1
2
2
TABLE OF CONTENTS Section
Table of Contain
Page
0.0 Tutor Log…………………………………………………………………………… Log…………………………………………………………………………… ...… ...…..04 1.0 Executive Summary………………………………………………………………… Summary…………………………………………………………………....05 ....05 2.0 Introduction……………………………………………………………………………… Introduction……………………………………………………………………………… 06
3.0
4.0
5.0
2.1
Aims an Objectives…………..…………………………………………………… Objectives…………..……………………………………………………06 06
2.2
Methodology……………………………………………………………….…… Methodology……………………………………………………………….…… ....06
2.3
Description of Organizations…………………………………………………….. Organizations…………………………………………………….. 07
2.4
Legal Environment………………………………………………….…………… Environment………………………………………………….…………… ..07
Review of Health Health and Safety Management System (H&S-MS) Description…0 Description…08 8 3.1
Descriptions ………………………………………………………………………..08 ………………………………………………………………………..08
3.2
Gap Analysis… Analysis….. ..……………………………………………………………...... ……………………………………………………………..........09 ....09
Hazards Identification………………………………………………………………… Identification………………………………………………………………….10 .10 4.1
Physical Hazards ………………………………………………. ………………………………………………..…………… .…………….....10 .....10
4.2
Health & Welfare Hazards ………………………………………………….…....13 ………………………………………………….…....13
4.3
High Priority Physical Hazards falling from height …….………………………14
4.4
High Priority Health Hazards -Sulfur Dioxide (SO2) exposure …….………..15 …….………..15
Risk assessment …………………………………………………………………….....15 5.1 Methodology of Risk Assessment …………….…………………………………...15 …………….………………………………….. .15 5.2 Risk Assessment for physical hazards falling from heights …………………….16 …………………….16 5.2.1
hazards…………………………………………………..16 Identify the hazards…………………………………………………..16
5.2.2
Decide who might be harmed and how……………………...……. how ……………………...…….16 16
5.2.3
Evaluate the risks and decide on precautions………………... precaution s………………........16 .....16
5.2.4
Record findings and implement …………………………………… …………………………………….19 .19
5.2.5
Review risk assessment and update if necessary ………………19 ………………19
5.3 Risk Assessment for health hazards Exposure to SO2…………...…………… SO2 …………...……………..19 ..19 5.3.1
Finding out what the problems are(information are(informat ion gathering) ……....19 ……....19
5.3.2
Evaluate the Health Risks …………………………………………..20 …………………………………………..20
5.3.3
Evaluation Evaluation of Existing Controls…………………………………. Controls………………………………….....20 ....20
5.3.4 5.3.5
Recording Risk Assessment findings and implementation implementatio n ……..22 ……..22 Proposed New Control measures…………………………………. measures………………………………….22 22
6.0
Conclusions…………………………………………………………………………… Conclusions……………………………………………………………………………..23 ..23
7.0
Recommendations ……………………………………… ………………………………………..………………………..…. ………………………..….24 24
8.0
Action Plan…………………………………………………………………………… Plan……………………………………………………………………………...26 ...26 8.0.1
Management System Gap Analysis & Gap Closure Action Plan…… Plan……...26 ...26
8.0.2 8.0.3
Cost and Benefit Benefit Physical Hazards Falling from Heights ………………27 ……………… 27 Cost and Benefit Health Hazards Exposure to SO2 ……………………28
8.1 Hazards & Risk ……………………………………………………………… ………………………………………………………………..……...30 ……...30
9 10
8.1.1
Physical Hazards Recommendation …………..……………………….. …………..………………………...30 .30
8.1.2
Health Hazards Recommendation Recommendation…………..……………..…………….. …………..……………..……………..32 32
Reference / Bibliography ……………………………………………………………..…… 33 Appendices …………………………………………………………………………………… 33
3
1.0 Executive Summary The report provides overview of current Tadmur Health and Safety management arrangements with critical review of Health and Safety Management System (H&S-MS). This will include an evaluation of risk assessment effectiveness respectively on one high priority physical and health hazards. As improvement new control measures shall be introduced to further reduce the risks. The recommendations for implementation of these new control measures will be strengthened with evidence base justification, cost-benefit analysis with specific action plan to improve company Health and safety performance. Risk Assessment evaluated using recognized methodology involves physical hazards falling from heights while working on ladde rs was rated “High Risk”. The risk rating reflected as such due to significant height involves where the person working on ladder cannot maintain three contact points and probability of falling is likely with fatal consequences. The risk evaluation exercise successfully manages to further reduce the risk from high to low with applications of new control measures by using new smart engineered designed platform ladder. This ladder is designed with working platform, complete with hand rail & middle rails which allow worker to work with both hands. Similarly a health Risk Assessment evaluation found workers engaged in activity at AKG are at high risk on exposure to hazardous Sulfur Dioxide Gas (SO2). This is due to inadequate collective safety measures in place to provide early warning system to work group. They rely on personal toxic clips, where plant fixed gas monitor is not strategically located near the SO2 source or their workplace. New mitigation measures is to strategically place four unit of Portable Multi-Gas detector which will give workers four minutes advance warning on SO2 hazards. Advance notice means more time to escape to safe area and less likely to be exposed to such a hazardous gas. It is estimated that the one-time cost (until project completions) of providing 2 units ladders and 4 unit of portable gas monitor is eighteen thousand dollars. Based on detail cost benefit calculations using recognized method, the investment on both this item clearly indicate that company monetary saving is about one hundred eight thousand dollars. This significant amount is saved when the probability of injury arising from fall from height hazards and health exposure to SO2 was brought to low probability at the same time drastically reduce the consequences throughout the project durations. Overview of Tadmur H&S-MS satisfactorily demonstrates that they have established policies and processes, to safely manage the work. Nevertheless there area of improvement or gap identified during the HSE-MS review process. Issues are insignificant in nature however need to be attended by providing adequate resources, coaching and mentoring. Concern including lack of updating legal register, Incident investigations root causes not giving significant to system factor (organization failures) and Lagging in emergency response plan implementations. Exposing personal at high risk is a non-conformance to safety standard set by company, client as well Qatar legal requirement on related laws, Timely approval by management on item involving additional cost shall allow all action items implemented without further delay. All administrative actions item has been progressively implemented. The fundamental questions need to be asked is not how much it cost but how bit many life it can safe.
4
2.0 Introduction 2.1 Aims an Objectives The aim of assignment is to carry out the detail review of health and safety performance of a workplace selected and produces a justified action plan to improve safety performance. This including review of Tadmur health and safety management system as an organization and indicate using risk assessment, the priorities for organization in future. The assignments will priorities the identified hazards and carry out a risk assessment on one physical and one health hazards. This shall include an evaluation of the effectiveness of organization in controlling the risk from hazards identified and proposed to further control the hazards and reduce the risks as low as reasonably practical. Specific action plans proposed with clear accountability measurable, realistic, timely & effectively implemented. This action plan if successful implementations can be measured for effectiveness using existing company key performance indicators (KPIs). Obtain management approval by providing required resources to implement the proposed new action items. This shall be significant undertaking by the organization to improve workplace health & safety. At the same time provide data on relevancy of costs involve to its benefits, nevertheless made them aware of the implications if the action plan not implemented. Report is structured in a way so that the Management is clear and realizes that there is important outcome identified both on health and safety issues related to workplace that must be urgently addressed by company.
