DOCUMENT NO.
BON-AME-3GN-G-00199-005
CONTRACT NO. : L 00802
CONTRACT No: P 0001
SNEPCO BONGA FPSO TOPSIDES, COMMISSIONING AND OPERATIONS HANDOVER
DOCUMENT TITLE :
HEALTH, SAFETY & ENVIRONMETAL PLAN
A03 A02 A01 REV.
Revised Revised & Reissued Issue for Design ISSUE OR REVISION DESCRIPTION
NJB BJM NB ORIG. BY
Aug-01 Mar 01 Feb 00 DATE
RM NB BM CHKD. BY
Aug-01 Mar 01 Feb 00 DATE
DMH DMH DMH APPD. AMEC
Aug-01 Mar 01 Feb 01 DATE
APPD Client
Page 1 of 48
DATE
REVISION CHANGE NOTICES Rev. A01 A02
Location of Changes Tender Version Throughout Throughout
A03
Throughout
Brief Description of Change First Draft Updated with internal comment Re-worked to include SNEPCO & BMT comments Yard HSE specific details deleted to avoid duplication with local plans
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CONTENTS AMEC HS&E VISION INTRODUCTION 1
2
3
4
POLICY, STRATEGY AND GOALS 1.1
POLICY
1.2
STRATEGY
1.3
GOALS
PROCESSES AND PROCEDURES 2.1
Design Safety Processes
2.2
Construction/ Fabrication Processes & Procedures
2.3
Pre commissioning, Hook Up & Commissioning Processes & Procedures
2.4
Sub contractor’s Procedures
RESOURCES AND ORGANISATION 3.1
Project Management / HS&E Organisation
3.2
Communications and Interfaces
3.3
Training and Competency
IMPLEMENTATION, MONITORING AND REVIEW 4.1
Active Monitoring
4.2
Reactive Monitoring
4.3
Accidents/Incidents & Near Misses
4.4
Audit and Review
4.5
Site Safety Inspections
4.6
Management Review
4.7
Incentive Schemes
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5
6
DEMONSTRATE COMPLIANCE 5.1
Inspections
5.2
HS&E Audits
MANAGEMENT REVIEW 6.1
HS&E Actions
7
REFERENCES
8
DEFINITIONS
APPENDICES 1
Safety, Health and Environmental Policy
2
Review/Audit Program
3
Shell Shearwater Incentive Scheme
4
AMEC Policies in line with SNEPCO
5
Emergency Contact Details
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AMEC HS&E VISION FOR BONGA To be the safest and most environmentally responsible organisation in the industry through the achievement of:
Reduction in personal injuries
Minimising pollution to the environment
Continuous improvement in HS&E culture and behavioural attitudes
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INTRODUCTION Health, Safety and Environmental is an inherent aspect of our core business process and our dayto-day activities. The AMEC health, safety and environmental management system is based on the Health and Safety Executive publication ‘Successful health and safety management’ HS(G)65, which enables the development, implementation and monitoring of processes and procedures for all our activities including engineering, design, construction and procurement, in line with contractual requirements and AMEC/SNEPCO management systems. A key aim of the hazard management process is to ensure that risks to personnel operating the Bonga FPSO are reduced to levels that are as low as is reasonably practicable (ALARP) in the context of internationally accepted standards. This plan describes the management of HS&E within AMEC during the project. It illustrates the AMEC commitment to the Health and Safety of all personnel involved in the design, engineering, construction, commissioning and integration phases of the Bonga development. All companies involved in the Bonga Development Project will interface their HSE responsibilities through applicable bridging interface documents and procedures. This process will be recorded in the SNEPCO Bonga HS&E Interfacing Document [Ref:1]. The chart below shows the HS&E Management System Interfacing Matrix:
AMEC SNEPCO Bonga HS&E System Interfacing Matrix Preliminary Objective to ensure: • Safe methods and systems of working and safe operations of AMEC equipment at all worksites. • Arrangement in place to prevent injuries and eliminate HS&E Management hazards, risk at the workplace & damage to equipment System • Minimisation of environmental discharges, management of waste SNEPCO Bonga HS&E System Interfacing Document
Ensure smooth transition of the management of health, safety and environmental concerns between all phases of the project.
Project Health, Safety & Environmental Plans
Project HS&E Plans Design / Procurement Fabrication Topsides
Project Sub-Contractors / Vendors
Integration of Topsides / Modules /Hull & Commissioning
Loadout / Transportation Construction Activities Offshore Nigeria Post Start Up
AMEC acknowledges its responsibilities as a Contractor to comply with all relevant statutory requirements pertaining to work completed by its employees and Sub-Contractors for all phases of the project.
Throughout each phase of the Bonga development this HS&E Plan shall be considered as a “Live” document and as such will be subject to continual review through each phase of the project.
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Any amendments to the plan will take into account any new HS&E initiatives and legislation that may affect the work conducted on the project by AMEC or Sub-Contractor personnel. The plan is organised in a hierarchical structure based on the policies, strategies and goals described in section 1.0. The structure is headed by the policy and cascades down through the defined management system strategy and goals and then into the more specific HS&E MS systems and procedures. The plan is designed to be flexible so that the HS&E requirements of the Bonga Project Management and of sub-contractors can be interfaced successfully Fig 2. To this end the plan together with the corporate AMEC HS&E Management System and the SNEPCO Bonga HS&E Systems Interface Document [Ref: 1] shall be used as guidance for the development of specific interface documentation covering the following phases of the project:
Design/Procurement Fabrication Topsides Integration of Topsides/Modules/Hull & Commissioning Load-out/Transportation Completion Activities Offshore (Nigeria) Post Start Up
Others
Security Plan (Nigeria), [Ref: 6] Community Affairs Plan (Nigeria) Site Security (all locations) IT Security
The Health, Safety and Environmental Plans shall be developed in line with the AMEC Safety Management System Structure shown below. AMEC SAFETY MANAGEMENT SYSTEM STRUCTURE
Policy, Strategy and Goals
Processes and Procedures
Resources and Organisation
Improve P
Correct
Implement, Monitor and Control
A
D C
Demonstrate Compliance
Re-Define
Management Review
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Fig: 2 Project Management & HS & E Document Interfaces
SNEPCO Project Management
SNEPCO HSE Manual SNHS-2000-0003
AMEC Project Management
Bonga Project HS&E Plan BON AME-3GNG-00199-005
AMEC Corporate HSE MS Policies & Procedures
Heerema Hartlepool & Zwijndrecht
Heerema HSE MS PMP-H-01-001 & PMP-77
Interface Document BON-AME-3GNG-00190-042
Amec Construction Wallsend
Wallsend HSE Plan AOS-PF-SM-001 & Procedures
Interface Document BON-AME-3GNG-00190-041
NETCO Design
NETCO CASHES Policy BON-AME-3AAX-09090-001
Interface Document BON-AME-3GNG-00190-043
Nigeria Construction Site
Nigeria Cont’n HSE Plan Hold
Interface Document Hold
AMEC Design & Procurement
Offshore HUC
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1.0
POLICY, STRATEGY AND GOALS
1.1
POLICY AMEC Policy statements on Health and Safety and the Environment are the key polices that shows the AMEC commitment to obtaining the highest practical achievable standards of safety, occupational health and environmental protection, while conducting its business. The corporate HS&E management system that clearly defines the activities and responsibilities of all personnel support these management policies. 1.1.1
Health and Safety
AMEC will comply with all relevant applicable health and safety legislation. To this aim AMEC has prepared Health and Safety Statements of Intent clearly stating the aims of the company along with responsibilities of all employees. A copy of the AMEC Health and Safety Policy Statement of Intent is attached within Appendix 1. 1.1.2
Environment
A prime AMEC objective is to maintain a healthy and safe environment and to minimise any impact on the environment. In order to achieve this, the AMEC environmental policy and procedures ensure that we comply with current environmental standards. Throughout the onshore pre-commissioning phase of the project, continuous monitoring shall assess any environmental impact. 1.2
STRATEGY The AMEC strategy, has been developed to achieve the highest possible health, safety and environmental standards throughout each phase of the Bonga development is as follows: Project Management/Supervision will be assessed on a regular basis to ensure their competence in HS&E Management. The HS&E Manager will conduct assessments through the monitoring and review process. This HS&E Plan will be fully disseminated to all personnel and implemented in its entirety. A message from the Project Manager to all new starters regarding the Projects HS&E requirements and their responsibilities will form part of the induction process to demonstrate his personal commitment and to request for the same commitment from all Bonga Project employees.
