CP-122 HSE Code of Practice

Petroleum Development Oman L.L.C. Document Title: Health, Safety, and Environment Code of Practice Document ID

Document Type

Security

Discipline

Document Owner

Month and Year of Issue

Version

Keywords

CP-122

Code of Practice

Unrestricted

MSE

MD

July 2011

5.0

HSE, Management System

Copyright: This document is the property of Petroleum Development Oman, LLC. Neither the whole nor any part of this document may be disclosed to others or reproduced, stored in a retrieval system, and/or transmitted in any form by any means (electronic, mechanical, reprographic recording, and/or otherwise) without prior written consent of the owner.

HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

Document Authorisation Document Owner Raoul Restucci MD July 2011

Document Custodian Naaman Al Naamany MSEM July 2011

Document Author Saeed Al Maamary MSE/5 July 2011

Revision History The following is a brief summary of the four most recent revisions to this document. Details of all revisions prior to these are held on file by the Document Custodian. Version No.

Month and Year

Author’s Name and Title

5.0

July 2011

Saeed Al Maamary MSE/5

4.0

April 2002

Gordon Muirhead, CSM/1

3.0

Aug 1999

Joppe Cramwinckel CSM/2

2.0

December 1998

Steve Williams CSM/2X

Scope / Remarks Completely revised and aligned with the most recent international best practices for HSE management systems, with added focus on process safety management. Revised to more closely align with EP 95-0100 and HSE MS elements reduced from 10 to 8. Definition of ‘incident’ and ’environmental incident’ revised, along with minor editorial revisions. Definition of ‘significant’ revised in line with CP 131 – ‘Risk Management,’ along with minor editorial revisions.

User Notes: 1. The requirements of this document are mandatory. Non-compliance shall only be authorised by a designated authority through STEP-OUT approval as described in this document. 2. A controlled copy of the current version of this document is on PDO's live link. Before making reference to this document, it is the user's responsibility to ensure that any hard copy, or electronic copy, is current. For assistance, contact the Document Custodian. 3. Users are encouraged to participate in the ongoing improvement of this document by providing constructive feedback.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

Related Business Processes & CMF Documents Related Business Processes Code

Business Process (EPBM 4.0)

EP.01

Manage Business Plan, Global Process #20 Risk Management in Projects

Parent Document(s) Doc. No. PL-04

Document Title Health, Safety, and Environment Policy

Other Related CMF Document(s) Doc. No.

Document Title

CP-107

Corporate Management Framework Code of Practice

CP-131

Risk and Opportunity Management Code of Practice

The related CMF Documents can be retrieved from the Corporate Business Control Documentation Register CMF.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

Table of Contents Document Authorisation

1

Revision History

1

Related Business Processes & CMF Documents

2

0. INTRODUCTION

4

0.1 OVERVIEW 0.1.1 The Structure of PDO’s HSE Management System 0.1.2 The Background and Basis of PDO’s HSE Management System 0.1.3 Using this Code of Practice

4 5 7 7

0.2 PURPOSE AND OBJECTIVES 0.2.1 Purpose of PDO’s HSE Management System 0.2.2 Objectives of the HSE Management System Manual – Code of Practice CP-122

9 9 9

0.3 TARGET AUDIENCE AND DISTRIBUTION

10

0.4 REFERENCE DOCUMENTS 0.4.1 Other useful reference documents: 0.4.2 Feedback

10 10 11

1.

LEADERSHIP AND COMMITMENT

12

2.

POLICY AND STRATEGIC OBJECTIVES

14

3.

ORGANISATION, RESPONSIBILITIES, RESOURCES, STANDARDS, AND DOCUMENTS

18

4.

HAZARDS AND EFFECTS MANAGEMENT

27

5.

PLANNING AND PROCEDURES

38

6.

IMPLEMENTATION AND OPERATION

47

7.

ASSURANCE: MONITORING AND AUDIT

57

8.

REVIEW

65

9.

GLOSSARY

68

10.

LIST OF HSE-MS DOCUMENTS

87

10.1 LIST OF CODES OF PRACTICE

87

10.2 LIST OF HSE COMMON PROCEDURES, SPECIFICATIONS, AND GUIDELINES

88

10.3 LIST OPERATIONAL SAFETY PROCEDURES, SPECIFICATIONS, AND GUIDELINES

89

10.4 LIST OF TECHNICAL SAFETY PROCEDURES, SPECIFICATIONS, AND GUIDELINES

90

10.5 LIST OF OCCUPATIONAL HEALTH PROCEDURES, SPECIFICATIONS, AND GUIDELINES

92

10.6 LIST OF ENVIRONMENTAL PROCEDURES, SPECIFICATIONS, AND GUIDELINES

93

10.7 LIST OF EMERGENCY RESPONSE PROCEDURES, SPECIFICATIONS, AND GUIDELINES

94

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0. INTRODUCTION 0.1 OVERVIEW PDO‟s Health, Safety, and Environment Management System (HSE MS) is a structured approach to achieving our HSE goals, objectives, and targets, and managing the HSE risks associated with our business. PDO‟s Statement of General Business Principles (SGBP) and the PDO Code of Conduct describe how we conduct our business in terms of the fundamental expectations and standards which we set for ourselves. Central to the SGBP is the following statement regarding HSE at PDO:

“The Company will endeavor to conduct its business in such a way as to protect the health and safety of its employees, its contractor employees, and other persons affected by its activities, as well as to protect the environment, minimise pollution, and seek improvement in the efficient use of natural resources.” Therefore, to be properly aligned, PDO‟s Health, Safety, and Environmental Protection Policy (PL 04) requires that a systematic approach shall be applied to HSE management in order to achieve this endeavor. PDO‟s HSE Management System provides this systematic and structured process for continual improvement in our HSE performance. It concentrates, using eight (8) management system processes, on those areas and activities with the potential to have the greatest impact on harm to people and the environment, to cause damage or loss to assets, to defer oil production, to cause financial loss, and/or to adversely impact the Company‟s reputation. Continual improvement within the management system is symbolized by the cyclical arrows and is an ongoing process within the entire HSE MS.

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PDO’s HSE Management System Logo - An Ancient Form is Renewed and Improved!

From ancient times, the spiral-shelled ammonite has been one of nature‟s perfect forms and symbols. Over the years, it has also been adopted and has proven itself to be the trusted symbol of PDO‟s HSE Management System, or “HSE MS.” The ammonite shell has particular significance. Its shape is based on the naturally occurring Fibonacci number sequence, continually spiraling outwards with systematic precision and accuracy. Also, as a logo for the Company, the stylized ammonite is individual, easily recognized, and is distinctly PDO‟s. The remains of life on earth from ancient times helped form the varied hydrocarbon resources upon which PDO depends, with ammonites and other fossils leading geologists back to ancient rock deposits in their search for oil and gas. The logo of PDO‟s HSE Management System is also distinctly PDO. Its colors represent each process of the Management System. The spiraling outward of the ammonite form evokes PDO‟s quest for continual and systematic improvement in HSE performance.

0.1.1 The Structure of PDO‟s HSE Management System No company can operate effectively without a management system and controls in some form. A management system and its associated controls are the structured means used to obtain reasonable assurance of achieving the Company‟s goals, objectives, and targets (including its HSE goals, objectives, and targets). These controls should be well thought out and designed, clear, and systematic, so as to be appropriate to the business. Without an appropriate management and business control framework, the Company and all involved stakeholders with it may be subject to an unacceptable level of risk. Internationally accepted standards and current good practices have five basic processes of business control, typically expressed in a “Continual Improvement Model” or loop, as follows: 1. 2. 3. 4. 5.

Policy Planning Implementation and Operation Checking Review.

PDO has adopted these five processes of business control and has developed an overall business control framework. This is the Corporate Management Framework or “CMF.” This is the highest level document in PDO‟s overall management system and describes the way PDO manages its business. PDO‟s documentation hierarchy and framework can be seen in Appendix One of this chapter. PDO‟s HSE Management System is an important part of PDO‟s overall business control framework, and this can be seen in detail in CP-107, the Corporate Management Framework. Table One on the next page gives an overview of the structure, associated documentation hierarchy, and documentation definitions of PDO‟s HSE Management System.

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Table One: PDO’s Documentation Hierarchy, Definitions, and HSE Management System DOCUMENTATION HIERACHY AND DEFINITIONS

HSE Management System Manual (CP-122)

“Key” HSE Management System Documentation (i.e., high-level hyperlinked documents in this manual)

Asset Level Business Control Documents and Records (i.e., examples of key documents and associated records)

Leadership and Commitment

PL-04 – Health, Safety, and Environmental Protection CP-107 – Corporate Management Framework Statement of General Business Principles (SGBP)

Self Assessment Questionnaires (SAQ) Statements of Fitness HSE Plans Evidence of Leadership Tours, inspections, communication activities, etc.

Policy and Strategic Objectives

PL-04 – Health, Safety, and Environmental Protection PL-10 – Security Policy & Emergency Response Policy CP-100 – Policy Approval CP-107 – Corporate Management Framework Statement of General Business Principles (SGBP)

HSE Legislation HSE licenses / approvals / permits Etc.

Organisation, Responsibilities, Resources, Standards, and Documents

PL-03 – Risk and Internal Control Policy PL-04 – HSE Policy PL-05 – Governance Policy PL-08 – Commercial Policy PL-09 – Human Resources Policy CP-100 – Policy Approval CP-102 – Corporate Document Management CP-107 – Corporate Management Framework CP-111 – Relationship With Stakeholders CP-123 – Emergency Procedures, Part I CP-129 – Contracting and Procurement CP-141 – Use of Concession Land by Third Parties CP-162 – Internal Communication

Job descriptions Minutes of committee and other meetings Training plans Contract documents Monthly HSE reports Competency / training records Reports to external stakeholders Etc.

←

Hazards and Effects Management (HEMP)

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection CP-131 – Risk and Opportunity Management

Hazards & Effects Registers HSE Cases Environmental Impact Assessments Integrated Impact Assessments Etc.

←

Planning and Procedures

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection PL-09 – Human Resources PL-10 – Security and Emergency Response PL-11 – Asset Integrity and Disposal CP-107 – Corporate Management Framework CP-114 – Maintenance & Integrity Management CP-115 – Operation of Surface Product Flow Assets CP-117 – Project Engineering CP-118 – Well Lifecycle Integrity CP-123 – Emergency Response Documents Part I CP-126 – Personnel and Asset Security CP-136 – Planning in PDO

Asset Manager Mandate(s) Emergency Response Documents Part II Specific Contingency Plans Asset Level HSE Plans Work Permit Procedure Operational Control documents / procedures / work instructions Etc.

Implementation and Operation

PL-04 – Health, Safety, and Environmental Protection PL-06 – Information Management and Internal Communication CP-114 – Maintenance and Integrity Management CP-115 – Operate Surface Product Flow Assets CP-117 – Project Engineering CP-118 – Well Lifecycle Integrity CP 123 – Emergency Response Documents, Part I CP-136 – Planning in PDO

POLICY A document broadly defining PDO‟s expectations and requirements.

↕ CODE OF PRACTICE A high level document that specifies the overall approach and procedure for performing a business process / activity, and which states the minimum requirements expected from employees, contractors, and/or other relevant stakeholders.

↕ PROCEDURE A document that specifies the way a work process / activity / task is to be performed, describing why (purpose), what (scope), who (responsibility), when (frequency), how (tasks involved), and how many / how much (specifications).

↕ SPECIFICATION The specific requirements that are mandatory – with respect to performance, implementation, monitoring, and reporting. A specification can apply to materials, products, activities, and/or services.

↕ GUIDELINES A non-mandatory document providing supplementary information about acceptable methods for implementing requirements found in policies, business processes, procedures, work instructions, etc.

Assurance: Monitoring and Audit

↕

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection PL-06 – Information Management and Internal Communication

RECORDS A document containing information with respect to results achieved and/or providing evidence of activities performed. (A record is an “output” document and it typically cannot be revised or altered. Records are typically created from forms and templates).

July 2011

Review

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection CP-100 – Policy Approval CP-107 – Corporate Management Framework CP-123 – Emergency Response Documents Part I

inputs

← ←

← outputs

All relevant Asset operational control procedures Work Permit Procedure Management of Change Procedure(s) Etc.

→

Audit reports Audit follow-up Action Plans Monitoring data Non-compliance report forms Corrective action plans Incident reports Follow-up Action Plans Etc.

→

Minutes of management review meetings Etc.

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0.1.2 The Background and Basis of PDO‟s HSE Management System This revision to the HSE Management System further advances PDO‟s continual improvement in HSE and its overall Corporate Management Framework (CMF), a structure and Code of Practice document developed to provide clarity and direction on the principles by which PDO manages its business. PDO‟s HSE Management System fits within the CMF. As such, the HSE Management System is aligned and meets stakeholder aspirations and expectations in that it delivers compliance with the following:       

Omani Law: While there is no specific legal requirement for PDO to have an HSE Management System in place, Omani Law essentially requires that many of the key processes of a Management System are in place. PDO Business Policies: PDO‟s Business Policies communicate our intentions and expectations for achieving stated Business Objectives. PDO‟s HSE Policy requires that a systematic approach to HSE management shall be applied. The ISO 14001 standard for environmental management systems. The OHSAS 18001 specification for occupational health and safety management systems. The Center for Chemical Process Safety (CCPS - 20 Elements for Process Safety). Shell HSSE & SP Control Framework, Version 2, 2009, Shell Group Standards for Health, Security, Safety, the Environment & Social Performance. PDO‟s Management System hierarchy of documents (The Corporate Management Framework [CMF], Policies, Codes of Practice, Procedures, Specifications, Guidelines, and Records).

The ongoing and future vision for PDO‟s HSE Management System is the systematic review, with revisions as necessary, leading to the continual improvement of measures taken to protect the health, safety, and environment of those that may be affected by the activities of PDO. This vision is also part of PDO‟s management commitment so as to ensure the suitability, adequacy, and effectiveness of the HSE Management System. See Table Two – ALIGNMENT OF PDO‟S HSE MANAGEMENT SYSTEM PROCESSES WITH 1SO 14001, OHSAS 18001, CCPS PSM, and the SHELL HSSE & SP CONTROL FRAMEWORK on the next page for details.

0.1.3 Using this Code of Practice

Language In this document the recommendations for a course of action are made with varying degrees of emphasis and mandate. As a rule: 

'shall' / „must‟ indicates a required course of action at all times, with mandatory status within PDO, and a good practice.



'should' indicates a preferred course of action, and a best practice.



'may' / „can‟ indicates a possible, optional, and/or supplementary course of action.

In this document the collective expressions of PDO are sometimes used for convenience in contexts where reference is made to the specific asset and/or for contractors in general. These expressions are used where no useful purpose is served by identifying the particular asset and/or contractor(s).

Application In general this Code of Practice is applicable to all PDO operations, assets, and facilities, employees, contractors, and other relevant stakeholders. Should any significant deviations be made from the recommendations in this document, then users are required to inform PDO of the nature and justification for these if it is intended that the deviations are to be permanent.

Feedback The content of the HSE MS is not static, but a growing and improving collection of HSE expertise. Consequently, users are invited to comment on the content to PDO and to suggest changes and additional material which they consider would be useful for inclusion in future revisions. Please refer such comments to MSE52 using the Feedback Form on Page 11.

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Table Two: ALIGNMENT OF PDO’S HSE MANAGEMENT SYSTEM PROCESSES WITH 1SO 14001, OHSAS 18001, CCPS PSM, and the SHELL HSSE & SP CONTROL FRAMEWORK HSE Management System Manual / CP-122

ISO 14001 : 2004

OHSAS 18001 : 2007

CCPS PSM

Shell HSSE & SP Control Framework, Version 2, 2009

Process / Chapter 1 Leadership and Commitment

No explicit reference.

4.4.1 Resources, Roles, Responsibility, Accountability, and Authority

1. Process Safety Culture

1. Leadership and Commitment

Process / Chapter 2 Policy and Strategic Objectives

4.1 General Requirements 4.2 Environmental Policy 4.3.2 Legal and Other Requirements

4.1 General Requirements 4.2 OH&S Policy 4.3.2 Legal and Other Requirements

2. Compliance with Standards

2. Policy and Objectives

Process / Chapter 3 Organisation, Responsibilities, Resources, Standards, and Documents

4.4.1 Resources, Roles, Responsibility, and Authority 4.4.2 Competence, Training, and Awareness 4.4.3 Communication 4.4.4 Documentation 4.4.5 Control of Documents

4.4.1 Resources, Roles, Responsibility, Accountability, and Authority 4.4.2 Competence, Training, and Awareness 4.4.3 Communication, Participation, and Consultation 4.4.4 Documentation 4.4.5 Control of Documents

3. Process Safety Competency 4. Workforce Involvement 5. Stakeholder Outreach 6. Process Knowledge Management 12. Training and Performance Assurance 15. Conduct of Operations

3. Organisation, Responsibilities, Resources (including Competence)

Process / Chapter 4 Hazards and Effects Management

4.3.1 Environmental Aspects 4.4.7 Emergency Preparedness and Response

4.3.1 Hazard Identification, Risk Assessment, and Determining Controls 4.4.7 Emergency Preparedness and Response

6. Process Knowledge Management 7. Hazards Identification and Risk Analysis 14. Operational Readiness 16. Emergency Management

4. Risk Management (including Managing Risk and Risk Assessment Matrix [RAM])

Process / Chapter 5 Planning and Procedures

4.3.3 Objectives, Targets, and Programme(s) 4.4.6 Operational Control 4.4.7 Emergency Preparedness and Response

4.3.3 Objectives and Programme(s) 4.4.6 Operational Control 4.4.7 Emergency Preparedness and Response

8. Operating Procedures 9. Safe Work Practices 10. Asset Integrity and Reliability 11. Contractor Management 13. Management of Change 15. Conduct of Operations 16. Emergency Management

5. Planning and Procedures (including Emergency Response, Management of Change, Permit to Work, Planning and Procedures)

6. Implementation Monitoring and Reporting (specifically – Implement)

Process / Chapter 6 Implementation and Operation

4.4.6 Operational Control 4.5.4 Control of Records

4.4.6 Operational Control 4.5.4 Control of Records

6. Process Knowledge Management 8. Operating Procedures 9. Safe Work Practices 10. Asset Integrity and Reliability 11. Contractor Management 13. Management of Change 15. Conduct of Operations

Process / Chapter 7 Assurance: Monitoring and Audit

4.5.1 Monitoring and Measurement 4.5.2 Evaluation of Compliance 4.5.3 Nonconformity, Corrective Action & Preventive Action 4.5.4 Internal Audit

4.5.1 Performance Measurement and Monitoring 4.5.2 Evaluation of Compliance 4.5.3 Incident Investigation, Nonconformity, Corrective Action Preventive & Action 4.5.5 Internal Audit

17. Incident Investigation 18. Measurement and Metrics 19. Auditing

6. Implementation Monitoring and Reporting (specifically – Incident Investigation and Learning, and Performance Monitoring and Reporting) 7. Assurance

Process / Chapter 8 Review

4.6 Management Review

4.6 Management Review

20. Management Review and Continuous Improvement

8. Management Review

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HSE MS Manual Format Each HSE MS Process chapter contains the following standard sections and format, in order to explain and simplify its content for the reader: 1. OVERVIEW: This explains the “WHY” or purpose of the Process in the overall HSE MS. 2. REQUIREMENTS: This explains “WHAT” is required to be implemented in the HSE MS Process. 3. PROCEDURES: This explains “HOW” the HSE MS Process / activity is to be implemented or conducted. 4. REFERENCES: This explains to the reader “WHERE” to look for further implementation information in other PDO documentation.

0.2 PURPOSE AND OBJECTIVES 0.2.1 Purpose of PDO‟s HSE Management System The purpose of PDO‟s Health, Safety, and Environment Management System is to manage threats, hazards, events, and effects to health, safety, and the environment in a systematic and structured way. The management of these involves a systematic process of risk identification, assessment / evaluation, control, monitoring, and recovery where necessary. The HSE Management System also sets performance standards for managing health, safety, and environment, which will be assessed and continually improved by a systematic approach to performance monitoring, audits, assessments, and reviews.

0.2.2 Objectives of the HSE Management System Manual – Code of Practice CP-122 The objectives of this HSE Management System Manual or CoP 122 are: 

To inform, by providing all employees, contractors, and other relevant stakeholders with a concise, comprehensive, and structured description of all aspects of PDO‟s HSE Management System. As such, the Manual / CoP describes the „processes‟ for managing HSE at the corporate level, and within any Asset Team. It also acts as the main reference framework for the various documents that make up the HSE Management System.



To illustrate the linkages between the HSE Management System and the Business Control Framework used to manage PDO‟s Asset Teams.



To provide a high level document which systematically addresses achievement of, and alignment to PDO‟s Three HSE Golden Rules: 1) Comply with the law, standards, and procedures; 2) Intervene in unsafe or non-compliant actions; and 3) Respect our neighbours.



To provide a high level document which systematically addresses achievement of, and alignment to PDO‟s Life Saving Rules.



To inform and communicate PDO‟s HSE Management System to employees, contractors, and other relevant stakeholders in a way that is interesting and easy to understand. It does this through color coding each chapter to represent each process of the HSE Management System and matches the colors on the HSE Management System logo, as well as formatting each chapter in a standardized way as defined above.

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0.3 TARGET AUDIENCE AND DISTRIBUTION PDO‟s HSE Management System applies to all PDO activities (including those conducted by employees, contractors, suppliers, and/or other relevant stakeholders). The main target audience for this HSE Management System Manual is all PDO employees and contractors; therefore it is designed for the widest circulation possible within PDO. Contractors, suppliers, and other relevant stakeholders may also be considered as a „target audience‟ in that they may wish to use this Manual / CoP as guidance in developing their own HSE Management Systems to meet PDO requirements. Distribution of this document is controlled by the Document Owner, the Corporate HSE Manager. PDO‟s Electronic Document Management System (EDMS) is used for document control. This document shall be reviewed annually by the Document Owner. The objective of this document review is to determine the ongoing suitability, adequacy, and effectiveness of CP-122, and to identify any needs for change, updating, and/or continual improvement. This can be included in or as part of the PDO HSE-MS Management Review process as described in Process 8.

0.4 REFERENCE DOCUMENTS Reference documents used in the writing of this Introduction, which may be used for more information: PDO Policies

PL-04 – Health, Safety, and Environmental Protection

PL 04

PDO Codes of Practice

CP-102 – Corporate Document Management CP-107 – Corporate Management Framework

CP 102 CP 107

PDO HSE Procedures

No direct link exists and/or is required.

--

PDO HSE Specifications

No direct link exists and/or is required.

--

PDO HSE Guidelines

No direct link exists and/or is required.

--

Other PDO Documents

Statement of General Business Principles (SGBP) PDO Code of Conduct

January 2007 April 2011

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

Occupational Health and Safety Assessment Series Environmental Management Systems –Specification with Guidance for Use Quality Management Systems – Requirements The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

OHSAS 18001:2007 ISO 14001:2004 ISO 9001:2008 CCPS 2010

0.4.1 Other useful reference documents: Please refer to the individual HSE MS Process for further reference documents and their hyper-links, and/or the Glossary for a complete listing.

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0.4.2 Feedback FEEDBACK FORM: In the spirit of continual improvement, CP-122 will be periodically reviewed and updated as necessary to incorporate corrections and improvements identified by users. PDO would very much welcome your comments and suggestions to assist this process. If you would like to make any suggestions for improvement please can you send your comments on an email to MSE52, organizing the information in a format similar to that shown below. CP-122 Reference / Section

Suggestions for Improvement

Appendix One: PDO Documentation Hierarchy and Framework

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1. LEADERSHIP AND COMMITMENT 1.1 OVERVIEW PDO promotes a strong culture of commitment to HSE management through:  Its core values of honesty, integrity, and respect for people,  Valuing trust and pride in PDO,  Openness, teamwork, and professionalism. The leadership in PDO is responsible to promote, discuss, provide, and set proper HSE examples and behaviours. PDO leaders demonstrate their commitment through various walk-the-talk activities.

Leaders / Leadership A leader is a person who motivates a group of people towards achieving a common goal. In PDO, there are leaders at all levels from the Managing Director to the Supervisor. Leadership is the collective function of all leaders.

HSE Culture HSE culture is the combination of HSE systems, peoples‟ behaviours, and attitudes.

1.2 REQUIREMENTS Leaders at all levels in PDO shall provide strong and visible leadership by setting a personal example to promote a culture in which all employees and company contractors share a commitment to HSE. The functions and responsibilities of the leadership shall include the following, within the limitations of their job responsibilities:

1.2.1 Visibility  Participating in HSE activities (e.g., training,

    

behaviour observation, commendation and coaching schemes, industry and contractor workshops, forums, and conferences, and audits / assessments). Putting HSE issues high on the agenda of the meetings they are chairing. Participating in the review of performance against all HSE plans, goals, objectives, and/or targets. Providing immediate and visible response and involvement in the case of an incident or any other disruption to normal business. Seeking internal and external views on HSE, and using and managing this knowledge in a meaningful manner. Recognizing individual and group HSE achievements, using positive behaviour reinforcement techniques, and coaching for correcting behaviour as necessary.

1.2.2 Goals, Objectives, and Targets  Jointly developing and discussing with PDO employees and contractors HSE „leading‟ and „lagging‟ improvement goals,

objectives, targets, and/or other indicators / KPIs.  Ensuring staff have a balance of HSE „leading‟ and „lagging‟ goals, objectives, and/or targets in their performance appraisals.

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1.2.3 HSE Culture Creating and sustaining an HSE culture that supports:  The slogan “Safe Production” becoming a core value.  The belief in PDO‟s desire to continually improve HSE performance.  The motivation to improve individual, team, asset, and company level HSE performance.  The acceptance of individual accountability and responsibility for HSE performance.  Participation and involvement at all levels in the development, implementation, maintenance, and continual

improvement of PDO‟s HSE Management System.  Empowerment for all to intervene and stop any substandard and/or hazardous work activity without blame or redress.  Empowerment for all to intervene, commend, and encourage safe work behaviour and activity.

1.2.4 Informed Involvement  Reviewing the progress both in the development and content of PDO‟s HSE Management System so as to ensure its ongoing    

suitability, adequacy, effectiveness, and continual improvement. Allocating appropriate resources and expertise to meet HSE goals, objectives, and targets (e.g., finance, manpower, time, technology, skills, and/or training). Undertaking relevant training and other HSE leadership competency development activities themselves. Being fully aware of PDO‟s high priority areas for improvements identified in the HSE Management System, particularly in relation to legal compliance, risk level, and stakeholder issues. Being fully aware of the status of follow up actions.

