KOC.ge.004 - HSE Compliance Identification and Tracking Procedure

KOC.GE.004 - HSE Compliance Identification and Tracking Procedure Page 1 of 11

HSE Compliance Identification and Tracking Procedure Document Number: KOC.GE.004 Approver: (Technical)

Manager HSE

Author:

TL HSE Systems

Approver: (Administrative)

Manager HSE

Document Coordinator:

TL Standards

Scope:

All KOC Directorates

Control Tier:

3

Issue Date:

March 1, 2004

Issuing Group:

HSE Group

Revision/Review Date:

May 13, 2012

Next Review Date:

May 12, 2015

1.0 Purpose/Scope This procedure describes the process for identifying, and providing access to legal and other obligatory requirements and to communicate these requirements to those KOC operations and support functions with responsibilities for compliance. This procedure applies to all KOC Directorates.

2.0 Definitions 2.1 Compliance – being in accord with regulations, standards, and/or rules. 2.2 KOC HSE Compliance Register – a corporate level document with listing of all applicable HSE legal requirements that apply to KOC-wide operations and activities. Only Occupational health related requirements are included in this register and all other health related requirements are included in the Health legal register maintained by the Medical group. 2.3 Group HSE Compliance Register – a group level document with shortlisting of all applicable HSE legal requirements from the KOC HSE Compliance Register that apply to the respective group’s operations/activities. 2.4 Legal Requirements – all applicable statutory and regulatory requirements or obligations (regulations) imposed by local, national and international regulatory agencies or governing bodies on KOC to control its operations, such as Kuwait EPA, Ministry of Oil, Ministry of Social Affairs & Labor, Ministry of Interior, Ministry of Health, Ministry of Communications, IMO, SOLAS, etc. 2.5 Other Obligatory Requirements – all non-legal requirements (national, regional and international) to which KOC subscribes and voluntarily committed for compliance, such as KPC requirements and any protocols such as MARPOL, etc.

3.0 General Requirements 3.1 KOC HSEMS Guide, Element 3, Risk Assessment, Compliance and Management  Expectation No.7: “System shall be in place to identify and have access to legal and other regulatory requirements applicable to KOC operations and monitor emerging issues and communicate potential impacts to affected organizations.”  Expectation No.8: “KOC shall ensure compliance with all applicable regulations related to KOC activities including Kuwait EPA, Ministry of Oil, health and other obligatory requirements from KPC.” Control Tier 3

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3.2 KOC HSEMS Guide, Element 12, Auditing, Assurance, Measurement, and Continuous Improvement  Expectation No.8: “A process to periodically evaluate compliance with relevant HSE regulatory and obligatory requirements shall be in place and documented.”

4.0 Key Responsibilities 4.1 Deputy Managing Directors (DMD)  Provide the necessary resources to assist with the implementation of this procedure within their respective directorate. 4.2 Manager HSE  Responsible to ensure processes are in place to administer and maintain all the HSE compliance requirements, including the mandatory elements of the KPC HSEMS standards. 4.3 Manager Legal Affairs  Provides advice and interpretation of legal issues and concerns. 4.4 Managers  Responsible for developing and maintaining the Group HSE Compliance Register.  Responsible for administering and maintaining the HSE compliance requirements, including the requirements of this procedure, within their respective group.  Responsible to ensure the implementation of the conformance measures and compliance to the respective Group HSE Compliance Register.  Responsible to ensure compliance to all the applicable mandatory KPC HSEMS requirements through the implementation of all the applicable HSEMS procedures. 4.5 Team Leader HSE Systems  Responsible for maintaining the KOC HSE Compliance Register.  Formally reviews the KOC HSE Compliance Register annually with the support of Safety and Health & Environment team leaders for the respective discipline, or whenever there has been a significant change in legal/other obligatory requirements, standards or policy as notified by the respective discipline specific team leaders (Health and Environment or Safety).  Ensures that copies of all HSE related legal documents that are applicable company wide, including regulations and permits, are maintained and available.  Notifies Asset/Directorate HSE Team Leaders whenever there is a change to the KOC HSE Compliance Register. 4.6 Team Leader Health and Environment  Responsible for identifying the existing, new and/or pending environmental and occupational health related statutes, regulations and other requirements applicable to KOC operations.  Assists the Team Leader HSE Systems in the compilation, review and update of the environmental and occupational health sections of the KOC HSE Compliance Register.  Monitors developing Health and Environment legal/other obligatory requirements and notifies Team Leader HSE Systems whenever the KOC HSE Compliance Register requires amendment. Control Tier 3