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Responsibilities for HS&E will be clearly defined through to Area Engineers and Supervision, they will be held accountable for all HS&E matters within their area of work and authority. Project Sub-Contractors will also have to demonstrate HS&E Management through their engineers and supervision. The Company Disciplinary Procedure for breach of HS&E policies, procedures and practices will be fully explained to all personnel and fairly administered by all levels of Management and Supervision. The Bonga Management Team ( BMT) will produce an annual Personal Safety Contract. The HS&E Manager will audit the implementation of these Personal Safety Contracts. All BMT Personnel Safety Contracts will be displayed. All Project Personnel must acknowledge the HS&E Site Advisers position and authority through actively supporting and acting upon their decisions. AMEC/Sub-contractors/Supervision will be assessed on their performance and approach to HS&E Management throughout the duration of the project. The Project Manager, HSE Manager and site HSE Advisers will carry out this assessment. All findings will be displayed on the project intranet site and notice boards. All project management, including those of Sub-contractors must be seen to be visible and play an active role in HS&E Management. The HSE Manager will regularly brief the BMT on HS&E issues. 1.3
GOALS Key health, safety and environmental goals have been set to give focus and direction to our activities and improvement plans and the project performance standards. The key goals are:
Minimise our impact on the environment. Eliminate, reduce or control risks to levels that are demonstrably ALARP in the context of an international project. Fully comply with applicable standards and legislation. Apply HS&E strategies that ensure compliance with SNEPCO’s incident frequency targets.
1.3.1
Project Health and Safety Performance Targets
AMEC endorse the SNEPCO visionary commitment to a zero target for health, safety and environmental performance as identified within the SNEPCO Activity schedule. The SNEPCO target that is in line with the overall target for Shell E&P worldwide are: Year
2001
2002
2003
TROIF
5.0
5.0
5.0
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In addition, all violations to the following health targets shall be reported.
No violations of drug and alcohol policy No cases of food poisoning. No cases of exposure to asbestos without appropriate control procedures, precautions and use of PPE. No cases of smoking in non-designated areas. No case of exposure to identified physical, chemical, biological, ergonomic and psychological health hazards. Reporting of non-accidental deaths, regardless of whether the likely cause was work related or not.
AMEC shall report the Total Record-able Occupational Illness Frequency (TROIF) monthly as: TROIF = Total Reportable Occupational Illness x 1,000,000 Man-hours worked Zero Fatalities and achievement of the following LTIF and TRCF rates: Year LTIF TRCF 1.3.2
2001 1.0 2.6
2002 0.9 2.3
2003 0.8 2.0
Project Environmental Performance Targets
AMEC acknowledge SNEPCO environmental targets:
Zero controllable releases of hazardous substances i.e. if the release is controllable it shall not happen Zero uncontrollable releases of hazardous substances through adequate prevention, control and emergency response arrangements Minimise damage to plant, animal life and environment Minimise negative long-term impact on the environment All AMEC established Corporate Environmental Objectives should be targeted and integrated with the Bonga project targets.
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1.3.3 Definitions a) Total Reportable Occupational Illness (TROI) An occupational illness is defined as a work related abnormal condition or disorder, other than that resulting from a work injury caused by or mainly through exposure at work, whether a case involves a work injury or occupational illness is determined by the nature of the original event or exposure that caused the case not by the resulting condition. Work injuries are caused by a single event in the working environment; cases resulting from anything other than a single event are considered occupational illnesses are record-able. b) Total Record-able Case incident shall be defined as: Lost Time Incident (LTI) The sum of fatalities and work related injuries that cause incapacity for more than three (3) workdays beyond the day on which the incident occurred. Incapacity Accidents Work related injuries that cause incapacity for more then one (1) work day beyond the day on which the incident occurred. Medical Treatment Case (MTC) A minor work related injury that requires hospital attendance/treatment and which result in the injured person returning to work on the day of the accident or the first work day after the day of the accident. c) The Total Record-able Case Frequency Rate shall be calculated on the following basis: TRCF Rate = Incapacity Accidents + MTC x 1,000,000 Man-hours Worked LTIF Rate = Lost Time Incidents >3days x 1,000,000 Man-hours worked 1.3.4
Project Objectives
Apply the AMEC experience in risk assessment and reliability engineering. To produce a cost-effective design that minimises impact to the environment throughout the project life cycle. Promote Health, Safety & Environmental management as our prime company priority. Consolidate and improve our health, safety & environmental performance. Develop a culture of reporting without fear of blame. Actively involve everyone in providing a safe and healthy environment. Take ownership of our HS&E responsibilities. Demonstrate to our customers the competence and commitment of our employees To establish safe working practices that will meet, and better in some cases, the acceptance criteria throughout the design, fabrication and installation.
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2
PROCESSES AND PROCEDURES
AMEC procedures for the Bonga Project define the management system for each phase of the project. AMEC procedures are managed and co-ordinated through the AMEC Quality Group. Full details of these are given in the Project Quality Plan [Ref: 2]. 2.1
Design Safety Processes 2.1.1
Organisation
The Bonga technical safety and environmental organisation for the detailed design phase is set out below – identifying personnel and contracted services. The engineers responsible for studies will be drawn from the Principal and Senior engineering categories. Lead Safety Engineer And Environmental Engineer HAZOP Chairman
Safety Studies
Fire & Explosion RAM Evacuation, Escape and Rescue Dropped Objects
Environmental
ENVID EIA ENV Awareness Dispersion Analysis
Loss Prevention
HVAC
Fire Protection Fire & Gas LSA
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AMEC will review the HAZID to identify all potential hazards to personnel and the environment. Risks to personnel including the most exposed user group will be assessed in accordance with the ALARP framework document [Ref:3]. 2.1.2
Hazard Management Process
The Hazard Management Process is pivotal to an effective HS&E Management system. AMEC will implement an extensive hazard identification process and consequence evaluation in order to develop the appropriate control and mitigation features. The management of hazards and risks process will include: -
Identification and assessment of hazards that are associated with significant risks to Bonga Adopt an inherently safe approach by hazard elimination where feasible Classify risks when necessary Develop Control and Recovery measures to deliver an overall ALARP solution Apply best practice where appropriate Deliver robust solutions based on engineering judgment
The AMEC engineer’s awareness of hazards and aspects of operational risk ensures that these effects are inherently minimized throughout the design and engineering process. AMEC will execute certain key hazard assessment activities under the appointment of suitably qualified and competent subcontractors. The following activities shall be performed on behalf of the project under a Bonga Subcontract:
HAZOP chairmanship Availability and Reliability modeling
The activities of these Subcontractors shall be integrated into the project work. Actions arising from the HAZID, HAZOP and ENVID and risk assessment process will be recorded on the AMEC Safety and Environmental database for further consideration and closeout. 2.1.3
Demonstration of ALARP
AMEC will contribute to the preparation of an HSE case (safety case) that demonstrates that risks to personnel operating the FPSO are ALARP. This process is detailed in the Guidelines for the Demonstration of ALARP [Ref: 3]. The demonstration of ALARP will include the following processes: 1. Identification of Hazards. 2. Assessment of Hazards. 3. Recommendations for measures to reduce risks.