PDO‟s commitment to HSE shall further be demonstrated and strengthened by:  Achieving and maintaining external certification of the HSE Management System to international standards  Communicating its HSE expectations to employees and contractors via various channels and best-practice activities.  Developing annually HSE Plan(s) and by including HSE issues in strategic planning and business risk assessments.

1.3 PROCEDURES The procedures specified in Section 1.3 for Leadership and Commitment at all levels shall be met as part of the job accountabilities and responsibilities defined for each individual within the Corporate Management Framework, Job Descriptions, etc.

1.4 REFERENCES The following documents provide further / related information on Leadership and Commitment: PDO Policies

PL-04 – Health, Safety, and Environmental Protection

PL 04

PDO Codes of Practice

CP-107 – Corporate Management Framework

CP 107

PDO HSE Procedures

No direct link exists and/or is required.

--

PDO HSE Specifications

No direct link exists and/or is required.

--

PDO HSE Guidelines

No direct link exists and/or is required.

--

Other PDO Documents

Statement of General Business Principles (SGBP) PDO Code of Conduct

January 2007 April 2011

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

OHSAS 18001:2007 CCPS (2010)

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2. POLICY AND STRATEGIC OBJECTIVES 2.1 OVERVIEW It is PDO‟s policy to conduct its business properly with respect to HSE (within the scope of legal and other requirements), not to violate these requirements, abide by all legal decisions, and to maintain a positive and proactive team approach to HSE at all times. PDO has a set of 15 business policies including the HSE Policy (PL-04). The HSE policy is the highest level document in PDO‟s HSE MS and is aimed at achieving the ultimate goal of zero harm to people and the environment. It is endorsed by the MDC and approved by the Managing Director. Its content is consistent with the requirements of the PDO Corporate Management Framework, ISO 14001 (for environmental management), OHSAS 18001 (for occupational health and safety management), and the Center for Chemical Process Safety / CCPS (for Process Safety). It also commits PDO to comply with all applicable Omani laws and regulations and continually strive to achieve improvement in HSE performance. PDO‟s overall business strategy is to integrate and balance economic, health, safety (occupational and process), environmental, and social requirements in all that we do, using risk-based approaches. To help focus our efforts at the strategy level, PDO has developed a Statement of General Business Principles (SGBP); also, various strategic objectives for HSE are also established, and these are reviewed and revised as required on an annual basis.

2.2 REQUIREMENTS Senior Leadership at PDO shall define and document its HSE policy and strategic objectives and ensure that they:   

  



Are consistent with those of the Company‟s external stakeholders. Are relevant to the Company‟s activities, products, and/or services. Are consistent with and are of equal importance to PDO‟s other business policies and strategic objectives. Are publicly available. Commit the Company to meet or exceed all relevant regulatory and/or legislative requirements. Commit the Company to reduce their risks and hazards to health, safety, and the environment to levels which are “As Low as Reasonably Practicable” (ALARP). Provide a structured framework for achieving continual improvement in both HSE performance and the management system.

2.2.1 HSE Policy PDO‟s HSE policy shall be produced in an easy to read format in both Arabic and English, and be approved and dated by PDO‟s Managing Director. To be effective, all employees and company contractors should be made aware of the HSE policy‟s existence. Its content, requirements, and intent should be formally distributed, communicated, and explained by all relevant PDO Leadership.

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2.2.2 HSE Strategic Objectives PDO‟s Statement of General Business Principles with respect to HSE and the management system shall be supported by goals, objectives, and targets at the corporate and asset levels, and are developed each year as part of PDO‟s strategic and business planning process. Refer to Chapter 5 of this Manual “Planning and Procedures” for more details about PDO‟s HSE planning process. Annual HSE plans and programs shall be implemented through People & Organisation, Business Processes, and Managing Assets. The business results of these shall be analyzed and reviewed against goals, objectives, and targets, and these results and feedback used to set future goals, objectives, and targets.

2.3 PROCEDURES 2.3.1 HSE Policy The process and requirements for managing the PDO HSE Policy is detailed in the flowchart below.

2.3.2 Legal and Other Requirements In order to ensure that the HSE policy, and therefore the strategic objectives are in line with all legal and other requirements, the following process shall be followed. Head of Corporate Legal Department: 

Maintain a “legal register” of all current Royal Decrees (RDs), Ministerial Decisions (MDs), and supporting Ministerial documents relating to HSE management.

 

Maintain a “register of other requirements” document relating to HSE management including ISO 14001, OHSAS 18001, CCPS, etc. Obtain and retain on file a current official Arabic transcript of each document.



Obtain and retain on file an English translation of each document.



Identify and review proposed and actual changes in legal and other requirements, and update the Corporate HSE Manager of these changes in legal and other requirements.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Corporate HSE Manager: 

Review legal and other requirements, and incorporate these legal and other requirements into the development and subsequent review of PDO‟s HSE MS.



Review all applications for HSE licenses, approvals, and/or permits. Where necessary, coordinate negotiating the terms and conditions with any relevant party(ies).

 

Submit license, approvals, and/or permit applications to the Ministry of Environment and Climate Affairs (MECA). Coordinate PDO‟s participation and input to Omani regulatory authorities in drafting new HSE laws and changes to existing laws.



Develop asset level business controls that incorporate PDO‟s HSE legal and other requirements.





Develop appropriate business controls to (a) obtain all necessary HSE licenses, approvals, and/or permits. Ensure they are cross referenced to the appropriate legal requirement, and referred to in the „Legal Register,‟ if applicable; (b) meet the implementation and technical conditions of HSE licenses, approvals, and/or permits; and (c) ensure proactive and timely review and renewal of HSE licenses, approvals, and/or permits. Review and update business controls to incorporate changes in PDO‟s HSE legal and other requirements.



Retain on file a current copy of all HSE licenses, approvals, and/or permits.

2.3.3 HSE Strategic Goals, Objectives, and Targets PDO HSE strategic objectives and corporate goals and targets for HSE performance shall be developed by the Corporate HSE Manager in line with the HSE policy statement and based on PDO‟s risk profile. While developing these, all Directors shall be actively engaged. Once developed, these shall be forwarded to the MDC for review and endorsement. The MDC endorsed corporate goals, objectives, and targets shall be communicated to the various Directorates. Each Directorate shall then develop their own goals, objectives, and targets in line with the corporate goals, objectives, and targets, and based on their own risk profiles. During this process, all Asset Directors / discipline level leaders, and HSE Advisors shall be actively engaged. HSE strategic objectives as well as the corporate / directorate goals, objectives, and targets shall be reviewed and revised, where necessary, on an annual basis.

The annual HSE goals, objectives, and targets are captured in the Annual Business Plans. The HSE strategic objectives and the corporate goals, objectives, and targets shall be distributed, communicated, and explained to all contractors. They shall also be distributed, communicated, and explained to other key external stakeholders. l July 2011

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2.4 REFERENCES The following documents provide further / related information on Policy and Strategic Objectives: PDO Policies

PL-04 – Health, Safety, and Environmental Protection PL-10 – Security Policy and Emergency Response Policy

PL 04 PL 10

PDO Codes of Practice

CP-100 – Policy Approval CP-107 – Corporate Management Framework

CP 100 CP 107

PDO HSE Procedures

No direct link exists and/or is required.

--

PDO HSE Specifications

No direct link exists and/or is required.

--

PDO HSE Guidelines

No direct link exists and/or is required.

--

Other PDO Documents

Statement of General Business Principles (SGBP) PDO Code of Conduct

January 2007 April 2011

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

Environmental Management Systems –Specification with Guidance for Use Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

ISO 14001:2004 OHSAS 18001:2007 CCPS (2010)

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3. ORGANISATION, RESPONSIBILITIES, RESOURCES, STANDARDS, AND DOCUMENTS 3.1 OVERVIEW All employees, individually and collectively, are responsible for HSE performance at PDO. To develop an effective HSE MS and make it work, line accountability and responsibility, informed involvement, and the active participation of all levels of leadership, is required. This accountability, responsibility, informed involvement, and active participation are exercised in PDO through:  The organisation structure that defines HSE accountabilities and responsibilities for each employee.  The resources (human, time, physical, and financial, for HSE development, implementation, and continual improvement) provided.  Communicating HSE MS requirements and standards to all employees, suppliers, contractors, and sub-contractors, and other relevant stakeholders.  Planning and scheduling the development, documentation, implementation, ongoing maintenance, and continual improvement of the HSE MS.  Ensuring that PDO employees, suppliers, contractors, and sub-contractors are competent, and that training is provided as needed to fill any competency gaps employees, suppliers, contractors, sub-contractors, and/or other relevant stakeholders may have for HSE success.

3.2 REQUIREMENTS PDO‟s organisational structures at the corporate level and at the directorate levels are available on PDO‟s intranet.

3.2.1 HSE Organisation With regard to HSE management, the Managing Director along with the Directors shall have the overall accountability for HSE management in PDO. The responsibility for implementing HSE Management System expectations / requirements and monitoring HSE performance shall lie with the Line Leaders. HSE Advisors and Team Leaders shall provide the necessary technical advice to Line Leaders on HSE issues. The Management Representative for the HSE function shall be the Corporate HSE Manager, who shall be responsible for developing and maintaining the HSE Management System as well as for HSE compliance assurance. The Corporate HSE Functional Discipline Heads (CFDHs) shall provide the necessary technical support to the Corporate HSE Manager. 3.2.2 HSE Standards

In addition to Omani law, PDO bases its HSE MS on other external standards and requirements. In line with the HSE Policy (PL04), which requires a "systematic approach to HSE management," PDO‟s HSE Management System shall comply and be certified to the requirements of ISO 14001. STANDARD

PERFORMANCE STANDARD

MANAGEMENT SYSTEM PERFORMANCE STANDARD

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A standard represents agreement on best practice for the technology or process concerned. For example, ISO 14001 is an international standard that represents worldwide agreement on best practices for environmental management. This is NOT a (technical) performance standard. A performance standard typically imposes quantifiable limits and targets, such as "how much gas can be released into the air." Many of the Royal Decrees and Ministerial Decisions in Oman are Performance Standards. These are often referred to as technical standards. A management system performance standard is a statement detailing WHO, does WHAT, WHEN and/or HOW OFTEN. These standards define performance expectations or requirements of PDO leadership, employees, and/or suppliers, contractors, and sub-contractors.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual In addition to the above standard, PDO‟s HSE Management System also addresses other external requirements. Therefore, PDO‟s HSE Management System:  Is aligned to and incorporates where relevant the requirements of OHSAS 18001, since this is also closely related to the requirements of ISO 14001.  Is aligned to and incorporates where relevant the requirements of The Center for Chemical Process Safety (20 CCPS Elements for Process Safety).  Adopts the general structure of the Shell HSSE & SP Control Framework (December 2009). The role of PDO‟s CFDHs includes responsibilities to screen technical innovation and promote technical HSE and business standards. The Functional Disciplines, therefore, shall be responsible for monitoring the development of industry and other standards, and incorporating them as applicable into PDO‟s business and HSE controls, and associated documentation.

3.2.3 HSE Committees and Meetings There is a cascading network of dedicated HSE management committees and meetings within PDO for reviewing HSE management and HSE performance, and which also ensures that current HSE issues are identified and communicated to all levels of the organisation in a timely manner. The HSE committees and meetings shall interface with business management committees and meetings at the same level of the company, enabling key HSE issues to be included on the agenda of these meetings. The reporting relationships between business management committees and meetings, and dedicated HSE committees and meetings are as shown in the following figure.

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3.2.4 HSE Responsibilities In PDO, HSE management shall be a line leadership and employee responsibility, requiring the active participation of all levels of leadership and supervision. The Corporate HSE Manager, HSE CFDHs and the Asset HSE Team Leaders and Advisors shall act in an advisory and/or support capacity to PDO‟s line leaders and employees. PDO‟s HSE Policy, Commitment, and Accountabilities booklet describes HSE roles, accountabilities, and responsibilities at each level of the organisation.

3.2.5 Individual Responsibilities Individual responsibilities and accountabilities relating to HSE management shall be as defined in individual Job Descriptions, an individual‟s Personal Performance Contract (PPC), supplemented by the specific requirements defined in the various HSE Procedures and Specifications, which are available in PDO‟s Electronic Document Management System (EDMS). However, the key responsibilities and accountabilities with regard to HSE are summarized below: MANAGING DIRECTOR The Managing Director shall have the ultimate accountability for the HSE function in PDO. He/She along with the other members of the MDC shall be accountable for the HSE policy, strategy, planning, providing the necessary resources, and management review of the HSE MS. DIRECTORS All directors shall be primarily responsible for reviewing and endorsing the HSE policy, strategy, planning, resource allocation, monitoring HSE MS performance, and conducting HSE MS management reviews. In addition, Functional Directors as the line leaders of their assets / disciplines shall be accountable for the implementation of the HSE MS in their areas of control. CORPORATE HSE MANAGER The Corporate HSE Manager, as the Management Representative, has overall accountability for coordinating the development, maintenance, and improvement of PDO‟s HSE MS. He/She shall be responsible for developing HSE systems, procedures, standards, as well as HSE goals, objectives, and targets on an annual basis, and providing HSE compliance assurance to the management. In addition, he/she shall be responsible for the following:         

Providing specialist HSE advice to other CFDHs and assets. Analyzing corporate HSE data. Screening and dissemination of technical innovations in HSE. Stimulating creativity with respect to managing HSE. Spreading lateral learning about HSE across Asset Teams. Developing and planning of HSE with CFDHs, HSE Team Leaders, and HSE Advisers. Promoting technical standards on HSE. Managing HSE knowledge within PDO. Managing and coordinating HSE Assurance activities within PDO.

CORPORATE HSE FUNCTIONAL DISCIPLINE HEADS HSE CFDHs, each of whom is a Subject Matter Expert (SME) in one of the HSE disciplines shall provide technical assistance to the Corporate HSE Manager in all his/her responsibilities, including HSE compliance assurance.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual HSE TEAM LEADERS AND HSE ADVISORS (ASSETS AND PROJECTS) HSE Team Leaders and HSE Advisors (Assets and Projects) are primarily responsible for compliance assurance at the asset / project level and providing the necessary technical advice and guidance to the Asset / Project / Contractor Managers as and when needed. LINE LEADERS (OPERATIONS, ENGINEERING, AND PROJECTS) Asset Directors / Project Managers shall be accountable for implementing PDO‟s HSE Policy and the HSE Management System within their assets or projects. They shall have the overall accountability for implementing the HSE MS requirements in their assets / projects / contracts as well as monitoring HSE performance. TEAM LEADERS, LINE SUPERVISORS, AND CONTRACT HOLDERS Team Leaders, Line Supervisors, and Contract Holders shall be primarily responsible for ensuring that activities are carried out in accordance with PDO‟s HSE Policy and other requirements of PDO‟s HSE Management System. EMPLOYEES, SUPPLIERS, CONTRACTORS, AND SUB-CONTRACTORS All PDO employees, suppliers, contractors, and sub-contractors shall be responsible and accountable for following the instructions of their line leader / supervisor, in accordance with PDO‟s HSE Policy and other requirements of PDO‟s HSE Management System.

3.2.6 Committee / Meeting Responsibilities The HSE roles, responsibilities, and accountabilities of PDO‟s business management committees and HSE committees and meetings shall be as detailed in their respective Terms of Reference (ToR).

3.3 PROCEDURES 3.3.1 Types of Resources Effective operation of PDO‟s HSE Management System requires sufficient allocation of human, time, physical, and financial resources. HSE resource requirements shall be considered during the HSE management planning process (see Process 5 of this Manual "Planning and Procedures") and during the HSE management review process (see Process 8 of this Manual "Review"). HUMAN RESOURCES Employees, contractors, sub-contractors, suppliers, and other relevant stakeholders. Effective HSE management relies on the competence (relevant education, training, and/or experience) of these people, and ultimately proactive workforce involvement.

TIME RESOURCES Allocating sufficient time to perform a task or activity in the “right way” – the healthy way, the safe way, the environmentally friendly way, the quality way, and the productive way.

FINANCIAL RESOURCES Allocation of necessary budget(s) for people, equipment, materials, and the environment, by balancing financial cost against the expected residual risk. This also relates to the „ALARP‟ concept described in Process 4: Hazards and Effects Management (HEMP).

PHYSICAL RESOURCES PDO‟s assets (e.g., buildings, equipment, materials, vehicles, tools, technology, etc.). Allocating physical resources requires consideration of the HSE risks that arise in all of PDO‟s activities, including the supply chain (i.e., purchasing and procurement activities).

Sufficient resource allocation shall also be considered in managing change (MOC) and during assessments of risk controls as part of HEMP (see Process 4 of this Manual "Hazards and Effects Management").

3.3.2 Competence PDO shall maintain processes for ensuring that personnel performing specific HSE Critical Roles are competent on the basis of education, training, and/or experience. The HSE competencies of all personnel holding positions with HSE Critical Roles shall be regularly reviewed and assessed, and their personal development and training requirements shall be identified and established. In short, PDO shall manage the fitness to work of their employees, taking into account the physical, mental, and psychological requirements of their occupation or function. HSE competence assurance is a process designed to provide adequate confidence to PDO‟s management and other stakeholders that PDO employees and contractors have the competence (knowledge and skills) to carry out HSE critical tasks of July 2011

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual their jobs to the standards expected. PDO‟s HSE competence assurance process and procedure PR-1029 is largely based on Shell Group Competence Assurance Standards and Guidelines. All staff holding Senior Leadership Positions, HSE Professional Positions, HSE Critical Positions (Level 1 & Level 2), Contract Holders (CHs), and Company Site Representatives (CSRs) of high / medium HSE risk contracts are required to complete the HSE competence assurance process. Contractors are required to implement and maintain a competence assurance procedure for their staff that is consistent with PDO‟s competence assurance requirements. PDO‟s competence assurance process is also linked with the Personal Development Plans and Performance Contracts of Individuals through the SAPpHiRe system. For HSE Professional Positions and Level 2 HSE Critical Positions, the HSE competence requirements are defined in their Job Competence Profiles (JCPs) in SAPpHiRe. All the Level 2 HSE Critical Positions are flagged out in the SAPpHiRe system. For CHs and CSRs of high / medium HSE risk contracts, there are specific HSE competence requirements in addition to the common requirements as defined in their JCPs. There are no specific JCPs for Level 1 HSE Critical Positions. These knowledge and skill requirements depend on the type of HSE critical tasks being carried out (e.g. driving, gas testing, welding, etc.), and are assured via other schemes and methods such as testing, discipline specific training, and licensing as appropriate. The “on line” HSE competence assurance process through the SAPpHiRe system is illustrated in the following diagram:

Responsibilities of the Individual: Confirm Job Requirements with Supervisor  Complete Self Assessment  Discuss with Supervisor  Agree Competence Gaps  Agree Actions to Address Gaps. Responsibilities of the Supervisor: Ensure Staff Complete the Process  Confirm Job Requirements of Staff  Review Staff Self Assessment  Conduct Open, Objective Discussion  Determine Competence Level and Define Competence Gaps  Determine Actions needed to Address Gaps. (Engage an assessor if assistance needed to make objective judgment on competence or to verify their skills.). Responsibilities of the Assessor (where used): Supervisor.

Provide specific assessment and judgment support, on request, to the

PDO‟s competency skills portfolio matrix is available in PDO‟s EDMS.

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3.3.3 HSE Training PDO shall maintain procedures to ensure and increase competence by identifying training needs and providing appropriate and needed training for all employees, suppliers, contractors, and sub-contractors. Training may be provided through internal or external formal courses, on-the-job training, and/or through structured development in the workplace, such as coaching or mentoring activities. The extent and nature of training should ensure achievement of PDO‟s HSE Policy and objectives and should meet or exceed standards required by legislation, regulations, and/or other requirements. Appropriate records of training should be maintained with refresher training scheduled, implemented, and recorded as required, to a defined frequency. PDO‟s requirements for HSE training courses are defined in SP-1157 Specification for HSE Training. Training requirements for contractors are specified in PR-1171 Contract HSE Management Procedure. Individual responsibilities with regard to HSE training are shown in these documents.

3.3.4 Contracting In carrying out its business activities, PDO provides a set of core services, concentrating on “what it does best,” while securing goods (procurement) and services (contracting and sub-contracting) from the market in “what the market does best.” PDO therefore depends on suppliers, contractors, and sub-contractors to carry out a wide variety of activities. On the downside, many of these activities pose HSE threats and risks. On the upside, use of suppliers, contractors, and sub-contractors also provides PDO with HSE benefits and opportunities. Recently, the emphasis on managing supplier and contractor HSE performance has shifted from monitoring of HSE performance after contract award, to early contract phases of tender evaluation and mobilization. However, monitoring workplace activity during execution of the work remains a crucial part of supplier and contractor HSE management. In addition, a final check or assessment of the contractor and work needs to be done to close out the contract appropriately. Overall, supplier, contractor, and sub-contractor management in PDO must nowadays take this holistic “cradle-to-cradle” lifecycle approach. PDO shall maintain procedures to ensure that its suppliers, contractors, and sub-contractors operate a management system that is consistent with the requirements and provisions of PDO‟s own HSE MS. These procedures provide an interface between supplier, contractor, and sub-contractor activities and with those of PDO. This is achieved by implementation of these three main documents:   

PR-1233 Contract & Procurement Procedure PR-1171 Contract HSE Management Part I - Mandatory for PDO Personnel involved in Contract Management PR-1171 Contract HSE Management Part II - Mandatory for Contractors & Contract Holders.

Significant aspects related to HSE in PR-1233 Commercial Procedures and Guidelines and PR-1171 Contract HSE Management Procedure include:  

Requirements for conducting an assessment of the HSE risks associated with the contract. Procedures for selection of suppliers, contractors, and sub-contractors (including specific assessment of their HSE policy, practices, performance, and the adequacy of their HSE Management System) in line with the risks associated with the services to be provided.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual 

Effective communication of the key elements of PDO‟s HSE Management System and of the standards of worker and environmental protection expected from the supplier, contractor, and sub-contractor, including agreed HSE objectives and performance criteria.



Sharing, by PDO and its suppliers, contractors, and sub-contractors, of relevant information which may impact on the HSE performance of either party. The requirement that each supplier, contractor, and sub-contractor have an effective and relevant training program, which includes records and procedures for assessing the need for further training. Definition of methods for monitoring and assessing supplier, contractor, and sub-contractor performance against agreed HSE objectives and other performance criteria.

 

Additionally, PR-1171: 



Requires the PDO Contract Holder to prepare requirements that define what the supplier, contractor, and sub-contractor must do to minimize HSE risks. These requirements are included in standard contract documentation as Document C-9 HSE Requirements (GU-140). Stipulates that supplier, contractor, and sub-contractor requirements for HSE management of activities conducted under a Minor Contract are described in SP-1151 General Conditions for Minor Works and Services Contracts.

3.3.5 Procurement The activities of PDO‟s suppliers pose certain HSE risks. Where possible, PDO seeks to influence improvement in HSE performance in its supply chain through the application of these documents: 

CP-129 Contracting and Procurement Code of Practice



PR-1233 Contract & Procurement Procedure



GU-425 Contracting and Procurement Guidelines.

3.3.6 Documents PDO‟s HSE MS is described by a hierarchy of business control documents. At the Corporate level, the HSE MS is described in Part I of this Manual‟s "Introduction." At the Asset level, documents that describe the implementation of PDO‟s HSE MS are part of the business management systems used to control the day-to-day tasks and activities of the Asset Team. To implement and maintain an effective HSE MS, these documents shall be developed and managed throughout their lifecycle according to the flowchart shown here. Document management and the documents themselves should incorporate the concept of traceability, i.e., be legible, dated (with dates of the most current revision), readily identifiable, numbered (with a version number), maintained in an orderly manner, and retained for a specified period. Procedures should be established for document creation, maintenance, and modification, and for their availability to employees, contractors, and other relevant parties.

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3.3.7 Stakeholder Communication Parties interested in PDO‟s activities are divided into two groups: Internal Stakeholders and External Stakeholders. INTERNAL STAKEHOLDERS

PDO Employees, Contractor Employees, Sub-contractor Employees, and Suppliers.

EXTERNAL STAKEHOLDERS

Shareholders, Regulatory Authorities, The public (including Community Groups), The Media, Industry Associations, Customers, Suppliers, Non Government Organisations (NGOs), Educational Establishments, Bankers, Financiers, Insurers, etc.

PDO maintains procedures for communicating HSE information, consistent with its HSE Policy, applicable legislation and regulations, and other requirements. PDO, whilst protecting confidential information, makes its HSE experience available to all employees, suppliers, contractors, sub-contractors, and any other interested stakeholders. PDO also maintains procedures for receiving and responding to communications from employees, suppliers, contractors, sub-contractors, and/or other external stakeholder concerning its HSE performance and management. Community awareness and consultation programs are also maintained where appropriate, and their effectiveness monitored and improved. CP-111 Relationship with Stakeholders describes PDO‟s overall strategy and practice on stakeholder engagement. Communicating with Internal Stakeholders PDO‟s internal stakeholders shall be communicated with respect to the following: 

Importance of compliance with PDO‟s HSE Policy and objectives and their individual roles, responsibilities, and accountabilities in achieving it.



HSE risks and hazards of their work activities and the preventive, corrective, and mitigation measures, and the emergency response procedures that have been established.



Potential consequences of departure from agreed operating procedures and mechanisms for suggesting to management improvements in the procedures which they and others use.

CP-162 Internal Communication describes the requirements and the procedure for communication with internal stakeholders. Maintaining means of external communication in times of an emergency is especially important and special contingency arrangements should be in place. Refer to Process 5 of this Manual "Planning and Procedures" for more details about communication in the event of an emergency. Communicating with External Stakeholders Communication with external stakeholders shall always be through or with the knowledge / consent of the External Affairs & Communication Manager. PR-1957 Issue Identification and Management Process identifies the external stakeholder groups and describes the scope and the method of communicating with them. This procedure is supplemented by PR-1707 Disclosure Procedure which specifies the restrictions on public disclosure of information that could potentially affect PDO‟s reputation.

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3.4 REFERENCES The following documents provide further / related information on Organisation, Responsibilities, Resources, Standards, and Documents.