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 Maintains awareness of current environmental and occupational health legal/other obligatory requirements.  Develops internal environmental and occupational health standards when existing legal/obligatory requirements do not exist or are inadequate.  Provides guidance and advice on the interpretation of environmental and occupational health compliance requirements as requested by Directorates. 4.7 Team Leader Safety  Responsible for identifying the existing, new and/or pending safety related statutes, regulations and other requirements applicable to KOC operations.  Assists the Team Leader HSE Systems in the compilation, review and update of the safety sections of the KOC HSE Compliance Register.  Monitors developing safety legal/other obligatory requirements and notifies Team Leader HSE Systems whenever the KOC HSE Compliance Register requires amendment.  Maintains awareness of current safety legal/other obligatory requirements.  Develops internal safety standards when existing legal/obligatory requirements do not exist or are inadequate.  Provides guidance and advice on the interpretation of safety compliance requirements as requested by Directorates. 4.8 Asset/Directorate HSE Team Leaders  Responsible for monitoring the HSE compliance requirements, including the requirements of this procedure, within the respective asset/ directorate.  Provide support to groups within the respective asset/directorate for reviewing and maintaining their Group HSE Compliance Register.  Inform the Corporate HSE Group of process or production changes that may affect compliance status.  Maintain general awareness of applicable legal/other obligatory requirements and standards, and promote awareness within the asset/directorate.  Seek advice from the Corporate HSE Group and other KOC resources when needed to clarify or interpret compliance issues.  Communicate changes, as and when notified by Team Leader HSE Systems, to all concerned within the asset/directorate. 4.9 Team Leaders  Support their respective Group Managers in the identification of HSE compliance requirements pertaining to their operations/activities.  Responsible for the implementation of the assigned conformance measures and compliance to the respective Group HSE Compliance Register.  Responsible for the compliance to all the applicable mandatory KPC HSEMS requirements through the implementation of all the applicable KOC HSEMS procedures.  Responsible to file copies of all certificates and approvals, as applicable and required, at the respective operational areas.  Responsible for informing the respective Asset/Directorate HSE Team Leader regarding any modification in the process and any up-gradation in the assets.

Control Tier 3

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4.10 Superintendents of Contract  Ensure contractor understanding and compliance with KOC HSE policy and legal and/or other obligatory requirements that are applicable to their role and activities.  Communicate changes, as and when notified by asset/directorate HSE Team Leader, to all concerned in the Contracts. 4.11 All Staff (including Contractors)  Understand the HSE compliance implications of their individual roles within the organization and communicate with HSE Team Leaders/ Superintendent of Contract regarding changes in KOC operations/activities that may affect legal compliance.  Maintain an awareness of the compliance requirements that relate to work activities.  Notify supervisor immediately whenever there is, or may be, non-compliance with any requirement (including requirements related to activities outside the work scope).  Inform their Asset/directorate HSE Team Leader if aware of any change, or likely change, in compliance requirements that may affect any part of KOC.

5.0

Procedure

5.1

HSE Compliance Register

5.1.1 KOC policies and standards shall be in line with all the applicable HSE legal and other obligatory requirements, including KPC, Kuwait EPA, Ministry of Oil, Ministry of Social Affairs & Labor, Ministry of Interior, Ministry of Health, IMO, SOLAS, MARPOL, etc. and any applicable International legislation and protocols the State of Kuwait has subscribed to. 5.1.2 The HSE Compliance Register is a reference to all HSE legal requirements that are applicable to KOC/Group activities. The KOC HSE Compliance Register is a corporate level document with listing of all applicable HSE legal requirements that apply to KOC-wide operations and activities. The Group HSE Compliance Register is a group level document, prepared from the KOC HSE Compliance Register by shortlisting all the applicable HSE legal requirements that apply to the respective group’s operations/activities. 5.1.3 However, the following exceptions shall be followed: (a) All legal requirements pertaining to medical health shall be incorporated in the Medical Group HSE Compliance Register and only the legal requirements related to Occupational Health to be included in the Corporate and Group HSE Compliance Registers. (b) All legal requirements pertaining to Marine operations shall be incorporated only in the Export and Marine Operations HSE Compliance Register. 5.1.4 All the obligatory requirements, such as KPC HSEMS mandatory requirements, are all embedded into the Company’s HSEMS procedures. The requirements of other applicable codes of practice are included in the respective pertinent Company standards. These requirements are implemented and monitored as part of the implementation of the respective Company’s HSEMS procedures and pertinent standards. Therefore, these requirements are not included in the HSE Compliance Register. 5.1.5 The HSE Compliance Register is organized on an issue-based “Categories” such as Atmospheric emissions/ Pollution, Chemicals and Hazardous Materials, Waste, Land Contamination, Surface/Ground Water Contamination, Produced/ Effluent Water, Resource Depletion/ Nature Conservation, Radiation, working conditions (Air Quality, Noise, Lighting, Temperature), transportation/transfer, general HSE legislation/legal Control Tier 3