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4. A “Test of Significance” will be carried out based on a comparison between the specific risk and other risks identified by the HAZID 5. Implementation of measures if called for by Codes and Standards. 6. For measures not covered by existing Codes and Standards, a framework for risk related support will be used to aid the decision making process. 7. Further consideration of measures using Good Practice/Engineering Judgment and coarse quantification and cost benefit analysis if required. 8. Further consideration of the effect of Company Values (both SNEPCO and AMEC and all other stakeholders) if required. 9. Further consideration of Societal Values if required. 10. Measurement of the process through performance standards. 2.1.4
Design Input
Contract Specifications shall be reviewed in accordance with the requirements of the Quality Management System (QMS). General Design Requirements
The designs shall be in compliance with relevant legislation. The technical content of the design(s) shall be suitable for submission to the Certification Authority AMEC shall appoint a competent Classification Society. The designs shall satisfy the SNEPCO environmental targets
2.1.5
Design Output
A formal process established in the Quality Management System (QMS) shall verify the project design outputs. 2.1.6
Design Review
Peer group design review on all project scope of works shall be accomplished at specific stages during the lifecycle of the Project by a number of methods including:
P & ID Reviews HAZID/ENVID and HAZOP Reviews Layout reviews Hazardous Area Reviews
The reviews shall ensure that the design:
Complies with specific safety, environmental, availability, operability and maintainability requirements and that operator health and welfare needs are addressed in the design through either specification or ergonomic/human factors analysis. Accounts for the major accident hazard consequences associated with un-ignited Gas releases, Fires, Explosions, and Smoke dispersion. Addresses Escape, Evacuation and Rescue control and recovery measures Provides input into a Safety Case for Bonga Demonstrates that the Bonga Topsides can be constructed, inspected, tested, operated and maintained in accordance with accepted practices Complies with weight and space requirements
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2.1.7
Design Certification
Design documents shall be subject to checks by independent competent persons in accordance with relevant project procedures to ensure that:
a correct, clear and unambiguous interpretation of the Contract requirements, the technical, format and presentation requirements, they are adequately substantiated by calculation.
Design documentation shall also be subject to inter-discipline review, checked to ensure that it incorporates applicable information and feedback from suppliers, sub-contractors, the client and third parties such as regulatory bodies in accordance with the project Quality Management System (QMS). The output from computer calculations shall be verified as part of the audit process, spot checks and verification of the computer program. Computer data shall be secured from loss or damage by regular back up and protected from unauthorized access. 2.1.8
Design Validation
The Project shall utilize design validation to ensure that supplied product conforms to agreed Contract requirements. 2.1.9
Design Change Control
Design change control procedures shall be in accordance with the requirements of the AMEC Quality Management System (QMS). 2.1.10 Reliability, Maintainability and Operability Reliability, maintainability and operability activities shall be performed using MAROS in accordance with approved project procedures. In addition, formal assessments shall be performed to demonstrate compliance with the specified reliability, maintainability and operability targets. 2.2
Construction/Fabrication Processes & Procedures At each construction site, site-specific safety processes and procedures will prevail. These will adhere to project requirements/standards and will be subject to the review and audit process. 2.2.1
Spill Response
Operatives will be made aware of the importance the Company attaches to minimising the effect of its operations on the environment. Should spills of chemicals, hydrocarbons or other potentially damaging materials occur or be observed by AMEC operatives or contractors; the following actions must be taken.
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Attempt to contain spills to minimise potential pollution where practicable and without endangering personnel. Inform AMEC Bonga Project Management/Supervision/HS&E Management. Where necessary, report the spill to the Emergency Services, local authorities, Environmental Agency etc.
Once the incident is under control the Supervisor will complete an incident report, with the assistance of the Bonga Project HS&E Adviser the report will be copied to the AMEC Project HS&E Manager. AMEC will ensure they fully comply with all relevant statutory and company requirements relating to the environment. The Company also undertakes to comply with all legislation regarding the disposal of waste materials. 2.2.2
Substances Hazardous to Health
Control of Substances Hazardous to Health (COSHH) Regulations 1999 All substances classified as hazardous to health that are transported, used or created during work on the SNEPCO Bonga Project shall be controlled in such a way as to minimise the risk to the health of employees, others and the environment in accordance with COSHH or equivalent regulations. COSHH related activities should be monitored to ensure all requirements of the regulations are satisfied. AMEC will not accept any materials on site unless accompanied with the supplier's/Manufacturer’s Material Safety Data Sheet (MSDS) documentation. A register will be assembled incorporating all MSDS documents and this register shall be readily accessible to all personnel required to transport, use or dispose of the hazardous material. The HS&E departments at each site shall hold all hazardous substance material safety data sheets with a duplicate copy being held at the site Medical facility for use in an emergency. 2.2.3
Ionising Radiation
Advice and information on radiography should be given as required under the Ionising Radiation Regulations 1999 or equivalent. Suitably qualified and competent personnel will carry out the work that for AMEC will be in accordance with their “Local Rules for Radiography”. These will be subject to routine HS&E audit and inspections. In addition AMEC have also published and circulated contingency plans for dealing with emergencies involving radioactive isotopes. Notices will be displayed on project site notice boards and work areas giving details of times and areas where radiography will be taking place.
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2.2.4
Noise/Nuisance
All UK sites shall comply with the Noise at Work Regulations 1989 and to limit potential nuisance to neighbours as defined in the Environmental Protection Act 1990 Similar processes will be applied at other project site locations. 2.2.5
Permit To Work
Personnel involved in the administration and operation of permit to work systems will receive training and information appropriate to their responsibilities and duties as set out in the site applicable permit to work procedure. Compliance with Permit to Work procedures will form part of the HS&E audit and inspection programme. 2.2.6
Work Packs/Job Safety Analysis/Risk Assessment
AMEC will ensure that Job Safety Analysis/Risk Assessments will be carried out to identify all the hazards and risks associated with work for the Bonga Project and that information is communicated to the employees who are required to carry out the work. 2.2.7
Hygiene and Occupational Health
Each site location will be provided with First Aid and/or Medical facilities, or one that can be accessed locally appropriate to the size of the operation, reflecting the risks and promoting the general health and safety awareness of employees. Where health hazards have been identified, appropriate information and training will be given to the personnel involved in the specific or periodic medical will be confidentially advised by a AMEC approved Doctor or Medical Advisor. Information and Training Where health hazards have been identified, appropriate information and training will be given to the personnel involved in the specific work activity. Equipment, facilities and information shall be provided as necessary so that work can be carried out safely and with minimum risk to personnel. First Aid Each site shall have a suitable number of personnel trained in first aid. Medical Evacuations The decision to evacuate an injured person will rest with the qualified Medical Attendant. Evacuation for medical reasons may be for one of the following. •
Injury as a direct result of a accident
•
Ill Health or a recurrence of an illness not associated with an accident.
In all instances the Medical Attendant will advise the Bonga Site Project HS&E Adviser and he, in turn, will advise Company Management, Bonga Project Manager and HSE Manager.
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Welfare/Amenity Provision Where appropriate, sufficient messing facilities will be provided to accommodate personnel. 2.2.8
Emergency Response
All site locations will have an emergency response capability plan, which will be maintained, exercised regularly and communicated to all personnel. . Emergency Exercises Exercises and Drills will be held on a regular basis and will cover realistic emergency scenarios, including all aspects of contingency planning and response procedures. Where necessary external bodies will be advised in certain exercise functions. Key personnel will be trained to a level of competence appropriate to their responsibility in an emergency situation. 2.2.9
Safe Means of Access/Place of Work
All sites will ensure that a Safe Place of Work is provided where the facilities, work methods and activities are managed and controlled to provide protection against injury or ill health to personnel or damage to pant, equipment and the environment. 2.2.10 Fire Protection Fire protection facilities will be provided at each site location as appropriate. In general these will consist of a fire main, hydrants/hose-reels and extinguishers as necessary. All office, welfare and storage areas have the appropriate certification where applicable. Fire equipment will be inspected on a regular basis and maintained in good order. Construction activities are catered for by the provision of sufficient numbers and types of fire extinguishers at various locations throughout the working areas.
2.2.11 Waste Management Waste management, including waste reduction, recycling and disposal is covered by Waste Management procedures appropriate to each site location.
2.2.12. Electrical Safety All portable electrical equipment and appliances shall be checked and certified as required by the applicable Electricity at Work Regulations or equivalent
2.3
Pre/commissioning, Hook-Up Processes & Procedures During the Pre/Commissioning phases of the project these activities will generally conducted in accordance with AMEC written processes and procedures. Where possible these same procedures will be carried over into the Offshore Hook-up phase so as to retain continuity between on and offshore working. The SNEPCO offshore working procedures will also be utilised where specific activities dictate their use. Page 19 of 48
2.3.1
Training
Bonga specific HSE training needs are detailed in a separate document (Ref 7.) 2.4
Subcontractors Compliance Where appropriate project sub-contractors will comply with the AMEC standard rules for contractor management of HS&E. Proposed sub-contractors will be required to demonstrate their competency and will be fully integrated into the project and subject to an integrated HSE/Q audit during the HSE Plan compliance audit programme.