PDO Policies

PL-03 – Risk and Internal Control Policy PL-04 – HSE Policy PL-05 – Governance Policy PL-08 – Commercial Policy PL-09 – Human Resources Policy

PL 03 PL 04 PL 05 PL 08 PL 09

PDO Codes of Practice

CP-100 – Policy Approval CP-102 – Corporate Document Management CP-107 – Corporate Management Framework CP-111 – Relationship With Stakeholders CP-123 – Emergency Procedures, Part I CP-126 – Personnel and Asset Security CP-129 – Contracting and Procurement CP-141 – Use of Concession Land by Third Parties CP-162 – Internal Communication

CP 100 CP 102 CP 107 CP 111 CP 123 CP 126 CP 129 CP 141 CP 162 PR 1029 PR 1171

PDO HSE Procedures

PR-1029 – Competence Assessment and Assurance PR-1171 – Contract HSE Management Part I - Mandatory for PDO Personnel involved in Contract Management PR-1171 – Contract HSE Management Part II - Mandatory for Contractors & Contract Holders PR-1233 – Contract and Procurement Procedure (CPP) PR-1707 – Disclosure Procedure PR-1957 – Issue Identification and Management Process PR-1980 – HSE Competence Assurance

PDO HSE Specifications

SP-1157 – HSE Training

SP 1157

PDO HSE Guidelines

GU-140 – C9 HSE Specification (Contracts)

GU 140

Other PDO Documents

PDO Code of Conduct

April 2011

Shell Group Documents

Other Requirements

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Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance) Environmental Management Systems –Specification with Guidance for Use Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS www.aiche.org/ccps) Royal Decree 34/73 Oman Labor Law Royal Decree 10/82 Law for the Conservation of the Environment and Protection of Pollution

PR 1171 PR 1233 PR 1707 PR 1957 PR 1980

December 2009 ISO 14001:2004 OHSAS 18001:2007 CCPS 2010 RD 34/73 RD 10/82

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4. HAZARDS AND EFFECTS MANAGEMENT 4.1 OVERVIEW PDO activities have the potential to harm people and the environment, to cause damage or loss to assets, to defer oil production, to cause financial loss, and to adversely impact the Company‟s reputation. A Hazards and Effects Management Process (HEMP) provides a structured approach to managing the hazards and potential effects of PDO‟s activities. There are numerous techniques to carry out HEMP, and the technique chosen should be aligned to the scope of work, risk scenarios in that work, etc. Once this is known, an appropriate technique can be chosen, such as Hazard Identification (HAZID), Hazards Analysis (HAZAN), Hazards & Operability (HAZOP), Task Risk Assessment (TRA), Quantitative Risk Assessment (QRA), Job Safety Plan (JSP), etc. Effective application of HEMP involves four steps: identify, assess, control, and recover, and all steps will generate records. These steps cover identification of the major hazards to people and the environment, assessment of the related risks, as well as implementing measures to control these risks, and to recover in case these measures fail. Although these steps are often described sequentially, in practice they overlap and are not always distinct. HEMP is an iterative process, i.e., a repetitive process wherein the HEMP cycle is ongoing and dynamic because the risk picture in PDO is always subject to change as well. HEMP is also a spoken process, ideally conducted using a team approach where everybody on the team is encouraged to provide their input and knowledge of the threats, hazards, and risks involved, as well as the resulting event that could occur.

This chapter: 

Introduces PDO‟s Hazards and Effects Management Process (HEMP) and describes its role within PDO‟s HSE Management System.



Describes each stage of HEMP.

 

Describes some commonly used HEMP tools and techniques to assist in developing and implementing each step. Describes the general scope of each step and also provides detailed procedures for carrying out and reporting each step.



Provides additional information sources for implementing HEMP.

4.2 REQUIREMENTS HEMP shall be conducted for new assets, facilities, and/or activities as well as regularly for existing facilities or operations whenever major changes take place. HEMP shall cover the lifecycle of asset / facility as illustrated below: LIFECYCLE STAGE

FOCUS OF HEMP

Planning for new assets, facilities, and/or operations

Identification and assessment of threats, hazards, and effects that may be avoided, reduced, and/or eliminated.

Reviewing existing assets, facilities, and/or operations

Identification and assessment of threats, hazards, and effects that may be avoided, reduced, and/or eliminated.

Operational and maintenance stages for all assets, facilities, and/or operations

- Development and implementation of effective controls for HEMP. - Development and implementation of effective recovery preparedness measures. - Identification of new hazards particularly in non-routine operations.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual LIFECYCLE STAGE Establishing a new Contract or renewing an existing Contract

Planning for abandonment and decommissioning Abandonment and decommissioning

FOCUS OF HEMP Identification and assessment of the major threats, hazards, and effects associated with the Contract so that the Contractor and/or Sub-Contractor can: - Develop and implement effective controls for hazards and effects management. - Develop and implement effective recovery and emergency preparedness measures. Identification and assessment of threats, hazards, and effects that may be avoided, reduced, and/or eliminated. Safe clean up and rehabilitation.

4.3 PROCEDURES – IDENTIFY

The first stage in HEMP is to systematically identify the potential health, safety, and environmental threats, hazards, and effects of your activities and operations. Threats, hazards, and effects identification is conducted at an early stage in the design and development of new facilities, equipment, and/or processes. This permits sound HSE practices, systems, and equipment to be 'designed-in,' and allows for a wider choice of hazard prevention, risk reduction, mitigation, and recovery measures to be employed than with existing facilities. Continual hazard identification and risk reduction is required at existing facilities to maintain and improve HSE performance. Threats, hazards, and their consequences can be identified and assessed in a number of ways, ranging from the simple to the complex, as shown in the order below: 

Through experience and judgment.



Using checklists.

 

By referring to regulations, codes, and/or standards. By undertaking more structured review and analytical techniques.

This first stage in HEMP also begins the formal process of documenting and recording the HEMP process. This is an important activity in that it creates a “risk history” for the organisation, and provides traceability when managing risk overall. This stage is also where risk(s) can begin to be „registered,‟ whereby a Company, Asset, or local risk register is established and populated with results of HAZID activities, for example.

4.3.1 Scope of Identification Identification of threats, hazards, and effects should cover the following: 

All activities, products, and/or services controlled by PDO, and those influenced by PDO, such as supplier, contractor, and sub-contractor activities.



All activities, products, and/or services carried out by all personnel having access to the workplace and facilities at the workplace including suppliers, contractors, and sub-contractors.



Routine (frequently performed), non-routine (infrequently performed), and/or emergency operating conditions and activities. Sometimes the categories of normal and abnormal operating conditions are also considered. The lifecycle of an asset or activity, from the planning stage, through operation to decommissioning, and disposal and restoration.



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4.3.2 HEMP Tools - Identification One or more of the following tools may be selected to assist in identifying threats, hazards, and effects. This selection may depend on the information available, the scope and/or phase of the activity or project, and/or maturity of the operation. Structured review techniques reflect collective knowledge and experience, and sometimes are codified into regulations, codes, and/or standards. Generally focused on hazard identification, assessment, and control, they contain specific information on hazards and their management for particular operations and activities.

Checklists are a useful way of ensuring that known threats and hazards have all been identified and assessed. However, use of checklists shouldn‟t limit the scope of the review because checklists should be customized to the area in which they are applied, perhaps entailing adding several categories to them. Hazard and Effects Registers are particularly useful as well, as they capture the knowledge derived from using the checklist(s). Knowledge and the judgment of experienced staff is invaluable for threat and hazard identification, assessment, and control, particularly direct feedback from incidents, accidents, near misses, and Job Safety Plans.

4.4 PROCEDURES – ASSESS

The second stage in HEMP is to assess the health, safety, and environmental risks of all activities, and then to rank these risks. Once the hazards and effects have been identified, their consequences and likelihood can be assessed, evaluated, and the risk level determined. It is important to contrast quantitative risk assessment (QRA) with qualitative risk assessment. Neither is a “better” means of evaluating risk than the other, and either or both can be a valid means of evaluation of a particular risk. Both methods use the same basic steps of hazard identification, consequence assessment, and exposure assessment in order to characterize risk. The primary differences in the methods are the level of complexity in these steps, as well as the level of experience and expertise of the personnel carrying out the assessment and a commensurate increase in the resources required to complete the exercise. Typically, qualitative risk assessment is used 1), to determine if a quantitative assessment is required, and 2), as a screening tool prior to the completion of a quantitative assessment.

4.4.1 Scope of Qualitative Risk Assessments Risk assessment of hazards and effects should cover the following:   

All activities, products, and/or services controlled by PDO, and those influenced by PDO, such as supplier, contractor, and sub-contractor activities. All activities, products, and/or services carried out by all personnel having access to the workplace and facilities at the workplace including suppliers, contractors, and sub-contractors. Routine (frequently performed), non-routine (infrequently performed), and/or emergency operating conditions and activities. Sometimes the categories of normal and abnormal operating conditions are also considered.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual 

The lifecycle of an asset or activity, from the planning stage, through operation to decommissioning, and disposal and restoration.

Qualitative methods are best used for risk assessments of simple facilities or operations, where the exposure of the workforce, public, environment, and/or asset is low. Qualitative risk assessments are typically a combination of judgment, opinion, and experience, and using structured review techniques with as much available risk information as possible. Qualitative risk assessments should be carried out with input from those people directly involved with the risk, using a team approach. The logic here is that those directly involved with the risk have the greatest self interest and “buy-in” to subsequently control it. Many structured review techniques have and use subjective or qualitative evaluation of risk. Techniques such as simple risk assessment, task risk assessment, structured brainstorming, and group risk assessments are useful here, and by their nature require team approaches. Procedures or guidelines detailing how to do these techniques should be available for risk assessment teams to refer to and use. Risk assessments can be undertaken using experience and judgment. A team approach is highly recommended because: 1) no one individual knows everything about the situation being assessed; 2) the quality of risk decisions tends to be higher and more accurate when done with a team; 3) the team approach gets involvement, especially when involving employees and contractors who face the risk; 4) risk decisions by a team also get higher levels of ownership, as the team also participates in determining and ultimately implementing the risk controls they have determined as most effective.

4.4.2 HEMP Tools – The PDO Risk Assessment Matrix (RAM) The PDO Risk Assessment Matrix (shown below) shall be used to assess and evaluate HSE risks. This matrix shows risk as the product of likelihood (or probability) and consequence (or impact). Likelihood here also incorporates the assessment of frequency, as frequency is a major influence on probability, the logic typically applying that the higher the frequency the higher the probability. Consequence is measured against the level of severity or “how bad” the outcome could be. It needs to be noted that there is often more than one consequence, in that one event could lead to primary, secondary, tertiary consequences, etc. For example, in process safety incidents, the consequences may include fatalities, injuries, environmental damage (prolonged release or fire), progressive asset damage, and/or deferred or lost production. However, asset damage normally occurs first, with secondary or more consequences affecting people, environment, reputation, etc. The assessment of likelihood is shown on the horizontal axis with assessment of consequence shown on the vertical axis. Four categories of consequence are considered at PDO: the impact on people, assets, environment, and/or reputation. Plotting the intersection of both likelihood and consequence provides a qualitative assessment of the risk level. Use of the Risk Assessment Matrix will: 







Enhance appreciation of HSE risk and help in reducing the residual risk to As Low As Reasonably Practicable (ALARP) at all levels in PDO (see Section 4.5.3 regarding ALARP). Assist in setting clear risk based strategic goals, objectives, targets, and controls. Provide a systematic, structured, and standardized basis for implementation of a risk-based HSE Management System. Provide consistency in evaluating and managing risk across all PDO activities, including contractor activities.

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4.4.3 Scope of Quantitative Risk Assessments Quantitative Risk Assessments (QRA) are undertaken for more complex facilities or activities, and/or where required by law. Determining whether a qualitative or quantitative technique is to be used depends on the scope and complexity of the scenario being assessed. However, the application of quantitative methods is considered to be desirable under the following situations:  

When evaluating and comparing risk reduction options and where the relative effectiveness of these options is not obvious. When the exposure of the workforce, public or strategic value of the asset is high, and risk reduction measures are to be evaluated When novel technology is involved resulting in a perceived high level of risk for which no historical data is available

 

When a demonstration that risks are being managed to a level which is as low as reasonably practicable (ALARP) is required. The application of QRA need not be limited to large, complex and expensive studies, however. It is a technique that can be applied quickly and inexpensively to help structure the solution to problems for which the solution is not intuitively obvious.



Only staff with adequate training and experience should undertake QRA, although it is critical that personnel familiar with the operation or facility are involved in the study. QRA often involves the use of specialized software. QRA provides a structured approach to assessing risk, whether the risks are human, hardware / software failure, environmental events, and/or combinations of failures and events. QRA identifies high-risk areas, assists in efficient and effective risk management, and helps demonstrate that risks are being managed to a level deemed ALARP. Refer to SP 1258 – Quantitative Risk Assessment for further details on QRA.

4.5 PROCEDURES – CONTROL

4.5.1 Scope of Controls The third stage in HEMP, developing fit-for-purpose risk controls, requires use of appropriate risk control identification techniques, such as HAZOP / PR-1696, for example. Application of the technique chosen should cover: 

All activities, products, and/or services controlled by PDO, and those influenced by PDO, such as supplier, contractor, and sub-contractor activities.



The activities, products, and/or services carried out by all personnel having access to the workplace and facilities at the workplace including suppliers, contractors, and/or sub-contractors. Routine (frequently performed), non-routine (infrequently performed), and/or emergency operating conditions and activities. Sometimes the categories of normal and abnormal operating conditions are also considered. The lifecycle of an asset or activity, from the planning stage, through operation to decommissioning, and disposal and restoration.

 

Risk controls should include prevention, mitigation, and recovery measures. The following table illustrates the difference among these various types of controls:

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual CONTROL PREVENTION MEASURES

MITIGATION MEASURES

RECOVERY MEASURES

USE To reduce the likelihood / probability of hazards or to prevent or avoid the release of a hazard.

To reduce or limit the number and severity of the consequences arising from a hazardous event or effect.

Includes top events.

DESCRIPTION AND EXAMPLE Examples include guards or shields (coatings, inhibitors, shutdowns), separation (time and space), reduction in inventory, control of energy release (lower speeds, safety valves, different fuel sources), and administrative (procedures, warnings, training, drills). Active systems - Intended to detect and abate incidents, i.e., gas, fire, and smoke alarms, shutdowns, deluge systems. Passive systems - Intended to guarantee the primary functions, i.e., fire and blast walls, isolation, separation, protective devices, drainage systems. Operational (non-physical) systems - Intended for emergency management, i.e., contingency plans, procedures, training, drills. All technical, operational, and organisational measures which can: - Reduce the likelihood that the first hazardous event or „top event‟ will escalate or develop into further consequences. - Provide life saving capabilities should the „top event‟ escalate further.

Development of risk controls should consider the “PDO Hierarchy of Risk Controls” as described below. PDO Hierarchy of Risk Controls In all cases, risk controls should be developed and established so that risk reduction achieves a level that is ALARP. The PDO Risk Assessment Matrix is to be used as a standard to identify controls that reduce risk to ALARP. This Matrix for Risk Management is shown below.

Depending on what the threat and/or hazard is, the same control may be used to prevent, mitigate, and/or recover from a threatening and/or hazardous event. For example, all measures ranging from the first steps in mitigation through to reinstatement of the operation assist in preparing for recovery. An important outcome of HEMP is identifying the HSE risks arising from PDO operations that are classified as “high,” prioritizing these, and identifying the actions that must be taken to manage them. These actions are defined as HSE Critical Activities and are a focus of PDO‟s HSE Management System.

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4.5.2. Risk Acceptance Criteria Risk Acceptance Criteria have been established at PDO to provide guidance to the question, “If the risk is determined to be Low, Medium, or High, what should we do with respect to demonstrating ALARP?” For example, SP-1258 – Quantitative Risk Assessment (QRA) refers to risk acceptance criteria. In general, risk acceptance criteria apply the following concept: 

For low risks, there is usually no formal need to demonstrate ALARP; the risks are already low.



For medium risks, sometimes there is a need to demonstrate ALARP by determining and incorporating risk reduction measures. This can be a leadership decision as to what types of controls are required for the various HSE risks that are faced.



High risks require some type of immediate risk reduction plan or measures so as to proceed with the work or activity. In some cases if an immediate risk reduction solution cannot be found and applied, the task or activity may not be allowed to proceed.

4.5.3 What is ALARP? ALARP – As Low As Reasonably Practicable - is often expressed in qualitative or quantitative terms. However, ALARP itself does not prevent accidents; suitable, adequate, effective, and timely implementation of risk controls prevents accidents. Therefore, the following statements are provided as a guide to determining whether a particular risk is being managed to an ALARP level:  

Management ultimately decides whether ALARP is achieved, on a case by case basis, for each particular risk. For each particular risk, ALARP can only be determined by comparing a number of risk control options or strategies.



If risk is not controlled in a manner that meets applicable standards (e.g., Omani Law, industry codes of practice, PDO Specifications, international standards, and/or other stakeholder concerns / expectations), ALARP has not been achieved.

 

ALARP has not been achieved if risk can be appreciably reduced further for only a small incremental cost or investment. There are several quantitative and qualitative tools that may be used to assist in determining and demonstrating that risks are managed to ALARP levels, e.g. the Risk Assessment Matrix, QRA, HAZID, HAZOP, Task Risk Analysis, Cost Benefit Analysis (CBA), etc.

Part of the ALARP demonstration process will involve assessing and evaluating the magnitude of the risk reduction that can be provided by a proposed option. Along with the benefit, the technical feasibility, cost and effort of the proposed risk reduction option should also be assessed as part of CBA. For more information about ALARP, see GU-655 Demonstrating ALARP. The quantified risk reduction considered within the scope of a QRA study, for example, should be limited to options that can be reasonably evaluated by QRA. These are broadly inherent safety options, but may also include some engineered and procedural controls. As many of the risk reduction options would involve changes to the process design, facility layout, safeguarding, or operations philosophy, the brainstorming of QRA risk reduction options should involve a multi-disciplinary team. Identified options should be ranked on quantitative risk reduction against cost and effort of implementing. The residual risk or the benefits gained from risk reduction initiatives, once risk reduction initiatives are approved and implemented, should also be determined by the team.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Example of Managing Risk to ALARP As a guide to deciding whether risk is managed to ALARP, the following statements can be made about the example above: 

Option 1 is not ALARP as the risk is not yet controlled to applicable standards.



Options 2 and 3 may be ALARP. However, if for only a small incremental investment, the risk level could be further reduced as in Option 4, Option 4 would then be ALARP.



Options 5 and 6 may not be ALARP as the reduction in risk may not be justified by the additional investments required for control.

4.5.4 Residual Risk Residual risk is the “remaining” risk after all proposed controls are applied and taking into consideration the quality and effectiveness of the controls in place. The potential difference between inherent and residual risk gives an indication of the quality and effectiveness of the controls put in place. When considering residual risk levels, this should be done in the context of the overall risk profile for the business. In the case of PDO managing major process plants and other process safety issues, major accident hazards are still likely to be a significant contributor to the overall PDO risk profile. Where the residual risks remain at high levels, PDO senior leadership should consider if and what strategic activities are required to further lower the risk levels during their management review processes. This is applying the concept of continual improvement to the overall HEMP process and the organisation‟s overall Risk Profile. The terms „risk acceptance‟ and „risk appetite‟ require consideration as well. Risk acceptance refers to a set of criteria defining the limits above which risks cannot be tolerated. Risk appetite refers to the positive benefits of exploiting a business opportunity associated with the risks. These two concepts together should be balanced against one another and against the cost of managing the exposure. Some other key points regarding residual risk with respect to the managing risk process: 

Residual risk, initially, is a prediction by the assessment team of the risk that will remain, assuming the recommended risk control(s) are implemented. At this stage it is not yet tested or proven.



Risk controls, once their implementation has begun, must be verified in the field at the point of control as to whether the targeted residual risk level has been achieved or not. At this stage, the key question becomes, “Have the implemented risk controls brought the risk down to the predicted level?” This is a key part of risk monitoring.



Once determined, the original risk assessment documentation has to be reviewed and changed as necessary. For example, if the original determination was that a high risk could be brought down to a low risk, but field verifications and the evidence shows the risk level to be actually a medium residual risk, then the risk register and other associated risk documentation must be changed and updated accordingly.

4.6 PROCEDURES – RECOVER

The fourth and final stage in HEMP is to ensure the necessary steps are planned to be able to recover from the release of a hazard, should the controls that have been put in place fail to prevent its release. Recovery from the consequences of the release of a hazard requires careful planning. Even with a comprehensive range of controls in place to prevent the release of hazards and/or their effects, things can still go wrong. Should the controls fail to prevent or avoid the release of a hazard then some kind of counter measures are required to limit the number and severity of the consequences of the hazardous event or effect. These counter measures are aimed at mitigating the consequences of the hazard and aid in reinstatement of the normal operation or activity.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Recovery measures can reduce the likelihood or probability that the first hazardous event will develop into further consequences and provide life saving capabilities should the „top event‟ escalate further. To assist with recovery, it is important that all personnel are fully briefed and drilled as to the response measures planned, including evacuation and restoration procedures. For major incidents, this may include also crisis management and business continuity planning.

4.6.1 Scope of Recovery Recovery should include: 

All activities, products, and/or services controlled by PDO, and those influenced by PDO, such as supplier, contractor, and sub-contractor activities.



The activities, products, and/or services carried out by all personnel having access to the workplace and facilities at the workplace including suppliers, contractors, and/or sub-contractors.



Routine (frequently performed), non-routine (infrequently performed), and/or emergency operating conditions and activities. Sometimes the categories of normal and abnormal operating conditions are also considered. The lifecycle of an asset or activity, from the planning stage, through operation to decommissioning, and disposal and restoration.



In developing recovery measures, consider and include both active (e.g., emergency shutdown procedures, automatic blowdown systems, alarms, fire protection) and passive emergency preparedness and response arrangements (e.g. emergency response call out and duty rosters) for both operational and contingency planning (abnormal situations and potential emergencies). Refer to Chapter 5 of this Manual “Planning and Procedures” for more details about emergency preparedness and response. For effective recovery procedures it is important that each recovery measure be accompanied by formal documentation. For instance, each action that should be taken in the event that a control fails shall be documented. In addition, the persons responsible and/or accountable for establishing, maintaining, implementing, and reviewing each associated procedure shall be defined and competent. Effective recovery procedures also require testing and review. For instance, all procedures for recovery from high risk and emergency scenarios shall be in place and subject to testing and defined review periods. In between the defined review periods, recovery procedures should be reviewed, and possibly updated, for the following situation: 

An incident has occurred.



Following analysis of drills and testing.



Any changes in the operational environment occur.



There are changes in legal and other requirements and/or industry best practice.

Performance against all recovery procedures should be recorded and formally reviewed periodically. Such performance may be linked to Company, Asset, and/or local goals, objectives, and/or targets. Parties responsible and accountable for implementing recovery procedures shall be competent to do so and clearly understand their roles, responsibilities, and accountabilities.

4.6.2 HEMP Tools - Recovery Experienced personnel can construct a bow tie diagram as part of a hazard analysis (HAZAN) and use this to consider the chain of events resulting from a top event and the recovery measures required to reduce the probability and effect of each consequence. Knowledge of experienced personnel is invaluable for hazard identification and analysis / assessment, particularly coming from direct feedback from incidents, accidents, near misses, and/or hazards. Procedures for recovery from high risk and emergency scenarios should be in place and subject to drills, testing, and review. Creating simple checklists and/or Work Instructions, based on procedures, clarify and expedite response in real emergency situations. All control and recovery procedures should be established, included, and recorded in the HSE Management System, an HSE Case, MOPO, and/or Job Safety Plans with recovery actions that should be taken in the event a control fails being documented.

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4.7 PROCEDURES – RECORD

It is important to establish, manage, maintain, review, and update HEMPrelated records to demonstrate traceability and compliance with the entire HEMP process itself, the HSE MS, and/or other requirements. This includes creating, making available, maintaining, and reviewing / updating the documentation for Safety Critical Equipment, including data and drawings that are critical to managing Process Safety / Technical Integrity. The PDO Matrix for Demonstration of Risk Management shown below shall be used as a standard for determining the type of HEMP records required for creating, recording, and retention.

4.7.1 HEMP Tools – Records The following documents should be kept to describe the hazards and effects identification, analysis, controls results, and their monitoring requirements. A Hazard and Effects Register demonstrates that all hazards and effects have been identified, are understood, and are being properly controlled. The Register is kept current throughout the life cycle of a project, i.e., from the planning and design stage, through operation, to decommissioning, abandonment, and disposal. The purpose of the Hazards and Effects Register is to present the results of the analysis made of each hazard or effect present in, or resulting from, the facility or operation. Once the Hazards and Effects Register is completed it is possible to complete a Manual of Permitted Operations (MOPO) which defines:

 The level and number of barriers put in place initially and the recovery measures to be put in place.  The limit of safe operation if the barriers and/or recovery measures are reduced, removed, bypassed, and/or purposefully defeated.

 The limit of safe operation permitted during periods of escalated risk in likelihood, consequences, or both.

 Which activities may or may not be carried out concurrently, often referred to „Simultaneous Operations.‟

Hazards and effects information gained from the Hazards and Effects Register and a MOPO is now incorporated into the HSE Case. The HSE Case must demonstrate that:

   

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All threats, hazards, and effects have been identified. The likelihood and consequences of a hazardous event have been assessed. Controls to manage potential causes (threat barriers) are in place. Recovery / emergency preparedness measures to mitigate potential consequences have been taken.

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4.8 REFERENCES The following documents provide further / related information on the Hazards and Effects Management Process (HEMP):

PDO Policies

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection

PL 03 PL 04

PDO Codes of Practice

CP-131 – Risk and Opportunity Management

CP 131

PDO HSE Procedures

PR-1232 – Design Integrity Review Procedure PR-1696 – HAZOP Procedure PR-1971 – HAZID Procedure

PR 1232 PR 1696 PR 1971

PDO HSE Specifications

SP-1075 – Fire and Explosion Risk Management (FERM) SP-1258 – Quantitative Risk Assessment (QRA) SP-2062 – HSE Specification: Specifications for HSE Cases

SP 1075 SP 1258 SP 2062

PDO HSE Guidelines

GU-195 – Environment Assessment Guideline GU-230 – Fire and Explosion Risk Management (FERM) Facility Plan Guideline GU-432 – Road Transport HSE CASE GU-447 – Integrated Impact Assessment Guidelines GU-611 – PDO Guide to Engineering Standards and Procedure GU-648 – Guide for Applying Process Safety In Projects GU-655 – Demonstrating ALARP

GU 195 GU 230 GU 432 GU 447 GU 611 GU 648 GU 655

Other PDO Documents

No direct link exists and/or is required.