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requirement, etc. to enable easy reference. Further reference may be made to more detailed or instructional documents where necessary, such as HSEMS procedures, emergency response plans, waste management manual, etc. 5.1.6 The template for the HSE Compliance Register is shown in Appendix-1, which shall include the following details of information for each of the legal/regulatory requirement:            5.2

Reference Number Title of the legislation/regulation with effective date Associated legal/regulatory body Accord – Approval/ Notification/ Reporting/ Record Related category & Key word Linked Area/ Activity/ Process Applicable Phase – Planning/ Design/ Engineering/ Operations/ Emergency The actual requirement Conformance measure Responsible personnel for conformance measure Remarks

The HSE Compliance Registers (HCR)

5.2.1

KOC HSE Compliance Register (KOC.GE.005)

The KOC HSE Compliance Register includes all the HSE legal requirements that are applicable to KOC activities, prepared as per section 5.1 including the exceptions mentioned in section 5.1.3, and is maintained on the KOC HSE Intranet site. The KOC HSE Compliance Register is formally reviewed on an annual basis and maintained by the HSE Group. This review will be documented and recorded by minutes of meeting detailing a formal review session. Additionally, the KOC HSE Compliance Register is revised whenever there is a change in legal/regulatory requirements that may arise from new and/or any amendments in the regulations applicable to KOC operations, changes in permits and approvals, or changes to operating equipment or processes. Date of last review/update shall be provided in the current KOC HSE Compliance Register. TL HSE Systems shall have access to documents relating to all applicable local regulations. Any changes in the KOC HSE Compliance Register shall be communicated by Team Leader HSE Systems to all asset/directorate HSE Team Leaders. Further, asset/directorate HSE Team Leaders shall communicate these changes, as applicable, to all concerned within their respective asset/directorate. The KOC HSE Compliance Register is referred whenever developing or preparing relevant HSE Management System documents. Such documents include, but are not limited to: 

Environmental Aspects Registers



Safety Risk Registers



Health Risk Registers



HSEMS Procedures



HSE Checklists/Worksheets



Emergency Response Plans



HSE Action Plans



Contract documents



Waste Management Procedure

Control Tier 3

Revision Date: May 13, 2012 Uncontrolled Copy if Printed

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Where appropriate, these documents should reference the KOC HSE Compliance Register. Where there is any doubt as to the application of any legal requirement to a KOC activity, advice shall be sought from the asset/directorate and corporate HSE teams and, if needed, the KOC Legal Teams. In case of any overlap between local regulations and KPC HSEMS compliance requirements, the most stringent shall be applicable. HSEMS procedures shall be in place, documented and up-to-date, to manage the compliance requirements in line with the themes as identified in the HSE Compliance Registers. 5.2.2

Group HSE Compliance Register (KOC.GE.005.XXX)

Each group shall maintain their group specific HSE Compliance Register, in line with the KOC HSE Compliance Register, shortlisting and detailing all the legal/regulatory compliance requirements applicable to the respective group. The Group HSE Compliance Register (HCR) shall have the document number as follows: KOC.GE.005.XXX Where, “XXX” shall be the respective Group’s abbreviation (all in capital letters) For example: 

The HCR for Operations (SK) group will be KOC.GE.005.OSK



The HCR for Support Services (WK) group will be KOC.GE.005.SSWK



The HCR for Field Development (NK) group will be KOC.GE.005.FDNK



The HCR for Public Relations & Information group will be KOC.GE.005.PRI



The HCR for Research & Technology group will be KOC.GE.005.RT



The HCR for Industrial Services group will be KOC.GE.005.IS



The HCR for Ahmadi Services group will be KOC.GE.005.AS



The HCR for Planning group will be KOC.GE.005.P

However, for groups having same initials, a second letter shall be added for distinguishing each other. For example: 

The HCR for Exploration group will be KOC.GE.005.EX and the HCR for Engineering group will be KOC.GE.005.EN