3
RESOURCES AND ORGANISATION
The foundations of health, safety and environmental control rely heavily on human factors for their success. It is therefore necessary that systems, which operate to manage the human element in the company, have HS&E considerations built into them. The following five “Human Resource” elements are addressed by the Bonga management system: 1 2 3 4 5
Recruitment of competent personnel Training of personnel Medical fitness Assessment of attitudes to Health, Safety & Environmental matters Disciplinary measures associated with infringement of HS&E standards.
3.1
Project Management/HS&E Organisation
The BMT are directly responsible for the implementation of the HS&E Plan, its policies, procedures and safety objectives. The overall organisation for the Project shall be as per the organisation charts included within the Project Execution Plan [Ref: 4]. AMEC Bonga Project Manager. Is responsible for endorsing the HS&E policies, by making available sufficient resources to enable the Project to meet its safety objectives and ensuring that all project staff are conversant with the requirements of the this Plan and are aware of their individual HS&E responsibilities. Project HS&E Manager. Is responsible for the implementation of the HS&E Plan and for ensuring by review and audit, that all Project and Legislative requirements are complied with and any actions resulting from audits are followed through and implemented. The HS&E Manager is also accountable for ensuring the Plan is followed and that the responsibilities and accountabilities specified therein are adhered to. Construction & Integration Manager and Site Construction Manager. Are responsible in assisting the Project and HS&E Managers in promoting HS&E in their sphere of influence in providing a safe working environment for all personnel in the Bonga Project. They are also required to assist in the implementation of the Bonga Project HS&E Plan and in achieving its objectives.
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HS&E Design team. Are required to achieve an integrated safe and environmentally sound design where risks are as low as reasonably practicable and for maintaining HS&E practices as an integral part of project philosophy. The HS&E design team shall contribute to the Bonga Safety Case. Site HS&E Advisers. Are required to assist the HS&E Manager, Site Construction Manager and Supervision in meeting the project HS&E objectives and implementation of the project performance standards. They are also responsible for ensuring that all project personnel are conversant with their obligations relating to HS&E in accordance with this Plan and the requirements of the company and relevant legislation. The site HSE/Q advisers shall prepare the site HSE/Q plans for implementation during the work phase Environmental Specialist. Is required to provide a point of contact for environmental matters and advise the Project and HS&E Manager on environmental management implementation. He is also responsible for ensuring Company operations are in compliance with AMEC, SNEPCO and statutory requirements. Safety Representatives. AMEC actively encourages and supports safety representatives and recognises the valuable contribution they can make as a direct link between the workforce and management in HS&E matters. Safety representatives are required to participate in site safety inspections and accident investigation teams as required. They shall also be consulted on health and safety issues, such as the selection of personal protective equipment and proposed changes to equipment or systems of work. Project Team. All members of the Project team will be responsible for the participation in and the implementation of the Project HS&E philosophy. Ensuring that corporate and project safety objectives are met and to report all accidents, incidents and unsafe acts or conditions. All Employees. Have a responsibility for HS&E matters while working on the Bonga Project. AMEC requirements are clearly set out within the policy statements in the HS&E Management System. Each employee has a duty to co-operate in ensuring that they maintain a safe system and a safe place of work at all times. 3.2
Communications and Interfaces Personnel are actively encouraged to be directly involved in the ongoing development and maintenance of the management system. This involvement and participation is sustained by line management commitment, effective communication and the co-operation of the workforce. Formal arrangements in terms of meetings, forums and a communication network have been developed in which personnel will participate in and contribute to as much as possible. 3.2.1
Project HS&E Meetings
Project site HS&E tours will be held on a monthly basis and will include a review of the project weekly reports, any previous minutes and the action points arising. The location for this meeting shall be on a rotational basis with each yard acting as host. In addition to the HSE manager the attendees will include but not necessarily be limited to:• • • •
Site Construction Manager Site Construction HS&E Adviser Environmental Adviser Area Engineers Page 21 of 48
• • • • • • • •
Supervision Workforce Staff Safety Representatives Sub-contractors Site Management Operations Department Integration/Commissioning Representative SNEPCO Site Representatives
3.2.2
Project HS&E Forums
Project HS&E Forums will be held at quarterly intervals where safety representatives are invited together with Bonga Project Management, Supervision, and Directors, workforce and SNEPCO personnel. 3.2.3 Toolbox Talks Toolbox Talks/Safety Briefings are designed to allow two-way communications, and to ensure that the work team fully understand the work to be undertaken, the hazards involved, the procedures to be followed and the precautions to be taken. 3.2.4
Safety Meetings
Safety meetings are conducted within a structured framework, with line management planning and co-ordinating the meeting, and encouraging group members’ participation, in accordance with project procedures contained within the Quality Manual. 3.2.5 General Promotions Safety Programmes in conjunction with various forums, meetings and communication structures help provide the knowledge and awareness, which promote a strong HS&E culture. To this end AMEC will promote the use of incentive schemes, periodicals, posters bulletins, mail-shots and promotions as a constant reminder of the commitment to HS&E issues. 3.3
Training & Competency
A training matrix shall be developed for all levels of employee to ensure that the minimum levels of HS&E training is identified and personnel are trained and competent to do their job. 3.3.1
Induction’s
The project will ensure that all personnel (including staff, manual workforce, Subcontractors, vendors and pre-commissioning personnel) involved in any activities at a Bonga office or site location attend a project induction prior to commencement of any work. A message from the Project Manager to all new starters regarding the Projects HS&E requirements and their responsibilities will form part of the induction process to demonstrate his personal commitment and to request for the same commitment from all Bonga Project employees. The HS&E Advisers shall conduct the inductions at each specific yard location. The induction course may be tailored to suit the current status of the project. In general the course will include but may not be limited to the following headings shown below: Page 22 of 48
Welcome and Introduction Corporate Information Working at the location (office or fabrication site) Security and Awareness Policy, Law and Information Manual Handling Safety in Practice Safety in an Emergency Personal Protective Equipment Injuries and Emergencies Safety Systems Environmental Care Systems – Implementation
3.3.3
Job Safety Analysis/Risk Assessment Training
The project will ensure that where applicable, personnel assigned to the project will receive training in Risk Assessment/Job Safety Analysis. The training will provide the basic knowledge of hazard identification and the steps the Bonga Project Management will take for risk reduction. 3.3.4
Competency
A developed and implemented procedure that ensures all personnel are suitably qualified in terms of education, training and experience shall be applied on Bonga. Office based staff shall be subject to annual appraisals in order that:
Performance is assessed against annual personal objectives. New objectives are defined and agreed for the forthcoming year. Any additional training requirements are identified. Personnel can discuss their job expectations.
The competence and abilities of subcontractor’s employees is assessed as part of the process of subcontractor evaluation.
4.
IMPLEMENTATION, MONITORING AND REVIEW
The Plan-Do-Check-Act cycle is an integral mechanism in the implementation of management system control. This forms the first level of continuous performance improvement to our operating processes and is directly influenced by the personnel who operate the process. The effectiveness of the HS&E controls within the management system is evaluated by the use of:
Active monitoring which measures compliance with standards and achievement of objectives. Reactive monitoring reports. Page 23 of 48
Continuous improvement. Preparation and implementation of performance standards
Measures used for both active and reactive monitoring are supported by formal procedures that ensure that suitable corrective and as necessary preventative actions are identified. 4.1
Active Monitoring
4.2
All site supervisors shall derive their own standards for active monitoring.