--

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

Environmental Management Systems –Specification with Guidance for Use Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

ISO 14001:2004 OHSAS 18001:2007 CCPS 2010

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5. PLANNING AND PROCEDURES 5.1 OVERVIEW Managing HSE risk and improving HSE performance requires careful planning at all levels in PDO. Goals, objectives, and targets should be set, with plans established to achieve these. In the event of an unplanned event and/or existing plans go wrong, emergency preparedness, response, and/or contingency plans should be in place. An important outcome of HEMP is identifying the key activities that must be controlled if PDO is to adequately manage HSE risks and planning for them. Procedures and work instructions should be established to manage these activities. These procedures should also address risk control requirements generated from the HEMP process. A Permit to Work system should be implemented to control work in areas where the area and/or the work itself is deemed to be hazardous and the associated risk level requires special precautions to be taken. This Chapter covers PDO‟s use of plans and procedures to achieve our HSE goals, objectives, and targets including: 

Background information on the HSE planning process (including Corporate and Asset Level HSE Plans, goals, objectives, and targets).



General information regarding planning and procedures for controlling PDO‟s implementation and operations. More detailed information is covered in Process 6, Implementation and Operation with respect to day-to-day implementation of plans and procedures. General information on emergency response and contingency planning, with links to the detailed documentation.



5.2 REQUIREMENTS PDO‟s planning process is the process by which corporate goals, objectives, and targets are agreed and then converted into plans and ultimately into budgeted activities, and is described in CP 136 Planning in PDO. This document also describes PDO‟s Annual Planning Cycle. The purpose of PDO‟s Annual Planning Cycle is to provide a planning framework for the Company to review, plan, and submit performance results, future strategies, and investment opportunities to the Company‟s shareholders and other relevant stakeholders. The main components of this planning framework are to:  

Analyze and report performance from the previous year (including HSE). Inventory corporate hydrocarbon resources.



Define and confirm the Company‟s long term aspirations and outline and agree with the shareholders the Corporate Strategies and Objectives to be set for the following year (including HSE).



Prepare a five year plan of activities comprising investment projects, technology projects, and business improvement activities which will allow PDO to meet the Corporate Objectives (including HSE), maximizing the long term value of the business and short term return to shareholders.



Obtain shareholder approval for the programmed activities along with the requisite budgets.



Cascade annual performance goals, objectives, and targets from the Corporate Plan to the teams within PDO (including HSE and Technical Integrity), and other relevant stakeholders, such as shareholders.

CP-136 Planning in PDO also describes how annual plans cascade through business planning (including HSE planning) and budget preparation, to integrated activity plans (i.e., 90 day and 14 day plans) and production forecasting.

5.2.1 HSE Goals, Objectives, and Targets PDO goals, objectives, and targets should be: 

“SMART” – Specific, Measureable, Attainable, Realistic, and Trackable / Time-bound, wherever practicable.



Clearly and unambiguously documented.



Communicated to all employees and contractors.



Reviewed regularly to ensure their continuing suitability, adequacy, and effectiveness.



A mechanism for motivating and delivering continual improvement in HSE performance.

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5.2.2 HSE Management Plans (Corporate and Asset Level) PDO‟s Corporate HSE Plan is annual and is prepared within the Annual Planning Cycle. The Plan is designed to meet PDO‟s Business Objectives, Company Policies, and its continual improvement objectives. The Corporate HSE Plan establishes Company-wide performance indicators and annual targets. It also includes a list of action items to be completed. This Action Plan sets completion target dates and defines action parties.

5.2.3 Activity Planning Cascading the Annual Exploration and Production Program (including HSE issues) to day-to-day activities is achieved through PDO‟s Integrated Planning System (presented below).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual The PDO Integrated Planning System

5.2.4 Emergency Response and Contingency Planning EMERGENCY RESPONSE Emergency response is an important part of PDO‟s HSE Management System. Although every effort is made to ensure that incidents do not occur, the potential for hazardous events and emergency situations still exists. It is PDO‟s responsibility to ensure that plans, procedures, and resources are in place to respond swiftly and efficiently to any emergency situation and to minimize any consequential losses. Anybody who witnesses an emergency incident must immediately raise the PDO emergency response organisation by calling 5555. Once called, further guidance will be given as necessary on how to manage the emergency situation by the emergency management center.

Refer to CP 123 Emergency Response Part I and PR 1065 Emergency Response Documents Part II – Company Procedure for more details about PDO‟s emergency response procedures. CONTINGENCY PLANNING A number of assets and activities have been identified as requiring individual emergency response Contingency Plans. These contain descriptions of high-risk emergency scenarios and plans for how to manage them. Refer to Emergency Response Documents Part III – Contingency Plans for more details about individual PDO Contingency Plans.

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5.3 PROCEDURES All HSE Critical Activities and their supporting tasks should have written procedures and/or work instructions in place. If these are to be effective, they should be simple, unambiguous, understandable, relevant, and detailing clear roles and responsibilities. More detail regarding their actual implementation is found in PDO HSE-MS Process 6 – Implementation and Operation. In addition to controlling activities and tasks, it is important that procedures include measures aimed at improving HSE performance or managing HSE risk. It is also important to consider how work instructions are communicated to the workforce ahead of job execution (e.g., through Permit to Work Systems).

5.3.1 Developing Procedures Any activity for which the absence of written procedures could result in violations or deviations to the PDO HSE Policy, breaches of legal, regulatory, and/or other requirements, and/or performance criteria, should be identified. Documented procedures and/or work instructions should be prepared for such activities, defining how they should be conducted whether by the company's own employees, or by contractors acting on its behalf to ensure technical integrity and to transfer knowledge effectively. In addition, not carrying this out risks the issuance of a non-conformity with respect to PDO‟s ISO 14001 certification. All written procedures should be stated simply, unambiguously, and understandably, and should indicate the persons responsible and accountable (i.e., use of RASCI), the methods to be used and, where appropriate, performance standards, and other relevant criteria to be satisfied. Procedures are also required for procurement and contracted activities, to ensure that suppliers, contractors, and those acting on the company's behalf comply with the company's policy requirements that relate to them. It is important to ensure that those who will be responsible and/or accountable for putting procedures and written instructions into effect are closely involved in their creation, implementation, monitoring, and review with the active engagement of affected stakeholders. Clarity and simplicity of style and language are the characteristics to aim for in writing them, consistent with accurate coverage of the activities which they address. For example, effective procedures and work instructions contain several important features: 1. Start with a statement of purpose and task importance. 2. Present the task in a step-bystep approach. 3. Express what to do positively. 4. Explain the reasons for the steps. 5. Print / publish in a simple and functional format. 6. Ensure review and feedback.

This is included to increase motivation and understanding, and thereby retention and conformance. In other words, explain why the worker should comply with the standard practice. Relate it to the worker‟s own welfare. Build a bit of pride and safe behaviour into the document. Define “HOW” to proceed. It is best to embed and reinforce in the relevant steps the most important HSE-related rules. Keep these as short and simple as possible; give the reasons for the rules and focus on the critical few. Rather than a long list of “don‟ts,” highlight the things that the person can do to ensure efficient, safe, and productive results. Keep the “thou shalt nots” to a minimum. Emphasize the positives. They answer the question “why?” As such, they also point out the most probable sources of problems for the specific task, the things to which special HSE attention should be paid. Since procedures are primarily teaching and learning tools, they must be clear, concise, correct, and complete. Determine periodical review frequencies for task procedures to ensure continual improvement. Ensure feedback of both commendation and correction is communicated to all relevant parties.

In addition, documents authors should pay attention to: 

Sentence structure: Avoid compound and run-on sentences. Comprehension is usually hindered by long sentence structure.



Use of words: Avoid using words and language that the average reader may not be familiar with. Don't try to impress people with the use of unnecessary tri-syllable words. Try to avoid using words that make suggestions appear to be edicts. Use words like “I, You, We, They,” as little as possible and seek to avoid repetitious use of words. The author should

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual always reread the entire document before having it issued to detect overused words as well as errors that may have been unintentionally made. 

Sequence of suggestions: The author should attempt to present and layout the document in a logical way which will facilitate their implementation. Use of standard PDO templates facilitates this process, and these can be accessed in the PDO CMF.

Providing instruction on the conduct of worksite tasks can take many forms, depending on the complexity of the task, the competence of the people performing it, the inherent hazards and risks associated with it, and the effects that it might have on other aspects of the operation or facility. Thus, verbal instructions will need to be supported with, or replaced by, written procedures or work instructions wherever the absence of written material could threaten proper HSE performance. Written work instructions will outline the work scope and reference any particular direction that is to be followed; similar considerations to those for system procedures also apply to their development. Monitoring and other HSE requirements, such as applicable rules and personal protective equipment, can be specified in these documents as well. For example, in a production facility where hydrocarbons are stored and/or produced, stringent controls are required and most work is conducted under a 'Permit-to-Work' system. Within this, the work is defined, the precautions specified, other parties whose activities may be affected are notified, and the permit signed off properly by all parties involved. However, supplementary documentation is also often required in the form of job safety / hazard analyses, procedures, and/or work instructions for the task(s) itself.

5.3.2 Issuing Procedures / Work Instructions Procedures and/or work instructions define the manner of conducting tasks at the work-site level, whether conducted by the company's own employees or by contractors acting on its behalf. In the case of HSE Critical Tasks, which have the potential for adverse HSE consequences if incorrectly performed, these procedures and/or work instructions should be documented, communicated to relevant personnel, and be subject to the requirements of PDO‟s document and records control system. Use of standard PDO templates facilitates this process, and these can be accessed in the PDO CMF. The activities which can be described as 'HSE Critical' must have procedures and/or work instructions. An HSE Critical activity is any activity that is undertaken to provide or maintain controls for RAM 3+ consequences. For more information on the PDO RAM, see PR-1418. In situations such as projects and/or major contracts where PDO is the overall accountable party, HSE Critical activities will also be identified as such areas where documented procedures are particularly necessary (as opposed to an absence of documented procedures) in order to cover interfaces between different groups or disciplines and where coordination is vital to achieve successful HSE outcomes. This often requires the use of a „bridging document.‟ For example, one or more parties may be using their existing procedures, either from PDO or the Contractor‟s organisation to carry out a work activity, yet these procedures do not completely cover the identified risks and contingencies in the work activity. In such a case, another document is often required to „bridge‟ the gaps so as to cover what is needed to be done to completely cover all risks and contingencies in the work activity. In addition to the points made above, procedures and/or work instructions should be:   

Subject to a regular and formalized system of review, update, approval, and re-issue. Dated and traceable to the activity involved. Identified with a custodian.



Accessible to all relevant personnel (not just physically evident but user-friendly and well indexed, either in soft- or hardcopy).

5.3.3 Accountability and Responsibility for Operational Control Asset Directors have single point accountability for the day-to-day management, performance, and development of all assets. This accountability includes controlling operations in a way that manages the HSE risks associated with each asset. The Asset Director Mandate describes the assets over which each Asset Director holds single point accountability. An asset may be passed between different Asset Directors during its life cycle.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Service Level Agreements (SLA) specify the nature, scope, roles, responsibilities, and accountabilities for the essential services to be provided by and for each party under the SLA. These also define the boundaries of operational control for each party / Asset Director. Contract Holders are accountable for specifying the applicable procedures and work instructions for Contractor activities, and for ensuring that they are complied with. Refer to PR 1171 Contract HSE Management for details about controlling and monitoring Contractor activities. Operational control documents (written procedures, work instructions, and/or specifications) within PDO are generally authored along Functional lines. When authored, the various roles, responsibilities, and accountabilities should also be clearly stated in the document, with use of the RASCI approach to ensure clarity. It is the accountability of individual Asset Directors to implement these documents within their Directorate Teams.

5.3.4 DCAF To further assist and improve planning processes, PDO also implements the Discipline Controls and Assurance Framework, or „DCAF.” This framework helps to standardize Quality Control (QC) and Quality Assurance (QA) across all disciplines. Both Controls and Assurance are covered in DCAF and its associated documentation. DCAF consists of three elements: 1.

2. 3.

Discipline Standards: Standards (global and local) that lists all discipline deliverables that need sign-off by an authorized individual. Note that DCAF does not set the standards, the relevant Disciplines do. Discipline Authority Manual: A list of individuals with their respective authority-levels. Project / Asset Controls and Assurance Plan: A plan, listing what needs to be controlled or assured per the Opportunity Realization Process (ORP) phase. Controls are routine, risk-based (refer to Process 4, HEMP), internal steps to confirm the effectiveness of a prescribed process or activity. Assurance is an objective and independent review (refer to Process 7, Assurance) to ensure goals, objectives, and targets are met, and policies, procedures, and processes are adhered to.

DCAF provides clarity; which decisions and deliverables must be quality controlled / assured and who is authorized to do so. It recognizes both the „Line of Sight‟ and the „Matrix‟ as sign-off occurs in the line of the Business, while Disciplines are responsible for providing standards and authorized and expert staff. In PDO, the Disciplines set the standards; DCAF does not. More access to DCAF can be found in the following link: http://sww.shell.com/ep/dcaf

5.3.5 Management of Change (MOC) PDO‟s requirements for initiating, planning, controlling, and closing out changes within its operations (both temporary and permanent), in people, plant, processes, and procedures, are addressed mainly through the Technical Integrity system and its associated procedures, operations procedures, as well as variance control procedures for projects. The purpose of Management of Change in PDO is to manage the HSE risks resulting from unforeseen consequences of changes. This applies to all employees and contractors in PDO, but is led by Managers and Management of Change process owners. In PDO, management of change applies to process changes (hardware, process control and process condition changes), procedural changes, and organisational changes (both PDO and contractors). Management of Change includes the following activities: 

Appointment by PDO leadership of a management of change “Process Owner(s).”

The MOC Process Owner should be responsible for implementation of the following: 

Ensure that all HSE Critical Roles / Positions know how to recognize changes covered by this manual.



Know how to initiate the management of change process, based on the type of change involved (procedural, engineering, organisational, or combination thereof).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual 

Establish and maintain documented Management Of Change Procedures to cover permanent changes, temporary changes, and emergency changes, which: 

Define Change Approval Authorities and communicate who they are.



Describe the stages in the Management Of Change process and approval steps: -

review and approval of the concept or proposal, review and approval of the design or plan, including Hazard screening and Risk analysis, review and approval of any scope or design changes arising during the work, readiness review, handover, and acceptance for use, and close-out and learning capture.



Inform and train the people affected by the change about what they have to do differently.



Manage Temporary Changes, including expiry dates and approval for extensions.



Manage Emergency Changes, including authorization to postpone the MOC process until control is regained.



Track the development and progress of change proposals from initiation to closeout.

In the MOC process, it is important to recognize that all changes have a “source.” These sources are many and can include:   

Corporate requirement Budgetary / financial needs Engineering modification



Operational needs and expenditures

    

Accidents / incidents / emergencies Competency gap Hazard identification and risk assessments Strategy / policy / objective change Merger / Acquisition / Divestment



Legislation / regulations

    

Recognized need to improve Capital expenditure project External influence Inspection / audit / assessment findings Inadequate systems, procedures, processes, practices



Opportunity analysis

 

Problem solving results Anything deemed as “new” and required by PDO.

The change source and the request to make the change, if approved, then requires careful planning. The major outcome of this activity should be a documented, risk-based “Change Plan.” At PDO, the relevant management of change procedure(s) used should include requirements for preparing change plans and control the process up to this stage. These procedures should be suitable to address the HSE issues involved, according to the nature of the changes and their potential consequences, and should deliver change information addressing: 

Identification and formal approval of the proposed change,



Documentation of the proposed change and its implementation for its entire life cycle, guaranteeing sufficient traceability and history of the change over time,



Responsibility and accountability for reviewing and recording the potential HSE hazards from the change and its implementation for its entire life cycle,



A documented Change Plan, including change communication requirements and change goals, objectives, and targets for action tracking, verification, and close-out.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual In PDO HSE-MS Process 6, Implementation and Operation, general requirements for implementation of the change is presented.

5.3.6 Technical Integrity Technical Integrity and management of HSE risks are closely linked. Maintaining Technical Integrity is a key element of Process Safety Management, the overall PDO HSE-MS, and is a major control mechanism to prevent and mitigate loss of containment and high risk process hazards (i.e., those with Severity 5 in the PDO RAM). PDO has chosen to align and measure its process safety management system and activities, including technical integrity, with The Center for Chemical Process Safety (CCPS) and their 20 Elements for Process Safety. These elements include, 1) Process Safety Culture; 2) Compliance with Standards; 3) Process Safety Competency; 4) Workforce Involvement; 5) Stakeholder Outreach; 6) Process Knowledge Management; 7) Hazards Identification and Risk Analysis (Renamed by PDO as Hazards and Effects Management Process - HEMP); 8) Operating Procedures (Renamed by PDO as Plant Operating Procedures); 9) Safe Work Practices (Renamed by PDO as Permit to Work); 10) Asset Integrity and Reliability (Renamed by PDO as Technical Integrity); 11) Contractor Management; 12) Training and Performance Assurance; 13) Management of Change; 14) Operational Readiness; 15) Conduct of Operations; 16) Emergency Management; 17) Incident Investigations; 18) Measurement and Metrics; 19) Auditing; 20) Management Review and Continuous Improvement. These Elements are embedded in the overall PDO HSE-MS and address Process Safety as and where relevant to PDO operations, assets, and activities. PDO has developed various types of documentation (Codes of Practice, Procedures, Specifications, Guidelines, etc.) to address Technical Integrity, and these are listed in the References section of this process chapter and others as relevant. The PDO Technical Integrity system addresses areas such as design integrity, start-up, operating integrity, structural integrity, process containment, ignition control, and systems for protection, detection, shutdown, emergency response, and life saving. This system ensures that HSE critical facilities and equipment which are designed, constructed, procured, supplied, commissioned, operated, maintained, and/or inspected by PDO are suitable for their required purpose and comply with defined criteria. Only designated personnel can permit deviation(s) from approved technical integrity design practices and standards, and after a rigorous review and approval process, using the Management of Change process and relevant procedure(s). This is shown in the barrier diagram below.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

5.3.7 Permit to Work The objective of PDO‟s Permit to Work System is: "To provide a system to ensure that both routine and non-routine hazardous activities can be implemented and operated in a safe manner." To achieve good HSE practices in the workplace, the Permit to Work System must ensure that everyone is aware of the hazards involved in their work, and of the precautions that they must take to work the „right way,‟ – the health way, the safety way, the environmental way, and the productive way. PDO‟s Permit to Work System is described in detail in PR 1172 - Permit to Work System procedure.

5.4 REFERENCES The following documents provide further / related information on Planning and Procedures:

PDO Policies

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection PL-09 – Human Resources PL-10 – Security and Emergency Response PL-11 – Asset Integrity and Disposal

PL 03 PL 04 PL 09 PL 10 PL 11

PDO Codes of Practice

CP-107 – Corporate Management Framework CP-114 – Maintenance & Integrity Management CP-115 – Operation of Surface Product Flow Assets CP-117 – Project Engineering CP-118 – Well Lifecycle Integrity CP-123 – Emergency Response Documents Part I CP-126 – Personnel and Asset Security CP-136 – Planning in PDO

CP 107 CP 114 CP 115 CP 117 CP 118 CP 123 CP 126 CP 136

PDO HSE Procedures

PR-1065 – Emergency Response Documents Part II PR-1171 – Contract HSE Management Part I PR-1171 – Contract HSE Management Part II PR-1172 – Permit to Work Procedure PR-1322 – Asset Register – Master Data Maintenance PR-1418 – Incident Notification, Reporting and Follow-up Procedure PR-1972 – Safe Driver PR-1973 – Safe Vehicle PR-1974 – Safe Journey

PR 1065 PR 1171 PR 1171 PR 1172 PR 1322 PR 1418 PR 1972 PR 1973 PR 1974

PDO HSE Specifications

SP-1127 – Layout of Plant Equipment and Facilities SP-2001 – Load Safety and Restraining

SP 1127 SP 2001

PDO HSE Guidelines

GU-611 – PDO Guide to Engineering Standards and Procedures GU-648 – Applying Process Safety in Projects

GU 611 GU 648

Other PDO Documents

No direct link exists and/or is required.

--

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

International Standard for Environmental Management Systems Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

ISO 14001:2004 OHSAS 18001:2007 CCPS 2010

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

6. IMPLEMENTATION AND OPERATION 6.1 OVERVIEW An important outcome of HEMP is identifying the critical activities that must be implemented if PDO is to adequately manage HSE risks. These are essentially the risk controls – the activities we do day-to-day in the Implementation and Operation process. Effective implementation and operation of these activities involves: 

Ensuring, that from the Hazard and Effects Management Process, the proper risk controls are defined and determined to be suitable, adequate, and effective for implementation.



Ensuring, where required, that these controls are documented as PDO codes of practice, procedures, specifications, work instructions, and/or guidelines.



Setting performance standards, both managerial and technical, to clearly describe how HSE risk management is achieved and what the required deliverables are.



Ensuring the active involvement and understanding of contractors in the implementation process, since they conduct and/or are involved in a majority of the work activities that are carried out at PDO. Drawing on the other processes of the HSE MS and in the organisation to support and assure proper implementation and operation, such as training and competence assurance processes, effective planning, PDO leadership, consultation and communication, monitoring of implementation activities, application of DCAF, etc. At the end of the day, “DO” is the critical word!



This process focuses on and describes how HSE Critical Activities are to be performed, and what the expected and required deliverables are. It does so, taking into account the points listed above.

6.2 REQUIREMENTS Full implementation and operation of the HSE Management System means that people are doing what the Management System says they should be doing, at all levels of the organisation. Successful implementation and operation requires embedding HSE into: 

Company Culture,



Having Clear Responsibilities, and



Ensuring Line Ownership.

Successful implementation of the HSE Management System requires that it be viewed as part of the way we do things at PDO in order to ensure safe production. HSE is an integral part of our work. It is not an „add-on.‟ Process 4, the Hazards and Effects Management Process, is one of the key ways PDO formally embeds HSE into the business by taking a risk-based approach to HSE management. This risk-based approach ensures that we perform our activities „the right way‟ – this includes the safe way, the productive way, the healthy way, the environmental way, and the quality way. In so doing, over time, a proactive and positive culture and appreciation develops for HSE in PDO.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Responsibility and accountability for both supervising and conducting HSE Critical Activities must be clearly communicated to the individuals involved. This includes the complexity of the activity including multiple concurrent tasks, non-routine and unexpected activities, and the competence of the individuals performing the activity. Each accountable person should monitor and regularly report the implementation performance of these critical HSE activities using set performance indicators. In this process, use of RASCI Charts is an effective tool to detail and communicate implementation requirements. Also, refer to Process 3 of this Manual "Organisation, Responsibilities, Resources, Standards, and Documents" for more details about individual HSE responsibilities and accountabilities. People identified as responsible and accountable for HSE critical activities must take ownership. To achieve this, it is essential for line personnel to be genuinely involved in developing the HSE Management System and HSE Cases. Some examples of areas where line personnel can be involved include: conducting hazard identification, analyses, and reviews; implementing inspections and observations in the field; implementing procedures according to their requirements.

6.2.1 Implementation and Operation using DCAF A specific implementation requirement of DCAF is to develop a Project / Asset Controls & Assurance Plan, essentially a plan, listing what needs to be controlled or assured per Opportunity Realization Process phase(s). DCAF is a simple and structured approach, focusing on the business-critical elements in projects and/or assets and can be scaled at the project level. These controls are routine, risk-based, 'internal' steps to confirm the effectiveness of a prescribed process or activity. DCAF consists of preparing two lists: a list of business / critical deliverables (Controls) and a list of authorized competent people who have the authority to sign off on these deliverables. This provides clarity; which decisions and deliverables must be formally quality controlled / assured and who is authorized to do so. It recognizes both the Line of Sight and the 'Matrix', as sign-off occurs in the line of the Business, while Disciplines are responsible for providing Standards and authorized staff. Discipline Controls are:  Business-critical (incl. HSE-critical).  

Either a recorded decision or a recognized deliverable, but never an activity. Known / established in the discipline and the wider function(s), i.e., examples and templates should be available.



Standardized and relevant, i.e., as applicable in the desert of Oman as in the main office.



Not scaled. Scaling preferably should be done only through the Project / Asset Controls and Assurance Plan (PCAP/ACAP) at the project or asset level.

Examples may include:  

Well Proposals SFR Initiation Notes



HAZID Reports

    

Cost Estimates CAPEX (+25% / -15%) Pore Pressure Prediction reports Project Controls & Assurance Plans (PCAP) Concept Selection Reports Field Development Plans.

More access to DCAF can be found in the following link: http://sww.shell.com/ep/dcaf

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual

6.3 PROCEDURES 6.3.1 Integrating HSE into PDO Activities and Tasks Activities and tasks should be conducted according to procedures and work instructions developed at the planning stage or earlier, in accordance with the PDO HSE policy:   

At the senior leadership level, the development of strategic goals and objectives and high-level planning activities should be conducted with due consideration for the HSE policy and relevant implementation and operation requirements. At the middle and supervisory leadership level, written documentation regarding activities (which typically involve many tasks and their work sequencing) will normally take the form of site plans and management procedures. At the work-site level, written documentation regarding tasks will normally be in the form of operational procedures and work instructions, issued in accordance with defined safe systems of work (e.g., permits to work, simultaneous operations procedures, lock-out / tag-out procedures, manuals of permitted operations (MOPO), task-specific work instructions, etc.).

Previous sections have described the planning process, from the development of procedures covering broad areas of activity down to the level of issuing work-site instructions for the conduct of specific tasks. The effective practical implementation and operation of these planned arrangements requires that procedures and instructions are followed, at all levels. Therefore, PDO employees, suppliers, and contractors should be familiar with relevant procedures and instructions before they start work. Leadership should ensure, and be responsible and accountable for, the conduct and verification of activities and tasks according to relevant procedures. This responsibility, accountability, and commitment of leadership to the implementation of policies and plans includes, amongst other duties, ensuring that HSE goals, objectives, and targets are met and that performance criteria and control limits are not breached. Leadership should ensure the continuing adequacy of company HSE performance through assurance activities, discussed in Process 7, Assurance: Monitoring and Audit. The PDO HSE Management System applies best practices and principles of quality management, and is part of the overall system for managing the business. Only once hazards and effects management processes and controls have been fully accepted as part of everyday responsibility, accountability, implementation, and operation can business integration truly be said to be achieved. Thus each member of the workforce must know his role and how implementation and operation activities contribute to the management of HSE risks and be able to recognize how this fits in with corporate HSE policy.

