level, the development of strategic objectives and high level planning activities are to be conducted with due regard for the HSE policy. At supervisory and management level, written directions regarding activities (which typically involve many tasks) will normally take the form of plans and procedures. At the work-site level, written directions regarding tasks will normally be in the form of work instructions, issued in accordance with defined safe systems of work (e.g., permits to work, simultaneous operations procedures, lock-off and tag-out procedures, manuals of permitted operations, etc.).


Management is to ensure, and be responsible for, the conduct and verification of activities and tasks according to relevant procedures. This responsibility and commitment of management to the implementation of policies and plans includes, among other duties, ensuring that HSE objectives are met and that performance criteria and control limits are not breached. Management will ensure the continuing adequacy of the HSE performance of the company through monitoring and review activities (see section 6.2).

6.2.

Monitoring: Procedures are to be in place for monitoring relevant aspects of HSE performance and for establishing and maintaining records of the results. For each relevant activity or area, at least: •

•

• • •

•

•

Identify and document the monitoring information to be obtained, and specify the accuracy required of results Specify and document monitoring procedures, locations and frequencies of measurement Establish, document and maintain measurement quality control procedures Establish and document procedures for data handling and interpretation Establish and document actions to be taken when results breach performance criteria (see sections 4.4, 4.5 and 6.4) Assess and document the validity of affected data when monitoring systems are found to be malfunctioning and/or sampling procedures are not conducted properly Safeguard measurement systems from unauthorized adjustments, damage or tampering

Procedures are required for both active and reactive monitoring. Active monitoring provides information in the absence of any incident, ill-health or damage to the receiving environment. It includes checking that HSEMS requirements (e.g., procedures) are being complied with, and that objectives and performance criteria are met. Reactive monitoring provides information on incidents (including near-miss incidents, ill-health or environmental damage) that has occurred and provides insights into the means of preventing similar incidents in the future. These insights become inputs to HSE planning.

6.3.

Records: A system of records should be maintained in order to demonstrate the extent of compliance with HSE policy and its requirements, and to record the extent to which planned objectives and performance criteria have been met. There must be procedures to ensure the integrity, accessibility and control of such records. This includes relevant contractor and procurement records, the results of audits and reviews (see section 7), training records (see section 3.4.2) and employee medical records. The retention times of records should be established and recorded, and procedures must be maintained regarding their availability and confidentiality.

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6.4.

Non-compliance and Corrective Action: Responsibility and authority will be defined for initiating investigation and corrective action in the event of non-compliance with specified requirements relating to the HSEMS, its operation or its results. Situations of non-compliance may be identified by the monitoring program, through communications from employees, contractors, customers, government agencies or the public, or from investigations of incidents (see section 6.5 and 6.6). Procedures will be developed for investigation and corrective action. The procedure should: • • • • • •

Notify the relevant parties Determine the causation sequence and likely root cause Establish a plan of action or an improvement plan Initiate preventive actions commensurate with the nature of the non-compliance Apply controls to ensure that any preventive actions taken are effective Revise procedures to incorporate actions to prevent recurrence, communicate changes to relevant personnel and implement them

Determine the causes

Plan action

Initiate preventive actions

Apply controls

Diagram 14

6.5.

Revise procedures and communicate changes

Incident Reporting: Procedures will be maintained for the internal recording and reporting of incidents which affected, or could have affected, HSE performance, so that the relevant lessons can be learned and appropriate actions taken (see section 6.6). There should be a defined mechanism for the reporting of incidents to government agencies to the extent required by law or to such greater extent as the policy of the company on external communication may require. Likewise, mechanisms should be maintained for communication to employees, partners, the media and public.

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6.6.

Incident Follow-up: Both the immediate circumstances of the incident and the underlying HSEMS weaknesses which caused it should be identified to enable judgements to be made by those responsible for authorizing the necessary follow-up action. The mechanism and responsibilities for follow-up of incidents must be clearly defined. The mechanism should be broadly similar to the procedures for implementing corrective action in cases of non-compliance with the HSEMS (see section 6.4). The defined responsibilities for follow-up of an incident should be appropriate to the severity of its real or potential consequences.

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7.

AUDIT AND REVIEW: .

This section addresses the periodic assessment of system performance, effectiveness and inherent suitability


Review


Evaluation & Risk Management Implementation & Monitoring

Planning

Diagram 15

7.1.

Audit

Audit: Audits will be performed as a normal part of business control in order to determine: •

•

• •

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Whether or not HSEMS Elements and activities conform to planned arrangements, and are implemented effectively The effective functioning of the HSEMS in fulfilling HSE Policy, Objectives, Guidelines and Performance criteria Compliance with relevant legal requirements Identification of areas for improvement, leading to progressively better HSE management (HSEMS Gap Analysis)


For this purpose, the audit plan will include at least the following elements: •

Specific activities and areas to be audited. Audits should cover the operation of the HSEMS and the extent of its integration into the activities, and should specifically address the following elements of the HSEMS model: Organization, resources and documentation Evaluation and risk management Planning Implementation and monitoring Frequency of auditing specific activities/areas. Audits should be scheduled on the basis of the contribution or potential contribution of the activity concerned to HSE performance, and the results of previous audits Responsibilities for auditing specific activities/areas n n n n

•

•

Audit protocols and procedures will be established and maintained. At a minimum, the following points should be covered: • •

Allocation of resources to the auditing process Personnel requirements, and specifically that the audit team has Adequate independence from activities audited to enable objective and impartial judgement The necessary expertise in relevant disciplines Support, if necessary, from a wider range of specialists Methodologies for conducting and documenting the audits, which may involve the use of questionnaires, checklists, interviews, measurements and direct observations, depending on the nature of the function being audited Procedures for reporting audit findings in a controlled manner to those responsible for the activity/area audited, who should take timely action on reported corrective actions and opportunities for improvement (see section 6.6). Reporting should address: Conformity or nonconformity of the HSEMS elements with specified requirements Effectiveness of the implemented HSEMS in enabling objectives and performance criteria to be met Implementation and effectiveness of corrective actions from previous audits Conclusions and recommendations System for auditing and tracking implementation status of audit recommendations Distribution and control of audit reports n

n n

•

•

n

n

n n

• •

7.2.

Review: The company's senior management should, at appropriate intervals, review the HSEMS and its performance, to ensure its continuing suitability and effectiveness. The review should specifically, but not exclusively, address: The possible need for changes to the Policy and Objectives, in the light of changing circumstances and the commitment to strive for continual improvement • The success of the system in integrating HSE Guidelines, Procedures and Performance criteria into the line function • Resource allocation for HSEMS implementation and maintenance • Are operations and/or sites truly being evaluated on the basis of hazards, risks and emergency planning Reviews are used to reinforce continuous efforts to improve HSE performance. The review process must be documented, and its results recorded, to facilitate implementation of consequent changes. •

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SUPPLEMENTARY S1.

LEADERSHIP AND COMMITMENT:

11

The foundation of an HSEMS is leadership and commitment from the top management of the company, and its readiness to provide adequate resources for HSE matters. Particular attention is drawn to the importance of senior management providing a visible expression of commitment. Failure to do so will undermine the credibility of HSE Policy and Objectives. Demonstrations of commitment to the HSEMS at different management levels include, among others: • • •

• • • • •

Allocating the necessary resources, such as time and money, to HSE matters Setting a personal example in day-to-day work Putting HSE matters high on the agenda of meetings, from the General Manager of ADNOC downwards to the Directorate and Group Company managers to line managers and supervisors and to contractors Being actively involved in HSE activities and reviews, at both local and remote sites Communicating the importance of HSE considerations in business decisions Recognition of performance when objectives are achieved Encouragement of employees' suggestions for ways to improve HSE performance Participation in internal and external initiatives

Management leadership is also necessary to promote a company culture conducive to good HSE performance, in which the HSEMS can function effectively. Senior management can foster active involvement of employees and contractors in improving HSE performance by encouraging a culture of belief, motivation, individual responsibility, participation and commitment: •

•

•

•

72

Belief in management’s will to improve its HSE performance - essential to open and supportive incident reporting, and to effective HSEMS implementation Motivation to improve personal HSE performance - based on awareness, understanding, acceptance of individual responsibility and positive recognition to reinforce desirable attitudes and behaviours Participation of staff at all levels - through seeking their views and involvement in HSEMS development, and energetically pursuing suggestions for improvement Commitment of staff at all levels is essential if the HSEMS is to be fully effective, and should follow from secure belief, personal motivation and active participation


S2.