2.2 Methodology As part of my assignment I shall review and conduct gap analysis on Tadmur H&S-MS. The Gap analysis shall recognized process e to determine where shortfalls occurring in Tadmur H&E-MS. Use the gap analysis to figure out what is needed to get what currently exists to the point where it becomes what the company desires (what is needed to get f rom point A to point B). Method of collecting information, data and feedback for assignment will be by participating in Safety walkthrough, inspection, hazards hunting, list all work activities and look at each step, look at the ways different tasks could interact and create hazard. Also look at past near misses incident, accidents, injuries and look at any hazards, safety information and instructions from manufacturers or suppliers instructions. Most importantly I will talk to people who have the knowledge on the similar job & finally with direct interaction with workers involved in the tasks. I obtained additional information by referring to OSHA, HSE UK and other relevant publications or website. The process will involve various methods including but not limited to comparisons against recognized Health & Safety model such HSG65 to determine the continuing suitability, adequacy and its effectiveness so that we can propose to improve and update an existing one if required. Meanwhile the Risk assessments shall be completed using recognized risk assessment tool combined with research, field observation, local legal applications and information gathering using various methods. I shall measure the adequacy of existing control measure & residual
5
risk, study the consequence & probability of the hazards and identify new control measures. This will eventually reduce the risks further as low as reasonably practicable (ALARP) and ensure fully comply with Qatari applicable legal requirements & best practices in the industry. 2.3 Description of Organizations Practical workplace assignment focused on one specific project, constructed by a company called Tadmur ROOTS Energy & Engineering Services W.L.L (Tadmur). The workplace location is at Ras Laffan Industrial City in Qatar. This project was awarded to Tadmur by one of world largest single LNG Producer RasGas Company Limited on January 2012. The project is plant labeling project which currently ongoing at our client RasGas sales gas processing unit called AKG. This is standalone complete processing plant. The number of workforce engaged in particular project is 292 persons including administration and management staffs. The organization leads by a Project Manager with two Construction Managers, four Site Engineers, and 10 Discipline Supervisor. Dedicated safety section oversees this project lead by Safety Manager with six Safety Officers and one Safety Administrator. Contractor work force include Skilled/ unskilled, different age group that range from 19 to 58 years, different ethnical backgrounds and nationalities such as Indian, Philippines, Pakistan, Qatari, Malaysian and British. Indian nationality made up 60 % of the total man power in the project, Filipino nationality 25% and the other 15% are equal representation of Qatari, Malaysian & British mainly on Senior Management levels. No female, young person or staff with disability engaged either from contractor or clients in the field. The project work equipment‟s including various types of work at height equipment‟s, machinery such as folk-lift, Man-lifts. Mobile crane, pick-up trucks, 3 ton cargo trucks, passenger bus and some specialized equipment used on ad-hoc on rental basis. Most, if not all of this machinery & equipment used at sites are relatively new approximately below five years. Currently work progresses on day shift, daily work start at 0700 hours and shift end at 1700, a total of 09 hours. This nine hours shift consists of eight hours of normal working hours and an hour for lunch break. The work currently 85% completed, well ahead of scheduled 80% versus actual as of July 2013. The project expected to be completed on December 2013, twenty four months from the day actual physical work started on January 2012. The physical work nature is to place color coded self-sticking adhesive label either with signage such as arrow or wording indicating the product & flow directions on each and every pipe line, valve and selected equipment‟s covering the AKG plant area. The purpose of placing the stickers is for operator to easily identify the process flow direction. This project when completed is expected to improve process safety in particular related incident involving human error opening wrong valve or operating wrong equipment‟s. 2.4 Legal Environment HSE Framework issued by Directorate on 5 May 2011 is the main piece of legislation on for oil & gas industry in Qatar. However HSE Framework is not an independent piece of legislation, but rather takes the relevant HSE provisions of the various Qatari laws and regulations and assembles them into a single document. Although the HSE Framework does
6
not replace the provisions of existing legislation, it cross-refers specific articles to their original legislative source, thereby providing valuable assistance and guidance in respect of complying with the various H&S requirements e.g. Qatar Construction Specifications 2010 (CDS), Qatar Labor Law 14 (2004), Qatar Environmental Law 30 (2002), Civil Defense, Fire Safety Standards Handbook, Qatar‟s Penal Code, Consumer Protection Law. A code of practice is admissible in court proceedings as evidence when managing a hazard, risk or control at workplace of whether or not a “duty of care” has been complied with. Approved code of practice applies to anyone who has a duty of care in the circumstances described in the code e.g. QCS Specifies Legal Duties to duty holders & empowers Qatar Authorities to prosecute for non-compliance. Current law mainly Prescriptive Legislation where the law state clearly what must be done or not done in particular situations. The government is moving towards Goal Setting type law, which is more relevant in this modern era when things keep changing in fast phase with benefit of promotion of self-regulation legislation e.g. CDS. Overall Qatar H&S legislation is influencing company to pursue high standard on H&S by exceeding the minimum standard set by legal requirement. A major incident at workplace will result in significant fines, jail term, attract unwanted publicity by media and these can tarnish company reputations hence is bad for business. Employers are more vigilant and committed in developing and enforcing H&S programs which can bring about improvements in safety management and more effective means of preventing harms and preparing fo r emergencies. 3.0 Review of Health and Safety Management System (H&S-MS) 3.1 Descriptions Tadmur is adopting OHSAS 1800, an internationally recognized accredited standard for occupational health and safety management. It provides detailed requirements for compliance with the legal requirements. It was awarded to organizations following a successful audit by an awarding body. Tadmur Management is aware that effective health and safety system will typically create safer and healthier workplaces, meet customer expectations better than an organization that does not have an effective H&S-MS comply with regulations e.g. (Section 11 - Health & Safety: Part 2 SAMAS 2.1 Safety, Health & Environmental Management System. Similar to HSG 65, it principles still revolve on „plan, do, check, and act. HSG 65 Health and Safety Management System (H&S-MS) is well known for systematic “POPMAR” policy, organization, planning and implementing, measuring, auditing and all elements are cross referencing with reviewing for Continual Improvements. The fundamental different is that HSG 65 H&S-MS is not a specification nor it is an approved code of practice. It does not provide detailed requirements for compliance with the legal requirements for key management activities such as planning, monitoring, measuring, audit and review. However it does state that following the guidance will normally be enough to secure compliance with the law (2) Successful health and safety management .
7
Nevertheless HSG 65 H&S-MS provides guidance and advice on good practice and raises the importance of leadership, employee involvement and gave significant important to health and safety culture. 3.2 Gap Analysis Gap Analysis was based on OHSAS 18001 2007 which defines a set of occupational health and safety management system requirements, review mainly based on sections 4.1 to 4.6 of these requirements (3) Institution OHSAS 18001 2007OH&S. This was accomplished by various means of initiative, starting with advance notification followed up with initial meeting with Tadmur Project Management and Work Supervisors to discuss the scope, objectives, and activities and schedule to review Tadmur level of compliances to HSE Management System. The review process was conducted between 3rd of August to 7th August, 2013. The exercise was scheduled and completed within 5 working days as planned. Document review mainly conducted in office environment except for selected document such as Permit to work and its attachments reviewed and audited at work sites. An on-site review was conducted by interviewing 21 Tadmur full-time personnel throughout the organization including the Projects Manager and Constructions Manager, discipline Engineer, Supervisors, Foreman, Permit Holders and all trade employees at office & work front. The process also included significant numbers of physical workplace visits, participations in scheduled Management Safety walkthrough, Site Inspection including checklist based inspections. Perceptions of the H&S-MS system components currently in place were discussed and significant important was given in reviewing Tadmur previous internal & external audit reports. Tadmur satisfactorily demonstrates that they have established policies and processes, to adequately manage the work. In most fields they exceed the minimum requirements set by OSHAS 18001 and compatible with Client H&S-MS. Occupational Health and Safety has Clear policies, documented system in place for continuous improvement and Leadership commitment found very visible. It describe adequately on how hazards and effects are to be identified, assessed, controlled and how recovery in the event of loss of control will be carried out. It also describes how the adequacy of existing controls is evaluated and additional methods for managing / minimizing the HSE risks are identified and implemented. Tadmur define the responsibility for developing and maintaining the H&S-MS and for establishing H&S accountabilities at each level of the organization. H&S competency levels defined and training provided to ensure that all employees are aware of, and understand, their H&S Policy. Implementations of corrective action system are in place to monitor and measure performance against compliance. Tadmur adopt a structured approach and ensure that activities and tasks are always conducted according to procedures and work instructions. Performance monitoring includes both leading and lagging indicators. There is system in place on efficient communication and consultation on H&S performance as well as document and data control. Personal who execute this task found Competent. Management Review system in place to ensure continuous improvement on all aspect of H&S-MS, noted effective system to develop workforce capability including in-house dedicated training center. There are audit plans, protocols for conducting the audit, reporting of findings, and tracking of recommendations for improvement.
8
Nevertheless there area of improvement or gap identified during HSE-MS review process. The Gap Analysis is presented in table format under 8.0 Action Plan heading page 28 for easy reference, understanding and tracking for close out . 4.0 Hazard s Identification The workers while carrying out their activity are exposed to wide range of type hazards. Exposure levels are different depending on their locations and nature of work. Overall the hazards involved in the workplace can be beaked down to categories such as chemical, physical, biological, psychosocial, mechanical ergonomics, stress, electrical, fire & explosions, and traffic. These hazards identified from workplace through inspections, consultation between employees and Tadmur Supervisors, monitoring injury & near miss records, recoded complaints and finally trend analysis from safety unsafe act & unsafe condition observation program. Hazard prioritization based on how likely an Injury will happen, how many people could be affected or exposed. Identify different situations or conditions that may exist could increase the risk, thinking about the consequences of each hazard Attend most serious risks as priority e.g. immediately. Minor risks more time is acceptable if required. Finally use existing RasGas Risk rating register as reference as attached in table below.
4.1 Physical Hazards The labeling points either on pipes or equipment located at various heights range from ground level at lowest & approximately 10 meters at highest. The type of ladder used mainly are twin step “A” frame ladder which provides rungs on either side of the ladder allowing one to climb up whichever side is more convenient.
9
At about six hundred labelling location at height between 5 to 10 meters the site conditions congested with piping and structure beam obstructions. This doesn‟t allow access for mobile elevating work platform or scaffold platform erections. Since the task is of the short duration, work ladders are the only realistic option; special design scaffolding will be expensive & not cost effective. Workers will be working on this “A” frame step ladder by engaging both of their hand on the task, as it is not possible to wrap the label using single hand. This exposed workers to fall from heights hazards & the risk of falling is considerably high & the consequences will be serious injury or even fatal. The existing control measures incorporate strict regime of safe work practices while working on ladders. (4) Safety in window cleaning using portable ladders (5) Safe use of ladders and stepladders Any work that is identified as meeting the W orking at Height criteria will be managed within the "Permit Pack" as required by the client permit to work system. Ladders only are used for light work of short duration at area not practical for man lift & not cost effective for scaffold platform. Ladders inspected by competent person with inspection tag, has a suitable load rating for the job, daily pre-use check, personnel trained with competency assessed for working with ladder and Work at Heights. An approved rescue plan is in place, Second & third person will hold ladder firmly at bottom while third person climbing. A shoulder bag will be provided for carrying labels while climbing ladder. No other equipment required for the task. Personnel will not stand on the top three rungs of steps of a stepladder, supervision, training & instructions. However due to task nature and site conditions following control measures seen as not practical and effective. Using personal fall protection equipment‟ (PFPE) Maintaining three contact points while working on ladder. Use of collective fall protection equipment such as air bag or net is also not feasible due to site conditions. These hazards shall be further discussed under high priority physical hazards.