6.3.2 RASCI Charting Experience shows that a critical success factor for effective management system implementation is to ensure that all individuals have a clear understanding of their Health, Safety, and Environmental (HSE) roles, responsibilities, and accountabilities with respect to implementation and operation. Individual task roles, responsibilities, and accountabilities for HSE management must be clearly defined, communicated, and followed up for all occupations in the organisation if they are to be carried out as intended. The RASCI chart is a useful tool for describing “who does what and when / how often.” The RASCI chart is a table which describes management system activities down the left hand column and organisation functional roles along the top row. The letter R, A, S, C, or I is entered under the job role to describe the level of responsibility that individual has for that particular activity: 

Responsible: the person who is owner of the activity.



Accountable: the person to whom "R" is Accountable and is the authority who approves to sign off on the activity before it is deemed effective.



Support: a person who provides resources or plays a supporting role in implementation.



Consulted: a person who provides information and/or expertise necessary to complete the activity / project.



Informed: a person who needs to be notified of results but need not necessarily be consulted about the activity.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual A “Site Emergency Plans” activity example is shown below: 

Responsible



Accountable



Support



Consulted



Informed

For PDO, the intended benefits of this approach are:  

A simple and systematic tool for mapping and communicating HSE roles is available, used, and the approach is consistent. Individuals have a clear understanding of what is expected of them within the PDO HSE MS.



These become the managerial performance indicators, against which performance appraisals can be based.



A basis for monitoring and following up on the individual performance of HSE roles is automatically created.

 

RASCI charts can be used to help develop job descriptions and/or role and post profiles for each role in the organisation. RASCI charts attach roles and requirements to the organisation, functions, and responsibilities rather than individuals. If an individual leaves or transfers, his/her replacement can quickly see what their HSE performance standards are.

6.3.3 Contractors and Suppliers Where activities involve contractors and suppliers, the process of familiarization with PDO‟s plans is especially important. Involvement of contractor and supplier key personnel jointly with PDO in the planning stage, whilst desirable, may not always be feasible. The process of initiating familiarization of contractors and suppliers with the plan is then essential and is typically carried out as part of a formal kick-off meeting. The initial period of a contract can be particularly vulnerable to HSE incidents. For this purpose, PDO has established an entire list of documentation for the contractor and supplier management process. Some of these critical documents are:   

PL-08 Commercial Policy, CP-129 Contracting and Procurement, PR-1171 Contractor HSE (Parts I and II),



GU-140 Contractor HSE (C9 HSE Specifications),



SP-1157 HSE Training.

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6.3.4 Management of Change (MOC) As a general “best practice” PDO should implement the documented procedures established for management of change in HSEMS Process 5, Planning and Procedures. Again, these should include requirements for planning, implementing, and riskcontrolling changes, both permanent and temporary, in people, plant, processes, organisation, procedures, and other related documentation, in order to avoid adverse HSE consequences. In Process 4, reference is given to the managing risk process using the HEMP approach. HEMP should also be applied to managing risks related to MOC, i.e., the identification, evaluation, control, and monitoring of HSE risks related to the change. An output of this process is a risk register for the change. These documents – HEMP risk assessments and risk registers form part of the documentation for planning and implementing change as described in HSE MS Processes 5 and 6. In Process 5, reference is given to initiating, assessing, and planning for „the change‟ and the preparation of formal Change Plans. These plans are required to be implemented in Process 6, Implementation and Operation. In this Process 6, the relevant management of change procedure(s) used should include requirements for implementing the change, based on an agreed and documented Change Plan and implementation procedure addressing: 

measures to identify HSE hazards and to assess and reduce risks and their effects,



communication, consultation, induction, and/or training requirements,

   

time limits, addressing as relevant both when and/or how often, if any, monitoring and verification requirements, acceptance criteria and action to be taken if change management activities are found to be noncompliant, authority for approval to implement the proposed change, including any staged approvals required during the life of the change.

Procedures should also describe how PDO will interpret and assess the implications of new, planned, and/or amended legislation and how revised regulatory requirements are to be incorporated into the HSE-MS. Separate change plans and their implementation should be established with respect to the HSE management of new operations (relating, for example, to acquisitions, developments, divestments, products, services, and/or processes), or of modified operations where the modification introduces significantly different HSE issues, to define:  

HSE goals, objectives, and targets to be attained, mechanisms for their achievement,

 

resource requirements to achieve HSE goals, objectives, and targets, procedures for dealing with changes and modifications as projects proceed (i.e., change within change), corrective mechanisms (employed should the need arise), how they should be activated, and their adequacy measured,

Any changes in the personnel, equipment, processes, and/or procedures of the company have the potential for adverse effects on health, occupational and process safety, the environment, assets, and/or company reputation. All changes, both hardware and organisational, should be considered. These will include not only equipment changes but also organisational changes and restructurings. Implementation relating to change plans needs to address the HSE aspects arising at all stages of the development, to ensure that risks and adverse effects are minimized by effective planning and design. For this reason, management of change is often directly related to the life-cycle of the asset. The diagram below illustrates this concept. For the same reasons, implementation plans relating to new installations and/or modifications to processes and plant need to cover all stages of the development, from feasibility studies, through planning and design, to construction, commissioning, operation, maintenance, eventual decommissioning, abandonment, and ultimate disposal. Changes which may be HSE-critical should be reviewed prior to implementation, as well as any necessary amendments made to the HSE-MS to ensure that their introduction does not threaten current HSE implementation and/or sound HSE performance. For projects or new developments, change control means the process by which proposals to change from an originally project plan, agreed scope, and/or terms of reference are reviewed and approval sought.

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In an operating plant, a change proposal may include a proposal to change hardware, operating procedures, and/or any aspect of the operation including, for example, level of competence, and/or change in input, throughput, or output. A procedure to ensure that such changes are reviewed must be clearly described and should involve the custodian of the appropriate HSE Case. He/she should ensure that the HSE MS documentation is maintained, up-to-date, and that the necessary hazards and effects assessment has been undertaken to confirm the continued validity of the HSE Case. It is important that related documentation, such as procedures, standards, guidelines, etc., clearly differentiate between the mandatory requirements and guidance to facilitate the change process. Of particular concern in the MOC context are gradual or „creeping‟ changes such as discharge composition or production creeping outside the design envelope. These need particular vigilance because they are often overlooked or seen as „out of scope.‟ Similarly, a change in the type of chemicals used or the encroachment of local dwellings on land adjacent to a process plant might all constitute a [creeping] change of circumstances requiring re-assessment.

6.3.5 Technical Integrity Technical Integrity and management of HSE risks are closely linked. Maintaining Technical Integrity is a key element of Process Safety Management, the overall PDO HSE MS, and is a major control mechanism to prevent and mitigate loss of containment and high risk process hazards (i.e., those with Severity 5 in the PDO RAM). The PDO Technical Integrity system addresses areas such as design integrity, start-up, operating integrity, structural integrity, process containment, ignition control, and systems for protection, detection, shutdown, emergency response, and life saving. HSE MS Process 6 requires the actual “doing” of Technical Integrity activities, based on good Technical Integrity planning in Process 5, the results of accurate HEMP activities in Process 4, etc. How to implement Technical Integrity is described in numerous Codes of Practice, Procedures, Guidelines, and Specifications. These are the documents which explain the implementation and operation requirements and guidance to ensure that process safety and HSE critical facilities and equipment which are designed, constructed, procured, supplied, commissioned, operated, maintained, and/or inspected by PDO are suitable for their required purpose and comply with defined criteria. A key, overall control for these activities is a Statement of Fitness for the Asset that must be issued. The Statement of Fitness is issued for 1) starting or commissioning a new asset or a modification to an existing asset; 2) restarting an asset after an incident involving uncontrolled shutdown, or an overhaul or a turnaround, or when the asset has been subjected to conditions outside the operational limits or has experienced environmental conditions beyond the original design parameters during operation. For this reason, PDO also subscribes to the requirements of the Center for Chemical Process Safety‟s (CCPS) 20 element process safety management system as both a reference for guidance on how to implement process safety management at PDO, and as an audit / assessment tool to measure process safety management activities at PDO sites and facilities. Links to these key documents are provided at the end of this chapter. Management of Change is also closely linked to Technical Integrity as well. Only designated personnel can permit deviation(s) from approved design practices and standards, and after a rigorous review and approval process. If such deviations are determined to be a „change,‟ as defined by PDO, then the relevant Management of Change procedure(s) shall be applied as a July 2011

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6.3.6 Permit to Work The objective of PDO‟s Permit to Work System is: "To provide a system to ensure that both routine and non-routine hazardous activities can be implemented and operated in a safe manner." To comply with HSE requirements in the workplace, the Permit to Work System must ensure that everyone is aware of the hazards involved in their work, and of the precautions that they must take to work the „right way,‟ – the health way, the safety way, the environmental way, and the productive way. Detailed information on how to implement PDO‟s Permit to Work System is described in detail in the Permit to Work System procedure, PR 1172, and linked for easy reference at the end of this chapter. However, in terms of the overall concept, implementers (e.g., Permit Applicant, Responsible Supervisor, Area Authorities, Permit Holders, Authorized Gas Testers, other affected Custodians, etc.) of the PDO Work Permit system should be aware of, and be able to handle potential problems arising from:  

Human factors arising during work permit implementation; Management of the work permit systems before, during, and after permit implementation;

  

Proper supervision and leadership in permit implementation at the site; Poorly skilled work force, including suppliers and contractors, applying and implementing the system; Unconscious and conscious incompetence;

  

Objectives of the work permit system; Types of work permits required; and Contents of the work permits.

The following issues may also contribute towards a major hazard or major incident, and therefore require special and continual attention:  

Failing of the site HSE management system to support the Work Permit system itself; Failure to recognize or identify a hazard before and during maintenance, and/or any potential hazard(s) arising after maintenance work done under a permit;

 

Failure to comply with the work permit system in hazardous environments; Communication failure before, during, and/or even after the use of the work permit system; and



Failure to review risks of the work activity, changes in the work scope (work environment), and/or change of personnel.

To prevent these issues from arising and/or to mitigate these issues, the PDO Permit to Work system requires: 

Training: To ensure everyone understands the PTW System and how to use it.



Licensing: People signing Permits must be tested to ensure they understand the System and have sufficient knowledge of hazards and controls to manage safe working. Planning: To ensure that work is well planned, with the workforce and equipment prepared for the job. Work Definition: To ensure that everyone understands the work content, and how and where it shall be done. Hazard Management: To ensure that the hazards involved in the work are identified, and the precautions and personal protection required for a task are correctly defined.

   

Co-ordination: To prevent conflicting activities from being authorized.



Communication: To ensure that all personnel understand the work content and the Job HSE Plan.



Authorization: Formal approval to do the work.



Supervision: Providing a person in charge of each work site, who is responsible for ensuring that work party complies with the requirements of the Permit to Work.



Briefing: Toolbox Talks at the worksite to discuss the job, how it will be done, and the precautions required.

 

Discipline: To ensure that everyone knows that they must comply with Permit requirements. Housekeeping: To ensure that the work site is kept clean and safe at all times.

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Verification: An audit program to help ensure requirements of the Permit to Work System are being met in all areas of PDO. Improvement: A Proposal for Change program, together with audits, to ensure that the system is improved whenever necessary.

For all work covered by a Permit, it is important that everyone associated with the job: 



Understands: The work content and how it will be done; the hazards involved, and precautions that are required; the work area hazards that may be present there and the precautions required; any emergency actions that may be necessary, and their own responsibilities. Complies: With all the requirements of the Permit to ensure the continued safety of personnel, plant, and equipment.

6.4 REFERENCES The following documents provide further / related information on Implementation and Operation: PDO Policies

PL-04 – Health, Safety, and Environmental Protection PL-06 – Information Management and Internal Communication

PL 04 PL 06

PDO Codes of Practice

CP-114 – Maintenance and Integrity Management CP-115 – Operate Surface Product Flow Assets CP-117 – Project Engineering CP-118 – Well Lifecycle Integrity CP 123 – Emergency Response Documents, Part I CP-136 – Planning in PDO

CP 114 CP 115 CP 117 CP 118 CP 123 CP 136 PR 1000 PR 1047 PR 1048 PR 1065 PR 1066

PDO HSE Procedures

PR-1000 – Operations Handover Procedure PR-1047 – Well Integrity Maintenance PR-1048 – Well Control / Well Kill PR-1065 – Emergency Response Documents Part II - Company Procedure PR-1066 – Emergency Response document Part III Contingency Plan, Volume III Production Operations PR-1067 – Emergency Response Documents Part III, Contingency Plan Volume 4 Main Oil Line PR-1068 – Emergency Response Document part III Contingency Plan Volume V Terminal & Tank Farm Operations PR-1069 – Emergency Response Document Part III Contingency Plans Volume VI Marine Operations PR-1073 – Gas Freeing, Purging and Leak Testing of Process Equipment and Pipework PR-1076 – Isolation of Process Equipment Procedure PR-1078 – Hydrogen Sulphide Management Procedure PR-1081 – The Buddy System Procedure PR-1084 – Leak / Spill Management, Site Clean-Up and Restoration PR-1148 – Entry into a Confined Space Procedure PR-1168 – Emergency Response Documents Part III, Contingency Plan Volume VII Power Systems Operations Interior PR-1171 – Contract HSE Management Part I - Mandatory for PDO Personnel involved in Contract Management PR-1171 – Contract HSE Management Part II - Mandatory for Contractors & Contract Holders PR-1172 – Permit to Work Procedure PR-1223 – Emergency Procedures Part III, Contingency Plans Volume 12 External Affairs & Communications PR-1243 – Emergency Procedures Part III, Contingency Plans Volume 13 Medical Emergencies PR-1243B – Emergency Procedures part III- Vol 12 Medical Emergency Response Manual Part II- Site Specific MER Procedure PR-1246 – Emergency Procedure Part III, Contingency Plans Volume 14 Government Gas System PR-1275 – Emergency Procedure Part III, Contingency Plans Volume 15 South Oman Gas line

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PR 1067 PR 1068 PR 1069 PR 1073 PR 1076 PR 1078 PR 1081 PR 1084 PR 1148 PR 1168 PR 1171 PR 1171 PR 1172 PR 1223 PR 1243 PR 1243B PR 1246 PR 1275

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PR 1287

SP-1005 – Emissions to Atmosphere SP-1006 – Aqueous Effluents SP-1008 – Use of Energy and Natural Resources SP-1010 – Environmental Noise SP-1012 – Land Management and Biodiversity SP-1075 – Fire and Explosion Risk Management (FERM) SP-1127 – Layout of Plant Equipment and Facilities SP-1170 – Naturally Occurring Radioactive Materials (NORM) SP-1230 – Medical Examination, Treatment and Facilities SP-1231 – Occupational Health SP-1232 – Public Health SP-1233 – Smoking, Drugs and Alcohol SP-1234 – Personal Protective Equipment SP-1237 – Ionising Radiation SP-1256 – HSE Specification - Camps, Offices, Labs, Workshops and Industrial Safety SP-1257 – Scaffolding, Working at Heights or Over Water, Lifting Operations and Earthworks SP-1259 – Safety Training Observation Programme (STOP) SP-2001 – Load Safety and Restraining SP-2085 – PDO Oilfield Transport & Interior Based Vehicle Specifications SP-2087 – Onsite Mercury Management SP-2097 – WE Specification for the Prevention of Dropped Objects

SP 1005 SP 1006 SP 1008 SP 1010 SP 1012 SP 1075 SP 1127 SP 1170 SP 1230 SP 1231 SP 1232 SP 1233 SP 1234 SP 1237 SP 1256

PDO HSE Guidelines

GU-230 – Fire and Explosion Risk Management (FERM) Facility Plan Guideline GU-611 – PDO Guide to Engineering Standards and Procedures GU-648 – Guide for Applying Process Safety In Projects GU-653 – Behaviour Based Safety

GU 230 GU 611 GU 648 GU 653

Other PDO Documents

Statement of General Business Principles (SGBP) PDO Code of Conduct

January 2007 April 2011

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

PDO HSE Specifications

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PR 1301 PR 1329 PR 1419 PR 1473 PR 1501 PR 1515 PR 1656 PR 1708 PR 1709 PR 1789 PR 1797 PR 1961 PR 1972 PR 1973 PR 1974 PR 1975 PR 1976 PR 1981

SP 1257 SP 1259 SP 2001 SP 2085 SP 2087 SP 2097

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Other Documents

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International Standard for Environmental Management Systems –Specification with Guidance for Use Royal Decree 10/82 Law for the Conservation of the Environment and Protection of Pollution Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

ISO 14001:2004 RD 10/82 OHSAS 18001:2007 CCPS 2010

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7. ASSURANCE: MONITORING AND AUDIT 7.1 OVERVIEW Assurance activities provide PDO management with a systematic approach to answer these questions regarding the HSE-MS:    

Are we prioritizing our assurance activities on our HSE critical activities? Are we doing what we said we would be doing based on the HSE-MS processes? Are there sufficient and traceable records to confirm this? Are we suitably, adequately, and effectively implementing these requirements?



Why and/or why not?

At the implementation and operation level, PDO implements and conducts many types of inspections and observations to verify whether what is required in procedures, specifications, etc., is actually done and done well. The focus of each is: 1)

Inspections focus on conditions – equipment, materials, and the environment. They generate findings that can be both positive – requiring recognition and commendation, and negative – requiring some type of corrective action.

2)

Observations focus on people – how people perform their tasks and their behaviour. There are essentially two types of observations:



Task observation: A technique to ensure that tasks / procedures are performed efficiently and in compliance with standards. Behavioural observation: The process of observing how individuals conduct themselves with reference to rules and practices, in order to reinforce and improve desired standards of behaviour.



Again, like inspections, observations can generate findings that can be both positive, requiring commendation, and those which require improvements, or correction. At the management system level, HSE audits / assessments provide management with a systematic, independent way to assess the implementation of the HSE Management System. PDO has and uses a three-tiered approach to HSE audits / assessments: 1)

Level 1: Includes HSE audits conducted on behalf of PDO‟s Internal Audit Committee (IAC) as part of the Integrated Audit Plan, and also includes independent audits carried out by external bodies, such as ISO 14001 certification audits, CCPS process safety management audits, etc.

2)

Level 2: Includes HSE audits carried out on behalf of Asset Managers as part of their own Asset Level assurance processes. These could include internal audits as required by external standards, such as ISO 14001, CCPS, etc.

3)

Level 3: Includes self-assessments, task / behavioural observations, and workplace inspection activities to supplement the formal HSE audit / assessment process. Refer to Chapter 5 of this Manual "Planning and Procedures" for more details about task observation and workplace inspection procedures.

Of the three types of audits carried out at PDO, Level 3 audits, because they are more of a monitoring activity, are carried out more frequently than Level 1 and 2 audits. PDO maintains procedures for HSE audits / assessments to be carried out, as part of its normal business activities, in order to: 

Determine whether or not the processes and activities of PDO‟s HSE Management System conform to the planned arrangements and are being suitably, adequately, and effectively implemented.



Determine whether or not PDO‟s HSE Management System is fulfilling the Company‟s HSE policy, goals, objectives, targets, and/or other relevant performance criteria. Determine whether or not PDO‟s HSE Management System complies with the relevant legal and/or other requirements to which it subscribes.

 

Identify areas for improvements in PDO‟s HSE Management System, with the aim of continually improving the HSE-MS.



Enable management to ensure that potential and/or actual deficiencies and deviations in the management system are remedied through their effective identification, evaluation / analysis, follow-up action, verification, and ultimate close-out.

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7.2 REQUIREMENTS 7.2.1 Performance Measures and Indicators Effective implementation of PDO‟s HSE Management System requires both leading and lagging indicators for monitoring. Leading indicators are pro-active measuring and monitoring criteria, and provide input or activity-based information in the absence of any incident, ill health, and/or damage to the receiving environment. Leading indicators are forward looking and predictive; they are aimed at raising the awareness of the possibility of incidents that might happen. They measure and monitor what we should be doing for managing HSE. Lagging indicators are reactive measuring and monitoring criteria, providing output-based information on incidents that have occurred and in addition providing insights into means of preventing similar incidents in the future. Lagging indicators provide evidence of deficient HSE performance. They tell us what has gone “wrong” in managing HSE. LEADING INDICATORS, EXAMPLES - Number and quality of successful emergency drills carried out. - Measuring the integrity of critical safeguarding systems. - Number and quality of progress on close out of audit action items. - Number and quality of PDO Management HSE inspections. - Number and quality of reporting of STOP cards, and their analysis. - Number and quality of structured HSE meetings conducted. - Journey Management Rate (JMR). - Percentage of audited MOCs that satisfied all aspects of the MOC procedure - Training for PSM Critical Positions rate. - Failure to follow procedures / safe working practices rate. - On time inspection rate for safety critical items of plant / equipment

LAGGING INDICATORS, EXAMPLES - Statistics on near misses / near-miss frequency rate. - Lost time injuries and their frequency and severity rates. - Occupational illnesses and their frequency and severity rates. - Deviations from permissible discharge levels. - Number of spills and/or spill frequency and severity rate. - Number and/or fatality rate. - Number or rate of complaints. - HSE performance trend analysis. - Total Count of Process Safety Incidents (PSIC). - Process Safety Total Incident Rate (PSTIR). - Process Safety Incident Severity Rate (PSISR). - Loss of Primary Containment (LOPC)

It is important to remember the following logic with respect to selecting and using leading and lagging indicators: the leading indicators chosen should have a direct cause and effect relationship with the lagging indicators chosen. For example, the number and quality of STOP cards reported directly helps to reduce the lost time injury frequency and/or severity rate. These types of HSE performance data are collected for:  

Internal performance reporting, analysis, review, and follow-up information and evidence. External performance reporting, analysis, review, and follow-up information and evidence for identified and relevant stakeholders.

7.2.2 Establishing and Documenting an HSE Monitoring System A monitoring system is required to measure HSE performance, and the implementation of the HSE Management System, against established goals, objectives, and/or targets. Leading indicators and measures such as „substandard acts / practices auditing,‟ „site HSE inspections,‟ „self-assessments,‟ as well as reactive measures, shall be used to measure and monitor HSE performance and identify opportunities for continual improvement at PDO. A monitoring system should: 

Identify the information to be obtained.

   

Fulfill the “SMART” criteria of being specific, measureable, attainable, realistic, and trackable / time-bound. Define the required accuracy of the results. Specify the monitoring methods / procedures and identify all required monitoring locations. Specify the frequency of monitoring and measuring.



Define roles, responsibilities, and accountabilities for monitoring. Use of RASCI charting here is invaluable.

The monitoring system should also regularly examine progress towards achieving Asset level HSE goals, objectives, and/or targets set in HSE plans.

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7.2.3 Monitoring Methods Methods of monitoring include: 

Periodical monitoring of leading and lagging indicators set for the Corporate, Asset, and Departmental levels.





Systematic observation of the work and behaviour of employees (including leaders), suppliers, contractors, and subcontractors to assess compliance with PDO documentation, such as procedures and work instructions. This includes Contract Holders monitoring and verifying the HSE requirements of contracts that are relevant to the competence and fitness to work of contractor personnel. Regular environmental sampling and analysis.



Health surveillance of employees (including individual, group, and area exposure monitoring and medical examinations).



Monitoring of employee performance and progress against personal HSE plans, goals, objectives, and targets.

7.2.4 Quality Control of Monitoring and Measurements Sufficient quality control over monitoring and measurement errors, should they occur, is important to ensure clear and accurate interpretation of monitoring results and to maintain the consistency of measurements taken. Competent personnel also should be properly selected and be given the role:   

To calibrate and use monitoring equipment on a regular basis. To carry out task or behavioural observations. To carry out HSE inspections.

Procedures should be established for the proper collection, analysis, interpretation, and reporting of monitoring data.

7.2.5 Records Management A system for identification of the necessary HSE-MS records and records management demonstrates the extent of measuring and monitoring done at PDO, and provides direct evidence of the levels of compliance with the HSE Management System. The key to good records management can be summed up in the following “5D” statement: “Diligent documentation delivers due diligence.” Examples of the HSE records generated and maintained by PDO under each process of the HSE Management System are listed in the following table. If other records are required locally and/or a new type of record needs to be created and generated, the relevant party (Corporate, Asset, site, etc.) should also identify these and include them in their Register of HSE records. HSE MANAGEMENT SYSTEM PROCESS

TYPES OF RECORDS

Leadership and Commitment Leadership and Commitment

- HSE SC/IC Minutes

- Management HSE Implementation records

- Copies of HSE legislation - HSE licenses / approvals / permits

- Copies of other references / requirements, such as ISO, CCPS, etc.

Organisation, Structure, and Responsibilities

- Job descriptions - Minutes of committees / meetings

Resources, Awareness, Training, and Competence

- Training / awareness program materials - Training plans / training need analyses

- Terms of Reference of meetings / committees - Competency / training records - HSE training passports - Competence assessments

Contractor Management

- Contract documents - Document C-9 HSE Requirements - Contract HSE Management Plan - Contract HSE Certificate (Start-Up)

- Contract Site Restoration Certificates - Monthly HSE Reports - Minutes of Contractor meetings

Procurement

- Supplier records

- Purchase Order documents

Policy and Strategic Objectives HSE Policy and Related Policies Legal and Other Requirements Organisation, Responsibilities, Resources, Standards, and Documents

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TYPES OF RECORDS

Communication and Reporting

- Newsletters, bulletins, magazines, booklets - Letters to regulatory authorities - Register of community complaints

- Reports to internal stakeholders - Reports to external stakeholders - Minutes of committees / meetings

Documentation and Document Management

- Register of business control documents - Document review records

- Step-out approvals

- Environmental Assessment reports - Permit / License Applications - Health Risk Assessment reports - HAZOP / HAZAN reports

- QRA reports - Hazards and Effects Registers - HSE Cases - MOPO‟s

- Corporate HSE Plan - Asset Manager Mandate - Tasks and Targets (employees)

- PDO Program Books - Asset-level HSE Plans

Operational Control

- Work Permits - Service Level Agreements - Task observation records

- Workplace HSE inspection records - STOP Safety Observation Cards

Emergency Response and Contingency Planning

- Emergency Exercise and Drill Reports

Hazards and Effects Management Process

(HEMP) HEMP

Planning and Procedures Goals, Objectives, Targets, and Management Plans

Implementation and Operation Key implementation procedures and their evidence of implementation: Permit to Work, Management of Change, Technical Integrity, etc.