POLICY AND STRATEGIC OBJECTIVES: It is important that Policy be initiated, developed, actively supported and endorsed by management at the highest level, and be made available in readily understood form to employees, contractors, shareholders, partners, government agencies and the public. Health and Safety Policy may, for example, include commitments to: •

•

• • •

Establish safe and healthy procedures and practices in all operations, and strive towards an incident-free workplace Provide properly engineered facilities, plant and equipment and maintain them in a safe and secure condition Promote openness and participation in health and safety matters Provide training to enable staff to work in a healthy and safe way Undertake health and safety awareness and education campaigns

The environmental policy may, for example, state commitments to: •

• • • • •

•

Undertake all operations with proper regard for the environment, and strive to reduce environmental risk to a level that is ‘As Low As Reasonably Practicable’(ALARP) Reduce waste and the consumption of materials, fuel and energy Reduce, and avoid where practicable, emissions and discharges Provide staff training and awareness programs Participate in suitable environmental initiatives Reduce the hazards and adverse environmental effects of new developments to a level that is ‘As Low As Reasonably Practicable’(ALARP) Work towards the goal of environmentally sustainable economic development

The management should also recognize the: • • • •

S3.

Importance of effective organization to successful HSE management Importance of communication with interested parties Need, as in other areas of the business, for a systematic, planned approach to HSE Frequent role of management control failure in causing incidents

ORGANIZATION, RESOURCES AND DOCUMENTATION: S3.1. Organizational Structure and Responsibilities: The allocation of HSE responsibilities will depend upon the nature and structure of the individual company, some examples might be: •

•

•

Senior Management - assume responsibility for developing, resourcing, reviewing and complying with the HSE Policy Finance - develop and maintain accounting procedures which enable identification and allocation of HSE costs and benefits, assumes audit function, reviews operations for HSE plans and implementation All individual function, activity and operations/business unit Managers (e.g., Operations, Drilling, Production, Exploration, Process and Projects, Engineering, Marketing, Contracts, Procurement, Legal, Finance and Site Personnel) - implement the HSEMS in their areas of responsibility (in consultation with employees) and maintain effective two-way communication and training programs on HSE matters

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S3.2. Management Representative(s): Management HSE representatives need to have sufficient knowledge of the company and its activities, and of HSE issues, to undertake the role effectively. While maintaining overall responsibility for coordinating HSE management activities across all functions and groups, these representatives will act in conjunction with line management in all functions, activities and processes. Line management remains fully accountable for developing and implementing the HSEMS in its area of responsibility. HSE implementation may be divided among different managers. However, a single, responsible management HSE representative (a champion) should be identified by each company. If the champion has other functions to perform, care will need to be taken to ensure that there are no conflicts of interest with HSE responsibilities.

S3.3. Resources: Resource allocation should be considered as it applies to all parts of the HSEMS; issues to consider include, among others: • •

• •

Facilities, plant and equipment to meet legal requirements Personnel, equipment and infrastructure to respond to and mitigate emergency situations Availability of management for HSE audits and reviews Resource allocation for new developments

Depending on the particular circumstances the champion, management HSE representative(s) and other managers may need support from specialist HSE advisers to accomplish their tasks effectively. The allocation of necessary and justified resources for HSE matters is widely regarded by staff and other interested parties as indicative of corporate commitment to HSE Policy and Objectives.

S3.4. Competence: In addition to allocating responsibilities, management will need to determine the level of competence (based on personal abilities, skills, experience, formal qualification and training) necessary to ensure the capability of personnel to carry out HSE-critical functions. Activities and roles which affect the HSE performance should be included in job descriptions and performance appraisals. Structured and documented competence assurance systems and procedures help to facilitate the processes of: • • • • • • • •

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Determining the competence requirements of particular activities Defining and recording criteria for competence Assessing individuals against the defined criteria Documenting and certifying competence when necessary Identifying aspects where personnel are not yet judged competent Training individuals to increase competence in those areas Periodic re-assessing of competent personnel Assessing competence for job transfers and new activities and technologies


12

75


Training - including refresher courses - helps ensure that: • •

•

All personnel can make an appropriate contribution to good HSE performance New recruits, and staff assigned to new tasks, understand equipment and responsibilities for HSE matters Managers understand the HSEMS, have the necessary knowledge to play their part in it, and appreciate the criteria by which its effectiveness will be judged

S3.5. Contractors: Contractors and sub-contractors play a substantial role, often working within a facility and alongside our own work force. The activities in which they are engaged (e.g., construction and major maintenance) are typically non-routine and are in exposed situations. For those reasons, these HSEMS Guidelines have been purposefully designed to apply equally to the operations of a contractor or sub-contractor. Recorded safety statistics across our industry have generally indicated that contractors' employees are involved in incidents more frequently than are employees of the principal company. For this reason it is particularly important to consider how the HSEMS of a company is interfaced with that of its contractors and subcontractors. In this context, particular attention is drawn to: •

•

Establishing clear communication between company and contractor staff, at all levels Procedures for the management of change Permit to work systems Incident reporting and follow-up Emergency plans and their communication Audit and review Communication of hazards and individual risks, and roles in risk management n n

• • •

However, contracted activities will also need to be considered in other parts of the HSEMS.

S3.6. Communication: Effective communication requires careful consideration of the message to be transmitted - or the information to be sought - and of the most appropriate medium for doing so. Effective two-way communication on HSE issues, including awareness programs and campaigns directed towards specific HSE concerns, are important means of motivating staff towards a proper regard for HSE issues. The need to communicate in an appropriate language and style needs to be borne constantly in mind, particularly when transmitting technical information to nonspecialists. HSE - critical procedures and instructions (such as emergency evacuation instructions, and recovery measures in the event of oil spillage) need to be in a language and style that is understood by site staff. Cultural and language barriers to communication (such as those for personnel whose mother tongue is not the main site language) need to be identified. Communications must be tested regularly. [Note: in cases of extreme stress or shock most people revert to their mother tongue].

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Community awareness and consultation programs should be considered for populated areas and/or responding to legitimate government agency or community concerns about the HSE effects of facilities.

S3.7. Documentation and its Control: The primary purpose of the documentation is to provide an adequate description of the HSEMS, and to serve as a permanent reference to the implementation and maintenance of that system. Documentation may be in paper, electronic, or other format, but it is important to ensure consistency in approach and content, and in control, review and amendment of procedures. Proper documentation enhances HSE management efficiency through: • • • • •

Channelling information efficiently to where it is used and needed by staff Aiding awareness of responsibilities and correct task performance Avoiding information-dependency on individuals Reducing learning time on new tasks Demonstrating the existence of systems and practices

In determining the degree of detail of HSEMS documentation, consideration will also need to be given to its use by system auditors to verify that the system exists, and that it is fit for its purpose, given the nature of the hazards, risks and environmental effects involved.

S4.

EVALUATION AND RISK MANAGEMENT: S4.1. Identification of hazards and effects: Identification of HSE hazards and effects typically requires the application of specialised techniques and systems, such as hazard and operability studies (HAZOPS), event or fault tree analysis, Failure Mode and Effect Analysis (FMEA) or Environmental Impact Assessment (EIA). It also requires the involvement of staff with specific expertise in risk management, HSE issues, design and operations. HSE hazards and effects may also be identified using operational checklists and informal ‘hazard hunts’ at operating sites. The participation of operational employees in such activities is to be encouraged as a means of increasing their understanding of hazards, risks and effects. Hazard identification is conducted at an early stage in the design and development of new facilities, equipment and processes. This permits sound HSE practices, systems and equipment to be ‘designed-in’, and allows a wider choice of risk prevention, emission and exposure mitigation and recovery measures to be employed than with existing facilities. Continuous hazard identification is required at existing facilities to maintain and improve HSE performance.

S4.2. Evaluation: Evaluation of the risks posed by the identified hazards, however sophisticated the detailed techniques employed (e.g., HAZOPS and HAZAN, QRA, health risk assessment, EIA), requires consideration of both the severity of the consequences of a potential event and the probability of its occurrence: Risk = Probability of occurrence x Severity of consequences

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Risks of different events can then be compared and considered against screening criteria. Such criteria are most often a range of considerations or values and can take a variety of quantitative or qualitative forms. There may be considerable uncertainty attached to the estimate of the probability of an event; the severity of the consequences if the hazard is realised may be more readily and precisely definable. This ‘two-factor model’ can be used to evaluate evaluate the acute safety and/or environmental risks of a specific incident (e.g., blow-out or oil spill). The evaluation of chronic effects on the environment arising out of a company's operations, however, will need to take account of some ‘events’ which are regular or continuous, and intentional - such as the discharge of effluent or the operation of flares. For such effects: Risk = Severity of consequences = Exposure x Degree of harmfulness (e.g., toxicity, disturbance to habitat) Similarly, in health risk assessment the probability of some degree of exposure may be 100%; thus: Risk = Severity of consequences = Exposure x Degree of harmfulness (e.g., toxicity) Regulatory controls, health surveillance programs or epidemiological studies may indicate exposure to health hazards, chronic effects and the need for risk reduction measures. Harmful agents (agents capable of causing chronic and/or acute adverse health effects) include chemicals (e.g. hydrogen sulphide, hydrocarbon vapours, solvents, coating materials), biological agents (e.g. pathogenic organisms causing malaria and legionella) and physical agents (e.g. ionising radiation, cold and heat stress, dust, noise and vibration). Ergonomic factors (e.g., equipment design and cumulative effects of repetitive movements) relating to the manner in which tasks are performed will also need to be considered. The results of formal risk evaluation facilitate: •