Reactive Monitoring Reactive monitoring includes recognition, consideration and reporting of:
Injuries and case of ill health. Other loss events e.g. property damage, fire. Incidents including “near misses” with the potential to cause injury, ill health, damage, loss or harm to the environment. Hazards. Weakness or omissions in the company arrangements. Complaints
Formal procedures exist to ensure the systematic recording of accidents, incidents, defects and hazards so that causes and potential loses may be analysed, corrective actions identified and implemented. Investigation to determine underlying causes may also highlight negative aspects of the operation of the Management System, however, these are viewed as "earning opportunities" allowing improvements to be made and the direction or resources and attention towards safety and environmental priorities thus strengthening the Management System. 4.3
Accidents/Incidents & Near Misses 4.3.1
Accident/Incident Prevention
To prevent injury and damage it is necessary to recognise potential hazards and take action to control or eliminate them. This involves systems of control, which will include safe methods of work, adequate supervision, planned maintenance, machinery guarding, personal protection and personnel HS&E awareness. 4.3.2
Accident/Incident Reporting & Investigation
The Bonga project shall adopt an accident and incident reporting and investigation for system for all sites. Each site may opt to employ its own system however the project system shall always apply. Refer SAD-92-005. 4.4
Audit and Review The BONGA project shall develop a program of audits and reviews throughout the lifecycle of the project [Ref: 5]. These shall include design and engineering activities. The HUC Team shall implement a system of audit, to include both internal and external audits of Sub-contractor (if deemed necessary).
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The audits will address those areas identified as critical within the work processes, systems and operating procedures. They will be planned and programmed to reflect the contract Key milestones/activities, Performance Measurements and Deliverables. 4.5
Site Safety Inspections Site safety Inspections shall be carried out on a weekly basis (as a minimum).
4.6
Management Review The HSE Management system shall be reviewed periodically to ensure that the system reflects the objectives of the project the review shall consider the following:
Contract Strategy and Goals Processes and Procedures Resources and Organisation Implementation, Monitoring and Control measures Compliance
The above subjects shall be reviewed with regards to the effectiveness of control and achievement of specific milestones against annual strategic targets. 4.7
Incentive Schemes AMEC utilises various incentive scheme methods to promote safety and environmental improvements. Bonga shall establish its own scheme and arrangements covering all site and locations.
4.8
Performance Standards A 10 element series of performance standards developed by AMEC shall be implemented on the Bonga project.
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5
DEMONSTRATE COMPLIANCE
5.1
Inspections Supervisors are responsible for carrying out daily inspections of the workplace where Bonga fabrication activities are being undertaken. These inspections will relate to the general tidiness and condition of the area, to ensure that safe working practices are being maintained. The Project HS&E Adviser will also carry out daily HS&E inspections to monitor compliance with this Bonga Project Health, Safety & Environmental Plan, Company Policies, legislation and good HS&E practises. Weekly Safety Inspections Site Management shall conduct weekly HS&E tours. The inspection team shall be led by the Site Construction Manager and shall include representation from the following:
Area Engineers Area Supervision HS&E Advisers/Manager Environmental Adviser Workforce Representative Safety Representative Sub-contractors AMEC Services Limited Integration/Commissioning Representative SNEPCO.
An inspection report will be produced and forwarded to the applicable personnel department for action. Copies of the inspection report will be submitted to the inspection team and persons who have been given a corrective action. HSE site construction meetings The BMT Construction and Integration manager and HSE manager shall convene a monthly site construction HSE meeting involving other members of the BMT and all project site location HSE representatives Monthly BMT site safety tours
5.2
Each month the BMT shall perform a scored HSE tour of the construction sites and offices. HS&E Audits & Reviews
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HS&E audits and reviews will be conducted to an agreed audit schedule by a combined audit team to evaluate compliance with the HS&E Management System and Bonga Project Health, Safety & Environmental Plan. The audit schedule will be combined where practicable with the Project QA audit and review programme as shown on the Integrated QA/HSE Audit & Review Schedule [Ref: 5]. The overall HS&E audit programme will be agreed with AMEC Project Management and SNEPCO Bonga teams. The aim is to perform the audits as the relevant activities are being carried out in order to maximise the benefit of the audit and have the opportunity to implement corrective actions when the function is being carried out.
6
MANAGEMENT REVIEW
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6.1
HS&E Actions HS&E actions, identified and recorded as a result of Accident/Incident Report, HS&E Management System/Project HS&E Plan Audit or a HS&E inspections will be constantly monitored to ensure they are completed. A realistic target date will be set to complete actions and the person nominated to complete the action will report back to the Project HS&E Adviser. A copy of the report will be maintained in the Central Health, Safety & Environmental Department. AMEC, through continuous analysis of site inspections, audits and accident/incident reports will identify trends for which corrective action can be established and implemented in order to prevent future accidents/incidents. The AMEC reporting procedure will provide the basis for monitoring HS&E performance and the assessment of improvement measures. Every effort will be made to encourage the reporting of near miss incidents and property damage as a significant contributing factor to a pro-active HS&E program. Apart from the review and action raising processes by the site management teams the overall BMT will actively monitor HS&E performance.
7.0
REFERENCES 1. SNEPCO Bonga Interface Document
Hold
2. Project Quality Plan
BON-AME-003-G-0001
3. Guidelines for the Demonstration of ALARP
BON-AME-3GN-X-00190-001
4. Project Execution Plan
BON-AME-3GN-G-00199-001
5. Integrated QA/HSE Audit Schedule
BON-AME-399-Q-PRC002
6. Security Plan (NIGERIA)
BON-AME-3GN-G-00199-006
7. Bonga HSE Training Plan
BON-AME-XXX-X-XXXXX-XXX
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8.0
DEFINITIONS ALARP
As Low As Reasonably Practicable
TROIF
Total Record-able Occupational Illness Frequency
TROI
Total Record-able Occupational Illness
LTI
Lost Time Incident
MTC
Medical treatment Case
HAZOP
Hazard Operability Study
HAZID
Hazard Identification Study
ENVID
Environmental Identification Study
OIM
Operations Installation Manager
HUC
Hook-up &Commissioning
LSA
Life Saving Appliances
JMS
Job-card Management System
QRA
Quantitative Risk Assessment
CFD
Computer Fluid Dynamics
QMS
Quality Management System
MAROS
Maintainability, Availability, Reliability, Operability Simulations
MSDS
Manufacturers Safety Data Sheet
PTW
Permit to Work
PPE
Personal Protective Equipment
APPENDICES 1.
AMEC Policies in line with SNEPCO
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APPENDIX 1 AMEC POLICIES IN LINE WITH SNEPCO
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES SNEPCO HSE STATEMENT HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES Give the highest priority to the Health & Safety of Employees, Contractors and Member of the Public.
NO
N/A
COMMENTS Ref. APEL Health & Safety Policy – attached to HSE Questionnaire. Ref. APEL Environmental Policy.
Continually assess Environment Impact and reduce it to a level as low as practicable.
Integrate Risk Management in the business plan.
Ref. APEL HS&E Policies HSE Management System
Have Staff and Contractors maintain an open dialogue with Stakeholders.
Dialogue is maintained but not in policies.
Work in partnership with Communities on Community Development projects.
Participate openly in regulatory development.
Make Supervisors responsible for compliance with relevant HSE standards.
Actioned but not explicit in policies. Actioned but not explicit in policies. Ref. HS&E Policies – attached to HSE Questionnaire.
Have employees and Contractors competently trained to perform their job in line with this policy.
Ref. APEL HS&E Policies – attached to HSE Questionnaire HSE Management System
Ensure that progress toward the implementation of this policy is measured against plans.
Ref. APEL HS&E Policies. Implementation is assessed on a regular basis through inspections and audit.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES HEALTH, SAFETY & ENVIRONMENT COMMITMENT HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. Pursue the goal of no harm to people.
YES
Protect the environment.
Use materials and energy efficiently to provide products and services.
Develop energy resources, products and services consistent with HSE aims.
N/A
Play a leading role in promoting best practice in the industry frontiers.
APEL do consult with stakeholders. Currently we do not report outside the AMEC Group. Through the Offshore Contractor Association Step Change in Safety Ref. HS&E Policies.