- Issued work permit forms, - MOC case documentation,

- Technical integrity inspection reports - Other reports or surveys

Performance Monitoring and Records

- Monitoring data (HSE leading and lagging indicator statistics)

- Equipment calibration records - Task / behaviour observation records

Non Compliance and Corrective Actions

- Non-Compliance Report forms

- Corrective action plans

Incident Notification, Analysis, Reporting, and Followup

- Incident Notification Forms - Incident reports

- Follow-up action plans - STOP Safety Observation Cards

Audit

- 5 year Integrated Audit Plan - Internal and external audit reports

- Annual HSE Audit Plan - Audit follow-up action plans

- Minutes of committees / management review meetings

- Letter of Representation - Self Assessment Checklist

Assurance: Monitoring and Audit

Review Management reviews of the HSE-MS

7.3 PROCEDURES Any incident (i.e., accident or near miss) and/or non-compliance must be notified, investigated, analyzed, reported, followed up, learnings extracted and applied where necessary, and ultimately closed out. This process of initiating corrective action is necessary to ensure that HSE Management System requirements are met, HSE performance continually improves, and that the likelihood of incidents is minimized. Details for this activity can be found in PR-1418. The PDO Risk Assessment Matrix (RAM) document shall be used as a standard in the process of notification, investigation, analysis, reporting, and follow up of incidents for PDO sites. The RAM could also be used in the process of notification, investigation, analysis, reporting, and follow up of non-compliances.

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7.3.1 Non-Compliance Non-compliances may be sudden and temporary, or they may persist for long periods. They may result from deficiencies and/or failures in the Management System itself, failures in plant and/or equipment, and/or from human error / behaviour. Investigation of non-compliance should fully establish the causes, including failures in the Management System. These investigations enable the planning of corrective action, including measures for:  

Restoring compliance as quickly as possible. Preventing any recurrence.

   

Evaluating and mitigating any adverse HSE effects. Ensuring satisfactory interaction with other components of the management system. Verifying and assessing the effectiveness of the above measures. Ultimately closing out the non compliance.

Implementing corrective action will not be complete until the effectiveness of the above measures has been demonstrated. This includes making the appropriate changes to PDO procedures, records, and/or other relevant factors.

7.3.2 Incident Notification, Investigation, Analysis, Reporting, and Follow-up The overall incident management process at PDO is graphically described below. Incidents may affect people, environment, assets, and/or the reputation of PDO. The corresponding consequences of incidents are:     

Personal injury / occupational illness / fatality. Environmental damage / impacts. Asset loss / property damage / process loss. Reputation damage. Legal fines.

Incident Analysis (Investigation) Incidents have multiple causes, with underlying causes often existing away from the site of the incident. When investigating incidents, the team should remember and apply the principle of multiple causes: “Problems and other loss producing events are seldom, if ever, the result of a single cause.”

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Proper identification of all causes requires timely and methodical investigation, going beyond the immediate causes and evidence, and looking for basic or root causes which may cause future incidents. For this reason, incident analysis should be seen as a means to identify not only immediate causes, but also basic causes and failures in the management system. The purpose of conducting an incident analysis and producing a formal report on the findings is: 

To identify the immediate and basic or root causes of an incident.



To prescribe and implement suitable remedial actions to prevent recurrence of a similar incident.



To ensure that all legal and other PDO requirements on incident reporting are met.



To protect against any unsubstantiated claims.



To provide a means for sharing learning, and the incorporation of such learning into PDO knowledge management systems.

The incident analysis, reporting, and follow-up process comprise a number of consecutive stages once the initial PDO notification procedure has been completed. These stages are: 1. 2. 3. 4. 5. 6. 7. 8.

Conducting the initial investigation / evidence collection and preservation. Establishing a full investigation team. Conducting the full investigation by the team, including the collecting of relevant evidence. Analyzing the findings. Preparing, reviewing, and publishing the report (including recommendations for remedial action). Implementing the action items as agreed. Verification and follow-up to ensure remedial actions are completed correctly and on time. Incident case and report close out.

Incident Notification, Reporting, and Follow-Up All incidents (including near misses) require a formal Incident Report in addition to the initial Incident Notification Form, with the following exceptions: 

Reporting of Low Risk incidents is limited to a completely and accurately filled out Notification Form.

To maximize incident learning benefits, relevant findings and conclusions of incident investigations should be given as wide a distribution as practicable. Lessons learnt from incidents, which are believed to be of benefit to other relevant internal and external stakeholders, are communicated throughout PDO. Distribution of information can occur through discussions and feedback from HSE meetings and team briefings, in addition to consideration given at the relevant Incident Review Committees. This will help maximize the benefits from the learning point s of the incident and help prevent recurrence of incidents with similar causes. PDO leadership fully supports the incident management process and its stages, encourages leadership involvement in the investigations, and requires sufficient allocation of resources to act on the resulting recommendations. PDO also supports objective investigations being carried out by competent and unbiased investigators, and taking prompt action to correct deficiencies. For the entire process of how notification, investigation, analysis, and reporting of events are managed in PDO, please refer to PR 1418 Incident Notification, Analysis, Reporting, and Follow-Up for details.

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7.3.3 HSE Audits and Hierarchy The hierarchy of HSE audits, task observations, and inspections within PDO is illustrated below.

7.3.4 Audit Tools An „Audit Kit‟ contains a set of tools to aid an Audit Team Leader to conduct an audit. It includes sample slide presentations, questionnaires, templates and guidelines that can be customized and supplemented by the Audit Team Leader to suit the individual audit requirements. Further guidance on conducting audits can be found in PDO procedures and guidelines. These include HSE-MS, PSUA, and AI-PS audit procedures.

GU 441 HSE Inspection Guide, contains checklists and tools for use in conducting HSE Inspections (e.g., Joint Management HSE Inspections).

Details on how to conduct audits, audit team composition, audit planning, and audit frequency can be found in specific PDO procedures, such as PR-1969 Corporate HSE Audits.

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7.4 REFERENCES The following documents provide further / related information on Assurance: Monitoring and Audit.

PDO Policies

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection PL-06 – Information Management & Internal Communication

PL 03 PL 04 PL 06

PDO Codes of Practice

No direct link exists and/or is required.

-PR 1171

PDO HSE Procedures

PR-1171 – Contract HSE Management Part I - Mandatory for PDO Personnel involved in Contract Management PR-1171 – Contract HSE Management Part II - Mandatory for Contractors & Contract Holders PR-1418 – Incident Notification, Reporting and Follow-up Procedure PR-1712 – Level 3 Audit (Engineering Operations) PR-1969 – Corporate HSE Audits

PDO HSE Specifications

No direct link exists and/or is required.

--

PDO HSE Guidelines

GU-441 – HSE Inspection GU-653 – Behaviour Based Safety

GU 441 GU 653

Other PDO Documents

Fountain Assurance User Guide

--

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

International Standard for Environmental Management Systems –Specification with Guidance for Use Royal Decree 10/82 Law for the Conservation of the Environment and Protection of Pollution Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

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PR 1171 PR 1418 PR 1712 PR 1969

ISO 14001:2004 RD 10/82 OHSAS 18001:2007 CCPS 2010

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8. REVIEW 8.1 OVERVIEW A key component of PDO‟s HSE Management System is a formal process whereby senior leadership reviews its efforts with respect to:  

Managing HSE risks. Reinforcing efforts to continually improve HSE performance.



Ensuring and documenting their decisions regarding the management system‟s continuing suitability, adequacy, and effectiveness.

In general, PDO‟s senior leadership should review the HSE Management System at least annually. Review components should address: 

The possible need for changes to PDO‟s HSE Policy and strategic goals and objectives, in the light of changing circumstances, and the commitment to strive for and make continual improvements to the management system.

 

Resource allocation for implementation, maintenance, and improvement of the HSE Management System. Sites and/or situations requiring special attention or focus, on the basis of evaluated hazards and risks and emergency planning.

These management review processes should be documented, with the results recorded to assist in action tracking and implementing any review findings, i.e., recommended changes or improvements which become apparent through the review. This Chapter covers the review components of PDO‟s HSE Management system. It addresses the various parts of formal management reviews, including review of PDO‟s HSE Policy and goals / objectives, HSE performance, HSE documents, and other HSE issues that may arise and are of importance. The intent and goal of reviews stated here is to determine the suitability, adequacy, and effectiveness of the HSE-MS.

8.2 REQUIREMENTS 8.2.1 Scope of Review The scope of the review process includes PDO‟s activities and its Corporate and Asset level HSE Management System documentation. The review process should begin with the Self Assessment Questionnaire process. Review this link for more detailed information: http://sww1.pdo.shell.om/dept/cd/csm/blocks/hsefunction/saq/saqhome.htm. Issues to be addressed as part of the review process and agenda should typically include: 

Any recommendations which have been made in audit reports.

 

Any recommendations made in the investigation and analysis of incidents. Extent of follow-up on audit and incident action items.



The continuing suitability, adequacy, and effectiveness of PDO‟s HSE Policy.



The continuing suitability, adequacy, and effectiveness of PDO‟s HSE goals, objectives, and/or targets, consequent amendments to the HSE Plan, and to HSE Management System documentation.



Comparison of business results against goals, objectives, targets, and/or KPIs.

    

Resources allocated to achieve HSE goals, objectives, targets, and/or KPIs. Review of goals and strategy. Status of actions in the business plan. Trend analysis of business results. Assessments of the organisation‟s residual risk profile – including health, process and occupational safety, and environmental risks.

 

Performance benchmarking results. Assurance activity results (Level I, II, and III audits).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual   

Analysis of monitoring reports. Improvement and action plans. Stakeholder suggestions.

   

Status of actions from previous management reviews. External changes which may affect the management system. Major changes in legal requirements. Asset performance / condition.



Customer satisfaction results.

8.2.2 Responsibility and Accountability for Review Reviews are to be carried out by PDO‟s senior leadership and/or by competent independent personnel appointed by the senior leadership. Within PDO, the following senior personnel carry out reviews:  

Board of Shareholders. The HSE Steering Committee.





The Integrated Audit Committee (IAC). More details about the review role of the IAC can be found in PDO‟s Corporate HSE Audits Procedure, PR 1969. The Emergency Response Steering Committee (ERSC). More details about the review role of the ERSC can be found in CP 123 PDO Emergency Documents Part 1. Incident Review Committees (IRCs). More details about the roles of IRCs are described in PR 1418 Incident Notification, Analysis, Reporting, and Follow-Up. The Managing Director (MD).

 

Directors, Asset Directors, Project Managers, and/or Line Leaders. Corporate HSE Manager.

 

8.2.3 Reporting of Reviews Reports of reviews shall: 

Include the review agenda, and those attending.



Document the results of the review.



Identify why the review was conducted (for example, routine management review as required by procedure, organisational changes, and/or reported deficiencies in HSE Management System).



Identify any necessary remedial actions, assign responsibility / accountability, and assign deadlines / time limits.



Ensure proper action tracking, verification, and close out of identified remedial actions.



Be distributed and communicated to all relevant internal and external stakeholders.

8.2.4 Applying Continual Improvement to the Review Process The management review process itself should be subject to continual improvement as well. This should include unbiased evaluations and activities including: 

Evaluation of review information to identify the basic causes of good and poor business performance.

 

Evaluation of basic causes to identify the strengths and weaknesses of the management system. Evaluation of the effectiveness of the management review process.

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8.3 PROCEDURES Conducting HSE-MS Reviews at PDO leadership levels shall be met as part of the job responsibilities defined for each individual within the Corporate Management Framework, Job Descriptions, Personal Performance Contracts (PPCs), and PR 1970 HSEMS Review.

8.4 REFERENCES The following documents provide further / related information on Review. PDO Policies

PL-03 – Risk and Internal Control PL-04 – Health, Safety, and Environmental Protection

PL 03 PL 04

PDO Codes of Practice

CP-100 – Policy Approval CP-107 – Corporate Management Framework CP-123 – Emergency Response Documents Part I

CP 100 CP 107 CP 123

PDO HSE Procedures

PR-1418 – Incident Notification, Investigation, Reporting, and Follow-Up PR-1969 – Corporate HSE Audits PR-1970 – HSE MS Review

PR 1418 PR 1969 PR 1970

PDO HSE Specifications

No direct link exists and/or is required.

--

PDO HSE Guidelines

No direct link exists and/or is required.

--

Other PDO Documents

Statement of General Business Principles (SGBP)

January 2007

Shell Group Documents

Shell HSSE & SP Control Framework, Version 2, (Shell Group Standards for Health, Security, Safety, the Environment & Social Performance)

December 2009

Other Documents

International Standard for Environmental Management Systems Occupational Health and Safety Assessment Series The Center for Chemical Process Safety (CCPS - www.aiche.org/ccps)

ISO 14001:2004 OHSAS 18001:2007 CCPS (2010)

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9. GLOSSARY Understanding the meaning of common terms in the PDO HSE-MS / CP-122 is an essential part of professional HSE management. It is important that PDO establish its own documented definitions and terms for relevant HSE management system terminology, so as to reduce the potential for reporting and other communication problems. This glossary is not exhaustive, and the definitions and abbreviations provided here are for reference only. Accident - The term „accident‟ is sometimes used to describe an incident which has caused actual injury, loss, or damage. For the purposes of PDO procedures the term „accident‟ shall not be used. (See incident. The following definitions beginning with the term “accident” are for illustrative purposes only and the term “incident” can be substituted for “accident” here.). Accident / incident rates - Measures of accident / incident loss experience within given time periods, developed as a means of comparison. (Examples: injury frequency rate, injury severity rate, injury index, all injury frequency rate, major property damage rate, and critical items damage rate). Accident report - A written summary describing the accident / incident, presenting an analysis of causes and suggestions for remedial action, and documenting actions taken as preventive or control measures. Accident / incident analysis - Study of accident / incident experience through compilation of related facts and information about the nature of injuries and/or damage, and the causal factors. The purpose is to define trends and problem areas and to identify the critical safety problems as a basis for program objectives and activities. Analyses usually include frequency of occurrence, severity, nature of injury / damage, part of body injured, part of equipment or material damaged, agency of the accident, substandard practices and conditions, job factors and personal factors. Refer to Basic Causes and Immediate Causes. Accident / incident investigation - A systematic search for factual information on the extent and nature of a specific loss or near-miss, the related events, the substandard practices and conditions which influenced the events, the basic or roots causes, and the management actions needed to prevent or control future occurrences. AI-PS - Asset Integrity Process Safety. AIPSALT - Asset Integrity Process Safety Asset Leadership Team. ALARP - As Low As Reasonably Practicable (ALARP). Risks are said to be reduced to a level of ALARP, at a point where the time, trouble, complexity, difficulty, and cost of risk reduction measures have been assessed, and where further risk reduction measures are considered to be unreasonable in regard to the additional risk reductions obtained versus the costs and benefits of doing so. All - This term generally refers to a 100% condition. The established method to evaluate an "all" condition is to apply the "3 strikes rule." The "3 strikes rule" means that the third time a deviation is noted, the "all" condition will not be true. (From the HSE-MS Framework Scorecard [FSC]). Aspect - The potential to harm people and the environment, cause damage and/or loss of assets, and adversely impact PDO‟s reputation. (See Hazard). When used in conjunction with environment, as environmental aspect, it has a slightly different meaning (see Environmental aspect). Assessment - (1) A comprehensive, systematic assessment of performance to established and accepted criteria. (2) (HSEQ) A systematic and independent examination to determine whether HSEQ activities and related results comply with planned arrangements and whether these arrangements are adequately and effectively implemented, and are suitable to achieve objectives. (See Audit). Asset Integrity - See Technical Integrity. Assumption - The rationale on which normative behaviours and beliefs are based. Assurance - A positive declaration intended to give confidence. Full confidence, freedom from doubt, certainty. Audit - (1) A comprehensive, systematic assessment of performance to established and accepted criteria.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual (2) (HSEQ) A systematic and independent examination to determine whether HSEQ activities and related results comply with planned arrangements and whether these arrangements are adequately and effectively implemented, and are suitable to achieve objectives. (See Assessment). Authority - The capacity to give commands which are accepted as legitimate by others. In the modern organisation the manager's authority to give instructions to subordinates is drawn primarily from his formal position as a manager, and from the set of rights and obligations formally associated with the post, rather than from the manager's individual leadership qualities. However, both sources of authority can be important. Banding - A process which details the contractor selection process for High and Medium Risk services to Petroleum Development Oman (PDO). The SP-1171 document describes the methodology that presents a consistent and standardized approach to HSE evaluation of contractors. The approach also aims to reduce the repeated data requests, for HSE information, from contractors as part of the technical evaluation process. The overriding objective is to reduce contractor incidents in PDO and to prioritize doing business with contractors who have a good HSE capability and performance. Basic causes - The job and personal factors, such as inadequate engineering, lack of knowledge or skill, etc., from which the substandard acts and/or substandard conditions originate. Basic causes may also be referred to as underlying, root or real causes, systems defects or contributing causes. Basic causes are most frequently the result of an inadequate management system, inadequate management system standards, and/or inadequate compliance with management system standards. (See Immediate Causes). BBS - Behavioural Based Safety. A system or program to identify, evaluate, control, and monitor behaviours in an organisation in order to change and improve „safe‟ behaviours and/or to reduce „at-risk‟ behaviours. Behavioural observation - The process of observing how individuals conduct themselves with reference to rules and practices, in order to reinforce and improve desired standards of behaviour. Benchmarking - Predetermined standard(s) against which research or assessments are measured. Budget - A firm's predetermined financial plan, expressed in quantitative or financial terms, for a given future period. (Examples: the sales budget is generally compiled with the aid of sales forecasts and shows quantities and values of planned sales broken down by product group, area and type of customer. The distribution costs budget shows planned distribution activity measured in packages, tonnage, etc., and associated warehousing and transport costs. The master budget aggregates all other budgets to produce a budgeted “profit-and-loss account” and “balance sheet.”). Business Assurance Letter – The Business Assurance Letter is a corporate PDO exercise conducted by Finance and with submissions made to stakeholders. This exercise involves all the functional departments, including MSE. The intent is to assure, with or without qualifications, that the current implementation status and integrity of the HSE-MS meets suitability, adequacy, and effectiveness requirements. PDO Leadership should consider whether the Business Assurance Letter can be made without qualification. In making their appraisal of whether or not a Business Assurance Letter can be made without qualification, Leaders may consider how an auditor would rate compliance with the Letter concerned. Letters should be qualified if a significant audit finding would be expected. An audit trail should exist to confirm the basis on which all Letters have been made. Business continuity planning - Arrangements for restoring business activities as soon as possible following an emergency to minimize loss to business and impact on stakeholders. Business controls - Structured means used to provide reasonable assurance that business objectives are properly set and are likely to be met with little risk of unacceptable deviation. Can - indicates a possible course of action. (See May). CCPS - The Center for Chemical Process Safety, an American organisation which has established guidance standards for developing and implementing process safety management systems. The CCPS process safety management system standards consist of 20 elements. For further information see their website at www.aiche.org/ccps CEPI - Composite Environmental Performance Indicator.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Chemical - A chemical may be a liquid, gas, solid, or powder which in normal use has the potential to cause a heath and/or physical hazard, and/or the release of toxins into the environment. This definition also includes any materials that will be created during the manufacturing process, either as intermediates, by-products, and/or wastes. A chemical may be further defined as: Used or consumed in the manufacturing, R&D, testing or assembly of products; Incorporated into the final product; Used or consumed in the maintenance of facilities, grounds and equipment; Raw materials, that when handled / processed at a site, can cause releases of potentially hazardous emissions, by-products or wastes; Any material received on site with a Material Safety Data Sheet (MSDS); Any material requiring an MSDS, either regulatory, or as required by PDO Policy (stated in Chemical Management Standards); Certain metal articles that are consumed (i.e., – tooling, weld rods, braze tapes, electrodes, etc.). A chemical may be a direct or indirect material. (From the HSE-MS Framework Scorecard [FSC]). CM - Corrective Maintenance. Coaching - The day-by-day actions you take to help people perform as well as possible. Code of Practice (CP – PDO) - A high level document that specifies the overall approach and procedure for performing a business process / activity, and which states the minimum requirements expected from employees, contractors, and/or other relevant stakeholders. Codes - Rules and standards which have been adopted, by a governmental agency or professional regulatory body, as mandatory regulations having the force and effect of law. Commitment, management - Visible participation of the (senior) management of their organisation's improvement efforts. Their participation may include establishing and serving on an HSE committee, establishing HSE policies and goals, deploying goals to lower levels of the organisation, providing the resources and training that the lower levels need to achieve the goals, participating in quality improvement teams, and reviewing progress organisation-wide. Communication - What we do to give and get understanding. Company - This term refers to PDO, a PDO asset, a PDO business facility / operation, or a PDO affiliate. It excludes contractors or other non-PDO entities. (From the HSE-MS Framework Scorecard [FSC]). Competence - The ability, in terms of skill, knowledge, and awareness to perform a role within specified standards. Competence is developed over time from among a combination of education, training, and/or experience. Competitive strategy - Deciding, on the basis of an evaluation of the firm's own competitive strengths and weaknesses visà-vis those of its rivals and the requirements of the customers, the direction(s) that firm will pursue. Complete task observation - An observation, planned in advance, of the complete task, using the established task procedure and/or the most recent task analysis worksheet as references, and recording the results on a specific form. Contingency measures - Measures that could be taken if an event occurs, in order to minimize its consequence. Consequence - The effect, result, impact, or outcome of something occurring earlier. Continual improvement - The ongoing improvement of activities, products, services, and/or processes through small steps and breakthrough improvements. Contract - Legally binding document or situation in which a seller undertakes to supply goods or services to a buyer in consideration of some financial or other return. Contractor - Person or company that conducts work under a contract for the organisation. (See also Sub-contractor). Contractor banding - See „Banding.‟ Control - (1) The process of ensuring that activities are carried out as intended. Control involves monitoring aspects of performance, making commendations and taking corrective actions where necessary. (2) Physical device to regulate a machine, apparatus, or system within prescribed limits or physical standards of safety and operating effectiveness.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Controls - Controls include preventive measures (reducing the likelihood / probability), mitigative measures (reducing the number and severity of consequence) and recovery or recovery preparedness measures (reducing the chain of consequences arising from a top event). Controls are also called risk reduction measures, preventive measures, barriers, and/or mitigative measures. Coordination - The process of combining the work of organisation members and departments to achieve the desired endproduct or goals of the organisation. Corporate Governance - Defining and implementing a system of rules, processes, procedures, and relationships to manage the organisation and fulfill its legal, financial, and/or ethical obligations. Corrective action - Any activity undertaken to address an incident or non-compliance, and if possible, to prevent its recurrence. Crisis - An emergency where the situation has escalated to the point where there is actual or potential media interest which might have a negative impact on reputation at the corporate level and could threaten the survival of the business. Critical controls - A control or contingency measure which is absent or ineffective would result in at least one risk becoming unacceptable. Critical / vital few - A basic management principle which states that a small percentage of specific items, actions, or activities account for the majority of all accidents and costs. Often referred to as the Pareto Principle. Critical equipment - Machinery, equipment, and/or materials that is likely to result in a major loss to people, property, process and/or environment when worn, damaged, abused, misused, improperly applied, etc. These critical few pieces of machinery, equipment, and/or materials which, when worn, damaged, abused, misused, or improperly applied, are more likely to result in a major loss. Critical equipment list - A comprehensive list that includes all critical equipment, machinery, and/or materials at the location that have historically resulted in the majority of losses (including injury or illness) or have the potential to do so. The list should include a statement of the criteria used to identify their criticality. Critical supplies inventory - Activity to identify, register, and evaluate critical spare parts or components resulting in a comprehensive list of the ones which have historically resulted in major quality problems or nonconformities or which have the potential to do so. Critical task - A specific element of work which historically has produced and/or which, when not properly performed, may produce major loss, either during or as a result of the task. CSU - Commissioning and Start Up. Culture - (1) The customary beliefs, social forms, and material traits of a racial, religious, or social group. (2) The characteristic features of everyday existence shared by people in a place or time. (3) The way the organisation believes, thinks, and acts with respect to risk. Customer complaint system - A structured method to handle and solve individual customer complaints and to take corrective actions to avoid or minimize all customer complaints. The system should cover: registration, analysis, solving complaints, customer feedback, preventive action, information to employees and customer(s), and evaluation of actions. Customer feedback - Information received via meetings, personnel talks, complaint forms, etc., from existing or new customers. Customer satisfaction - The most important criteria in all quality work in the organisation. Approximating or exceeding customer expectations. DCAF – Discipline Controls and Assurance Framework. Design - The process of translating a product idea into a product which can be produced and marketed on a commercial basis.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Design failure - A failure due to inadequate design of an item. Design input - All documents required to serve as source for basic information for development and design. (Examples: customer requirements, rules and regulations from external authorities, functional requirement lists, contract documents, engineering handbooks and technical standards, and design data from suppliers). Design output - The final work result of the development and design function. specifications, manuals and bills of materials).