•

• •

•

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Assessment of the feasibility of the proposed activity, based on compliance with the defined screening criteria Identification of the need for specific prevention, mitigation and/or recovery measures Identification of permitted operations (e.g., simultaneous operations) Identification of monitoring requirements (e.g., for emission and exposure monitoring) Prioritisation of opportunities for improvement


13

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Evaluation of HSE risks requires access to information on the probabilities of specific events and/or on the nature and severity of likely consequences; sources of such information include, for example: • • • • •

Internal knowledge and experience of managers and HSE experts Industry frequency and failure rate databases and co-operative research programs Relevant international, national and company standards and Codes of Practice Industry and trade association codes of practice and other guidance Continuous efforts aimed at identifying hazards and effects, and assessing and reducing the risks associated with them should be the norm

S4.3. Recording of hazards hazards and effects: Results of the evaluation need to be recorded, together with the data sources and assumptions used. This record is used by operations personnel to develop procedures and issue work instructions. Other key personnel will use this record to communicate the hazards that have been identified and the measures that are in place to prevent and mitigate the risks of occurrence. The hazards and health and and environmental effects documentation may be joint or separate documents. Inventories of routine emissions to air, water and land may be maintained to monitor and manage effects.

S4.4. Objectives and Performance criteria: The establishment and periodic revision by senior management of HSE objectives and performance criteria and the continual enhancement of the HSEMS underpins the commitment to improvement of HSE performance. Objective and performance criteria quantification, and association with specific timetables, is important to establish the credibility of company intentions. HSE objectives and performance criteria will need to take into account previous performance and to reflect any external changes of circumstances as well as any changes in the business itself. The detailed objectives and performance criteria within the strategic objectives of a company should be developed with the active participation of those who will be responsible for their achievement. Performance criteria describe the standards to which a particular activity or system element is to perform, and can apply at various levels within the HSEMS. For example, in addition to specifying acceptable levels of outputs or parameters (e.g., effluent quality, occupational exposure levels, lost-time incident frequency (LTIF), emission/discharge levels), such criteria may establish the nature and frequency of such tasks as: • • • • • • • •

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Plant maintenance HSEMS reviews and audits Assessment of training needs Hazard and effects identification and risk assessment Testing of emergency plans Testing emergency shut-down and blow-out prevention systems Testing fire detection, protection and alarm systems Process and emission monitoring


As the basis for control, monitoring and performance measurement, criteria need to be both readily measurable and clearly and unambiguously documented. As a minimum, performance criteria must satisfy any relevant regulations, Guidelines, Codes of Practice or Policy requirements. A hierarchy of HSE Goals is thus formed. These are formed from company strategic objectives (e.g. to minimize adverse HSE effects), through organizational and more detailed local objectives (e.g., to increase efficiency of energy usage by a stated amount) to specific performance criteria (e.g., to ensure emissions of hydrogen sulphide remain below stated levels).

S4.5. Risk Reduction Measures: Risk reduction measures can reduce HSE risks and effects in a number of ways, for example by: • •

•

Preventing acute and chronic incidents Reducing the exposure (concentration/duration) of people to harmful agents that are routinely present in the work area Reducing emissions/discharges to the environment

A variety of risk reduction measures may be employed, appropriate to the nature, probability and severity of the HSE risk or effect (e.g., chronic or acute effects, routine or non-routine operations). Prevention measures are designed to prevent the realisation of hazards. Such measures include specific hardware to control hazardous operations and to maintain asset integrity, such as: • • • •

Blow-out preventers Pressure release systems Personal protective equipment Security systems

It is important to realise that they also include organizational and system measures, such as: • • • • • • • • •

Intrinsically safer designs Quality assurance, maintenance and inspection procedures Safe working practices Permit to Work systems Plans that take account of human factors Clear and well-communicated work instructions Use of Material Safety Data Sheets (MSDS) Prophylactic medical treatments such as vaccination/immunisation Alcohol and drug-use programs

Measures are also required to mitigate or lessen adverse effects in the event that a prevention measure fails, and these measures are employed during abnormal or emergency situations. Such measures include, among others: • • • • •

Ignition control systems Blast walls Secondary tank containment Passive fire protection Gas/fire/smoke detection

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S5.

PLANNING: S5.1. General: As the means of achieving HSE policy and objectives, soundly-based improvement plans are key components of the HSEMS. Such plans require adequate resources and visible commitment from all management and personnel. Ideally, such plans will form an integral part of the overall business plans. HSE plans may require development for such activities as: • • • • • • • • • • •

Acquisitions New developments Existing operations Modifications to existing facilities Process turn around Decommissioning and Abandonment programs Geological surveys Seismic surveys Exploration or development programs Project design Ships and harbour facilities

The resourcing requirements and time scales also require definition to ensure that manpower is available and that necessary budget commitments can be made.

14

Consultation with authorities, International Standard Organizations, and other external bodies drafting laws, regulations and standards is recommended to ensure that planning takes account (so far as is possible) of future requirements.

S5.2. Asset Integrity: It is important that accepted Codes of Practice and standards for key equipment and related activities are followed. To help ensure the integrity of existing and planned facilities, careful attention needs to be paid to the completeness of the engineering process - with specific reference to the design, manufacture, installation, maintenance, testing and inspection of key equipment. In this context, key equipment refers to that identified in the evaluation process as being critical to the continued effectiveness of HSE controls. Particular emphasis needs to be placed on the design of new facilities, and hazard identification at an early stage allows the best risk reduction measures (those that prevent incidents through eliminating hazards at source) to be employed.

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Quality assurance measures during the fabrication of key equipment help ensure that materials and construction are in accordance with design specifications. Installation processes need to be managed and inspected to check that design specifications and manufacturers' instructions are followed. Attention to effective maintenance, testing and inspection systems helps ensure the continuing integrity of key equipment. All personnel who perform the activities described above, related to asset integrity, are HSE-critical staff and therefore require appropriate experience, qualifications and training to ensure their competence to undertake these important risk reduction measures.

S5.3. Procedures and Work Instructions: It is important to ensure that those who will be responsible for putting procedures and written instructions into effect are closely involved in their production. Clarity and simplicity of style and language are the characteristics to aim for, instructions must be consistent and provide accurate coverage of the activities which they address. Providing instruction on the conduct of work-site tasks can take many forms, depending on the complexity of the task, the competence of the people performing it, the inherent hazards and risks associated with it, and the effects that it might have on other aspects of the operation or facility. Thus, verbal instructions will need to be supported with, or replaced by, written work instructions wherever the absence of written material could prejudice HSE performance. Written work instructions will outline the work scope and reference any particular direction that is to be followed; similar considerations to those for system procedures apply to their development. Monitoring requirements and needs for personal protective equipment can be specified in the work instructions. For example, in a facility where hydrocarbons are produced, stored or processed, stringent controls are required and most work should be conducted under a ‘Permit to Work’ system. Within this, the work is defined, the precautions specified, other parties whose activities may be affected are notified and the permit signed off by all parties involved.

S5.4. Management of Change: Any changes in the personnel, equipment, processes and procedures and of the company have the potential for adverse effects on health, safety and the environment. All changes should be considered. These will include not only equipment changes but also organizational restructuring. Plans relating to changes need to address the HSE aspects arising at all stages of the development, to ensure that adverse risks to facilities, health and on the environment are minimized by effective planning and design. For the same reasons, plans relating to new installations or modifications to processes and plants need to cover all stages of the development from feasibility studies, through planning and design, to construction, commissioning, operations, maintenance and eventual decommissioning, abandonment and environmental restoration. Changes which may be HSE-critical should be reviewed prior to implementation, and any necessary amendments made to the HSEMS to ensure that their introduction does not prejudice sound HSE performance.

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S5.5. Contingency and Emergency Planning: Foreseeable emergencies for which planning needs to be undertaken may include: • • • • • • • • • • • •

Fire and explosion Failure of key controls, of power sources, or of services Structural Failures Work-site injuries Diving, marine, aviation and vehicle incidents Man overboard or missing person situations Spills and unplanned releases of product or other materials Loss of radioactive material Security breaches and sabotage Outbreaks of disease Civil disorder and military actions Geophysical and natural events

and other emergency events highlighted by hazards and effects identification. Emergency response measures include, among others: • • • • • • •

Emergency shut-down systems Fire-fighting devices Emergency evacuation procedures Rescue craft First-aid equipment and personnel Specialist medical treatment Oil-spill clean-up systems

An important point to note about recovery measures is that since they are only required to act in emergency situations - i.e. rarely - emphasis must be placed upon their reliability. This must be assessed through regular and thorough inspection, testing and scenario based exercises. [Account should be taken of the increased risk involved in carrying out drills and testing of emergency procedures]. The emergency plans must: • • • • • •

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Be clearly communicated Be well-rehearsed Coordinate internal and external emergency response teams Pay particular attention to external communication Include provision for the reporting and investigation of incidents Take account of the environmental effects of measures taken to manage escalating emergency situations (such as the effects of unconstrained fire-water run-off)


S6.