HEALTH, SAFETY AND ENVIRONMENT POLICY YES NO N/A Has a systematic approach to Health, Safety and Environmental management designed to ensure compliance with the relevant National laws and Shall Group standards and to achieve continuous performance improvement. Sets targets for improvement and monitors, appraises and reports HSE performance. Requires contractors to manage Health, Safety and the Environment in line with this policy. Requires partners not under its operational control to apply this policy and uses its influence to promote it in its other ventures.
COMMENTS Ref. HS&E Policy APEL HS&E Objectives 1999 Ref. HS&E Policy APEL HS&E Objectives 1999 Ref. Environmental Policy APEL Environmental Objectives 1999
Consult with our stakeholders and publicly report on performance.
Manage Health, Safety and Environment matters as any other critical business activity. Promote a culture in which all SNEPCO employees, contractors and partners share this commitment.
NO
AMEC Promote the AMEC HS&E culture with clients, subcontractors and Partners. APEL openly and fully support the Shell HSE Commitment through the course of the project.
COMMENTS Ref. HS&E Policies and HS&E Management System.
Ref. HS&E Policies and APEL HS&E Objectives. AMEC require all subcontractors to comply with its HS&E policies and its standard rule for subcontractors. When AMEC work on joint ventures and on alliancing projects we would always seek to influence and promote the improvement in HS&E performance. This has been successfully done on the Shell Shearwater project.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES COMMUNITY DEVELOPMENT POLICY HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES Establish a community development programme which applies world standards of practice to serve its communities.
Work in partnership with host communities and where appropriate with government, donors, non-governmental organisations, community-based groups and other stakeholders.
Encourage the full participation of host communities in project planning, implementation and monitoring.
Maintain communication with all social segments of host communities in order to address their needs.
Focus community development assistance on activities having high impact and broad benefits for the host population.
Pay special attention to the most economically disadvantaged social groups.
NO
N/A
COMMENTS AMEC understand the need for smooth harmonious relationships with the various host communities during the various stages of the Bonga project. It is the intention of AMEC to adapt and implement policies to ensure that AMEC is valued as a business partner and neighbour of choice to our host communities and other stakeholders in the projects in which we participate. AMEC intend to deal with the communities as partners in our relationships with them, and will treat their internal matters with due sensitivity. AMEC will, within the limits of available resources assist in community development. AMEC will seek to ensure that recruitment and sub-contract awards will take due cognisance of the need to adequately embrace the core catchment areas where its operations are based or carried out. By adhering to the principles / policies included above we aim achieve the desired harmonious relationships without sacrificing standards or quality required for the safe, efficient and effective implementation of the project. AMEC will promote and sustain trust and favourable reputation with the host communities, the media and other stakeholders, through constant communication, education and support of suitable activities. We will base the extent of assistance to communities on need, proximity to AMEC’s operations and communities’ contribution to harmonious coexistence AMEC will within it’s limits of available resources help in this area.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES COMMUNITY RELATIONS POLICY HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES Establish and maintain close relationships with all segments of the local population to better understand their concerns, needs and aspirations.
Continuously assess and abate the social and economic impact of all business activities and take needed preventive or mitigating measures. Respond to formal community requests in an appropriate and timely manner.
Bring relevant issues affecting host communities to the attention of appropriate authorities and other bodies that can be of assistance. Manage the settlement of compensation for land acquired for company operations and for damages in a demonstrably fair, accountable and transparent manner and in accordance with statutory provisions and approved procedures.
NO
N/A
COMMENTS AMEC will co-ordinate all external relations efforts through a highly competent External Affairs unit and a committed management. We will strive for mutual understanding, using efficient, but transparent and ethical processes. AMEC will continuously assess/review that social/economic impact of it’s business activities and take preventative or mitigated measures as required. AMEC are committed to maintaining open communications internally and externally to guard against misconceptions, while ensuring confidentiality of project proprietary information. AMEC will assist within it’s limits to bring issues affecting host communities to the attention of appropriate authorities/bodies that can be of assistance. If there was any requirement AMEC would comply with it’s legal obligation, but would discuss the matter fully with SNEPCO.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES SECURITY POLICY HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES If sufficient physical threats exist against our people and property we would expect the forces of law and order of the State to give us appropriate protection. The right to use force rests with the state. In pursuance of the mission and objectives of the security management system, line management will draw on the services of SNEPCO’s security department and, through the latter, the support of the SPDC Supernumerary Policy Unit, the Nigerian Police Force and other Nigerian Security Organisations as required, subject to (ii) and (iii) below. SNEPCO will not operate in an environment where the continuous deployment of military or para-military forces is required to comply with the above policy, except where deployment is at the instance of Government for protection of key national facilities. Where the lives of personnel are at risk, SNEPCO recognises that the deployment of military or para-military forces by the government, in support of the police and civil authorities, may be necessary for as long as is required to restore law and order, if protection cannot be achieved by other means. This policy will be pursued in compliance with SNEPCO’s Guidelines on Use of External Security agents, insofar as SNEPCO is able to exercise control.
NO
N/A
COMMENTS AMEC will develop a security plan to ensure a secure environment and physical security of Personnel, worksites, equipment and material of AMEC, Clients and Sub-contractors. AMEC agree with SNEPCO Policy. Discussion on the matter would be essential.
AMEC agree with SNEPCO Policy.
AMEC agree with SNEPCO Policy. Discussion on the matter would be essential.
AMEC agree with SNEPCO Policy. Discussion on the matter would be essential.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES HSE MANAGEMENT POLICY HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES Set targets for improvement and monitor, appraise and report performance against those targets.
Make an assessment of the major hazards and effects to the environment and to the health and safety of people on all activities, materials, products and services to ensure that risks are tolerable and as low as practicable. Implement and maintain an HSE Management System, develop and maintain HSE Cases for HSE critical activities and assets that demonstrate HSE risk management application and improvement measures. Conduct Environmental Impact Assessments for all key activities and include the relevant recommendations in project execution plan for implementation. Comply with relevant legislation, identify areas of non-compliance and remedy as necessary.
Investigate and report all HSE incidents and near misses.
Provide the resources necessary to manage HSE risks.
NO
N/A
COMMENTS AMEC have an HS&E Leadership Team consisting of Director/Senior Managers and HSE Professional who monitor and review HS&E Performance and compliance to objectives set. Leadership and Board Report also document performance. AMEC will assess all aspects of health, safety and environmental hazards and effects to ensure the health and safety of people and the environment.
AMEC review and maintain its HS&E Management System regularly. HS&E cases are prepared when the project demands.
AMEC conduct environment impact assessments for all projects where it is required. Ref. HS&E Policy. AMEC also maintain a register of HS&E legislation and assess to identify areas of noncompliance. All accidents/incidents and near misses reported. The level of investigation is determined by actual or potential loss or harm. Full resource are provided within AMEC to manage HS&E risk.
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HSE MANAGEMENT POLICY YES Develop and maintain an HSE awareness and competence programmes for employees and contractors. Develop an awareness programme for third parties that may be impacted by her activities. Have an audit programme in place to review and verify effectiveness of the management system. Externally verify the SNEPCO HSE Management System to Group & international standards. Require partners, contractors, and suppliers to align with this policy.
NO
N/A
N/A
N/A
COMMENTS Ref. HS&E Policies and its HS&E Management System addresses competency of its employees. A training matrix has been produced and where necessary a project HS&E programme of training for AMEC personnel and third parties. Ref. HS&E Policies, HS&E Management System document and project HS&E Plans identify audit review will take place. AMEC’s HS&E Strategy document commits to external scrutiny of companies HS&E Management System, e.g. ISO 18001 assessment. AMEC will always seek to influence and improve the HS&E performance of all we work with.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES EMERGENCY RESPONSE POLICY HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES That response to any emergency will be directed towards: Saving life Caring for the injured Protecting the environment Limiting damage to assets
Close liaison shall be maintained with appropriate government and industry organisations and with host communities during emergencies. Regular exercises shall be carried out to confirm effectiveness of response and identified improvements made promptly.