(Examples: drawings, technical

Design review - A formal and independent examination of an existing proposed design for the purpose of detection and remedy of deficiencies in the requirements and/or design which could affect such things as reliability performance, maintainability performance, maintenance support performance requirements, fitness for the purpose and the identification of potential improvements. (Note: Design review by itself is not sufficient to ensure proper design.). Design verification - Activity to check whether the design (work results) meets the input requirements by conducting design reviews, qualification tests, alternative calculations, and comparison with similar proven designs. DI - Design Integrity. Directive, management - Specific instruction from management. Disability - Any injury or illness, temporary or permanent, which prevents a person from carrying on his or her usual activity. Disabling injury - A work injury which results in death, permanent total disability, permanent partial disability, temporary total disability, or restricted ability to perform normal work. Distribution - The process of storing and moving products to customers, often through intermediates such as wholesalers and retailers. The task of physical distribution management involves moving specified quantities of products to places where customers can conveniently buy them, in time to replenish stocks, in good condition. The objective is to maximize availability of product while minimizing cost of distribution (synonym: physical distribution). Document - A paper and/or electronic file containing information. Document control - The operational techniques and activities to ensure the right and proper use of all documentation in the organisation. Document control addresses: document layout, approval, issue, changes, modifications, distribution, and removal of obsolete documents. Document distribution list - Comprehensive list mentioning document numbers, date of issue, revision number, document name, quantity issued, department of issue, department of destination, file storage place, retention, etc. Documented - Written information about an activity. Dosimeter - A personal device used to monitor an individual's exposure to an occupational health hazard, such as radiation, vibration, noise, etc. Duty of Care - An obligation and concept that a sensible person / organisation would apply or use in circumstances when acting towards the public, and/or other stakeholders. Considered in some countries to be a legal requirement. If the actions of a person or organisation are not made with watchfulness, attention, caution, and prudence, their actions are considered negligent. Consequently, the resulting damages may be claimed as negligence in a lawsuit. PDO has now formerly adopted the term to mean it will take full cognizance of the health and welfare of all employees, contractors, and other persons that may be affected by its operations in Oman. The duty of care shall in particular monitor the working and living conditions of the workforce. Economic quality - The economic level of quality at which the cost of securing higher quality would exceed the benefits of the improved quality. Effect - An adverse impact on people, the environment or PDO‟s reputation; damage and/or loss of assets. (See Impact). Emergency - A situation that poses an immediate threat to human life, major / serious damage to property / assets, the environment, product / service and other quality matters, and/or the security of the site / organisation. July 2011

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Emergency needs assessment - The process of recognizing and evaluating potential emergencies that could occur in an organisation. Used as the basis for developing a comprehensive emergency response plan. Emergency plan - A comprehensive document to provide guidance on actions to be taken under various possible emergency conditions. Includes responsibilities of individuals / departments, resources available for use, sources of aid outside the organisation, procedures to follow, authority to make decisions, requirements for implementing procedures within departments, training in and practice of emergency procedures, communications, and reports required. Emergency team - A group of employees who act as a unit in some or all types of emergencies. Employee - A person employed by PDO who is not directing or controlling the activities of a group of workers. (From the HSE-MS Framework Scorecard [FSC]). EMS coordinator / Management Representative - A person, reporting to upper management, one of whose functions is to measure and evaluate the environmental management system effectiveness. The coordinator also advises and assists on matters relating to the environmental management system. Environment - Surroundings in which an organisation operates, including air, water, land, natural resources, flora, fauna, humans, and their interrelation. Environmental accident - An unintended event that results in loss to the environment above an acceptable level / threshold limit. Environmental aspect - Element of an organisation‟s activities, products, and/or services which can interact with the environment. Environmental aspects can have both positive and negative consequences or impacts. NOTE: A significant environmental aspect is one which has or can have a significant environmental impact. Environmental effect - Any direct or indirect impingement of the activities, products, and/or services of the organisation upon the environment, whether adverse (negative) or beneficial (positive). Environmental hazard - An operating condition that may result in an environmental incident or accident. A negative environmental aspect is the same as an environmental hazard. Environmental incident - An unintended event which could or does result in a loss to the environment. Environmental Management System (EMS) - That part of the overall management system which includes organisational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, achieving, reviewing, and maintaining the environmental policy. Environmental objective - Overall environmental goal, arising from the environmental policy, that an organisation sets itself to achieve, and which is quantified where practicable. Environmental performance - Measurable results of the environmental management system, related to an organisation‟s control of its environmental aspects, based on its environmental policy, objectives, and targets. Environmental management program - A description of the means of achieving environmental objectives and targets. Environmental target - Detailed performance requirement, quantified where practicable, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. EPZ - Emergency Planning Zone. Ergonomic Risk Factor Analysis - Formally reviewing and documenting the presence and severity of ergonomic risk factors in a job process. (From the HSE-MS Framework Scorecard [FSC]). Ergonomic Risk Factors - Forceful exertions, awkward postures, repetitive motions, duration, vibrations, contact stress. (From the HSE-MS Framework Scorecard [FSC]).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Ergonomics Team - A group of employees working together to solve ergonomic problems. (From the HSE-MS Framework Scorecard [FSC]). ERP - Emergency Response Plan. ESP - Ensure Safe Production. Established - A routine or procedure that is valid, recognized, and accepted on a permanent basis. Event - Something that occurs in a certain place during a particular interval of time (and after a hazard is released). Event Tree Analysis (ETA) - Works in the opposite direction to FTA. ETA takes an event and predicts an outcome. Event Tree Analysis uses inductive reasoning / logic. Evidence - Information (from documents, records or any other source) given to establish fact. eWIMS - Electronic Well Integrity Management System. Exposure hours - Exposure Hours represent the total number of hours of employment for work as defined under section 2.1.3 of the HSE Statistics guidelines, including overtime and training but excluding leave, sickness, and/or other absences. External parties, environmental - Those with an interest in the environmental effects of an organisation's activities, products and services (e.g., government agencies; local residents; the organisation's investors; insurers; customers and consumers; environmental interest groups; and the general public). Extrinsic motivation - Means of motivating behaviours applied to individuals by outside agents. Characterized by consequence (reward / punishment) management, observation and coaching processes, promotional activities, etc. Failure costs, external - The costs arising outside the manufacturing organisation of the failure to achieve quality specified. Failure costs, internal - The costs arising within the manufacturing organisation of the failure to achieve quality specified. The term can include the cost of scrap, rework and re-inspection, and also consequential losses within the organisation. Failure Mode Analysis (FMA) - A procedure to determine which malfunction symptoms appear immediately before or after a failure of a critical parameter in a system. After all the possible causes are listed for each symptom, the product is designed to eliminate the problems. Failure Mode and Effect Analysis (FMEA) - A procedure in which each potential failure mode in every sub-item of an item is analyzed to determine its effect on other sub-items and on the required function on the item. Failure Mode Effects and Criticality Analysis (FMECA) - A procedure that is performed after a failure mode effects analysis to classify each potential failure effect according to its severity and probability of occurrence. Fatality - A fatality is a classification of a death resulting from a Work Injury, or Occupational Illness, regardless of the time intervening between injury / illness and death. Fault Tree Analysis (FTA) - A procedure / graphical technique that provides a systematic description of the combinations of possible occurrences in a system, which can result in an undesirable outcome. This technique can combine both hardware and human failures. Often, while a hazardous event has not occurred before, the preconditions and underlying causes and failures have. It is therefore possible to synthesize a top event or the undesirable outcome. This technique is one of the most powerful used to examine how failure events can occur following a sequence of other faults. Fault Tree Analysis uses deductive reasoning / logic. FERM - Fire and Explosion Risk Management. FIFO - First In, First Out. First goods produced or received should be picked first. Used in purchasing / procurement and inventory control. First-aid injury - A minor injury requiring only first-aid treatment, normally given by someone other than a physician.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual First / Front - line management - Those who directly supervise most of the non-managerial employees. Typical titles include: foreman, supervisor, unit supervisor. Formal - External form or structure. According to fixed customs or rules. Done or made in an orderly fashion: methodical, definite, and explicit. Formal Evaluation - A documented review of program progress against performance requirements and goals, including recommendations for future improvements and activities. (From the HSE-MS Framework Scorecard [FSC]). FSR - Facility Status Report. Functional responsibilities - Ensuring an efficient and coordinated effort from the various operational divisions of the firm (marketing, production, etc.) through appropriate management and organisational structures and management control and reward systems. Goal - 1) A statement describing a desired level of performance. Objectives and targets are both types of goals. Goals should be SMART- Specific, Measurable, Achievable (Attainable), Realistic, and Time bound. 2) The result or achievement toward which effort is directed. (See Objective and Target). Good / best practice - An error free, proven and documented working practice that exceeds the norms of known, current operational performance within a specific business environment. Guideline (GU – PDO) - A non-mandatory document providing supplementary information about acceptable methods for implementing requirements found in policies, business processes, procedures, work instructions, etc. Hazard - 1) The potential to harm people and the environment, cause damage and/or loss of assets, and adversely impact PDO‟s reputation. (See Aspect). 2) A condition, act, and/or practice with the potential for accidental loss. Hazard classification - A designation of relative loss potential. A system to code substandard practices or conditions by the potential severity of the loss, should an accident or loss occur. Hazards and effects register - A quality record that demonstrates that all hazards and effects have been identified, are understood, and are being properly controlled. This Register is kept current throughout the life cycle of a project or activity, i.e., from the planning and design stage, through operation, to decommissioning, abandonment, and disposal. HAZID - Hazard identification. A structured technique used to identify hazards. HAZOP - Hazard and operability. The application of a formal systematic detailed examination of the process and engineering intention of new or existing facilities to assess the hazard potential of operation outside the design intention or malfunction of individual items of equipment and their consequential effects on the facility as a whole. The HAZOP technique was "defined" in the Chemical Industries Association Code and updated more recently in the CCPS Hazard Identification Procedures. Hearts and Minds - Hearts and Minds is all about developing a safety 'culture.' The Hearts and Minds safety program was developed by Shell Exploration & Production in 2002, based on research with leading universities since 1986, and is being successfully applied in Royal Dutch / Shell Group companies around the world. The program uses a range of tools and techniques to help the organisation involve all staff in managing Health, Safety, and Environment as an integral part of their business. Collectively, these tools and techniques are known as the Hearts and Minds Toolkit. High risk incident / high potential incident - Incident for which the combination of potential consequences and probability is assessed to be in the high risk – red shaded area – of the Risk Assessment Matrix. HSE - Health, Safety, and Environment. HSE Case - A demonstration of how the Company manages “high” HSE risks to a level that is ALARP. HSE Critical Activity - Any activity that is undertaken to provide or maintain controls for RAM 3+ consequences. HSE Critical Roles - Includes any job description with accountabilities and/or responsibilities for conducting HSE Critical Activities. July 2011

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HSE-MS - Health, Safety, and Environment Management System. Human resources management - The branch of management concerned with administering the employment relationship and with achieving effective use of human resources available in the organisation. The rationale for employing human resource managers is that specialized knowledge of aspects of “people management” (recruitment and selection, training, performance appraisal, welfare, payment systems, labor law, industrial relations) will lead to better managerial and organisational performance (synonym: personnel management). Immediate causes - The substandard acts / practices and/or conditions which directly contribute to the occurrence of an accident / incident. Frequently referred to as unsafe acts or conditions, or direct causes. Impact - An adverse impact on people, the environment or PDO‟s reputation; damage and/or loss of assets. (See Effect). Improvement teams - Team approach to achieve objectives. Incident - 1) An incident is an unplanned and undesired event or chain of events that has, or could have, resulted in injury or illness, damage to assets, the environment, company reputation, and/or consequential business loss. (From PDO – from PR1418 Incident Notification, Reporting, and Follow-up procedure). 2) The release or near release of a hazard, which exceeds a defined limit or threshold limit value. These are unplanned events or a chain of events, which has caused or could have caused injury, illness, damage and loss to assets, the environment, and/or company reputation. (For Process Safety Management, and for reference in Process 4, HEMP). Induction - See orientation. Information management - The process of gathering, processing and interpreting data both from the firm's external environment and from inside the firm, generally using the information technology provided by computers. Inherent (“gross”) risk - is an assessment without any responses being applied and assuming no controls are in place (or failure of existing ones). (From CP-131). Injury frequency rate - A lagging indicator and an injury experience measurement. An injury frequency rate may also be referred to as a lost-time frequency rate. Local jurisdictional standards should be consulted. Injury severity rate - A lagging indicator and a severity of injury measurement. Local jurisdictional standards should be consulted. Inspection - A scheduled, structured examination of a work site with a specific focus on physical conditions and working acts and/or practices, in addition to normal supervisory duties. (A type of monitoring). Interested Parties (stakeholders) - People or organisations with an interest in the organisation‟s activities, products, and/or services. This can include government regulators and inspectors, investors, insurance companies, employees, the local community, customers and consumers, NGO‟s, environmental groups, and the general public. Intrinsic motivation - A means of engaging the individual to develop an internal competence and desire for appropriate behaviours. Characterized by education and training, empowerment, meaningful tasks, and opportunities, etc. IPF - Instrumented protective function. IRPA - Individual risk per annum. ISO - International Organisation for Standardization - ISO (International Organisation for Standardization) is the world's largest developer and publisher of International Standards. ISO is a network of the national standards institutes of 163 countries, one member per country, with a Central Secretariat in Geneva, Switzerland, that coordinates the system. ISO is a non-governmental organisation that forms a bridge between the public and private sectors. On the one hand, many of its member institutes are part of the governmental structure of their countries, or are mandated by their government. On the other hand, other members have their roots uniquely in the private sector, having been set up by national partnerships of industry associations. The ISO website is: www.iso.org

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Job description - A written statement describing the activities involved with a particular job or occupation, e.g., purpose, major responsibilities, accountabilities and functions, (synonym: position description). Job Process - The set of tasks that an employee performs. Job processes include assembly, disassembly, testing, repair, inspection, data entry (office environment), maintenance, programming, and/or many others. (From the HSE-MS Framework Scorecard [FSC]). Joint safety and health committee - A committee consisting of non-supervisory and supervisory representatives appointed to consider safety and health matters. The existence of a joint safety and health committee is frequently required by law. JMR - Total number of kilometers driven per man-hour worked. Just-In-Time (JIT) system - A production management system in which materials, components and products are produced for, or delivered to, the next stage of production (or customers) at the exact time needed. JIT seeks to minimize the amount of work-in-process stocks held by a firm by synchronizing the flow of materials between production processes; and to economize on finished product stocks by matching the final assembly of products with the rate of customers' orders. Lagging indicators - Measurements of consequence or results. Reactive measures. Leading indicators - Measurements of inputs to a process. Answers the question, “How well are we doing our work?” Proactive measures. Leadership – 1) Leadership is the collective function of all leaders. (from CP-122, Process 1, Leadership and Commitment). 2) Leadership is the process wherein a leader engages with and mobilizes others to drive change in an organisation. 3) The process of influencing others to achieve certain goals. Effective leadership is often seen as the outcome of leadership qualities (traits) which some people have and some do not. Lesson plan - A document which provides guidance to a course instructor regarding the proper presentation of a subject. Lesson plans usually include learner objectives, educational approaches to be used, materials and learning aids to be used, outlines of the presentations and time to be spent in teaching the subjects. Letter of Assurance (LOA) - The LOA is a confirmation from a contractor CEO, with or without qualifications, that the current implementation status and integrity of the Contractor‟s HSE management system meets the Contract requirements. Each Contractor is required to submit one LOA only to cover all contracts with the Company that are operational on 1 January of that year. These statements shall be in bold type and where necessary are followed by explanatory guidance in italics. Contractor CEOs should consider this guidance in deciding whether or not a statement can be made without qualification. In making their appraisal of whether or not a statement can be made without qualification, Contractor CEOs should consider how an auditor would rate compliance with the statement concerned. Statements should be qualified if a significant audit finding would be expected. An audit trail should exist to confirm the basis on which all statements have been made. Life cycle, product - Term relating to a generally accepted hypothesis that all products are subject to a pattern of demand which, after its start, grows, stabilizes for a period, then tends to decline and finally disappear. The life cycle contention is that all products have both a beginning and an end. This dictates the need for new product development; the order of time frame determines the intensity with which such development takes place. LIFO - Last In, First Out. Last goods produced or received should be picked first. Used in purchasing / procurement and inventory control. Likelihood - The expectation, possibility, and/or chance of an event happening. Usually expressed as a frequency (i.e. once every 10 years), but sometimes as a probability (i.e. 0.2, 40% etc.). Lock-out - A practice for preventing the undesired operation of equipment or power systems by the affixing of a device with a lock which prevents anyone from turning on the power or energy source. Logistics - Term borrowed from the military, describing the science and practice of estimating the likely flows and timings of company resources for any particular project or campaign and providing the means to achieve them. Primarily used in physical distribution and the control of materials transfer and stock holdings. Logistics consist of materials management and physical distribution (synonym: logistics management).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Loss - The avoidable waste of any resource, such as people, equipment, materials, and/or the environment. Loss control - Activities to reduce accidental losses to an organisation. These losses may include injuries, occupational illnesses, property damage, process losses, down-time, quality degradation, environmental impacts, etc. These activities include anything done to prevent or minimize the risk of loss exposures, reduce losses when loss-producing events occur, and/or terminate or avoid risks. LSIR - Location specific individual risk. LTI - Lost Time Injuries are the sum of Fatalities, Permanent Total Disabilities, and Lost Workday Cases. N.B. If, in a single Incident 20 people receive lost time injuries, then it is accounted for corporate reporting purposes as 20 LTI's (not 1 LTI). LTIF - The Lost Time Injury Frequency is the number of Lost Time Injuries per million man-hours worked during the period. Major hazard - Any hazard giving rise to “high” HSE risks. Major injury / illness - Injury or illness resulting in at least a temporary disability (disabling injury). Major property damage rate - The degree of economic loss determined by the organisation to be significant enough to require the same management attention normally given a disabling or lost-time injury. See Disabling Injury. Management - 1) Getting things done through others. The process of organizing and directing human and physical resources within an organisation to meet defined objectives. Key management functions and roles are planning, organizing, leading, and controlling. 2) A person, or persons, who directs or controls the activities of a group of employees. (From the HSE-MS Framework Scorecard [FSC]). Management audits - Comprehensive audits of managers' compliance with clearly defined criteria, conducted by managers of comparable levels and experience. Management system - (1) ISO: The part of the overall management system that includes organisational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, achieving, reviewing, and maintaining the (environmental) policy. (2) A framework of controls for managing organisational risks and driving continual improvement. Management system performance standard - A management system performance standard is a statement detailing WHO, does WHAT, WHEN and/or HOW OFTEN. A management system performance standard is a statement detailing WHO, does WHAT, WHEN and/or HOW OFTEN. These standards define performance expectations or requirements of PDO leadership, employees, and/or suppliers, contractors, and sub-contractors. Manual - A document that links the policy with all related codes of practice, procedures, specifications, work instructions, and/or guidelines for performing a business activity. Manual of Permitted Operations (MOPO) - Defines the limit of safe operation permitted for a particular asset if control and or mitigation measures are reduced and/or removed, yet maintaining a tolerable level or risk. It considers combinations of hazards and hazardous events. Materials handling - The physical movement of materials from place to place, their packaging (in carton / pallet / containers) and storage as they proceed through various production, warehousing, and distribution processes. Materials handling seeks to minimize internal transport costs, damage to, and waste of, materials. Handling activities can include: unloading, sorting, palletizing, storing, order picking, loading, discharging, unpacking. May - indicates a possible course of action. (See Can). MCP - Maintenance craft procedure. Medical Case Management Representative - Individual contracted or employed by PDO to manage: injury costs (worker compensation), absences, return to work placements, and/or employee health care programs. (From the HSE-MS Framework Scorecard [FSC]).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Medium and low risk incident - Incident for which the combination of potential consequences and probability is assessed to be in the yellow or blue shaded area of the Risk Assessment Matrix. Middle management - Those between the senior managers and first-line supervisors. Titles typically relate to department head or general supervisory personnel. (See Senior Management, First-Line Management). Mission statement - An explicit written statement for the reason an organisation exists, the social needs it fulfils, and its fundamental business focus. Mission statements are designed to give substance to the perceived purposes of the organisation and provide all employees with an indication of what they are attempting to achieve through their collective endeavor (related terms: policy statement, organisation statement). Mitigation measures - To reduce or limit the number and severity of the consequences arising from a hazardous event or effect. Monitoring - To oversee, supervise, or regulate for purposes of control, checking continually, and/or keeping track of. Monitoring here may include using specialized equipment, human observation, and/or a combination of both. MOPO - See “Manual of Permitted Operations.” Must - indicates a course of action with a required, mandatory status within PDO. (See should). Mutual aid agreements - Formal agreements with local, private organisations to provide resources in the event of an emergency. Near-miss - An incident that could have caused illness, injury or damage to assets, the environment or company reputation, or consequential business loss, but did not. All near misses shall be treated as incidents and shall be investigated and reported according to their potential risk. (From PDO PR-1418). Non-compliance - Failure to meet the HSE Management System requirements. Non-compliance may be identified by monitoring activities, adverse trends in performance indicators, non-completion of HSE Plans, failure to meet targets, incident investigations, and/or audits / assessments. Nonconformity - (1) Deviation from the specified situation. (2) The non-fulfillment of specified requirements. Norm - A belief or action shared by two or more people. NORM - Naturally occurring radioactive material. OAASAWKI - “Our assets are safe and we know it.” Objective - A statement about where PDO wants to be in regard to HSE issues, sometime in the future. Objective setting - Determining the general goals of PDO, i.e., increasing the rate of return on capital employed, increasing earnings per share, etc. (synonym: goal setting). OBRA - Occupied Building Risk Assessment. Observation - Seeing with sufficient care to be able to give an account of conditions and behaviour. Observing means to perceive or identify through various senses (e.g., vision, hearing, taste, smell, touch). Observing includes noticing, noting, and understanding the significance of what you observe. In this sense, observing is more of a psychological process. Occupation - A position title covering all work activities that a person performs while holding that title. (Examples: electrician, carpenter, loss control coordinator, welder, doctor). Occupational illness - (1) Any abnormal condition or disorder of an employee, other than one resulting from an occupational injury, caused by exposure to environmental factors associated with employment. (2) Any illness that results from a work accident or from an exposure involving a single incident in the work environment.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Occupational safety - The control of personal injury, illness, and property damage in work-related environments and situations. Off-site emergency - An emergency occurring outside the boundaries or direct control of an organisation, but that affects or has the potential to affect the organisation‟s stakeholders. Off-the-job safety - The control of exposures to hazards outside the workplace environment. OI - Operating Integrity. Operations planning - The planning of a firm's production operations including: (1) The operations or work tasks to be performed. (2) The order in which they will be carried out. (3) The time which each operation should take. (4) The layout of plant and machinery of the factory. Opportunity - 1) A possible action with the potential to produce an event with positive consequences. Sometimes referred to as upside risk. 2) Opportunities are those factors, which could influence the achievement of business objectives having a potential positive consequence. The opportunity can be assessed in terms of its probability of success and upside potential. (From CP-131). OR&A - Operations Readiness and Assurance. Organisation - Any organized body or establishment, such as a business, company, government, department, charity, and/or society. For bodies or establishments with more than one site, each single site may be defined as an organisation, and the group is called a corporation. Orientation - Commonly divided into three types: (1) General Orientation. A pre-assignment presentation to employees on the major points of the organisation's policies, benefits, services, facilities, general rules and practices, and work environment. Frequently conducted by Human Resources staff personnel. (Synonym: induction) (2) Job Orientation. An orientation that is specific in nature and designed to orient the employee to the specific information necessary to prepare him or her for the specific job. Usually conducted by the employee's immediate supervisor / team leader. (Synonym: induction) (3) Leadership Orientation. An orientation that is HSE specific in nature and designed to orient a manager / leader to the specific HSE management system information necessary to prepare him or her for the specific job. Usually conducted by professional HSE staff. (Synonym: induction) Pareto principle - See Critical / vital few. Partial task observation - A planned observation of a segment or part of a task that includes the noting and recording of facts and events relating to the observation. See Random Sampling as a guide to the selection of jobs to be partially observed. Performance - A measure of attainment achieved by an individual, team, organisation, and/ or process. Performance indicators (KPI) - A proxy measure of organisational performance often used where profit or “bottom-line” indicators are either inadequate or irrelevant guides to performance. Use of performance indicators is thought to improve managerial decision making concerning resource allocation. Performance standard - A performance standard typically imposes quantifiable limits and targets, such as "how much gas can be released into the air." Many of the Royal Decrees and Ministerial Decisions in Oman are Performance Standards. These are often referred to as technical standards. Personnel - The term personnel includes people at all organisational levels including hourly workforce, management / supervision, and HSE. It also includes any special considerations that may be required for the handicapped. (From the HSE-MS Framework Scorecard [FSC]). Physical capability analysis - A systematic analysis of jobs or tasks to determine size, strength, endurance, acclimatization, and other similar physical aspects needed to perform a job or task safely and effectively. July 2011

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Plan - A document describing what procedures and/or other associated documents and resources shall be applied by whom and when / how often to a specific project, process, activity, and/or contract. Planned general inspection - A general inspection of the overall workplace that is planned in advance. Planned inspections are usually done at an established frequency and by properly trained operating personnel. Planned personal contacts - An intentional daily / weekly meeting of a manager and an employee to discuss a critical HSE and/or production topic related to that employee's work. Planning, business - A method of controlling the business that involves the setting of long-term objectives and the formulation of action programs designed to achieve those objectives. PM - Planned Maintenance. Policy, business - (1) The strategies and measures adopted by the organisation to manage the business as a means of achieving its organisation objectives. (2) A concise statement of PDO‟s attitude on a particular subject in response to business needs. (From CP-100). (3) A senior management statement which guides administration, reflects management's attitudes and commitment to safety and health, and defines the authority and respective relationships required to accomplish the organisation's objectives. (4) The overall intentions and direction of an organisation regarding quality, as formally expressed by senior management. Practice(s) - General methods or guidelines to follow when performing a task that does not have to be performed identically each time it is done. Pre-placement physical examination - A medical examination prior to job placement to determine suitability for work. Preventive action - Any action taken to investigate, prevent, and/or reduce defects, failures, and other causes of loss. Prevention measures - To reduce the likelihood / probability of hazards or to prevent or avoid the release of a hazard. Primary processes - The chain of activities which add value to the product, activity, and/or service (i.e., marketing, design and development, production, distribution, after-sales service). Often referred to as core processes. Probability - See Likelihood. Procedure (PR – PDO) - A document that specifies the way a work process / activity / task is to be performed, describing why (purpose), what (scope), who (responsibility), when (frequency), how (tasks involved), and how many / how much (specifications). Process - A sequence of activities that adds value by producing required outputs from a variety of inputs. Process hazard - The intrinsic property of a dangerous substance or physical situation with the potential to cause major accidental loss. Process monitoring and control - Checking performance of the process at regular intervals in relation to pre-established norms, including taking corrective action where necessary. Process safety - The control of process hazards with the potential to cause major accidental loss. Product stewardship - The responsible and ethical management of the health, safety, and environmental aspects of a product from its invention through its processes of production to its ultimate use and beyond. Production - The conversion process for transforming inputs such as materials, labor, and capital into goods and services. Production scheduling - The detailed planning of production to achieve production targets within specified timetables and avoid production delays, while making effective use of labor resources and ensuring high rates of machine utilization. Production scheduling is generally undertaken by the production planning department and will be based on orders received for products or forecasts of product demand.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Program - A description of the means of achieving objectives and targets. Project - A project is a temporary and one-time endeavor undertaken to create a unique product or service. This property of being a temporary and one-time undertaking contrasts with processes, or operations, which are permanent or semipermanent ongoing functional work to create the same product or service over-and-over again. Protocol(s) - Standardized, documented process for managing a specific illness or injury type according to current medical practice guidelines. (From the HSE-MS Framework Scorecard [FSC]). PS - Performance Standard. PSM - Process Safety Management. PSUA - Pre Start Up Audit. PTW - Permit to Work. Purchasing - The business function which is involved in procuring raw materials, components, finished goods, and capital equipment; and ordering and acquiring supplies and services at competitive prices (synonyms: procuring, buying). QRA - Quantitative Risk Assessment. Qualified / approved suppliers - A group of suppliers or subcontractors who fulfill the approval criteria for purchasing products or services. Quality - (1) The degree to which the perceived situation meets the expected situation. (2) The totality of features and characteristics of a product or service that determine its ability to satisfy stated or implied needs. Quality assurance - All planned and systematic actions necessary to provide adequate confidence that a product or service will satisfy given requirements for quality. Quality control - The operational techniques and activities used to fulfill requirements for quality. Quality management - That aspect of the overall management function that determines and implements the quality policy. Quality manual - A document outlining the general quality policies, procedures, and practices of an organisation. Quality system - The organisational structure, responsibilities, procedures, processes, and resources for implementing quality management. Quality-related costs - The expenditure incurred in defect prevention and appraisal activities plus the losses due to internal and external failure (synonym: costs of non-quality). RAM - Risk Assessment Matrix. Random sampling - A method for selecting units to be examined or population to be interviewed in an audit which gives every unit of the same type equal chance of being selected for inclusion in a sample that is statistically valid. Sample size(s) can be adjusted for desired accuracy and confidence levels. RASCI Chart - A RASCI chart is a tool for describing “who does what and when / how often.” R = Responsible, A = Accountable, S = Supportive, C = Consulted, and I = Informed. This is taken from the more generic concept of “R-A-C-I.” Record - A document containing information with respect to results achieved and/or providing evidence of activities performed. (A record is an “output” document and it typically cannot be revised or altered.). Recovery measures - Those measures aimed at reinstating or returning the situation to normal operating conditions. Regulation - A rule or ordinance, law, and/or device by which people, equipment, materials, and/or the environment are controlled by an external agency or organisation. July 2011