IMPLEMENTATION AND MONITORING: S6.1. Activities and Tasks: Previous sections have described the planning process, from the development of procedures covering broad areas of activity down to the level of issuing work-site instructions for the conduct of specific tasks. The effective, practical, implementation of these planned arrangements requires that procedures and instructions are followed at all levels. Company and contractor staff need to be familiar with relevant procedures and instructions before they start work.

S6.2. Monitoring: Monitoring provides the means of measuring performance against established requirements, including HSE objectives, targets and performance criteria. Thus, monitoring may include such activities as: •

•

•

• •

Regular monitoring of progress towards objectives and targets achieved by implementation of HSE plans Regular inspection of facilities, plant and equipment against specific performance criteria Systematic observation of the work and behaviour of first line supervisors to assess compliance with procedures and work instructions Regular analysis of discharges, emissions and waste disposal Health surveillance of staff, including exposure monitoring and medical surveillance

Monitoring facilitates control of HSE-critical activities and processes, and the detail and frequency of measurement need to reflect the nature and extent of the risks involved, and concentrate on the areas where it produces the most benefit. Thus ‘higher-risk’ facilities, plants, activities and tasks require monitoring in more detail and at a greater frequency.

S6.3. Records: Records are the evidence of the ongoing operation of the HSEMS. Care is to be taken to limit them to the extent necessary for the specific application, but they need to be kept in order and designed to enable assessment of compliance with policy and of the extent to which objectives are being achieved. Relevant records compiled under other parts of the overall management system need not be duplicated, but means of access to them is to be specified. In addition to legal requirements, and significant hazards and environmental effects, records should include: • • • • • • • • •

Reports of audits and reviews Situations of non-compliance with HSE policy, and of improvement actions Any incidents and follow-up actions Any complaints and follow-up actions Appropriate supplier and contractor information Inspection and maintenance reports Product identification and composition data Monitoring data Training records

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Records provide historic information on reported incidents and cases of noncompliance with the HSEMS, and can thus provide useful information on long-term trends. For example, analysis of records of medical treatments might show an increasing frequency of stomach complaints, suggesting a possible problem in the food handling area or potable water system. Similarly, analysis of records of oil in produced water might show a gradual increase over time, indicating a possible change in the fluids processed or a need for maintenance/modification of the treatment system.

S6.4. Non-compliance and Corrective Action: Incidents of non-compliance with specified requirements may be sudden and temporary, or they may persist for a long period. They may result from deficiencies or failures in the management systems itself, or in plant or equipment, or from human error. In the investigation of non-compliance the causative mechanism(s) should be fully established and reported, including factors within the management system. Such investigation will enable planning of corrective action, including measures for: • • • •

•

Restoring compliance as quickly as practicable Preventing recurrence Evaluating and mitigating any adverse HSE effects Ensuring satisfactory interaction with other components of the management system, such as quality management Assessing the effectiveness of the above measures

The implementation of the corrective action will not be deemed to have been completed until the effectiveness of all the above has been demonstrated and the appropriate changes made in the procedures, documentation and records. Where corrective action may involve the initiation of a project over a significant time scale, this will form part of the management plan.

S6.5. Incident Reporting: It is important that staff report all incidents and near misses so that lessons can be learned and the HSEMS improved. This requires an open approach to communication and a ‘blame-free’ approach to reporting and follow-up. The key data which reporting systems acquire include, as appropriate: • • • • • • •

Details of any injuries, occupational illness or adverse environmental effects Details of involved and/or injured person(s) A description of the circumstances Details of the event Details of the outcomes Potential consequences The contribution made to the incident by any failures of the HSEMS

Generally, reporting of incidents resulting in injury or property damage is prompt and comprehensive. However, incidents which do not result in injury or property damage (so-called ‘near-misses’) are more frequent and their causes may have the potential to bring about a major incident under slightly different circumstances. Such near-misses - and the valuable information they encapsulate - often go unreported, either because their potential significance is not realised or because staff are discouraged from

86


reporting them by, for example, the fear of blame or the complexity of the reporting system.

S6.6. Incident follow-up: All incidents, including higher-potential near-misses, require appropriate investigation in order to: • •

•

Provide a factual record of the circumstances of the incident Establish their root cause and identify actions to minimize the chance of recurrence Allow sharing of information across companies

The investigation process comprises the following basic steps: • •

•

• •

Notification, initial assessment and incident report Decision on the need for further investigation, and appointment of investigation team The investigation itself, comprising review of the incident site and circumstances, interview of witnesses, and analysis of operating conditions, data and other evidence Preparation of investigation report and agreement of remedial actions (if any) Issue of report and plan of action for follow-up

The first step following the report of the initial assessment of an incident is to decide the appropriate level of investigation. This will depend on the seriousness of the incident and its actual or potential consequences. The significance of the actual consequences should be clear, but that of the potential consequences may not. The potential significance of an incident can be established by asking ‘what if’ questions. The size and composition of the investigating team will depend on the particular incident. It is important that the team members are properly trained to carry out the task objectively, impartially and effectively. [It should be noted that the investigation may be conducted in parallel to an external investigation by the authorities]. The primary function of an investigation is to identify the likely cause(s) of an incident and identify appropriate remedial actions. Thus the team will need to have the support and authority of company management to obtain the necessary information, and to secure agreement for any remedial action identified. Progress in implementing remedial actions will need to be monitored and will not be deemed completed until effectiveness has been demonstrated. Where action may involve the instigation of a project over a significant time-scale, this must be integrated into the HSE plan.

S7.

AUDIT AND REVIEW: S7.1. Audit: Audits may be internal (carried out by personnel from within the company, but independent of the part being audited) or external (carried out using resources selected by the company). In either case the persons conducting the audit will require training to carry out the task objectively, impartially and effectively. The company should identify and make arrangements for independent, external verification of audits where required.

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The audit team will require broad knowledge of HSE matters and experience in auditing practices and disciplines; specialist HSE or other technical expertise may also be necessary. Audit teams require personnel with operational experience in the area being audited, or access to such personnel. To ensure audit effectiveness, the company will need to ensure that audit personnel have the support and authority to procure the necessary information. Audits may suggest remedial measures to overcome problems, or they may simply note the nature of the problems and require the management of the audited function to devise and implement an appropriate solution. In either case, the recommendations should be agreed and followed-up in the next audit cycle, to ensure that necessary improvements have been made. The audit report will be submitted to line management of the activity/area being audited and to company management for distribution and action as appropriate. The final audit report will be submitted to the ADNOC Group HSE Committee. The company will have a certain time (usually 30 days) to review the audit findings and propose solutions (a corrective action plan). The corrective action plan will be submitted to the ADNOC Group HSE Committee for approval. This assures high level review and sharing of problems and solutions across all Group Companies and Directorates. In addition to having an independent audit procedure, companies will find it beneficial to encourage line management to carry out similar self-assessment procedures.

S7.2. Review: The scope of reviews includes the company and its activities, products and services with a focus on HSEMS and HSE-critical activities. Thus, for example, a review of the HSEMS elements for designing a new facility would examine the extent to which the HSE objectives for the project required revision. It will judge whether or not resource allocation to the project was satisfactory in relation to HSE matters, and it will determine the extent to which any audit recommendations had been successfully implemented. Reviews are to be carried out by appropriate members of, or competent independent personnel appointed by, the company's senior management. Issues to be addressed as part of the process will typically include: •

•

Any recommendations which have been made in audit reports, and whether or not these have been implemented The continuing suitability of HSE Policy, and possible revision to address, for example: Emerging/growing HSE concerns in specific areas Developing understanding of HSE issues Potential regulatory developments Concerns of employees, contractors, customers, government agencies and the public Market pressures Changing company activities and locations Changes in the sensitivity of the environment n n n n

n n n

•

88

The continuing suitability of, and possible revisions to, HSE objectives, and consequent amendments to the HSE plan and other HSEMS Elements and documentation


•

•

Reports of reviews need to make clear why they were conducted (e.g., routine procedure, organizational changes, developments in understanding of HSE issues, changes in environmental sensitivity, regulatory developments, reported deficiencies in HSEMS, etc.) Reviews should be used to reinforce the continuous efforts to improve HSE performance

S7.3. Levels of Audit: Audits as stated in S7.1 cover a wide range of HSE activities. Audits may be thought of as line self-assessments, HSE audits directed by the ADNOC Group HSE Committee and Management audits directed by ADNOC Internal Auditors. Line audits are self assessments performed by line management to ensure proper HSE procedures are in place and functioning satisfactorily. ADNOC Group HSE Committee directed audits will usually involve an overall review of a facility or operation for compliance with legal requirements and policies. This group will also assess the suitability of plans and procedures to achieve stated objectives and goals. Deficiencies will be reported as a “Gap Analysis” of the HSEMS along with non-compliance situations. Internal Auditors in their HSEMS function will review the HSEMS to ensure it meets ADNOC Policies and Guidelines and that proper management attention and resources were being dedicated. They will also look for resolution of previous line and ADNOC Group HSE Committee audit findings. This approach provides overall assurance that the HSEMS addresses Policy, Objectives, Goals and Procedures.