The HCR for Major Project (I) group will be KOC.GE.005.MPI and the HCR for Major Project (II) group will be KOC.GE.005.MPII

Appropriate records shall be maintained to document its compliance with the compliance register. All documentation shall be in line with the Company’s HSEMS document control procedure (KOC.GE.013) and the HSE records management procedure (KOC.GE.045). The Group HSE Compliance Registers shall be reviewed on an annual basis. Date of last review/update shall be provided in the current group HSE Compliance Register. In case the HSE Compliance Register (HCR) is deemed necessary and appropriate to have at any team level, then such HCR shall have the document number as follows: KOC.GE.005.XXX.YYY Where, “XXX” shall be the respective Group’s abbreviation (all in capital letters) And, “YYY” shall be the respective Team’s abbreviation (all in capital letters) Control Tier 3

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For example:  5.3

The HCR for Production Operations (WK) team, which is under Operations (WK) group, will be KOC.GE.005.OWK.POWK Handling Deviations and Non-Compliance

In case of any deviations, the pertinent directorate management through HSE Group shall present the respective deviation to the concerned regulatory body for approval with valid justification for the deviation request. Upon approval from the concerned regulatory body, the deviation approval shall be documented and reflected in the compliance register. In case of any rejection of the deviation request by the concerned regulatory body, appropriate action shall be taken to ensure compliance. For any non-compliance, the pertinent directorate line management shall develop and implement an action plan to ensure compliance with appropriate corrective and preventive action along with the identified responsible parties and timeframe for implementing the action. Such action plans shall be approved by HSE Group and the line management. 5.4

Competency, Training and Awareness

Management shall define the level of experience, competence and training required to ensure capability of personnel for HSE protection, including compliance with HSE legal requirements. All key personnel involved in the HSE compliance management shall have sound knowledge of the HSE laws/regulations, the Health, Safety & Environment Management Systems and shall have appropriate certifications based on their job functions, which shall be part of their training and awareness program. Refresher training/awareness program every three (3) years shall be in place for all personnel, as applicable. Any changes, new or amendments, in the regulations shall be reflected in the concerned employee’s training/awareness program. Awareness on the HSE compliance requirements and the consequence of deviations shall be provided to all personnel, including induction for new employees and Contractor key personnel. The Contractors’ key personnel shall in turn provide awareness to all their respective employees. All training and awareness provided shall be in line with the Company’s procedure for HSE Training, Awareness and Continued HSE Learning Process (KOC.GE.028). 5.5

Audits and Inspections

Auditing against the requirements of this procedure shall be included in the KOC annual audit register and the asset/directorate annual inspection registers. All audits and inspections shall be carried out as per the Company’s HSE Audit, Inspection and Selfassessment procedure (KOC.GE.016). 5.6

Records Management

All records as stipulated in the above sections and as specifically identified in section 8.0 of this procedure shall be maintained as per the Company’s HSE Records Management procedure (KOC.GE.045) and the respective pertinent HSEMS procedures.

Control Tier 3

Revision Date: May 13, 2012 Uncontrolled Copy if Printed

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6.0 Key Documents/Tools/References                

KOC HSE Management System Guide (December 2009) KOC.GE.001 – KOC HSE Management System Manual KOC.GE.005 – KOC HSE Compliance Register KOC.GE.009 – HSE Internal Communication Procedure KOC.GE.010 – HSE External Communication Procedure KOC.GE.013 – HSEMS Document Control Procedure KOC.GE.016 – HSE Audit, Inspection and Self-Assessment Procedure KOC.GE.028 – HSE Training, Awareness and Continued HSE Learning Process KOC.GE.045 – HSE Records Management Procedure KOC.HE.019 – KOC Health Risk Register KOC.SA.033 – KOC Safety Risk Register KOC.EV.002 – KOC Environmental Aspects Register KOC.GE.026 – KOC Corporate Emergency Response Plan Site Specific Emergency Response Plans Appendix-1 – Template for HSE Compliance Register Group HSE Compliance Registers

7.0 Abbreviations           

HSE – Health, Safety & Environment HSEMS – HSE Management System KOC – Kuwait Oil Company KPC – Kuwait Petroleum Corporation Kuwait EPA – Kuwait Environmental Public Authority NK, WK, S&EK – North Kuwait, West Kuwait, South & East Kuwait Directorates E&PD – Exploration & Production Development Directorate E&MO – Export & Marine Operations IMO – International Maritime Organization SOLAS – Safety Of Life At Sea MARPOL – Marine Policies