COMMENTS AMEC do not have a written policy for Emergency Response. However specific arrangements are set out in: Company Standard Health, Safety & Environmental Procedure; AMEC-SP-GSP-010, International Emergency Response, which addresses emergencies occurring overseas. This requires that all overseas locations implement an emergency response procedures that addresses local arrangements Local procedures at each UK location addressing the arrangements for local emergencies. Addressed in company and local emergency response procedures
Addressed in company and local emergency response procedures
NO
N/A
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES HEALTH POLICIES HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES DRUG AND ALCOHOL POLICY STATEMENT The abuse of drugs and alcohol can be injurious to people and impair performance at work. SNEPCO shall ensure that all employees recognise this fact and aim to minimise associated risks.
NO
N/A
COMMENTS AMEC Group – AMEC Approach and Procedures relating to ‘Substance Abuse Policies’ – GSD/DRUG/REV 0-2/99, (sect. 3.0 ‘Framework Substance Abuse Policy’). Copy of AMEC Approach Procedure attached. GSD/DRUG/REV 0-2/99, (sect. 3.7 – ‘Advice and Assistance’).
SNEPCO recognises alcohol or drug dependence as a treatable condition.
Employees who have an alcohol or drug dependence are encouraged to seek medical advice, and to follow treatment.
GSD/DRUG/REV 0-2/99, (sect. 3.7 – ‘Advice and Assistance’).
SNEPCO will assist any employee to obtain treatment.
GSD/DRUG/REV 0-2/99, (sect. 3.7 – ‘Advice and Assistance’).
Any employee who seeks such help will not jeopardise his employment, however, alternative work may be considered.
GSD/DRUG/REV 0-2/99, (sect. 2.2, 3.7).
For any employee to be at work whilst impaired by drugs or alcohol.
For any employee to possess, uses, distribute or sell alcohol or illegal drugs on company business or work locations.
GSD/DRUG/REV 0-2/99, (sect 3.6 appropriate to testing, sect. 3.7 appropriate to personnel requesting help. GSD/DRUG/REV 0-2/99, (sect. 3.4, 3.5).
Take disciplinary action against any employee who, due to illegal drug or alcohol use is unable to work, except where such employee is undergoing medical help.
GSD/DRUG/REV 0-2/99, (sect. 3.4, 3.6, 3.7).
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HEALTH POLICIES
Test for abuse of drug and alcohol prior to accepting individuals for employment and at any other such time that there is reasonable cause for suspicion with the employee’s consent.
YES
NO
N/A
COMMENTS GSD/DRUG/REV 0-2/99, (sect. 3.6 – pre-employment screening, unannounced and testing on suspicion.
Conduct impromptu searches for drugs and alcohol at work locations.
GSD/DRUG/REV 0-2/99, (sect 3.4, pre-mobilisation search).
Conduct impromptu and periodic or random testing on employees.
GSD/DRUG/REV 0-2/99, (sect 3.6, unannounced and random testing).
If, on a first time basis, a test result is positive the employee will be allowed to continued in employment, provided there is compliance with the appropriate rehabilitation procedures. If thereafter a test result is positive, disciplinary action will be at SNEPCO discretion.
GSD/DRUG/REV 0-2/99, (sect.3.6, 3.7)
All SNEPCO contractors and subcontractors are required to comply with this policy.
All AMEC locations have a substance abuse policy.
In pursuing this policy, the company will continue to respect the rights of individuals, and will minimise intrusion into the private lives of its employees.
AMEC agree.
In the case of any illness, normal company benefits will be available. SMOKING POLICY Smoking, being recognised as injurious to health, is actively discouraged.
GSD/DRUG/REV 0-2/99, (sect. 3.7)
AMEC have a Company Policy on smoking in the workplace.
The smoking of cigarettes, cigars or pipes is prohibited in all SNEPCO hydrocarbonprocessing facilities, and other designated non-smoking areas, which includes offices and shared areas.
AMEC will comply fully with SNEPCO Smoking Policy.
AMEC agree with SNEPCO Policy.
CATERING
HEALTH POLICY All catering premises and activities over which SNEPCO has prevailing influence, should present no risk of illness to people.
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HEALTH POLICIES All food be protected from the risk of contamination of any kind. All catering staff be certified medically fit before employment, and periodically thereafter, and obtain a certificate of health and fitness. OCCUPATIONAL HEALT H POLICY To identify and make inventory of potential, physical, chemical, biological, ergonomic and psychological health hazards that may be associated with work and the effects of the working environment on employees. Evaluate the risk to health associated with exposures to these hazards and take action to remove or adequately reduce them.
ASBESTOS POLICY It is SNEPCO policy not to use asbestos. Use of Asbestos cement products is acceptable provided precautions are taken to eliminate any exposure of people to asbestos dust generated during a dust producing operation. Asbestos waste is extremely hazardous to health and shall be disposed in strict accordance with SNEPCO asbestos disposal procedures. MEDICAL EMERGENCY POLICY Maintain Medical Emergency Response Plans with the objective of minimising the consequences of acute illness or injury occurring at the work place.
YES
NO
N/A
COMMENTS AMEC agree with SNEPCO Policy.
AMEC will comply fully with SNEPCO Policy.
AMEC Health and Safety Policy – General Statement of Intent, Jan 16, 1998, endorsed by Roddy Grant, Managing Director.
Health and Safety Policy, (above). AMEC Group – AMEC Approach and Procedures relating to ‘Management of Health and Safety at Work Regs. 1992 – GSD/MHS/REV 1-12/97, (sect. 3.0, Risk Assessment).
AMEC will comply fully with SNECCO procedural requirements with regard to asbestos. AMEC also prohibit the procurement of asbestos products. Where asbestos is encountered in existing facilities AMEC have procedures for dealing with this.
AMEC have an International Emergency Response procedure which deals with acute situations and illness. Local UK arrangements are also in place. As above.
Maintain readiness to rapidly respond at all times.
Carry out regular exercises to confirm and assure effectiveness and identify improvement.
Yearly exercises are carried out to ensure effectiveness and identify improvements.
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SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY LIMITED (SNEPCO) HSE POLICIES ENVIRONMENTAL POLICIES HSE Policy and Objectives In this Section the Tenderer is required to include its policies on Health, Safety and Environmental Preservation. In addition, the Tenderer shall document where its Company Policies are in line and where they deviate from SNEPCO policies included in Part 4 – Proposed Contract, Section VIII – Drawings and Documents. Special, attention is brought to SNEPCO’s Third Tier (Worksite level) HSE Policies. YES ENVIRONMENTAL ASSESSMENT POLICY Identify any such interface between activities and environment for the complete lifecycle of facilities and operations.
Enhance positive effects and prevent intolerable impacts from occurring.
Limit the nature and extent of any residual negative impacts, however caused, such that they are as low as practicable.
Consult relevant stakeholders.
Leave the environment at the end of the useful life of any operation in a condition suitable for future use.
Routinely monitor the environmental status of each operation and take corrective action as necessary.
MATERIALS & ENERGY POLICY Use for its field location roads, facilities, borrow pits, etc the minimum surface area of land necessary for efficiency and safety.
NO
N/A
COMMENTS Each phase of activity shall undergo an assessment to determine all the environmental impacts associated with it. A significance evaluation is then carried out to determine those with the highest impact. Refer to APEL-EMP-01. Significant impacts are included within a Management Programme, ensuring that targets are set for continuous improvement. Impacts of medium and low significance are monitored as part of a programme to ensure that their impact does not increase. All relevant stakeholders are consulted. The operational controls in place as part of APEL’s Environmental Management System ensure that environmental impact is minimised. Monitoring of each operation is carried out on a routine basis, with corrective action being taken where necessary.
Refer to APEL Environmental Policy.
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ENVIRONMENTAL POLICIES YES Use the minimum of material and resources such as sand, laterite, fresh water and timber in order to achieve its business objectives.
Avoid competition that may arise with other users of natural resources.
Include fuel and energy efficiency as specifications and considerations in the procurement and operation of equipment.
Ensure that disposed items shall wherever technically feasible and economically viable; be maintained in a condition such that they can be re-used by other interested parties. PRODUCED
N/A
COMMENTS Refer to APEL Environmental Policy waste minimisation and efficient resource use are key to AMEC continuous improvement. Refer to APEL Environmental Policy Energy efficiency is a consideration in procurement decisions. Site based equipment is subject to a Planned Preventive Maintenance Schedule to ensure efficient working. Employees are encouraged to operate equipment efficiently through awareness programmes.