Ignitions source -To gained access to height for labeling Man Lift, scissors lifts & similar type aerial work equipment‟s run by diesel is widely used in this project. The use of such equipment is rated as high risk fire and explosions hazards in live plant. Operation of this mechanical equipment strictly control by client operated Permit to work system. Addition control measures include use of flame arrester on exhaust and boom gate blocking strictly no go area. Heat Stress - The summer climate in Qatar is very hot and humid, with summer temperatures ranging from 30 to 50 °C and average relative humidity of 25 to 75%. The climate creates a potentially dangerous situation (high risk) for personnel exposed to the heat and humidity. As most of activity involves working at height this significantly increase the risks secondary effects such as fall from heights. Workers are trained to recognize heat stress signs and symptoms, as well as environmental conditions, to protect themselves and others. They are briefed on f actors such as age, weight, degree of physical fitness; degree of acclimatization, metabolism, clothing type use of alcohol or drugs and a variety of medical is contributing factor. Administration control includes Work Scheduling, Work-Rest Intervals, Employee Rotation, Fluid Replacement (provision of coo water & need to carry water bottle while working), Buddy System, Acclimatization, Reduce Internal Heat Generated by Workers & advisory on applicable diets. Finally Clothing and PPE as a last resort.
10
Hot surface and cold surface of pipelines and equipment‟s has high probability for workers to come in direct contact with of these hazards. Existence of such hazards cannot be completely eliminated due to the nature of natural gas processing. In some area pipelines is insulated with insulation materials however in other area it is without any insulations. Advertent contact with these surfaces can cause burn to skin (hot) or cold burn (frostbite) injuries to workers engage in labeling tasks. Two such cold burn reported as first aid treatment case in past six months. Surveying the area with plant operator and identify such hazards before work commence is established in work system. If the condition permit heat retardant barrier sheet utilized. In other are it is area marked with temporary caution sign‟s. Other mitigations include maintaining adequate distance from the hazards and as last resort use of hand gloves. Noise hazards in operating plant is of continuous magnitude rather that intermittent or impulsive, the source is from equipment such turbine compressor and generator in the vicinity of work. Noise is considered significant hazards since the decibel involve is about 85db to 98 (dB) decibels. It can cause noise-induced hearing loss, it can affect workers by damaging damage the hair cells and nerve endings in the cochlea. One of the most common types of hearing loss is called tinnitus. Damage to the cochlea or any part of the inner ear often leads permanent hearing loss is more significant. Noise also can cause other effects such as speech interference, lack of concentration, and annoyance, these conditions is more harmful to susceptibility individual. The existing noise level is a residue after engineering control measure already incorporated in the equipment design hence nothing much can be done to mitigate other than administration & PPE controls. Existing control including permanent signage posted on level of noise & mandatory PPE requirements. Some area requires ear plug while other area require ear muff and there is area where dB is more than 95 double hearing protections is required. Workers are trained in use of hearing protection equipment‟s, and managing exposure time. Workers also provided information in noise hazards & its effects of hearing loss potentials on continuous or prolong exposure without adequate hearing protections. As part of pre-employment medical assessment Audiometric test is conducted to ensure there no existing condition, which can be made worse on continuous exposure. Hazards associated with operating Man Lift and similar type aerial work equipment‟s common dangers of operating a man lift involve more than just fall from heights. Scissor lifts hazards including body party or limb getting caught and crushed in the scissor arms. This could occur when the scissor lift lowers and the arms compress over each other. Danger of electrocution when come into contact of power line, checking for power lines or electrical hazards in the work area before operating a man lift is essential. Loading too much weight into the basket of the man lift could result in the man lift collapsing or being overturned. Overturning could also result when the base of the man lift is set on uneven ground or slopes. Potential workers falling off the man lift drop an object from up high on the man lift and could cause bodily harm to individuals below. This is why most workers with a man lift are required to put up safety signs or caution around the perimeter of their workspace. Uses of full-body harness where workers need to be train on it use e.g. never hook the lanyard snap hook outside the basket, there is lanyard securing point designed in the basket itself. Other Mechanical hazards are from labeling work which takes place near compressor or generators under maintenance or repair. The guarding for rotating part removed in generator
11
to accommodate such work. There is potential this equipment switch on without knowing labeling activity is taking place near or on the equipment‟s. We mitigate such hazards mainly using Permit to Work System by not allowing any labeling near the equipment under maintenance regime. Other barrier in place is by placing rigid barricade, signage posted, Supervisions & good communication between different work party or different company coordinated by client. Traffic hazards such as vehicle, man lift or pick-up truck struck personal, permanent structures and collisions between other equipment‟s. Loss of stability is another high risk hazards, it can cause significant harm to operator & to other person the vicinity nevertheless can damage the plant equipment‟s and as secondary impact on this is potential fire or loss of containment of product e.g. LNG due to line or equipment rupture. Engineering control measure mainly incorporated in design of equipment. The cage would need to be of adequate design and construction and provided with guard rails and toe boards, and its total weight including that of the person or persons allowed to work clearly rated safe working load of the have to be clearly marked on the cage. Administration control in important for safe operation of such equipment‟s both the cage and truck should have been thoroughly examined and tested in accordance with the requirements of LOLER. Communication between the driver and the person in the cage (if not controlled from cage) should be maintained. Barriers need to be positioned round the working area to protect from collision and to prevent passers get into line of fire. Training for operator includes combination of documented instruction using lecture, discussion and written material. They shall be engage in practical training such as demonstrations performed by the qualified Instructor and finally he shall undergo practical exercises, assessments & evaluation when operating at the workplace.
4.2 Health & Welfare Hazards Sulfur Dioxide Health Effects is significant hazards as work is carried out at live operating LNG plant. SO2 is by product during sulfur recovery in LNG liquidation process. It has no monetary value and incinerated before released to atmosphere. Loss of containment is the main cause of accidental release, mainly caused by leaks in valve. Workers are exposed through inhalation or skin contact; it mostly affects the nose, throat if high concentrations or breathing heavily through the mouth will significantly impact on the lungs. It Sensitivity varies among people. Corrosive effects on skin eyes and lungs may be delayed and damage may occur without the sensation or onset. Repeated exposure may lead to contact dermatitis, may cause bronchitis with cough shortness of breath and emphysema (chronic runny nose, nose bleeds, tearing of eyes & stomach upset) Existing medical conditions possible aggravated by exposure (existing skin lesions, person subject to asthma attack may experience asthmatic paroxysm, cardiovascular disease. (5)NIOSH & Centre of Disease Control & Prevention Existing control measure including continuous gas monitoring, 4 fixed gas monitor at various location in plant, wind socks erected & visible from work locations, all personal provided with SO2 toxic clips, SO2 awareness sessions conducted, restricted access to high risk area of AKG via signage and barricades and standing instruction was created which covered strict emergency response, evacuation to identified temporary refuge building in the vicinity.