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Residual (“net”) risk - an assessment of the risk taking the quality and effectiveness of the controls in place and after responses have been applied. The potential difference between inherent and residual risk gives an indication of the quality and effectiveness of the controls in place. (From CP-131). Resource, general - Anything used to produce goods or services. Responsibility - The obligation to carry out specified duties and tasks (e.g., someone who has responsibility for “X” in an organisation is obliged to carry them out, or to ensure that others do so). A common problem in organisations is that responsibilities are weakly defined; it is not fully clear who is responsible for what, with the result that certain functions are not carried out effectively. Review, system / management system - A formal evaluation by upper management of the status and adequacy of a system in relation to policy and new objectives resulting from changing circumstances. Risk - The frequency of occurrence (likelihood) of an undesired event, and the severity of the consequences (effects) of that event. Risk acceptance - A set of criteria defining the limits above which risks cannot be tolerated. Risk analysis - The quantitative or qualitative process to assess the likelihood and potential consequences of a possible event. Risk appetite - The positive benefits of exploiting a business opportunity associated with the risks. Risk assessment – 1) Any process used to identify, quantify, or rank risks. 2) The total process of risk analysis, interpretation of results, and recommendations of corrective action (from SP1258). (See Risk analysis). Risk competence - An individual‟s risk perception, risk acceptance, and knowledge and commitment to norms in order to be able to correctly identify, evaluate, and control the risks they are exposed to. Risk evaluation - The process by which risk information is considered against judgment and standards, to ensure that the controls in place are adequate to reduce risks to an acceptable level. Risk exposure - The amount of risk taken. Risk management - A process that is used to ensure that all significant risks are identified, evaluated, prioritized, managed (controlled), and monitored effectively. Risk management system - A structured approach used by organisations to coordinate risk management related activities and drive continual improvement. Risk matrix - A tool for conducting qualitative risk assessment, which characterizes risks based on their likelihood and consequences. Risk measures - Measures that effect affect the likelihood and/or the consequences of events. Risk register - A catalogue / inventory of risk information. Routine - Regular course of action, unvarying performance of certain acts. Rule - (1) A prescribed guide for conduct or action. (2) A bylaw governing activity or controlling conduct, instituted by the organisation involved. Safety - Control of accidental loss. Satisfaction measurement - To measure the satisfaction of customers with a product or service via interviews or other techniques. SCE - Safety Critical Element. July 2011

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Senior management - Group of managers who have a substantial role in formulating the objectives and policies of the organisation. Usually managers at the top of the hierarchy are described in this way, but where there is substantial decentralization of decision-making; managers at lower levels of the organisation may have this status. Typical titles include: President, Vice-President, General Manager, Plant Manager, etc. (synonyms: top management, upper management). Senior manager - The most senior decision-making person at a location. Service department - Part of an organisation concerned with providing after sales service to customers; frequently involved with the handling of complaints which require tactful replacement or rectification to avoid temporary or permanent loss of goodwill. Service Level Agreement - Service Level Agreements specify the nature, scope, and flexibility of essential services to be provided by Service Asset Managers to Product Flow Asset Managers. They also specify quality of a service, how it is measured, on what terms payment is made, deliverables, and responsibilities (including management of HSE risks). Severity - A measure of the level of harm or damage that the accident could cause. Also known as consequence, impact, or hazard effect. Severity is often expressed as the level of injury or the financial costs of damage. Shall - indicates a course of action with a required, mandatory status within PDO. (See Must). Should - indicates a preferred course of action. Significant incident - Incident with actual consequences rating of 4 or 5 on the Risk Assessment Matrix. SIL - Safety Instrumented Level. SIMOPS - Simultaneous Operations. Simple risk assessment - The process of asking one‟s self a brief, simple series of questions relating to a specific task that enables more effective risk recognition, evaluation, and control. Site / Operation Ergonomic Priority List - A list of job processes that have the highest ergonomic concerns. For small sites, a general operation level list may be developed instead as long as individual sites can add their own specific priorities. (From the HSE-MS Framework Scorecard [FSC]). Site Medical - Medical professionals contracted or employed by PDO to service employees at one or more PDO sites. (From the HSE-MS Framework Scorecard [FSC]). Skill development coaching - (1) The actions taken to help employees perform as well as possible through techniques such as performance reviews, discussions, etc. (2) Actions taken on a day-to-day basis, designed to motivate an employee to improve his or her skills. Specification (SP – PDO) - The specific requirements that are mandatory – with respect to performance, implementation, monitoring, and/or reporting. A specification can apply to materials, products, activities, and/or services. Stakeholders - See “Interested parties.” Those groups who affect and/or are affected by the organisation and its activities. These may include, but are not limited to: owners, trustees, employees, associations, trade unions, customers, members, partners, suppliers, competitors, government, regulators, the electorate, non-governmental organisations (NGOs) / not-forprofit organisations, pressure groups and influencers, and/or communities. Standard - A standard represents agreement on best practice for the technology or process concerned. For example, ISO 14001 is an international standard that represents worldwide agreement on best practices for environmental management. This is NOT a (technical) performance standard. Standards, performance - The defined criterion for effective performance of work or activities. Performance standards should define who is responsible for performing what work when or how often. (See Management system performance standard).

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Standards, ISO-9000 and ISO 14000 series - A set of individual but related international guidelines on quality and environmental management developed to help companies effectively document the quality and environmental activities to be implemented to maintain an efficient quality and environmental management system. The standards are developed by the International Organisation for Standardization (ISO), an international agency composed of the national standards bodies of 160+ countries. (See ISO). Statistical Process Control (SPC) - The application of statistical techniques to control a process. Often the term statistical quality control is used interchangeably with statistical process control; however, the SPC includes acceptance sampling as well as statistics process control. STOP - STOPTM refers to Dupont‟s Safety Training Observation Program (STOP). Strategic direction - Deciding what business activities the firm should conduct and where. (Examples: continue its existing activities, divest some of them and/or diversify into new product markets, remain a national supplier, etc.). Strategy - The formulation of a unified body of strategic plans by a firm in order to achieve its business objectives. Business strategy integrates all aspects of a firm's production activities through all levels, including: (1) Objective or goal setting, (2) Strategic direction, (3) Choice of growth mode, (4) Competitive strategy, and (5) Functional responsibilities. (Related terms: business policy, corporate strategy, strategic management). Structured - The pattern of roles and relationships in a group or organisation. Subcontracting - Arrangement by which a person or a firm, based on a legal contract, supplies goods and/or services to another person or firm. Subcontractor - Person or company that does work under a contract with the contractor. Substandard acts and substandard conditions - Acts or conditions that do not meet established standards; frequently referred to as unsafe acts or conditions. Survey - A systematic study to identify and assess a defined issue or condition. Sustainable development - Defined in the 1987 Report of the World Commission on Environment and Development Our Common Future as “development that meets the needs of the present, without compromising the ability of future generations to meet their own needs.” System - An established way of carrying out an activity or series of activities, including the identification, training, and involvement of individuals responsible for the activity; a clear definition of the activity and how to do it; and a mechanism to ensure that the activity is performed as expected. TA - Technical Authority. TI - Technical Integrity. (See Technical Integrity.) Target - A specific endpoint, usually either stating the date of completion of particular actions needed to achieve the objectives and/or achieving specified quantitative performance measures. Task - A specific work assignment within an occupation, consisting of a definite sequence of steps. Task analysis - A systematic analysis of the steps involved in doing a task, the loss exposures involved and the controls necessary to prevent loss. It is a prerequisite to the development of job / task procedures and practices. An important step in the analysis would be consideration of the elimination or reduction of loss exposures. Task instruction - The process of transferring the knowledge and skills necessary to properly perform a job / task. Task observation - Task observation is a technique to ensure that tasks / procedures are performed efficiently and in compliance with standards.

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Technical Integrity - An asset should be procured, designed, constructed, commissioned, operated, and maintained so that it is suitable for its required purpose, considering structural integrity, process containment, ignition control and systems for protection, detection, shutdown, emergency response, and life saving. Tender - Offer to supply goods or services at a price; usually a detailed document outlining all the conditions which would relate to any ensuing contract. Commonly associated with government contracts for building, construction service, or periodic supplies. Threat - A possible cause that will potentially release a hazard and produce an event. Top Event - The „release‟ of a hazard; something that occurs in a certain place during a particular interval of time. Top Management - The most senior management members at the site, typically a Director, service manager, and/or other operations managers. (From the HSE-MS Framework Scorecard [FSC]). TRC - Total Reportable Cases are the sum of Fatalities, Permanent Total Disabilities, Permanent Partial Disabilities, Lost Workday Cases, Restricted Work Cases, and Medical Treatment Cases. This is sometimes referred to as Total Recordable Cases. TRCF - The Total Reportable Case Frequency is the number of Total Reportable Cases per million Exposure Hours worked during the period. Trend Analysis - This term refers to a process by which data is analyzed to determine underlying contributing factors, such as but not limited to, root causes, location, department, specific equipment, lack of procedures, failure to follow procedures, and/or improper procedures. (From the HSE-MS Framework Scorecard [FSC]). TROIF - The Total Reportable Occupational Illness Frequency is the sum of all occupational illnesses whether or not they have resulted in deaths, permanent total disabilities, permanent partial disabilities, lost workday cases, and/or restricted workday cases per million working hours during the reporting period. Unbiased - Independent or impartial. Also, not having a vested interest in the subject or object being evaluated, audited, and/or assessed. Unbiased person - A person who, by lack of vested interest or external pressure, can render an objective observation or decision. Usually someone outside of the direct line of authority. Values - The understandings and expectations that describe how the organisation‟s people behave and upon which all business relationships are based (e.g. trust, support, and truth). VIAR - The Vehicle Injury Accident Rate is the number of company and (sub)contractor employees who sustained an injury as a consequence of road traffic accidents per 100 million kilometers driven. Vision - A statement that describes how the organisation wishes to be or become in the future. Work Instruction - A document that specifies in a step-by-step manner how a task or a set of tasks is to be performed. (Work Instructions are often simplified from an associated procedure.) Work practice - See Practice(s). Work-related - Work related activities are defined as those activities for which management controls are in place, or should have been in place. Work Restrictions - Clear definitions of the physical activities an employee may perform while recovering from an injury or illness. (From the HSE-MS Framework Scorecard [FSC]). Zero energy state - The state of equipment in which every power source that can produce movement of a part of the equipment or release of energy has been rendered inactive.

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10. LIST OF HSE-MS DOCUMENTS 10.1 LIST OF CODES OF PRACTICE Hyper-Linked Documents CP-102 - Corporate Document Management CP-107 - Corporate Management Framework CP-111 - Relationship With Stakeholders CP-114 - Maintenance & Integrity Management CP-115 - Operation of Surface Product Flow Assets CP-117 - Project Engineering CP-118 - Well Lifecycle Integrity CP-123 - Emergency Response Documents Part I CP-126 - Personnel and Asset Security CP-129 - Contracting and Procurement CP-131 - Risk and Opportunity Management CP-162 - Internal Communication Referred Documents CP-100 - Policy Approval CP-109 - Delegation of Authority CP-116 - Information Planning and Appraisal CP-127 - IM & T Security CP-130 - HLD COP for Learning & Development Services CP-132 - Logistics Services CP-136 - Planning in PDO CP-139 - Corporate Data Management CP-141 - Use of Concession Land by Third Parties CP-145 - Optimisation Management CP-146 - Social Investment CP-148 - Media Relations CP-152 - Resourcing and Leadership Development CP-156 - Integrated Activity Planning CP-174 - Omanisation CP-180 - Recruitment CP-190 - Quality Management System for Project Delivery CP-193 - Inventory Management CP-196 - Surplus Materials Management

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Document Author UIIM FCC HXM23 UOP6 UOP6 UEJ1 UPT UIC4 UID FPS11 FCC HRD Document Author FCM FCM TCP UIIC4 HD UWL412 UCPM UIIM UPT1 UPT1 CAM23 HXM23 HD UOX2 HOM HRD1 UEQ FPP FPC33

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10.2 LIST OF HSE COMMON PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents PR-1078 - Hydrogen Sulphide Management Procedure PR-1081 - The Buddy System Procedure PR-1148 - Entry into a Confined Space Procedure PR-1171 - Contract HSE Management Part I - Mandatory for PDO Personnel involved in Contract Management PR-1171 - Contract HSE Management Part II - Mandatory for Contractors & Contract Holders PR-1418 - Incident Notification, Reporting and Follow-up Procedure PR-1501 - Fire Brigade Procedure PR-1515 - Onsite Mercury Management Procedure PR-1712 - Level 3 Audit (Engineering Operations) PR-1797 - PDO Airports Safety Management System PR-1969 - Corporate HSE Audits PR-1970 - HSE-MS Review PR-1980 - HSE Competence Assurance PR-1981 - Chemical Management SP-1157 - HSE Training SP-1234 - Personal Protective Equipment SP-1259 - Safety Training Observation Programme (STOP) GU-140 - C9 HSE Specification (Contracts) GU-653 - Behaviour Based Safety Referred Documents PR-1263 - Managing HSE in Exploration Directorate PR-1264 - Exploration HSE Procedure (Deep Oil) PR-1357 - HLD - HSE Procedure for Learning and Development Centres PR-1433 - HSE Management in Exploration Laboratory PR-1451 - (HP-GEN-006), Use of Equipment in Hazardous Areas PR-1453 - Hazardous Substances PR-1502 - Crisis Evacuation Procedure (highly confidential so not in EDMS) PR-1829 - Exploration Worksite Hazards Procedure PR-1830 - Exploration Contractor HSE Management Procedure PR-1957 - Issues Identification and Management Process SP-2087 - Specification for Onsite Mercury Management GU-441 - HSE Guideline - HSE Inspection GU-464 - HSE Guideline: HSE is Teamwork GU-573 - HSE Guideline - Managing HSE Issues in Company Organised or Supported Field Trips and Social Events GU-612 - Guidelines - Incident Investigation and Reporting GU-624 - Permit to Work Licensing Guidelines

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Document Author UOP6 UOP6 UOP6 MSE12 MSE12 MSE52 UIT5 UOP6 UOP6 UWLC MSE54 MSE52 MSE/6 TKM HLD8 MSE4 MSE11 FPB MSE1 Document Author XPS XPS HLD6 XGL UWH UWH UID XPS XPS HXM23 UOP6 MSE4 MSE53 MSE54 MSE52 UOP6

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10.3 LIST OPERATIONAL SAFETY PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents PR-1172 - Permit to Work Procedure PR-1696 - HAZOP Procedure PR-1708 - Lifting and Hoisting Procedure Inspection Testing and Certification PR-1709 - Lifting and Hoisting Procedure Lift Planning Execution PR-1971 - HAZID Procedure PR-1972 - Safe Driver PR-1973 - Safe Vehicle PR-1974 - Safe Journey SP-1075 - Fire and Explosion Risk Management (FERM) SP-1127 - Layout of plant equipment and facilities SP-1256 - HSE Specification - Camps, Offices, Labs, Workshops and Industrial Safety SP-1257 - Scaffolding, Working at Heights or Over Water, Lifting Operations and Earthworks SP-1258 - Quantitative Risk Assessment (QRA) SP-2001 - Load Safety and Restraining SP-2062 - HSE Specification: Specifications for HSE Cases SP-2085 - PDO Oilfield Transport & Interior Based Vehicle Specifications SP-2097 - WE Specification for the Prevention of Dropped Objects GU-432 - Road Transport HSE CASE Referred Documents PR-1042 - General Operational Safety PR-1043 - General Requirements for Well Services Equipment in Hazardous Areas PR-1045 - Hazardous Substances PR-1827 - Exploration Office Safety Procedure SP-1251 - Training Requirement for Lifting Operations Personnel GU-230 - Fire and Explosion Risk Management (FERM) Facility plan Guideline GU-375 - Guideline for conducting Defect Elimination Analysis (Root Cause Analysis & Failure Investigation) GU-377 - Guideline for carrying out Reliability Centered Maintenance (RCM) Analysis GU-432A - Appendix - Road Transport HSE CASE GU-437 - Guideline on SIL Assessments and Implementation Guideline GU-445 - Transport Operations Guidelines GU-463 - Task Risk Assessment GU-501 - Guidelines for Excavating and Working Around Live Pipelines

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Document Author UOP7 UEF2 UEC14 UEC14 MSE4 MSE15 MSE15 MSE15 MSE1 MSE4 MSE1 UCE14 MSE45 MSE13 MSE4 UML UWH2 MSE15 Document Author UWH21 UWH21 UWH21 XPS UEC14 MSE1/ UOP7 UEM UEM MSE15 UEP351 UWL412 MSE1 UIP5

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10.4 LIST OF TECHNICAL SAFETY PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents PR-1000 - Operations Handover Procedure PR-1029 - Competence Assessment & Assurance PR-1047 - Well Integrity Maintenance PR-1048 - Well Control / Well Kill PR-1076 - Isolation of Process Equipment Procedure PR-1154 - Gas Testing Procedure PR-1232 - Design Integrity Review Procedure PR-1233 - Contract & Procurement Procedure (CPP) PR-1961 - Process Leak Management SP-2110 - AI-PSM Assurance Framework GU-611 - PDO Guide to Engineering Standards and Procedures GU-625 - PDO Operations and Maintenance Related Documents GU-648 - Guide for Applying Process Safety In Projects GU-655 - Demonstrating ALARP Referred Documents PR-1001a - Facility Change Proposal Procedure PR-1001b - Trip Alarm SCADA Settings Change Procedure PR-1001c - Temporary Override of Safeguarding System Procedure PR-1001e - Operations Procedure Temporary Variance PR-1001x - Operations Variance and Change Management PR-1002 - Operations Excavation Procedure PR-1005 - Maintenance and Inspection Activity Variance Control Procedure PR-1023 - Automation Systems Software Management Procedure PR-1033 - Well Test Operations PR-1034 - Wireline Operations Procedure PR-1035 - Well Pulling Hoist Operations PR-1036 - Coiled Tubing Operations PR-1038 - Workshop Operations PR-1039 - High Pressure Operations - Fracture Stimulation Operations Procedure PR-1046 - Concurrent Drilling, Hoist and Production Operations PR-1052 - Preparation and Updating of Station Plant Operating Manuals PR-1073 - Gas Freeing, Purging and Leak Testing of Process Equipment and Pipework PR-1079 - Gas Freeing and Purging of Petroleum Storage Tanks PR-1083 - Safe Working on the Roof of a Floating Roof Tank PR-1086 - Locked Valve and Spectacle Blind Control PR-1088 - Organisational & Staff Changes Process Control PR-1098 - Well Activity Coordination and Control PR-1106 - Changes and Administration of Authorities PR-1159 - Commissioning and Start-up PR-1247 - Project Change Control & Standard Variance Procedure PR-1473 - Well Barrier & Isolation PR-1721 - Shutdown Management PR-1947 - Electrical Safety Rules PR-1948 - Electrical Safety Operating Procedures PR-1960 - Control of Portable Temporary Equipment SP-1131 - Handover and As-built documentation SP-1190 - Design for Sour Service Specification SP-1219 - Well Engineering Hydrogen Sulphide Specification

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Document Author UOP6 UOP6 UWXZ4 UOW & UWH UOP6 UOP6 UEP3 FPM UOP7 MSE4 UEP3 UOP6 UEP351 MSE4 Document Author UOP6 UEV11 UEV11 UOP6 UOP6 UOP6 UOP6 UEC212 UEO UWXU3 & UWXZ42 UWH21 UWH2 UWH2 UEO UWS UEC341 UOP6 UOP6 UOP6 UOP UEP UOP6 FCN UOP6 UEP3 UWX51 UOP3 UIE3S UIE3S UOM2 UEV11 UEP1 UWS81

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual SP-1278 - Specification for Site Selection and Soil Investigation Works Engineering Guidelines SP-1284 - Signs and Signboards SP-2017 - Well Failure Model SP-2061 - Technical Authority System SP-2113 - Specification for Commissioning and Start-Up (Key Principals) GU-289 - PDO Security Guide GU-425 - GU-425 Contracting and Procurement Guidelines GU-513 - Guidelines for Alarm Management and Rationalisation GU-622 - Contract Performance Management (CPM) Framework Guideline GU-632 - Water Management Control Framework Guideline

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UIB UIB UPT UEQ2 UOP6 UIC4 FPB3 UEP351 FPS12 UCG

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10.5 LIST OF OCCUPATIONAL HEALTH PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents SP-1170 - Naturally Occurring Radioactive Materials (NORM) SP-1230 - Medical Examination, Treatment, and Facilities SP-1231 - Occupational Health SP-1232 - Public Health SP-1233 - Smoking, Drugs, and Alcohol SP-1237 - Ionising Radiation Referred Documents SP-1218 - Radioactive Sources

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Document Author MSE32 MCC MSE32 MSE32 MSE32 MSE32 Document Author UWB42 & MSE32

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10.6 LIST OF ENVIRONMENTAL PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents PR-1084 - Leak / Spill Management, Site Clean-Up, and Restoration PR-1419 - Abandonment and Restoration Procedure PR-1975 - Waste Management PR-1976 - Environmental Permitting SP-1005 - Emissions to Atmosphere SP-1006 - Aqueous Effluents and Accidental Releases to Land and Water SP-1008 - Conservation of Natural Resources SP-1010 - Environmental Noise SP-1011 - Biodiversity SP-1012 - Land Management GU-195 - Environment Assessment Guideline GU-447 - Integrated Impact Assessment Guidelines Referred Documents SP-1225 - Environmental Management GU-634 - Guidelines for Sampling of Sewage for Sewage Treatment Plant GU-643 - Green IT Strategy

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Document Author UOP6 UOP6 MSE22 MSE21 MSE21 MSE21 MSE21 MSE21 MSE21 MSE21 MSE21 MSE21 Document Author UWH UIB4 UIIC

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10.7 LIST OF EMERGENCY RESPONSE PROCEDURES, SPECIFICATIONS, AND GUIDELINES Hyper-Linked Documents PR-1065 - Emergency Response Documents Part II - Company Procedure PR-1066 - Emergency Response Document Part III Contingency Plan, Volume III Production Operations PR-1067 - Emergency Response Documents Part III, Contingency Plan Volume 4 Main Oil Line PR-1068 - Emergency Response Document part III Contingency Plan Volume V Terminal & Tank Farm Operations PR-1069 - Emergency Response Document Part III Contingency Plans Volume VI Marine Operations PR-1168 - Emergency Response Documents Part III, Contingency Plan Volume VII Power Systems Operations Interior PR-1223 - Emergency Procedures Part III, Contingency Plans Volume 12 External Affairs & Communications PR-1243 - Emergency Procedures Part III, Contingency Plans Volume 13 Medical Emergencies PR-1243B - Emergency Procedures part III- Vol 12 Medical Emergency Response Manual Part IISite Specific MER Procedure PR-1246 - Emergency Procedure Part III, Contingency Plans Volume 14 Government Gas System PR-1275 - Emergency Procedure Part III, Contingency Plans Volume 15 South Oman Gas line PR-1287 - Emergency Procedures part III Contingency Plans, vol II Well Engineering Operations. PR-1301 - Emergency Procedures part III Contingency Plans, vol II Personnel Centre PR-1329 - Emergency Procedures part III Contingency Plans, vol 10 Mina al-Fahal Ras Al- Hamra Building PR-1656 - Emergency Response Document Part III Contingency Plans Volume 8 - Information Management & Technology PR-1707 - Disclosure Procedure PR-1789 - Corporate Business Continuity Plan (BCP) Referred Documents PR-1091 - Operations Emergency Telephone Network Procedure PR-1147 - Operational Integrity Testing of Fixed Firefighting Systems PR-1299 - Management of First Aid and Evacuation Within Corporate Affairs Department PR-1447 - Emergency Well Control for Central Oman LNG Gas Wells PR-1618 - Emergency procedures during operation demand PR-1802 - PDO Fahud Emergency Plan PR-1805 - PDO MARMUL Emergency Plan PR-1808 - PDO Qarn Alam Emergency Plan PR-1958 - Suspected Object Bomb Threat GU-288 - Emergency Response Document Part IV, Guidelines GU-576 - Blowout Contingency Plan

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Document Author UIC4 UOP6 UIP61 UIP31 UIT4 UIE3 HXM2 MCO11N & MCO3 MCO11N & MCO3 GGO2 UIP31 UWD1 HRO4 HES4 UIIO12 HXM23 UIC4 Document Author UEP351 UOP6 MCC UWX51 UIE3 UWLB21 UWLB21 UWLB1 UIC5 UIC4 UWH2

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