15

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Audit Program

III B.

AUDIT PROGRAM

91

Audit Program

III.b.

AUDIT PROGRAM

INTRODUCTION: ADNOC Policy emphasises the importance of conducting operations in a responsible, healthful, safe, and environmentally sound manner through full compliance with all applicable HSE laws, regulations, Codes of Practice and Guidelines. The Audit Program, is intended to provide an objective and independent assessment of the compliance status of selected functions, and facilities, and the effectiveness of compliance programs, organizations, and staff within companies. It is a quality assurance program conducted on behalf of ADNOC and company management. Its prime objective is the assurance that HSE compliance programs and results are consistent as well as cost effective and in accordance with ADNOC Policy. HSE audit program benefits include: An ongoing mechanism for evaluating, improving, and reporting the level of compliance within • the Directorates, Group Companies and contractors • A set of minimum performance standards for compliance as defined in audit checklists • Capture and transfer of creative and cost efficient HSE ideas from companies Training of auditees and auditors in the audit process and in compliance requirements • • Providing a program to ensure HSEMS is functioning properly and is modified as needed to enhance business needs Providing ADNOC Management through the ADNOC Group HSE Committee assurance of • compliance • Integral part of the HSEMS that ensures continuous improvement of HSE performance Ensuring identified Gaps in the HSEMS are documented and resolved •

1.

AUDIT PROGRAM OVERVIEW: 1.1.

Program Responsibility: At the ADNOC level, the ADNOC Group HSE Committee, is responsible for implementing and maintaining the ADNOC HSE Audit Program.

1.2.

Program Objectives: HSE Audit Program objectives include: •

•

•

•

1.3.

Providing oversight to Directorate or Group Company compliance management programs Providing feedback to ADNOC management through the ADNOC Group HSE Committee on the effectiveness of HSEMS programs Assisting Directorate and Group Companies to maintain compliance levels of their operations within legal requirements and ADNOC standards Training operating and HSE staffs in auditing techniques

Program Scope: The HSE Audit Program assesses compliance of sites with applicable laws and regulations, Guidelines and Codes of Practice, including but not limited to: • •

Employee exposure Product Stewardship

93


• • • • • • •

•

• • • •

• •

• • •

Air pollution control Surface water pollution control Spill prevention and control Solid/hazardous waste management Storage tanks Soil contamination Groundwater protection and remediation Hazardous material transportation, storage and handling Land use Pipeline safety Process Safety Management Toxic/hazardous material release reporting Management of Change Process, facility, employee and public safety Industrial hygiene Oil, gas and drilling operations Port and shipping safety

The audits also assess HSEMS, including: • • • • •

Policies, programs and procedures Contingency or emergency action plans Communication (internal and external) Organization and staffing Root cause evaluation.

Checklists will be prepared and maintained as applicable by ADNOC, the Directorates or Group Companies. The development of an HSE Audit Manual complete with checklists and based on this guidance document, will be coordinated by the ADNOC Group HSE Committee appointed Audit Manager.

1.4.

Program Elements: The HSE Audit Program consists of the following major elements. summarised here and discussed in detail in the rest of this manual.

94

These are

•

Prioritisation and Selection of Sites A representative sample of unit locations will be selected each year based on factors such as risk, type of operation and breadth of coverage of assets. At a minimum, major facilities will be audited once every three years. Once the sites have been selected, an audit schedule will be developed. (The definition of a major facility may change over time and should be documented in the HSE Audit Manual.)

•

Pre-Site Visit Activities Activities that will be completed prior to the on-site visit include audit team selection and training, preparing or revising checklists, and gathering preliminary information on the site.

Audit Program

17

95


1.5.

•

The On-Site Audit The audit will be conducted using the protocol defined by this guidance document, consisting of a mix of observation, inquiry and verification testing.

•

Post-Site Visit Activities A report will be prepared to document the audit findings and recommendations and assist the site in timely resolution of those findings. A corrective action plan will be prepared to address each finding and recommendation. Progress toward completion of the plan will be monitored to ensure appropriate priority is given to correction of the findings.

•

Quality Assurance Procedures Periodic reports will be made to management. These will include summaries of audit results, status of corrective action implementation and trends derived from analysis of results. Internal audit will review these corrective action plans and implementation during regular business audits.

Program Participants: Responsibilities for the HSE Audit Program elements are noted below.

1.5.1. ADNOC Group HSE Committee: Is responsible for: • • •

• • • • • • •

Appointing an ADNOC HSE Audit Manager Approving HSE Audit Team Leaders Ensuring annual updating, approval and distribution of this audit document Ensuring compliance with ADNOC Policy on HSE audits Providing ADNOC management with special reports as appropriate Approval of annual ADNOC audit schedule and sites to be audited Assurance of qualified audit teams Approving audit reports and corrective action plan for each audit Providing ADNOC management with annual summary reports Providing other audit guidance and support as appropriate

1.5.2. ADNOC HSE Audit Manager: Will functionally report to ADNOC E&S Division and is responsible for: • • •

• • • •

• • •

•

96

Selecting HSE Audit Team Leaders and auditors Updating biennially this HSEMS Guidance document Securing concurrence for update revision from ADNOC Group HSE Committee Development coordination of an HSE Audit Manual and Audit Checklists Ensuring the audit teams have appropriate tools, such as current checklists Developing annual audit plan, schedule and selection of sites Ensuring preparation and completion of a corrective action plan after each audit Ensuring consistency in the audit process Preparing summary, annual and special reports on the audit programs Reviewing and monitoring Directorate and Group Company HSE auditing programs and providing technical support, training, and feedback to them and ADNOC management regarding program effectiveness Other duties as assigned in relation to HSEMS quality assurance

Audit Program

1.5.3. Audit Team: Audit teams may be staffed and/or led by ADNOC, Group Company staff or consultants. All Audit Team members shall be subject to the HSE Audit Manager's and/or Audit Team Leader's direction and control. The Audit Team Leader and team members have duties as outlined below. Audit Team Leader

•

Is responsible for: Completing pre-site visit activities Conducting the audit Writing audit reports

n

n n

•

Site Managers and HSE Staff These individuals responsible for: n n n n

1.6.

18

are

Completing the pre-audit questionnaire Assisting the audit team in the on-site review Preparing a corrective action plan Implementing the plan

DOCUMENT RETENTION PROCEDURE: The Audit Manager or Audit Team Leader will maintain a secured filing system for all audit documents. Documents and information will be retained and subsequently destroyed according to the schedule below. DOCUMENT

RETENTION TIME

Pre-audit Information

Retain and update for each audit

Working Papers

Six months after final report issued

Exit Briefing Notes

Until final report is issued

Draft Reports

Until final report is issued

Comments on Draft Reports

Until action plan is approved

Final Report and Checklists

Until next audit or seven years

General Correspondence

Until next audit or seven years

Summary of Findings, Completed

Ten years (minimum)

Corrective Action Plans

Ten years (minimum)

Closing Memos

Ten years (minimum)

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2.

PRIORITISATION AND SELECTION OF SITES: Selection of sites to be audited each year will be based on the following criteria: • • •

A site or facility in each Group Company will be audited at least once every three years Each Process Directorate site will be audited at least once every three years Projects Directorate sites will be audited as appropriate

Selection of specific sites meeting the above criteria will also include consideration of: •

•

•

•

Non oil and gas producing, processing or refining sites or activities (ports, housing complexes, drilling locations, seismic operations, etc.) as appropriate to provide broad coverage of operations Risk of the operation, based on proximity to natural resources, communities, sensitive areas etc., type of operation (plant, presence of H 2S, etc.), HAZOP risk assessment, and other available information A mix of different types of facilities (i.e., oil, gas, gas plants, refineries, chemical plants, ports, old, new, etc.) Input from management, which sites they want included in the audit program

Each year, the HSE Audit Manager will propose to the ADNOC Group HSE Committee an audit plan and schedule. Upon approval the audit plan and schedule will be forwarded to ADNOC Management.

3.

PRE-SITE VISIT ACTIVITIES: 3.1.

Audit Team Selection: Audit team members will be chosen by the ADNOC Audit Manager and/or Audit Team Leader from Directorate, Group Company and ADNOC HSE, technical and operations staffs and from consultants. The size and composition of a given team will depend upon the size of the site or operation and the complexity and magnitude of the HSE requirements. Size of the team and duration of the on-site visit will generally vary from three to ten persons working on-site for three to five days. Size and duration for Projects Directorate operations will depend on the audit scope. The audit team as a whole should have knowledge of HSE legal requirements, Guidelines and Codes of Practice that matches the audit scope and an understanding of the operations to be reviewed. Team members should also be far enough removed from management of the audited site to be objective in their work.