12
Biological hazards is not significant but still need to be addressed virus infections such as Hepatitis A is usually spread when a person ingests fecal matter even in microscopic amounts from contact with objects, food, or drinks contaminated by the feces, or stool, of an infected person. This health illness potential arising from poorly maintained personal hygiene and portable toilet mobilized for workers use at various locations at worksite. Portable toilet is not easy to be maintained in tip top condition or at high level cleanliness at all time. This due to the nature they are spread out in large area & limitation on water storage. Mitigation measure are by providing pre determine schedule to clean it more frequently & system in place to arrange for sewage removal when required or as per scheduled. Other main mitigation is by practicing good hygiene e.g. washing hand after visiting toilets, before handling food or before taking lunch breaks & end of shift. Manual handling hazards arises when workers carrying boxes of stickers, ladders and scaffold materials to and from storage area to work locations. This involves lifting, pushing, pulling, carrying or moving of various size and weights of load. Poor posture arises from everyday activities aggravating back pain and damaging spinal structures. Effective ergonomics & correct manual handling technic are within our control and not difficult to mitigate, by conducting ergonomic risk assessments we identify ways to improve posture especially for target workers who are more exposed to such hazards than others. These hazards rated as medium since there is no reported case for last 3 years. This not only implemented at work site but in office environments as well (contractor site office). Workers are trained to identify good and bad working posture & they are made aware of warning signs of back pain caused by poor ergonomics and posture. Among other control measures incorporate body in alignment while sitting and while standing, distribution of body weight, regular exercise, lift with leg strength rather that back, keep back straight while lifting material, limit the weight one can carry, keep load close to body and continuous. Work related stress hazards arising from range of work related activity rated as medium risk hazards. Fatigue is a concern as at a time in project phase working in access of 12 hours shift cannot be avoided. Prolong exposure to the elements e.g. extreme summer heat combine with peer pressure to coup up with strict schedules. Supervisor is subjected to work related stress mainly due to having too much to do with too little time. They are made accountable on safety & progress of multi group workers. They are also accountable or and responsible on workers traveling or commuting arrangement within multiple project site within Ras Laffan. Stress involving lower ranks such as semi skill & unskilled workers includes excessive demands impose by Supervisor to achieve target on how many number of labels completed daily. Hazards related to life style such as drug abuse & alcohol is negligible (low) based on previous history and the culture of state of Qatar which is a Muslim nations. 4.3 High Priority Physical Hazards is falling from height while working on ladder. My high priority physical hazards selections is falling from heights while working on A frame ladder. Detail of these hazards was captured on physical hazards headings. The hazard selected due to project recoded four near misses on falling from heights, on top of that the project safety observation trend analysis continue to show uptrend on non- compliance on 3 contact points requirements when working on ladder. Feedback from workers engaged in the
13
labeling activity shows their frustration when explaining it is practically impossible to use single hand to wrap the label around large pipes. To get the job done they simply has no other options other than use two hands to work where this placed them at risk of falling from heights. Existing mitigations does not satisfy the duty of care obligations by employer to bring the hazards as low as reasonably practicable (ALARP) as per State of Qatar applicable legal requirement. It did meet RasGas procedural requirements on working on ladders and suitable and sufficient risk assessments. Legal requirement applicable includes SAMA Article 2.3.12 Control of Working at Heights When considering what precautions are necessary to control risks associated with a project, everyone who has a duty under these Regulations must take account of the general principles of prevention in line with SAMAS Article 2.3.1 Risk Identification & Management. The risk arising from these hazards shall be evaluated and mitigated further to reduce the risk to as low as reasonably practicable under the heading of Risk Assessment. 4.4 High Priority Health Hazards -Sulfur Dioxide (SO2) exposure to plant labeling crew. SO2 is selected as high priority health hazards due increase reported case of SO2 uncontrolled releases at AKG area. SO2 were being released. There is evidence of client Engineering design failure in SRU incinerator located near work locations at AKG. This product is listed in as a highly hazardous and can cause severe health effect both chronic (6) SO2 Material Safety Data and acute. It can be exposed to large number of workers at any given time. Existing control measures on SO2 health hazards found to be inadequate and the risk level is rated high. Current Risk assessment did not satisfy Qatar legal requirements and finally to further reduce the risk as low as reasonably practical. Similar to physical hazards the evaluation of this health hazard shall be addressed under the heading of Risk assessments. 5.0 Risk Assessment (RA) 5.1 Methodology of Risk assessment - RA My RA shall be Scenario Based Risk Analysis (SBRA) it is Qualitative and it employs structured brain-storming in which the RA Team uses its knowledge and experience to identify potential hazards. Qualitatively assess the risks associated with those hazards. The hazard identification process focuses on human action/inaction, work process, equipment used and external factors that may cause an incident to occur. Hazards are identified using one or more methodologies such as brainstorming, What-if/Checklist, workplace inspections , consultation between employees and employers, monitoring injury and illness records and observation. Once hazards have been identified along with their possible causes, consequences and safeguards, risk scenarios are developed to describe how each event may occur. The Risk Matrix provides a means to estimate and convey the probability category and consequence(s) of a potential incident as regards the safety and health of workers and the public, the environment, public disruption and f inancial loss. The position of a risk scenario on the risk matrix helps to determine the priority for risk reduction measures, as well as the level of management approval required for those measures or for continued operation.
14
The RA methodology is based on client Risk Management System (RasGas management‟s expectations regarding the role and use of the RasGas Risk Matrix and its classification system). 5.2 Risk Assessment for hazards falling from heights while working on ladder 5.2.1 Identify the Hazards As identified in Risk Assessment Methodology section various means has been used to identify the hazards this includes , inspection, hazards hunting, list all work activities and look at each step, look at the ways different tasks could interact and create hazard. I also review past near misses incident, safety information and most importantly the detail of hazards surfaces when talk to people who involved in the tasks. I obtained additional information by referring to OSHA, HSE UK and other relevant publications or website. 5.2.2 Decide who might be harmed and how Most all plant labeling operatives engaged in work on ladder is exposed to harm falling from heights. Detail of who might be harmed discussed with Tadmur Supervisor to identify whether any new or young workers involve in the activity. It was established only 2 persons from each group allowed to work on ladders; all of t hese workers are adequately trained and has good knowledge on work area environments. Period of Exposure based on work expected completion for AKG in 6 months, shift working hours 8 hours per day, 6 days week is 2,160 hours. Calculations breakdown as follows: Per day 1 person actual exposure to falling from heights (ascending + descending + working), for placing 6 label is 20 minutes x 6 labels = 120 minutes Per day 6 persons actual exposure to falling from heights per 8 hour shift is 720 minutes (12 hours) Per month exposure for 6 personal 720 minutes x 30 days = 21,600 minutes (360 hours) Per 6 months 21,600 minutes x 6 months = 129,600 minutes (2,160 hours) Note: 60 minutes required shifting and assembling the ladder at each work locations, working with ladder requires 20 minutes. Means actual time for completion of each label using one ladder is approximately 80 minutes. Work descriptions using 6 ladder involving 6 personal (Each ladder group consist of 8 to 10 personal but only one personal working on ladder at a time).
The operatives can fall from heights while working on ladder using both hands for placing labels on the pipe spools and equipment‟s when loose his balance, try to overreach, person holding the ladder fail to keep the ladder firmly upright, or ladder assembly fault. They also can fall when ascending and descending from ladder due to damage rug, slippery due to oil or poor footwear sole, carrying material on hand and fail to maintain three point contacts on ladders. Other possibility includes fatigue, secondary effects from heat stress, horse paly and finally rushing to come down from ladder to react to gas emergency alarm. The consequences of fall can be severe bodily injury or even fatality. . 5.2.3 Evaluate the risks and decide on precaution Current risk rating is CI fall under high risk region in as the Consequence lead to one or more fatality and Probability is measured as Possibility of Occurring Sometime. – Refer to Table 01 Risk Rating. Risk rating evaluations based on the effectiveness of existing control measures by observation of actual task and taking feedback from workers engaged in the activity and with following considerations.
15
Working on normal twin step “A” frame ladder height about 10 meters, not practical to achieve 3 contact points while working on ladder due to both hands required to place the label. Ladder cannot be secured at top & bottom, it is firmly held by two people to maintain stability. Persons holding the ladder potential to be off-guard momentarily or leave only one person for the job which is inadequate. Provision of Personal Fall Protection Equipment not practical since there is no firm anchoring point. No collectives fall protection equipment use due to site conditions Ladder use strictly limited within those areas where MEWP have limited maneuvering space and scaffolding erection not feasible due to site conditions Provision of ladder inspections by competent person & pre-use user inspections in place All operatives adequately trained in working at heights & working on ladders Provision of Safe work practice on ladder fully adopted & robustly maintained by full time Supervisions e.g. not stepping on last 3 rugs, tool belt, not carrying material while ascending & descending, no overreaching, work short duration not to exceed 10 minute for each label. Work control by Work Permits, Job safety analysis capturing hazards & control measures of all work sequences. The existing control measures incorporate strict regime of safe work practices while working on ladders . (4) Safety in window cleaning using portable ladders (5) Safe use of ladders and stepladders . Reference also made from HSE UK Publications 5 Step Risk Assessment
Proposal to mitigate the hazards with new Engineering hierarchy of control measures to further reduce the risk associated with the same scenario. Risk rating evaluations based on the effectiveness of new control measures obtained from Consultations with Tadmur Management and workforce. Further details obtained from manufacturer through their supplier at Qatar who provided work at height on ladder, assembly & disassembly demonstrations video, appraisal by three existing user of the platform ladder and reference made to approval of the platform ladder by recognized certification body. New Risk rating based on following consideration & control measures:
Use of Specialist ladders make (Zarges Germany) and internationally certified and are highly reliable for working on heights with engineering arrangement for stability and fall protection. Appendix 2 Zarges Platform Ladder Specifications & image The areas for ladder use to be identified listed and agreed on by Operations Assets o owners. The Specialist ladders have robust engineering arrangements and are reliable for o use with no break downs or fault. Use of Manufacturer provided competent Person Inspection and Safety Pre-sue o checklists. The ladder placement shall be limited on only firm and rigid ground surface. o Ladder designed with wheel for easy mobilization within work areas o The personnel shall work on ladder platform provided fall arrest inertia reels attached o to ladders.
16
o
o o
o
o o
The mock up test shall be conducted in presence of all agreed parties prior to use of ladders. The regular use and maintenance log to be maintained. Only trained (2 days training by ladder regional distributor at work site) & experience fitters shall be authorized to use the ladder for placing labels. The manufacturer‟s recommendations shall be included within Method statement and JSA prior to use. No alterations to be made on ladder that affects its integrity for use. Labels and tools kits accessories shall be attached along ladders (lifting rope using gin Wheel provided on ladder) to avoid carrying material while ascending & descending ladders.
New risk rating after the applications of new control measures is DIV fall under Low region in safety category as Consequence could lead to minor impact on personnel such as First aid only and Probability assessment indicate that falling from height not likely to occur- Refer to Table 01 Risk Rating & Table 02 RasGas Risk Matrix.