Be committed to development and application of renewables for its own energy consumption. Return any used assets to its original owners in a condition that is as near as reasonably possible to its original condition.
NO
All assets shall be treated with respect and care and will not be maliciously damaged. Whenever practicable, equipment is retained and refurbished for further use, for example computer equipment.
WATER POLICY
Dispose of produced water in an environmentally acceptable manner.
All emissions to water are with the prior knowledge and consent of the Environment Agency.
Prevent the disposal of produced water into inshore waters.
Adequate control measures are implemented to prevent this occurrence.
Reduce level of oil in water to the prevailing regulatory requirement as a minimum standard.
WASTE MANAGEMENT POLICY Take all practical and reasonable measures to minimise the generation of solid and liquid waste, as well as emissions to air from flares or otherwise.
In accordance with the APEL Environmental policy, oil levels are reduced to a practicable minimum and are in full compliance with legislative requirements.
AMEC strives to reduce emissions and wastes wherever possible, All aspects of waste minimisation are included within our objectives and targets in order to achieve continuous improvement. Refer to APEL-EMP-04.
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ENVIRONMENTAL POLICIES YES Not dispose to sea Oil-based Mud during drilling, but will return such wastes to shore for proper recycling or disposal. Manage and dispose all wastes in line with relevant regulatory requirements and environmentally responsible manner.
Track and maintain records of the full life cycle of waste streams and provide an auditable trail as to its management and disposal. POLICY ON THE USE OF CHEMICALS Use chemicals only where operationally necessary. Consider HSE aspects of all chemicals together with their commercial and process performance attributes and consideration of safer alternatives, before selecting and deploying them for use.
Eliminate Halons and CFCs from operations and prevent losses from existing stocks.
Provide Safe Handling of Chemicals (SHOC) cards for all chemicals used in the company.
N/A
COMMENTS
Store, transport, and dispose of all chemicals in accordance with statutory requirements.
Not accept any new chemicals from a supplier without the appropriate Material HSE Data Sheet (MDS).
NO
All AMEC produced waste is handled, segregated and stored in an appropriate manner. The waste is disposed of in accordance with our Duty of Care, using licensed waste management companies and disposal sites. A clear auditable trail can be shown from Duty of Care licenses through to waste transfer and consignment notes. Audits are also carried out upon the Waste Disposal Companies. Refer to APEL Environmental Policy. Chemicals are only used where necessary and where practicable, alternatives with less environmental impact are used. All chemicals are stored, transported and disposed of in accordance with statutory requirements. Refer to APELSP-016. Halons and CFC’s shall, where used, be phased out in accordance with the regulations governing substances that deplete the ozone layer. MSDS are required for all chemicals in use. The MSDS are retained and updated when necessary. Refer to APEL-SP-016. Details of any chemicals used would be included within the job risk assessment, and would highlight any precautionary measures.
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ENVIRONMENTAL POLICIES YES Specifically train all chemical handlers and emergency response staff in the safe handling of chemicals. GAS FLARING POLICY Ensure that all projects and activities avoid routine flaring as a means to dispose associated gas and similarly, require operators to do the same in other acreage with SNEPCO interest. Keep flaring to a minimum during production tests, commissioning, start-ups and operational upsets.
POLICY ON USE OF HALON FIRE EXTINGUISHING SYSTEMS SNEPCO is aware of potential impact of its activities on the environment and the people living in its area of operations.
The use of portable and fixed Halon fire extinguishers systems remain prohibited in SNEPCO operations as a result of its ozone depletion potential. This policy shall be applicable to all SNEPCO locations and our contractors shall comply with it. It is the responsibility of every contract supervisor therefore, to ensure that no Contractor deploys any Halon based fire extinguishing or suppressing medium. POLICY ON SPILLS Clean up all hydrocarbon and chemical spills emanating from the Company’s operations in a timely and efficient manner.
NO
N/A
COMMENTS All necessary training is provided to ensure the safe and correct handling of chemicals. Routine flaring of associated gas is avoided. For example, the Shearwater Environmental Discharge Objective for flaring is to restrict flare gas emissions to 0.3% boe. Flaring in these situations is minimised, as on the Shearwater project where onshore commissioning was maximised using LNG as the fuel gas, the use of Bacton pipeline gas and recycle mode for offshore start-up, and the control of WOBBE onshore by nitrogen injection, allowing off spec gas to be potentially exported and the WOBBE to be corrected onshore rather than having to by flare it offshore.
AMEC are also aware of potential impact of its activities on the environment and people. APEL’s HS&E Policies, HS&E Management System and procedures are in place to protect both the environment and people. AMEC do not use halon fire extinguisher systems due to their damaging effect on the ozone layer.
Refer to comment above.
Any spillage that may occur is responded to rapidly to ensure minimal environmental impact. The response is effective due to defined procedure and adequate training. Refer to APEL-EMP06 for typical example.
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ENVIRONMENTAL POLICIES YES Draw up contingency plans and provide resources for prevention and timely response to spills.
Effect clean up where the cause of the spill or the party responsible is unknown and in situations where SNEPCO is not liable, but public opinion may tarnish the company’s image.
NO
N/A
COMMENTS Spill response kits are made available throughout each area of operation as appropriate, in order to bring about a timely response. However, the occurrence of spills is minimised by control measures and procedural control. Wherever possible, AMEC shall always assist in situations where there is potential for environmental harm, and when necessary, would liase with the appropriate organisations to effect a clean up response.
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APPENDIX 5 EMERGENCY CONTACT DETAILS
Robbie Blight Tunde Ogunbiyi Denis Railton Philip Thomas
Company AMEC DEXTRON SPIE British Embassy
Telephone 00 234 053 253085 00 234 1 615254 00 234 1(2)616798 00 234 1 262 5930 to 37
Fax 00 234 053 253085 00 234 1 610299 00 234 1 261 6618 00 234 1 262 5940
Mobile
Email
[email protected]
002341 4708654
Warri Lagos Lagos
Philip.Thomas@abujx. mail.fco.gov.uk or
[email protected] v.uk
Dr Alibe
NETCO
00 234 1 (2) 611 232 00 234 1 (2) 611 230
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[email protected]
Lagos
th
2001 Schedule th th W/c 15 W/c 15 October November
BMT Representative
W/c 15 September
Brian Dixon
(Hartlepool)
Zwijndrecht
Colin Schofield
(Zwijndrecht 211,Old St.)
(Hartlepool)
Bob Austin
Derek Harwood
(Wallsend) 5. (Hartlepool 211,Old St.)
Wallsend 6.
Stephen Hope
(Hartlepool 5. 211,Old St.)
Bob Hamilton
(Hartlepool)
(Zwijndrecht)
Eric Abbott
(Zwijndrecht 211,Old St.)
(Wallsend)
1. 2. 3. 4. 5. 6. 7. 8.
(Zwijndrecht)
th
W/c 15 December
th
W/c15 January
W/c15th February
2002 Schedule th W/c 15 March
th
W/c 15 April
th
W/c 15 May
(Wallsend 211,Old St.)
Hartlepool 5
Zwijndrecht
(Wallsend)
(Zwijndrecht)
Zwijndrecht 5. 211,Old St.)
(Hartlepool)
(Wallsend)
(Zwijndrecht)
Wallsend Hartlepool Hartlepool
Wallsend (Wallsend 211,Old St.) (Hartlepool)
Zwijndrecht
Fabrication starts in Hartlepool 4.9.01 Fabrication starts in Wallsend & Zwijndrecht on the 1.10.01 Sites in BOLD type are the monthly HSE construction site meetings attended by the nominated BMT representative and Ron Malone/Nick Beesley for all meetings. Refer to the HSE plan S5.1 Demonstrating Compliance. This will also incorporate a BMT site safety tour and scoring audit. The locations in (brackets) reflect the allocated BMTsite and office inspection rota. Please note the changes and switch in site allocated. The first meeting at Wallsend is targeted to be a best practises workshop and will also incorporate a BMT site safety tour and scoring audit. Nigerian Fabrication to be added when available. NETCO office inspections to be undertaken as visited by BMT.
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