3.2.

Team Leader Responsibilities: The Audit Team Leader will have the following responsibilities: • •

• • • • • •

98

Review of audited function or facility to identify audit team member qualifications Recruit audit team members and gain approval from Audit Team Manager and, as appropriate, ADNOC Group HSE Committee Review Audit Manual and Audit Checklists to determine applicability to site Prepare pre-audit questionnaire Determine any special safety training required for the site Contacting and orienting team members Contacting and orienting site management Co-ordinating the on-site audit, including logistics

Audit Program

•

•

3.3.

Developing the audit report, submitting it to the Audit Manager within the prescribed time and maintaining its confidentiality and applicable privilege Working with site management, as requested, to develop the corrective action plan.

Team Member Responsibilities: Each member of the audit team should be thoroughly familiar with individual and team responsibilities for the conduct of the audit. They should: • •

Familiarise themselves with relevant background on the site prior to the audit Understand audit team operating procedures, including: How to conduct the site walk-around, interviews and verification What items are to be documented Procedures to follow for potential incidents requiring immediate attention Gain any required special safety training prior to site visit Conduct the audit in a confidential, tactful, efficient and impartial manner Complete all items on the audit agenda Document each finding in a manner that would allow an auditor of similar skill level to confirm the conclusion without consulting other resources Submit their portion of the audit report to the Team Leader within the prescribed time Turn in all audit checklists, notes and findings to the Audit Manager or Team Leader at the conclusion of the on-site visit Submit all working papers to the Audit Team Leader at time of exit from site n n n

• • • •

•

•

•

3.4.

Team Training: Specialised training may be required for team members to ensure understanding of their charge from management and consistency in application of audit procedures and guidelines. This training will emphasise the mechanics of how to perform the audit in an effective, confidential, impartial, non-personal, and timely manner and in accordance with audit checklists, as opposed to the technical skills and knowledge which are considered when selecting team members. The HSE Audit Manager is responsible for this training.

3.5.

Site Notification: The team leader will notify the appropriate line and HSE supervisors of the audit at least four weeks prior to the on-site visit. They should discuss: • • • • • • • •

3.6.

Dates and anticipated length of the on-site portion of the audit Names of team members Logistics support required by the team (including pre-audit visit, if appropriate) Agenda Data to be collected at and to be made available by the site Site support required Procedures for responding to the pre-audit questionnaire (if one is used) Any special items to be considered

The Pre-Audit Questionnaire: A pre-audit questionnaire may be used to help the audit team focus their questions and optimise their time on-site and to familiarise site personnel with the information to be reviewed by the audit team. For small sites where little site staff co-ordination is necessary, at the discretion of the Audit Manager, the questionnaire may be shortened or eliminated. The Audit Team

99


Leader is responsible for development of the pre-audit questionnaire and for ensuring that the site has sufficient time to complete the questionnaire and return it prior to the audit. It should be sent to the site at least 4-6 weeks prior to the on-site visit. Several basic topics should be covered in the questionnaire, including: •

Site operations Current or planned operations Pollution control procedures Unusual features Special training or requirements required for auditors before entry to site Locations of HSE files Permits held and any restrictions on permits Emissions or discharges to air, water and ground Hazardous and Toxic materials Emergency Action Plan Presence of underground storage tanks, PCBs or asbestos Presence and history of pipelines, including maintenance, corrosion and replacement Presence of threatened or endangered species or sensitive areas Unusual safety issues Waste inventory and management procedures, including active and inactive disposal sites (on-site and off-site) Topographical map and/or facility/process drawings showing Location of fields or plant structures, facilities, buildings, etc. Nearby water bodies, wetlands, and oases or other environmentally sensitive features All drinking water and water supply wells on the property and in the vicinity Sewage treatment facilities, septic tanks or drain fields Compliance reports, schedules, incidents of non-compliance, or corrective action plans related to HSE audits List of regulated substances used at the site and any reportable releases Copies of Site Self Assessments n n n n

• • • • • • •

• • •

•

n n

n n

•

• •

3.7.

Data Review: The audit team should review pertinent laws, regulations, Guidelines and Codes of Practices, responses to the pre-audit questionnaire, this manual, and the results of previous audits at the site. This will help identify potentially significant issues. The team should also become familiar with site operations through discussions with appropriate personnel and study of available files.

3.8.

Checklist Update: Each audit will employ written checklists which establish standards for the issues to be reviewed and the level of detail for each issue. These checklists developed for item 1.5.2 above should be reviewed, updated, and revised as necessary prior to an audit. Checklists for Projects Directorate operations may need to be developed by the Audit Manager based on the

100

19

Audit Program

location and scope of each audit. The checklists will be completed during the on-site phase of the audit and become the basis for the audit report.

3.9.

Audit Team Meeting: The audit team will meet prior to the on-site visit to discuss the background data received and to identify key areas to be highlighted during the site visit. The team leader should also review the on-site visit protocol, suggestions to follow in reporting of findings including whom to notify and what to write, team assignments, and visit logistics.

4.

THE ON-SITE AUDIT: This phase of the audit will consist of an appropriate mix of observation, inquiry and verification testing. Inquiry, or questioning, is the most frequently used means of collecting audit evidence. Observation, or physical examination, is one of the most reliable sources of audit evidence. Testing refers to the wide variety of verification or data sampling activities employed to increase confidence in the audit evidence and the site's internal controls. Major elements in this process are detailed below. These elements will be modified as appropriate for audits of Project Directorates sites, drilling operations and seismic operations.

4.1.

Entrance Briefing And Tour: The team's first step after arrival at the site is to meet with the site manager, HSE specialists, and other key staff. The purpose of this meeting is to further familiarise the audit team with the operation of the site and acquaint site personnel with the auditors and the auditing process. During the meeting, which is chaired by the Audit Team Leader, the following items are generally discussed: •

Overview of the audit concept Describe the reasons for the audit, the areas of focus, the procedures to be used in conducting the audit, the areas of responsibility of each team member, the audit schedule, any potential legal implications, and the reports to management.

•

Overview of site operations The site manager should present a brief description of the site activities and organization, including materials used and produced, on-site operations, off-site operations (e.g., waste management, drilling, etc.) and an overview of HSE responsibilities.

•

Discussion of preliminary concerns The team should raise any major HSE concerns that were noted in the pre-audit phase. Site personnel should note any HSE concerns they have that were not highlighted in the pre-audit questionnaire. These areas will be addressed further during the audit to assess their importance and the need for action, if any.

•

General General matters, such as communications, training, and public relations programs, should be briefly discussed with site management to determine how they interface with the HSEMS programs.

The briefing will generally be followed by a guided familiarisation tour of the site.

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4.2.

File And Data Review: The next step in the on-site audit is reviewing the site files. The review of files and data will include: • • •

HSEMS Policies, Guidelines, programs, procedures and activities Record keeping and reporting Permits and/or operating restrictions/agreements

The review should identify whether: • • • • •

4.3.

The site has prepared and maintained the necessary documents The documents contain all necessary information The documents have been prepared on time The documents have been distributed to all necessary parties Document information is consistent by a cross-check of information recorded on more than one document

Site Inspection: Each auditor will tour his assigned portion of the site to observe and evaluate general operating practices. This phase of the audit should focus on whether: •

•

•

The site is operated consistent with applicable HSE requirements and sound practices There is sufficient communication and coordination between site operations, HSE, engineering, and management personnel The operators are trained sufficiently in safety practices, pollution control, and HSE emergency response techniques

During the site review tour by an auditor, he should be accompanied by a site staff member capable of explaining HSE issues and site operations. Any areas of potential impact or specific questions should be noted and discussed. Team members must comply with all site employee safety requirements during the audit. If special training is required for site safety this should be arranged in advance of the site inspection.

4.4.

Interviews: The audit team will conduct interviews with individual site personnel to develop an understanding of site operations and HSE programs, and to focus on details of any previously identified areas of concern.

4.5.

Management Systems Review: The audit team will develop an understanding of the site's internal control system for HSEMS. Internal control refers to the actions taken within an organization to help regulate and direct its activities. The HSEMS must be reviewed for the following: •

•

• •

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Policies - information, directives, guidelines and standards concerning operations and performance Procedures - instructions intended to ensure that operations are carried out as planned Practices - ways that people typically and routinely carry out operations Controls - checks and balances built into site operations that have an impact on continuous HSE performance improvement

Audit Program

This review will assess the policies, procedures, practices and controls to determine whether the necessary HSE systems exist to maintain compliance and verify that these operating procedures are being followed and documented. It will also assess historical performance to determine if relevant legal requirements have been addressed. It will note “Gaps” in the HSEMS.

4.6.