17
5.2.4 Record findings and implement The actual practical applications of risk assessment new control measures cannot be demonstrated at sites as the required equipment in not in place. However extensive knowledge obtained from watching video of operation of platform provided by manufacturer through their supplier in Qatar. The results of risk assessment captured in RasGas Risk assessments template and shall be transferred to Job safety Analysis (JSA) f ormat which is more simplified easy to understand versions similar to Health and Safety Executive published risk assessment template. Appendix 1 Working on Ladder at Heights of 10 meter Detail Risk Assessment Template
The shall be briefed to work force and attached to work permit as quick reference for work group to use as checklist on identifying hazards and verify the implementations of control measures. 5.2.5 Review risk assessment and update if necessary Review assessment and update if there are any incident, complaints, Gap identified during safety Audit, Inspections, change in work process, change in plant conditions, change in existing legislations or if it is discovered that the existing risk assessment or control measures are insufficient to protect the workers from the falling or other hazards. Review updated to project team during monthly safety meeting on 14/11/2013. Action by Tadmur Project Engineer Wilson. 5.3 Risk Assessment for health hazards Exposure to SO2 The Methodology of Health risk assessment of employees exposed to SO2 during engaging in plant labeling activity at AKG was assessed using the steps in RasGas Health Risk Assessment Methodology E07-X09-002. Existing controls are reviewed and potential monitoring, control and remedial action are proposed based on the health risk rating. Each hazard associated with a task is assigned a health risk rating. A health risk record will summarize information gathered through the health risk assessment process. The final health risk rating identifies the levels of health risks associated with tasks performed. 5.3.1 Finding out what the problems are (information gathering) Health effects attributed to SO 2 have been reported by some members of the workforce over the last several months. These effects include complaints of sore throats, eye irritation, and coughing as revealed in interviews with exposed workers. RasGas initial investigation identify SO2 were being released due to Engineering design failure in SRU incinerator Personal monitoring was done using Drager Pac 7000 personal monitors which recorded peak measurements, short term measurements, and time weighted averages. Overall range of measurements was 0.1 to 8.0 ppm. Locations where 0.25 ppm 15 minute time weighted averages could be exceeded were in the plant labeling area at AKG and production upper decks downwind from Sulfur Recovery Unit (SRU) incinerator stack. Area monitoring on from April to June 2013 was typically 2-4 ppm on the upper deck AKG during the morning hours. (Measured via BM25.) (Quote from RasGas Asset Engineering Team investigations finding ) “Several factors contribute to the dispersion of SO2 to ground level. Based on the data presented significant levels of SO2 were being released by each SRU incinerator. All of the SRU incinerators are located at the south end
18
of AKG. The stack height of all the SRU incinerators (48 meters), is technically low. Stack height is important for proper dispersion of pollutants. The exhaust gas will be most likely to hit the ground at a shorter distance compared to those sources with higher stack height” unquote . Considering all the factors above AKG area was primarily affected with intermittent exposure to SO2 on the days when wind was from the north-west. 5.3.2 Evaluate the Health Risks In deciding who might be harmed, this initial study focus on Tadmur plant labeling team engaged at AKG. Workers in this portion of the plant have the highest probability of being exposed to SO2 emissions. This involves forty eight persons working eight hour shift at AKG. The number of personnel at risk of exposure to SO2 was considered likely to be more than just plant labeling team due to the spread and depending on concentration at source and wind turbulence, enough dilution might not have occurred over wide area. RasGas plant Operator and other contractor personnel engaging work at adjacent plant not considered in the Risk assessment process. Other people at risk of exposure are visitors to the work area such as supervisors and safety officers on routine inspections of work area. If t he concentration of the vapors is high enough to exceed the short term (15 minutes) exposure limit value, then these categories of people might be harmed. Personnel with existing health condition such as asthma are also at higher risk. This could be respiratory condition that may be made worse by exposure, or it may be previous exposure to SO2 or other substances from other sources which may have synergistic effect with exposure to this gas. Age is another factor that could affect exposure. Elderly people may not have an efficient metabolic mechanism if exposed even at lower concentration. Exposure to this substance is intermittent but could be significant when it occurs. Exposure time for workers involved in plant labeling could be up to 8 hours‟ Time Weighted Average (TWA) daily for about 6 days per week. Based on the available data from measurement taken by Industrial hygiene team throughout AKG plant, exposure to levels detected is significant enough to cause damage to workers health if not controlled. This risk assessment referring specific health exposure to Tadmur Plant labeling worker involving 6 group consisting of 8 persons in a group. Working in day shift of 8 hours, 6 days a week, exposure is intermittent but daily and cannot be precisely calculated. 5.3.3 Evaluation of Existing Controls A combination of control measures are already in place in view of known hazards of SO2 leakage, they have failed to adequately protect the workers from its health exposure, Judging from records of few near misses where significant number of workers was exposed. It is fortunate no recorded acute illness to health results from SO2 exposure. The SO2 Occupational Exposure Limit (OEL) of 0.25 ppm 15 minute time weighted average (TWA) can be exceeded in the plant labelling activity area Facility and upper deck areas in AKG. It can also be exceeded in the adjacent plants at infrequent intervals. We conclude that the existing controls are not adequate to safeguard the health and safety of the workers at AKG area.
19
The existing control measure in place includes: No work activity if SO2 traced in the vicinity regardless the concentrations. Zero toxic gas policy. AKG-2 has four Fixed Detectors aligned to the PAGA System Ensure all non-essential personal keep off limit near plant labelling activity. Verify that workers in engaged in any activity in danger zone are “asthma” free by medical evaluation. All engaged it the activity provided with emergency escape respiratory mask (parat mask) Personal toxic clip or gas batch (SO2, H2S) worn at all time at breathing region, calibrated & not expired. Enter & work at AKG with Permit to Work only, job Safety Analysis & tool box to cover hazards of SO2 & emergency response in the event of gas alarm sounded All personal trained in use, maintenance & storing of personal protective equipment (emergency escape respirators use for escape only not for working) In the event of SO2 high alarm all personnel in the affected area to evacuate and muster at Safe Location away from the SO2 atmosphere. Wind socks installed at all work locations to identify wind directions All work group to be provided with communication device – intrinsically walkie talkie or mobile phone (IS) No work alone (buddy system) & without Supervisions Notify adjacent plant of potential SO2 emissions from other plants that could be contributing to RasGas worker exposure. SO2 hazard communication for all site workers via dedicated safety induction specific for working at AKG. AKG Asset Plant Operators to donning BA sets when responding to initial SO2 Alarm to verify SO2 Levels (if any), confirm the presence of SO 2 via a hand held SO2 gas monitor.
Administrative controls such as Safe System of Work system including developing method statement, Job safety analysis and MSDS for all activities which breaks down the activities down to task during which hazards inherent in each task is carefully identified. All workers engaged in activity inside live plant have to undergo Mandatory Safety Inductions, Specific Training on hazards at AKG asset and trade specific training e. fire watcher, safety watch and etc. A Permit to Work is required for any activity in live plant and finally before engaging in the task a Job specific tool box talk is a must and checklist to be dully filled by Permit Holder to verify all JSA control measures fully implemented. Overall good training and practical exercise (drills) to workers on emergency respond on sudden release of SO2 and effective awareness on hazards and control measures associated with SO2 exposure increase their alertness on the prevailing SO2 hazards. Personal Protective Equipment (PPE), in addition to the mandatory PPE for plant access, additional PPE such as suitable respiratory protections are provided & training provided for workers to wear it correctly, is an effective control but since only a fraction of exposed personnel uses this, it cannot be said to be effective control measure. Based on the review of the existing control measures, certain gaps and drawbacks are identified such as training tends to have limited effect unless reinforced by adequate supervision and reminder. The
20
fact that project tied to tight schedule means work rest cycle may not be observed so as to meet target so this control cannot be relied upon. The effective use of PPE depends on other factors such as fit with the user, compatibility with other mandatory PPE worn by user and how comfortable the wearer feel wearing them. In addition, routine inspection and maintenance is required for reusable PPE as well as need for replacement when it becomes worn or less effective, these depends on the competence of the user 5.3.4 Recording Risk Assessment findings and implementation The outcome of the risk assessment is detailed in table 04 on next page (Health Effects & Exposure Rating).The existing control measures are not adequate to protect the health and safety of the workers involved in in plant labeling activity at AKG Area. The controls have, however failed to offer protection against such toxic gas exposure which is significant enough to cause both acute and chronic ill-health. Current health risk rating is 3 for health effects & 4 for exposure rating, this fall under high region as per RasGas health Risk Matrix Table 04. Appendix 3 Workers Exposure to SO2 Detail Health Risk Assessment RasGas Template The danger is significant as the release of SO2 can happen anytime without prior warning, this has been proven during data collections. The personal gas monitor & their training is the last line of defense and it won‟t help much in the event of high concentrations sudden release. The risk increase as SO2 gas is colorless gas, suffocating odor and corrosive to the respiratory tract. A severe short-term exposure may cause long-term respiratory effects (e.g., reactive airways dysfunction (rads) corrosive causes severe skin burns and eye damage may cause frostbite and even suspect mutagen. suspected of causing genetic defects. 5.3.5 Proposed New Control measures The under listed actions are some further actions which would provide adequate protection and control the risk. Elimination or substitutions is not possible in this case but with current technology risk of exposure to such health hazards can minimised. The additional controls proposed focus still on administrations hierarchy of control as this is offer more reactions time to take refuge at safe area from toxic gas exposure. This new control measure is collective measures rather than depending on personal toxic clips. Provide additional 4 portable SO 2 Detector (BM 25 model), alarm capacity level at 110 dB (to be audible at noisy area) and rotating blue beacon light and with integrated infrared functional system e.g. one device sensor the gas it will activate all other portable device in the vicinity. This device to be place near the source of SO2 in addition to fixed SO2 detector which is not strategically positioned near the SO2 sources. Immediate actions
.
As to address the root cause Initiate Engineering feasibility study to improve the design of SRU incinerators heights from current 48 meters to higher as engineering possible and allow proper dispersion of pollutants -As proposal Utilize scrubber to reduce emissions from incinerators and/or manage processes to reduce SO2 emissions
21
With the application of new control measures the health risk rating shall be brought to as low as reasonably practical & proportionate with the hazards and risk. At the same time it shall comply with applicable local legal requirement as well comply with international best practices. The new health risk rating shall be drastically reduced to 2 for health effects & 2 for exposure rating, this fall under low region as per RasGas health Risk Matrix. Recommendations
6.0 Conclusions Review of Tadmur health and safety performance of a work place results can be concluded the organization is committed to the fundamental requirement that anyone working must have a safe environment in which to perform assigned Work. They have internationally recognized standard an assessment series for the Health and Safety part and it was manage as intended and desired outcome was achieved. The assignment aim to identify workplace existing hazards, who might be harmed, its effects to safety & ill-health and present mitigations in place was successfully identified. One physical and one health hazard which high potential to cause injury & ill-health to worker selected for detail risk assessments to further mitigate to ALARP. Both hazards risk from high brought to low with introductions of new control measures. The exercise completed with the reference to various AcoP‟S OSHA, HSE UK, Manufacturers & etc. The ultimate goal to identify specific action plans described in detail in next section by taking into account Qatar legal requirements and best practice in the industry concluded successfully. This action plan which is Specific Measurable, Accountability assigned, Realistic, Timely (SMART), and cost effective. In the recommendation section this action plan shall be detailed for implementations.
22
7.0 Recommendations As concluded above the physical hazards associated with working at heights on twin step “A” frame ladder using both hands during plant labeling activity is assessed as high. Client standing instruction clearly indicates that failure to maintain 3 contact points while working on twin step “A” frame ladder at heights is not acceptable. The risk rating outcome on initial risk assessment is seen as not satisfy Qatar related legal requirements & industrial best practices. The clear message from client Senior Management is that the concern related to project progress is secondary considerations compared to safety, client Safety philosophy that” No work is so urgent that it cannot be done safely” is literally applicable to this scenario. As concluded in the selected physical hazards risk assessment with practical engineering solutions as new control measures to purchase two unit of specially Engineered Ladder (ZAP Telescopic Platform Ladder) where worker can operate or carry out his task from the safe position on platform on top of the ladder. This platform has built-in fall protection system with middle rail & guard rails. This is further reinforced with full body safety harness anchorage points. During ascending & descending workers are secured to fall restrainer fixed to vertical anchorage life line also build-in the ladder design. The ladder is tested and internationally certified and proven highly reliable with unique engineering design for stability even when a fall take at highest point. The outrigger system further reinforced the stability where there is no need for securing at top or bottom of the ladder. There is no requirement for additional hand to hold the ladder in place. On the second health hazards selected, the health risk assessment without any doubt showing the risk of workers exposed of such hazards is high and the proposed new control measure it paramount to reduce the risk to ALARP or low. The risk assessment proposal for Tadmur to purchase four new portable unit of BM 25 SO2 Gas detector to safe guard workers health & safety while engaged in activity at AKG area is an interim measures. As a permanent solution client already initiated engineering feasibility study to improve the design of SRU incinerators heights from current 48 meters to higher structure Utilize scrubber to reduce emissions from incinerators and/or manage processes to reduce SO2 emissions. The SO2 detector could not eliminate or block the SO2 exposure risk however it serve as early warnings system for workers to initiate their emergency response the evacuate the area. The engineering inspections by plant subject matter expert has ascertained that SO2 source is from flair stack at 28 meter heights and this gas travel to lower or g round level with the help of prevailing wind. The existing plant fixed SO2 detector scattered throughout the plant but none of them are strategically located in-between the source of hazards and plant labeling workers locations. As there is no fixed or portable gas detector between the source of hazards & workers, the risk was rated as high. The last line of defense currently sole rely on workers personal gas batch or monitor, in high concentration the warning from personal gas monitor might be too late leaving little time to evacuate or to don their emergency escape respirator. By positioning the proposed portable SO2 gas monitor at interval heights & location between source of hazards and workers, this will drastically increase warning time & shall provide adequate reaction time to proceed to safe area.
23
The additional few minutes provided by this devise drastically reduce the risk from high to low; the additional time gained might be the difference between live & fatal exposures. The cost benefit table below will demonstrate the benefit outweigh the cost, such investment on new technology is good for business. Cost and Benefit of Proposed additional Controls The table 05 & 06 below summarizes the cost and benefit associated with implementing the control measures proposed on both selected hazards. The following assumptions were made in the cost and benefit estimates below. Cost does not include value of people life as it value cannot be justified with monetary figures The cost of delay in specific labelling project due to stoppage of work using twin step “A” frame ladder at AKG area not included as the same workers are utilized for activity in other location working with man lift & scaffold platform at AKG on same project. Risk assessment conducted specific for total number of Tadmur employees engaged at AKG area only (Client & other contractor engaged in the area not included). Cost related to personal administrations such salary, office, transport, health surveillance, gas monitoring or any other activity involved in Risk assessment process not included as the exercise concluded with client & Tadmur personal only. Salary cost is marginal as they are also engaged in other their specific routine tasks. Labour cost for Maintenance and cost for spare purchase for the item proposed is not included, however crucial spares for initial effective operation is included e.g. spare battery and consumable spares is included. Continuous monitoring and supervision of personnel is part of normal job procedure, so no additional cost. Periodic health surveillance of at risk workers will attract marginal extra cost as there is an existing health monitoring programme by the Occupational Health team in RasGas. This cost is not included as well. Assumption on cost figure based on communication with only one respective supplier for both risk assessments, as at the time only the base estimation is required. With more company participate in quotation shall bring the cost down. Cost of training & loss of work during training and awareness session mentioned in risk assessment control measures shall be included in action plan section of the report (basically all training provided free of charge by client, supplier who shall provide the material & Tadmur In-house training regime time however workers attending training cannot carry out their normal duties. Production based on number of label installed is also lost). Cost reflection on special design scaffold, this is the only available safe means of work options other than as proposed in RA new control measure ZAP Telescopic Platform Ladder. Calculation of Special design scaffold based on Middle East region approximate costs. Cost reflected in United states dollars Cost for scaffold installation and removal is UDS 16 per meter square, 10% of the overall cost is applied as rental costs per week.
24
Calculation based on assumptions number of location identified at AKG as unique is 600 where labeling need to be installed. The only way forward without using special design ladder is by installing special design scaffold. This location does not allow access for man lift & construction of normal scaffold e.g. mobile tower scaffold. If special scaffold construction is opted at 600 hundred locations, each location need about 4 meters square at 12 meters heights or 6 stacks heights (4m2 x 6m2 =24m2), at one location scaffold cost is approximately USD 384 (24 x 16). Total 600 location x USD 384 = USD 230,400 + 10% weekly rental cost USD 23,040 = USD 253,44
8.0 Action Plan 8.1.1 Cost and Benefit of implementing proposed additional controls on Physical Hazards Falling from Heights – Table format page 27 8.1.2 Cost and Benefit of implementing proposed additional controls for Health Hazards Exposure to SO2 Table format page 28 8.1.3 Management System Gap Analysis & Gap Closure Action Plan page 29 8.2 Hazards & Risk 8.2.1 Hazards & Risk Physical Hazards - Recommendation use of work equipment ZAP Telescopic Platform Ladder Table format page 30 & 31 8.2.2 Health Hazards Recommendation to procure & utilize Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area Monitor for Sulfur Dioxide Table format Page 32
25
8.0.1 Cost and Benefit of implementing proposed additional controls on Physical Hazards Falling from Heights COST
Total Saving Benefit
BENEFIT Cost in USD per unit
Control action item
Unit Requir ed
Total amount
ZAP Telescopic Platform Ladder Platform Height – 8.10m, Working Height – 9.85m, Extended Length – 9.45m , 400mm x 400mm Platform Made of Embossed Aluminum alloy, Closed Length – 5.65m, weight 86 kg Accessories charges included in one unit price. Installing Middle rail on the platform additional to hand rails. Vertical life line for anchoring Personal fall Protections Device Bucket hook fixed on ladder Hanging tool box Tray for ladders with rungs Set of horizontal stabilizer bar Note: Delivery to site in included if purchase more than one unit
Amount USD
Saving element Improved Safety Saving from Injury fall from height & drop object hazards- Potential absence, treatment, training for replacement employee, Insurance claim (increased premium) and fines by authority Work Progress delay on overall project completions (measurable but not calculated).
USD 4,000.00
USD 8,000.00
2
USD 8.000
Total cost
Other non-measurable saving such as improved public image for company. Moral boost and Increased productivity for workers who see company as caring No interruption to client LNG operations. (Interruptions involve major cost >1 million per day). The hazards exposed to scaffold for building special design scaffold eliminated as there is no need to construct
Total Saving
USD 32,000 (6 workers x USD 2,000 per person)+ Job stoppage 10,000 + Other 10,000
USD 24,000
USD 32,000
USD 24,000
26
8.0.2
Cost and Benefit of implementing proposed additional controls for Health Hazards Exposure to SO2
COST
Control action item Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area Monitor For LEL, Hydrogen Sulfide, Oxygen And Sulfur Dioxide With Diffusion Draw. Interchangeable “smart” sensor options that alarm signals transfer from one unit to another an intrinsically safe trickle charge power. Complete with additional accessories. 100 meter-long cable and wiring arrangements
Total Saving Benefit
BENEFIT Cost in USD per unit
USD 3,000
Unit Requir ed
4
Total amount
USD 12,000
High capacity rechargeable nickel metal-hydride spare battery pack
Saving element
Amount USD
Improved Safety Saving from Health Exposure SO2 hazards - Absence from work due to treatment, medical expenses, training for replacement staff, investigation cost, compensation, Insurance claim (increased premium) & fines by authority. Total 48 workers exposed to SO2 Hazards at any given time. Other non-measurable saving such as Improved public image for company. Moral boost and Increased productivity for workers who see company as caring
USD 96,000 (48 workers x USD 2,000 per person)
USD 84,000
Total Saving
USD 96,000
USD 84,000
Industrial Scientific BM25 Multi guard Total 48 workers exposed to SO2 Hazards at any given time.