Evaluation: Audit team members will be in frequent contact with site staff during the audit and will therefore, discuss potential findings throughout the audit. Before results are formally presented, however, the team will meet to review all potential findings. During these sessions the team will develop consensus on the audit findings and on the strong and weak points of the site compliance programs. These sessions, which are normally held at the end of each workday, will be open to site personnel. The team will also analyse the findings and make recommendations where appropriate to address the underlying or root causes. This process may continue into the report writing phase of the audit.

4.7.

Exit Briefing: The team's conclusions will be drafted into a report which will be used to brief the site manager and staff. It may be written or verbal. A typical exit briefing agenda will include: • • •

Program strengths and weaknesses Items needing attention, recommended solutions and priorities Issues whose compliance status could not be fully determined

The purpose of the exit briefing is to communicate the team's findings and allow site staff to provide information not uncovered by the audit team. There will be "no surprises" after the exit briefing. That is, if an issue is not presented at the briefing it should not appear in subsequent reports or correspondence on that audit, unless the site staff is first informed of the concern. ALL INCIDENTS OF SERIOUS, POTENTIAL NONCOMPLIANCE SHALL BE DISCUSSED WITH SITE STAFF UPON DISCOVERY SO THAT THEY CAN TAKE IMMEDIATE ACTION.

5.

POST-SITE VISIT ACTIVITIES: 5.1.

Report Preparation And Distribution: The Audit Team Leader will compile the audit team's notes into a draft report presenting the findings and recommendations. The report will also include the following: •

•

•

Recommendations for improvement to the site HSEMS, programs, and procedures, based on analysis of root causes of the findings A recommendation for resolving each finding (the site is responsible for determining if these are the most cost effective solutions), where the solution is not obvious Guidance on priority for corrective action for each finding. The highest priority should be given to issues posing significant risk to human health or the environment and to those that represent significant potential legal liabilities

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Reports will be concise, accurate summaries of the team's observations and findings. The purposes of the reporting process are to identify concerns and to furnish the information to those who can most effectively correct the concerns. The draft report will be sent to the Audit Manager, and designated management and site personnel. The purpose of this review is to ensure that the report is factually correct. The Audit Manager will ensure consolidation of comments on the draft report and send them to the Audit Team Leader, who will prepare the final report. The final report will be sent to the Audit Manager, who will distribute it as follows: • •

5.2.

Site operations and HSE Supervisors - full report Directorate or Group Company Manager and ADNOC Group HSE Committee Executive Summary and List of Findings

Corrective Action Plan Preparation: Site management is responsible for preparing the corrective action plan. The plan should address each concern noted during the audit. It should be completed within thirty days of issuance of the final audit report. The Audit Team Leader is responsible for assisting the site as requested. The plan should include: •

• •

5.3.

The proposed actions to correct the concerns in sufficient detail so that all steps are clearly understood Assignment of responsibility for each step to specific personnel or groups The estimated completion date for each step

Corrective Action Plan Implementation: Once the corrective action plan has been prepared the Audit Manager will review the plan to determine if: • • •

It is an acceptable corrective action The scheduled completion date is reasonable Appropriate management and staff are assigned responsibility and accountability for completion of the action

Following determination by the Audit Manager that the plan is completed and acceptable, he will present it to the ADNOC Group HSE Committee for final approval. Following ADNOC Group HSE Committee actions, the Audit Manager will notify line management either that the plan is approved or that further analysis is required. Distribution of the approved corrective action plan will be as follows • • •

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Site management and HSE staff - full report Directorate or Group Company HSE Manager - full report Directorate or Group Company Management - Executive Summary

Audit Program

Once the plan is approved, the site will periodically report to the Audit Manager the status of each corrective action. If a scheduled completion date is missed, the Audit Manager will request an explanation and a new completion date from the site and will, if appropriate, notify company management and the ADNOC Group HSE Committee. This process will be repeated if the scheduled completion date is again not met. The intent of this procedure is to ensure timely completion of the corrective actions. The Audit Manager will confirm completion of all corrective actions by issuing an audit closing memo approved by the ADNOC Group HSE Committee. The memo will be distributed as follows: • • •

5.4.

Site management and HSE staff Directorate or Group Company HSE Manager Directorate or Group Company Management

Follow-up Reviews: ADNOC Internal Auditors, E&S Division Manager and the Audit Manager will conduct follow-up reviews of Corrective Action Plan implementation for up to 25% of the audits conducted each year. The reviews will be held approximately one year after the on-site visit. They will generally consist of an on-site meeting with appropriate personnel, a review of documentation and a brief site tour to review the actions taken to correct audit findings. The Internal Auditor will provide feedback to management on appropriateness, and effectiveness of the Corrective Action Plan. The Internal Auditor will use the results of this review to make recommendations to the Audit Manager for improving the audit and audit follow-up process and procedures.

6.

QUALITY ASSURANCE PROCEDURES: 6.1.

Annual Report: The Audit Manager will prepare and submit to the ADNOC Group HSE Committee a formal, annual audit program summary. As a minimum, this report will contain: • • • • • • •

6.2.

Number of audits conducted by type of facility A discussion of corrective actions not yet completed Discussion of improvements in compliance programs as a result of the audits Overall appraisal of audit program effectiveness Overall appraisal of ADNOC Directorate and Group Company compliance status Estimated costs of the audit program for the past year Recommendations for improvement of the audit program

Management Reporting: The Audit Manager will provide quarterly status reports to ADNOC Group HSE Committee. These reports will cover, as a minimum: • • • •

Progress toward closing audits Major findings Progress toward completion of Corrective Action Plans Identified root causes that need action at the applicable management level

Verbal briefings may also be periodically provided to management as requested.

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6.3.

Networking Of Findings And Solutions: The Audit Manager will provide periodic reports to Directorate or Group Company HSE groups on overall audit findings and systemic problems, and innovative solutions developed by the audited sites.

6.4.

Upgrading Audit Program: The Audit Manager will use competitor and internal surveys to improve the Audit Program each year. The Audit Manager will also have the audit checklists updated and improved through annual review by appropriate technical staff.

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III C.

AUDIT CHECKLIST

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108

Audit Checklist

III.c.

AUDIT CHECKLIST

INTRODUCTION: The following is a tool for the Audit Team Leader who should ensure its applicability to the audit to be undertaken. It is the Audit Team Leader who is responsible for completion of the checklist. Its completion will require significant interaction with the other audit team members, and interviews with key management and staff personnel associated with the facility. This suggested management systems checklist is used to form a basis for analysing the following components at the facility: • • • • • • • • • • • • •

Leadership (Section 1) Personnel (Section 2) Project Management (Section 3) Operations Integrity (Section 4) Contractors and Suppliers (Section 5) Management of Change (Section 6) Environmental Protection (Section 7) Incident Management (Section 8) Emergency Preparedness (Section 9) Legal Requirements and Standards (Section 10) Continuous Improvement (Section 11) Field Review and Visual Inspection (Section 12) Site Profile (Section 13)

This checklist in one of the tools for the audit process. Please go through each checklist item in detail. Enter additional written comments on the audit worksheet for any items noted as exceptions to legal or ADNOC Policy, Guidelines or Codes of Practice. The notes on the audit worksheet should be referenced to the checklist by item and page number. Also include on the audit worksheet notes on areas where the facility is doing an exceptional job on programs and / or systems. Items that are to be documented by photograph or drawing should be noted on the site plan and referenced to the checklist by item and page number.

1.

LEADERSHIP: 1.1. 1.2. 1.3. 1.4. 1.5. 1.6. 1.7. 1.8. 1.9.

How are HSE policies communicated to employees and contractors? Are roles and responsibilities for HSE related issues clearly defined and assigned? How is active leadership and commitment to the HSEMS plan demonstrated? How do leaders and supervisors achieve active involvement of the workforce in applying Continuous Improvement techniques to HSE and to the HSEMS plan? Are mechanisms in place to involve employees in hazard studies and process safety management initiatives? Is HSE performance included as part of overall individual and team performance targets, measures and evaluations? Are mechanisms in place to pro-actively identify, understand, consider and respond to employee, community and government agency concerns about company operations? Do supervisors understand the nature of the HSE risks at their facility? (Knowledge of legal and physical setting) Is ownership for HSE activities at the facility level evident?

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2.

PERSONNEL: 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. 2.10. 2.11. 2.12.

3.

PROJECT MANAGEMENT: 3.1. 3.2. 3.3. 3.4. 3.5. 3.6. 3.7. 3.8. 3.9. 3.10. 3.11.

4.

Are mechanisms in place to provide systematic identification and review of significant HSE hazards? Do new projects or process changes undergo an HSE review early in the planning stages? (HAZOP) Is a mechanism in place to ensure qualified HSE specialists are consulted when complex assessment or risk analysis studies are required? Are decisions regarding the adequacy of risk reduction measures made by appropriate personnel? Does documentation of the HSE hazard and exposure identification process include all major issues considered, not only those resulting in findings or recommendation? Are records of decisions and actions taken as a result of HSE risk analysis studies kept and do they form part of the project and/or equipment records? Are proposals reviewed for technical integrity, hazard identification, compliance with applicable legal requirements and economic feasibility by appropriate personnel? Does a mechanism exist to ensure that concurrence with ADNOC Codes of Practice, Guidelines or permits is part of pre-job planning? Are pre-start-up HSE reviews performed for new and significantly modified surface equipment, facilities and processes? Does final documentation of design information, equipment specification, P&ID's, hazard analyses, etc. represent as-built conditions? Are deviations from original designs and procedures fully documented? Prior to establishing or re-establishing production from a drill well, work-over or just returning an existing well to production, is a review conducted to ensure a safe operation and to minimize environmental impact?