Total cost
USD 12,000
27
8.0.2
Cost and Benefit of implementing proposed additional controls for Health Hazards Exposure to SO2
COST Cost in USD per unit
Control action item Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area Monitor For LEL, Hydrogen Sulfide, Oxygen And Sulfur Dioxide With Diffusion Draw. Interchangeable “smart” sensor options that alarm signals transfer from one unit to another an intrinsically safe trickle charge power. Complete with additional accessories. 100 meter-long cable and wiring arrangements
Total Saving Benefit
BENEFIT
USD 3,000
Unit Requir ed
4
Total amount
USD 12,000
High capacity rechargeable nickel metal-hydride spare battery pack
Saving element
Amount USD
Improved Safety Saving from Health Exposure SO2 hazards - Absence from work due to treatment, medical expenses, training for replacement staff, investigation cost, compensation, Insurance claim (increased premium) & fines by authority. Total 48 workers exposed to SO2 Hazards at any given time. Other non-measurable saving such as Improved public image for company. Moral boost and Increased productivity for workers who see company as caring
USD 96,000 (48 workers x USD 2,000 per person)
USD 84,000
Total Saving
USD 96,000
USD 84,000
Industrial Scientific BM25 Multi guard Total 48 workers exposed to SO2 Hazards at any given time. USD 12,000
Total cost
27
8.0.3 Management System Gap Analysis & Gap Closure Action Plan Syste m Ref.
4.1.1
4.4.8
Characteristic / Section Respect Legal and Non-legal OH&S Requirements
Gaps
Action Required
There is procedure in place to identify and access the legal List of Qatari laws and regulations. However the legal & non Legal requirement pertaining to work on ladder not adequately captured in procedure.
Identify applicable laws and regulations & non Legal OS& H requirements that would be applicable to Tadmur working on ladders tasks. List of Qatari laws, regulations and non-legal pertaining to work on ladder to be updated in the procedures.
Establish an OH&S Emergency Management Process Implement Test, Review and revise emergency management
No rescue plan implementation, equipment‟s and test provisions (Rescue mock exercise) for working at heights addressed in Tadmur OH&S Emergency
Provision of rescue plan, including overhung syndrome, provision of suitable rescue equipment‟s & trained personal to be established. The need of rescue exercise in appropriate intervals, review
28
Priorit y Action Taken By: Remarks (H, M, Name Date L) Applicable legal requirement on M Ossa 20 related section 11 - Health & ma Septem Safety: Part 2 Safety & Accident Tadm ber Prevention Management / ur 2013 Administration System (SAMAS) Projec 22.3.9 Personal Protective Fall t Protective Equipment‟s. Manag HSE Regulations & Enforcement er Directorate HSE Legal Framework in Oil and Gas Sector DG-GEN-39-2011 5th May 2011 Chapter 1 Occupational Health Section 6 Facilities and Work Places Risks Article 149 – Fixed Ladder & mobile ladder As best practice client adopting Provision and Use of Work Equipment Regulations 1998 (PUWER). H Ossa 7 Qatar‟s Penal Code, Labor Law, ma Septem Civil Defense Law. Violate Tadm ber various H&E, civil & criminal ur 2013 legislation, provisions. Projec t Manag er
8.0.3 Management System Gap Analysis & Gap Closure Action Plan Syste m Ref.
4.1.1
4.4.8
Characteristic / Section Respect Legal and Non-legal OH&S Requirements
Gaps
Action Required
There is procedure in place to identify and access the legal List of Qatari laws and regulations. However the legal & non Legal requirement pertaining to work on ladder not adequately captured in procedure.
Identify applicable laws and regulations & non Legal OS& H requirements that would be applicable to Tadmur working on ladders tasks. List of Qatari laws, regulations and non-legal pertaining to work on ladder to be updated in the procedures.
Establish an OH&S Emergency Management Process Implement Test, Review and revise emergency management
No rescue plan implementation, equipment‟s and test provisions (Rescue mock exercise) for working at heights addressed in Tadmur OH&S Emergency
Provision of rescue plan, including overhung syndrome, provision of suitable rescue equipment‟s & trained personal to be established. The need of rescue exercise in appropriate intervals, review
Priorit y Action Taken By: Remarks (H, M, Name Date L) Applicable legal requirement on M Ossa 20 related section 11 - Health & ma Septem Safety: Part 2 Safety & Accident Tadm ber Prevention Management / ur 2013 Administration System (SAMAS) Projec 22.3.9 Personal Protective Fall t Protective Equipment‟s. Manag HSE Regulations & Enforcement er Directorate HSE Legal Framework in Oil and Gas Sector DG-GEN-39-2011 5th May 2011 Chapter 1 Occupational Health Section 6 Facilities and Work Places Risks Article 149 – Fixed Ladder & mobile ladder As best practice client adopting Provision and Use of Work Equipment Regulations 1998 (PUWER). H Ossa 7 Qatar‟s Penal Code, Labor Law, ma Septem Civil Defense Law. Violate Tadm ber various H&E, civil & criminal ur 2013 legislation, provisions. Projec t Manag er
28
procedures
Management procedures or address in working at heights procedures.
& revise the provisions to be included in Tadmur Emergency Response Management Procedures.
‘8.2Hazards
Actions
& Risk Physical Hazards – 8.2.1 Recommendation use of work equipment ZAP Telescopic Platform Ladder Responsib Time scale ilities
a) Raise requisition for ZAP Telescopic Platform Ladder - Platform Height – 8.10m, Working Height – 9.85m, Extended Length – 9.45m , 400mm x 400mm Platform Made of Embossed Aluminum alloy, Closed Length – 5.65m, weight 86 kg. Delivery in 30 days as per stated in quotations initiated by RA team
b) Develop a safe work guideline and initiate Job Safety analysis for activity using the new proposed ladders. Reference to be made to Manufacturer manual, legal & best practices.
c) Initiate practical training for ZAP Telescopic Platform Ladder assembly, disassemble and working conducted by supplier provided trainer as per agreement in purchase contract. Must use the actual ladder and training record provided to client. Working demonstrations shall be presented in
29
01/09/2013
Tadmur Project Manager Osama Challak
01/09/2013
Tadmur Project Engineer Wilson
01/10/2013
Tadmur Safety Officer Norman
Success Criteria High – Approva ls is expecte Negligible d consider ing the risk ratings High – Only need to update USD 1,000 from relevant publicati ons USD 4,800 Medium48 persons dependi x USD 100 ng on Daily equipme Cost
Review date/format 14/09/2013 Review & discuss during Weekly progress meeting
14/09/2013 Review & discuss during Weekly progress meeting
14/10/2013
procedures
Management procedures or address in working at heights procedures.
& revise the provisions to be included in Tadmur Emergency Response Management Procedures.
‘8.2Hazards
Actions
& Risk Physical Hazards – 8.2.1 Recommendation use of work equipment ZAP Telescopic Platform Ladder Responsib Time scale ilities
a) Raise requisition for ZAP Telescopic Platform Ladder - Platform Height – 8.10m, Working Height – 9.85m, Extended Length – 9.45m , 400mm x 400mm Platform Made of Embossed Aluminum alloy, Closed Length – 5.65m, weight 86 kg. Delivery in 30 days as per stated in quotations initiated by RA team
b) Develop a safe work guideline and initiate Job Safety analysis for activity using the new proposed ladders. Reference to be made to Manufacturer manual, legal & best practices.
c) Initiate practical training for ZAP Telescopic Platform Ladder assembly, disassemble and working conducted by supplier provided trainer as per agreement in purchase contract. Must use the actual ladder and training record provided to client. Working demonstrations shall be presented in
01/09/2013
Tadmur Project Manager Osama Challak
01/09/2013
Tadmur Project Engineer Wilson
01/10/2013
Tadmur Safety Officer Norman
Success Criteria High – Approva ls is expecte Negligible d consider ing the risk ratings High – Only need to update USD 1,000 from relevant publicati ons USD 4,800 Medium48 persons dependi x USD 100 ng on Daily equipme Cost
Review date/format 14/09/2013 Review & discuss during Weekly progress meeting
14/09/2013 Review & discuss during Weekly progress meeting
14/10/2013
29
presence of all stake holders (OPD & AKG asset team) prior to actual use the equipment‟s
d) Rescue & Emergency Plan shall be prepared, reviewed by all project stake holders and approved by RasGas emergency Response Services.
e) A drill conducted (Mock up test) on rescue & emergency arrangement while working at heights e.g. workers rescue from overhang from fall personal protections device.
f)
Safety assessment conducted on the 30 days operations performance of the ZAP Telescopic Platform Ladder.
g) Review assessment and update if there are any incident, complaints, Gap identified during safety Audit, Inspections, change in work process, change in plant conditions, change in existing legislations or If it is discovered that the existing risk assessment or control measures are insufficient to protect the workers from the falling or other hazards.
30
01/09/2013
Tadmur Safety Officer Norman
salary
nt delivery date
Negligible
High
07/09/2013- By RasGas EMS
14/10/2013
Tadmur Safety Officer Norman
USD 1,000
High
21/10/2013 Review & discuss during Weekly progress meeting
7/10/2013
Tadmur Project Engineer Wilson
Negligible
High
14/10/2013 Review by project team
01/11/2013 or when required
Tadmur Project Engineer Wilson
High
14/11/2013 Review updated to project team during monthly safety meeting
Negligible
presence of all stake holders (OPD & AKG asset team) prior to actual use the equipment‟s
d) Rescue & Emergency Plan shall be prepared, reviewed by all project stake holders and approved by RasGas emergency Response Services.
e) A drill conducted (Mock up test) on rescue & emergency arrangement while working at heights e.g. workers rescue from overhang from fall personal protections device.
f)
Safety assessment conducted on the 30 days operations performance of the ZAP Telescopic Platform Ladder.
g) Review assessment and update if there are any incident, complaints, Gap identified during safety Audit, Inspections, change in work process, change in plant conditions, change in existing legislations or If it is discovered that the existing risk assessment or control measures are insufficient to protect the workers from the falling or other hazards.
01/09/2013
Tadmur Safety Officer Norman
salary
nt delivery date
Negligible
High
07/09/2013- By RasGas EMS
14/10/2013
Tadmur Safety Officer Norman
USD 1,000
High
21/10/2013 Review & discuss during Weekly progress meeting
7/10/2013
Tadmur Project Engineer Wilson
Negligible
High
14/10/2013 Review by project team
01/11/2013 or when required
Tadmur Project Engineer Wilson
High
14/11/2013 Review updated to project team during monthly safety meeting
Negligible
30
8.2.2 Health Hazards Recommendation to procure & utilize Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area Monitor for Sulfur Dioxide Responsi Success Review Actions Time scale Cost bilities Criteria date/format h) Raise requisition for Industrial Scientific BM25 Multi guard Transportable 14/09/2013 Multi-Gas Area Monitor For LEL, Hydrogen Sulfide, Oxygen And Sulfur Tadmur Review & Dioxide With Diffusion Draw. Interchangeable “smart” sensor options that Project discuss during alarm signals transfer from one unit to another an intrinsically safe trickle 01/09/2013 Manager Negligible High Weekly charge power. Complete with additional accessories. Delivery in 30 days as Osama progress per stated in quotations initiated by RA team. Initial on job training provided Challak meeting by supplier as per sales contract, 14/09/2013 i) Training of dedicated personal & prepare safety guideline for maintenance, Tadmur Review & calibrations and initiate to include the new control measure in Job Safety Project discuss during analysis for activity at AKG. Advice & guidance can be obtained from client 07/10/2013 USD 2,000 High Engineer Weekly operations staff that has good knowledge on the operations of the said Wilson progress equipment‟s. Guideline can be obtained from client existing procedures. meeting j) A joint survey to be scheduled for Tadmur Project Engineer, OPD Responsible Person for Labeling Project & Asset Authority for physical visit 07/10/2013 Tadmur & mapping of suitable locations for placing the portable gas monitors at Review & Project AKG. Identified locations by marked in plot plan & clear instruction to discuss during 28/09/2013 Manager USD 500 High workforce that no activity shall progress without deployment of the said Weekly Osama device. The same followed up with official communications to Permit progress Challak Issuing office to authorize the device use inside live plant. Use of devise meeting must be approved by AKG Asset Manager. k) Review assessment and update if there are any incident, complaints, Gap 14/11/2013 Tadmur identified during safety Audit, Inspections, change in work process, change 01/11/2013 Review Project in plant conditions, change in existing legislations or If it is discovered that or when Negligible High updated on Engineer the existing risk assessment or control measures are insufficient to protect required project monthly Wilson the workers from the falling or other hazards. safety meeting
31
8.2.2 Health Hazards Recommendation to procure & utilize Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area Monitor for Sulfur Dioxide Responsi Success Review Actions Time scale Cost bilities Criteria date/format h) Raise requisition for Industrial Scientific BM25 Multi guard Transportable 14/09/2013 Multi-Gas Area Monitor For LEL, Hydrogen Sulfide, Oxygen And Sulfur Tadmur Review & Dioxide With Diffusion Draw. Interchangeable “smart” sensor options that Project discuss during alarm signals transfer from one unit to another an intrinsically safe trickle 01/09/2013 Manager Negligible High Weekly charge power. Complete with additional accessories. Delivery in 30 days as Osama progress per stated in quotations initiated by RA team. Initial on job training provided Challak meeting by supplier as per sales contract, 14/09/2013 i) Training of dedicated personal & prepare safety guideline for maintenance, Tadmur Review & calibrations and initiate to include the new control measure in Job Safety Project discuss during analysis for activity at AKG. Advice & guidance can be obtained from client 07/10/2013 USD 2,000 High Engineer Weekly operations staff that has good knowledge on the operations of the said Wilson progress equipment‟s. Guideline can be obtained from client existing procedures. meeting j) A joint survey to be scheduled for Tadmur Project Engineer, OPD Responsible Person for Labeling Project & Asset Authority for physical visit 07/10/2013 Tadmur & mapping of suitable locations for placing the portable gas monitors at Review & Project AKG. Identified locations by marked in plot plan & clear instruction to discuss during 28/09/2013 Manager USD 500 High workforce that no activity shall progress without deployment of the said Weekly Osama device. The same followed up with official communications to Permit progress Challak Issuing office to authorize the device use inside live plant. Use of devise meeting must be approved by AKG Asset Manager. k) Review assessment and update if there are any incident, complaints, Gap 14/11/2013 Tadmur identified during safety Audit, Inspections, change in work process, change 01/11/2013 Review Project in plant conditions, change in existing legislations or If it is discovered that or when Negligible High updated on Engineer the existing risk assessment or control measures are insufficient to protect required project monthly Wilson the workers from the falling or other hazards. safety meeting
31
9.0 Reference / Bibliography 1. Gulf News Qatar sentences five over Villaggio fire Published: 14:40 June 20, 2013 By Habib Toumi, Bureau Chief http://gulfnews.com/news/gulf/qatar/qatar-sentences-fiveover-villaggio-fire-1.1199728 Assessed 16/08/2013 2. Health and Safety UK Successful health and safety management HSE‟s Publications obtained through website: www.hse.gov.uk. Assessed on 16/08/2013 3. Praxiom Research Group Limited OHSAS 18001 2007OH&S TRANSLATED INTO PLAIN ENGLISH http://www.praxiom.com/ohsas-18001.htm accessed on 18/8/2013 4. Health and Safety UK Safety in window cleaning using portable ladders HSE Information Sheet MISC613 http://www.hse.gov.uk/pubns/misc613.pdfFirst published 09/03 accessed on 18/8/2013 5. Health and Safety UK Safe use of ladders and stepladders An employers‟ guide HSE‟s website: www.hse.gov.uk. accessed on 18/8/2013 6. NIOSH & Centre of Disease Control & Prevention Occupation Health Guideline for sulfur dioxide (SO2) CDC - Sulfur Dioxide - NIOSH Workplace Safety and Health Topic accessed on 18/8/2013 7. Air Product SO2 Material Safety Data Sheethttp://avogadro.chem.iastate.edu/MSDS/sulfur_dioxide.pdf Assessed 18/08/2013
9.0 Reference / Bibliography 1. Gulf News Qatar sentences five over Villaggio fire Published: 14:40 June 20, 2013 By Habib Toumi, Bureau Chief http://gulfnews.com/news/gulf/qatar/qatar-sentences-fiveover-villaggio-fire-1.1199728 Assessed 16/08/2013 2. Health and Safety UK Successful health and safety management HSE‟s Publications obtained through website: www.hse.gov.uk. Assessed on 16/08/2013 3. Praxiom Research Group Limited OHSAS 18001 2007OH&S TRANSLATED INTO PLAIN ENGLISH http://www.praxiom.com/ohsas-18001.htm accessed on 18/8/2013 4. Health and Safety UK Safety in window cleaning using portable ladders HSE Information Sheet MISC613 http://www.hse.gov.uk/pubns/misc613.pdfFirst published 09/03 accessed on 18/8/2013 5. Health and Safety UK Safe use of ladders and stepladders An employers‟ guide HSE‟s website: www.hse.gov.uk. accessed on 18/8/2013 6. NIOSH & Centre of Disease Control & Prevention Occupation Health Guideline for sulfur dioxide (SO2) CDC - Sulfur Dioxide - NIOSH Workplace Safety and Health Topic accessed on 18/8/2013 7. Air Product SO2 Material Safety Data Sheethttp://avogadro.chem.iastate.edu/MSDS/sulfur_dioxide.pdf Assessed 18/08/2013
10.0
Appendices
Appendix 1
Working on Ladder at Heights of 10 meter Detail Risk Assessment Template RasGas Scenario Based Risk Analysis from main manual Risk Assessment Management System Manual E01-X01-RAM110
Appendix 2
Zarges Platform Ladder Specifications & Image
Appendix 3
Workers Exposure to SO2 Detail Health Risk Assessment Template RasGas Health Risk Assessment Methodology E07-X09-002
32