OPERATIONS INTEGRITY: 4.1. 4.2. 4.3.

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For critical jobs, does selection and placement criteria include required skills, knowledge and training? Are orientations conducted and documented for new personnel and personnel entering new positions? Are criteria for HSE related training established according to employee assignment, experience, certification and regulatory requirements? Review documentation. Are sufficient numbers of employees in each area trained in hazard identification and risk assessment? Are replacements adequately trained before fully assuming critical positions? Are records of required training retained/maintained in accordance with clear guidelines? Are potentially significant health exposures identified and addressed? Are quantitative assessments provided where health exposures are likely to approach established limits? Are health exposure assessment results reported, documented and retained for an appropriate period of time? Are results of exposure assessments communicated to affected HSE personnel? Is a hazard communication system applied where appropriate? Are mechanisms in place to assure proper monitoring and/or use of Personal Protective Equipment?

Is a mechanism in place to ensure operating procedures are maintained, communicated and made accessible to applicable personnel? Where appropriate, are production, plant, shipping, transport, pipeline, operations, maintenance, and emergency action plan manuals established and maintained? Are operating procedures updated whenever a change in process, equipment or operating parameters occur?

Audit Checklist

4.4. 4.5. 4.6. 4.7. 4.8. 4.9. 4.10. 4.11. 4.12. 4.13. 4.14.

5.

CONTRACTORS AND SUPPLIERS: 5.1. 5.2. 5.3. 5.4. 5.5. 5.6. 5.7. 5.8.

6.

If a deviation from an operating procedure occurs, is a mechanism in place to allow for a shutdown of the operations and a review and approval for the deviation documentation? Is a mechanism in place to ensure critical operating parameters are reviewed and updated periodically? Are personnel trained and qualified in operating parameters and procedures? Is a mechanism in place to plan, track and document maintenance operations? Is a mechanism in place, in conjunction with the maintenance program, to schedule and track testing and inspection of equipment and systems? Is a system in place to maintain documentation of operating design and current conditions of protective systems? Is a mechanism in place to ensure that safe work practices are established for the conduct of protective systems? Are assets being removed from service decommissioned, secured and managed on a timely and systematic basis? Is a mechanism in place to manage the risk associated with idle wellbores? Are HSE assessments completed at proposed abandonment sites? Are systems in place for cleanup, mitigation and restoration of decommissioned or abandoned sites?

Are mechanisms in place to consider contractor/vendor HSE management and performance as a part of the selection process? Is communication of contractor performance expectations part of the selection process? Is a list of approved contractors whose HSE performance and programs meet company standards maintained? Is a mechanism in place to determine the adequacy of contractor training? For major contractors and sub-contractors, does monitoring include assessments of HSE preparation, processes and performance? Are rig inspections conducted and documented on a consistent and timely basis? Do formal purchasing and contract control mechanisms include arrangement for appropriate HSE requirements? Is a system in place for review of safety and health aspects of potentially hazardous materials.

MANAGEMENT OF CHANGE: 6.1. 6.2. 6.3. 6.4.

Are mechanisms in place to manage and control changes in facilities, technology and personnel? Are changes to mechanical design or changes in operating conditions subject to review and/or approval? Are changes in process, equipment and materials identified and reviewed before implementation? Is a communication loop in place to ensure appropriate personnel are informed about facility, technology, and/or personnel changes?

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6.5.

7.

ENVIRONMENTAL PROTECTION: 7.1. 7.2. 7.3. 7.4. 7.5. 7.6. 7.7. 7.8. 7.9. 7.10. 7.11. 7.12. 7.13.

8.

8.2. 8.3. 8.4. 8.5. 8.6. 8.7.

Are mechanisms in place to ensure appropriate notification, reporting and investigation of incidents? Is a mechanism in place to ensure appropriate training is provided on spill or loss of hazardous materials? Is responsibility for incident and near-miss investigations clearly established? Are lessons learned from potentially significant incidents and near-misses communicated to appropriate audiences? Is current information on incident experience and causes tracked, analysed and reported? Are reports submitted and incident records maintained, as required by ADNOC Policy and legal requirements? Is required incident recommendation follow-up responsibility clearly assigned and understood?

EMERGENCY PREPAREDNESS / CRISIS MANAGEMENT: 9.1. 9.2. 9.3. 9.4. 9.5.

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Are significant releases and all wastes from operations identified, quantified and reported as appropriate? Are mechanisms in place to identify and quantify air emissions from the operations? Are mechanisms in place to operate in compliance with applicable permit conditions, regulations, Guidelines and Codes of Practice? Are environmental risks and exposures associated with assets and operations systematically identified, assessed and managed? Is significant discharge reduction potential prioritised and managed? Is corrective action implemented and reported if discharge levels exceed defined operating parameters or legal requirements? Are mechanisms in place to classify, separate and segregate wastes based on potential hazards? Are mechanisms in place to control and document the storage, transport, treatment and disposal of waste? Have significant spill risks been identified, assessed, prioritised and mitigated? Are maintenance of spill plans and inspection activities clearly addressed and documented? Are spill and leak prevention addressed in design and operating practices for tanks, equipment, pipelines and marine operations? Are mechanisms in place to identify, assess and manage risks of soil, groundwater or surface water contamination? Are soil, groundwater, surface water or benthic monitoring and/or reclamation steps taken where required?

INCIDENT MANAGEMENT: 8.1.

9.

Is HSE responsibility and accountability updated and clarified in the event of changes to the organizational structure, reporting relationships, personnel, etc.?

Are objectives, duties and responsibilities within the emergency management organization clearly defined and communicated? Are Emergency Response Plans and/or Crisis Management based on credible, major emergency scenarios identified in risk assessments? Are Emergency Response and/or Crisis Management Plans comprehensive, regularly tested, reviewed and revisions communicated? Are emergency call-in systems and communication links for alerting off-site employee contacts established and regularly tested? Are procedures, agreements and communication channels for external sources of emergency assistance clearly outlined?

Audit Checklist

9.6. 9.7. 9.8.

10.

LEGAL REQUIREMENTS AND STANDARDS: 10.1. 10.2. 10.3. 10.4. 10.5. 10.6. 10.7.

11.

Are regular, emergency preparedness training exercises and drills conducted as appropriate? Are contractors, communities and external responders invited to participate in emergency response drills? Are post-emergency reviews conducted for analyses of actions taken and procedural adequacy?

Is a mechanism in place to ensure compliance with ADNOC Codes of Practice and Guidelines and that permitting is initiated in an expedient manner? Are applicable company guidelines and industry standards readily available and applied? Is a variance procedure in place to handle instances where specific local conditions necessitate deviation from standards? Are areas and activities requiring instructions or procedures to further minimize risks identified? Are selected key general work rules posted in places that reinforce their message? Do mechanisms exist to ensure instructions and procedures are accessible, current and communicated to applicable staff? Are procedures in place to ensure monitoring and sampling are conducted according to applicable ADNOC Guidelines and industry standards?

CONTINUOUS IMPROVEMENT: 11.1.

Are person to person contacts between supervisor and employees on HSE related issues made on a regular basis? 11.2. Is important facility HSE related information, correspondence and news effectively communicated? 11.3. Are HSE improvement meetings conducted regularly and documented? 11.4. Do managers and supervisors periodically participate in HSE improvement meetings? 11.5. Do management presentations to work groups include safety and environmental issues? 11.6. Is a mechanism in place for planned inspection(s) of the facility by management? 11.7. Are periodic checks on the proper implementation of work procedures carried out by company and contractor managers or supervisors? 11.8. Is a mechanism in place for conducting HSE audits on a regular basis in accordance with defined criteria? 11.9. Following analysis of HSEMS plan assessments, are improvement action plans developed, reviewed and implemented on a prioritised basis? 11.10. Are key performance indicators for HSE results established?

12.

FIELD REVIEW AND VISUAL INSPECTION: After the site tour, comment generally on the housekeeping and overall appearance of the site. Include observations from other audit team members. This includes, but is not limited to, the condition of emission stacks, water discharges, material and waste handling/storage areas, process areas, maintenance areas, and housing.

13.

SITE PROFILE: The Audit Team Leader is responsible for gathering the information required to prepare the site profile portion of the audit report. While most of this information can be obtained from the pre-audit questionnaire, additional information (plans, expansions, exploration, etc.) should be obtained during the on-site portion of the audit.

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Adnoc Hsems Guidelines

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