8.0 HSE Records (Retention Period)      

HSE Compliance Registers (continuous, updated & current) Non-compliance Reports & Data Sheets (5 years after closing the non-compliance) HSE Compliance Register Review Minutes (5 years) Relevant internal and external transmittals (5 years) Training records (5 years) Audit/Inspection Reports (refer to KOC Audit, Inspection & Self-assessment procedure – KOC.GE.016)

Control Tier 3

Revision Date: May 13, 2012 Uncontrolled Copy if Printed

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Review and Revision Log Review/ Revision Date February 9, 2003

Document Approver Manager HSE

Document Author TL HSE Systems

March 1, 2004

Manager HSE

TL HSE Systems

HSEMS Implementation Committee comments incorporated. Approved and issued for implementation.

July 3, 2005

Manager HSE

TL HSE Systems

New HSE Teams added in section 4.0. Replaced “KOC Legal Department” with KOC Legal Teams in sections 4.0 & 5.3.

July 3, 2006

Manager HSE

TL HSE Systems

Section 4.0, Directorate “E&PD” changed to “OS”. Section 4.0, Key Responsibilities of TL-H&E, bullet no.6 revised to add “Health and Environment”. Section 6.0, reference documents added “GE.KOC.009” and “GE.KOC.010”

July 14, 2007

Manager HSE

TL HSE Systems

Document numbers changed in the title and Section 6 to be in line with document control procedure. “Review and update” added to the responsibilities of TL-Safety and H&E and the same reflected on the responsibility of TL-HSE Systems for clarity and avoiding conflict of responsibilities.

June 19, 2008

Manager HSE

TL HSE Systems

Document format revised as per the document control procedure. Section-4; "OS" changed to "E&PD" to reflect the current organization. Section-6; Procedure reference numbers corrected. Section-7; Abbreviation added.

May 31, 2009

Manager HSE

TL HSE Systems

Section-5.2; date of last update included in place of Revision log for Compliance Register revision status. Section-5.3; “General Safety” revised as “HSE”. Section-8; HSE Records added.

July 4, 2010

Manager HSE

TL HSE Systems

Section-1.0 & 2.0; included & defined obligatory in other requirements. Section 3.0; revised the expectations in line with updated HSEMS Guide. Section 4.0 & 5.2; clarified the communications methodology for changes.

July 24, 2011

Manager HSE

TL HSE Systems

Amended Header and Footer as per the document control procedure. “Legislation” replaced with “legal and other obligatory requirements” in line with KOC HSEMS Manual. Added KPC mandatory requirements in Sections 2.0, 4.1, 4.6, 5.1, 5.2 and new section 5.4. Section 7.0; added KPC.

Review/Revision Details Draft for HSEMS Committee review.

Control Tier 3

Implementation

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May 13, 2012

Manager HSE

TL HSE Systems

Revised all the sections and added 4.4, 4.9, 4.10, 5.2.2, 5.4, 5.5 and 5.6 to incorporate additional KPC mandatory requirements and the recommendations from the ISO 14001:2004 and OHSAS 18001:2007 audits to have HSE Compliance Registers at the group level for effective implementation. Added the revised template for HSE Compliance Register as an appendix. Approved by the HSEMS Implementation Committee and has been re-issued for implementation.

Control Tier 3

Revision Date: May 13, 2012 Uncontrolled Copy if Printed

Name of the Regulatory Body

State the regulatory body which published the legislation/regulation

Control Tier 3 Revision Date: May 13, 2012 Uncontrolled Copy if Printed

6 7

Area / Activity / Process Phase

9 10

Requirement Conformance Measure Personnel (Designation) responsible for Conformance measure Remarks

State the method of conforming to the legislation/regulation State the personnel, as designation, who would be responsible for the implementing conformance method State the status or any other remarks related to the legislation/regulation

8

State the actual requirement as published

Emergency

Operations

Design/Engineering

Planning

Offshore

Onshore

Marine

Loading

Storage

Process

5

State the phase or stage when the legislation/regulation is applicable

State the area, activity or process where the legislation/regulation is applicable

Flowlines/Pipeline

Accord

Wells

Drilling

Survey

Related Category & Key words

4

State the category of the legislation/ regulation such as “Air pollution”, “Sea pollution”, etc. or “Others”, and some key words for easy reference

Records

3

Reports/Notification

2

State the type of consent required from the regulatory body

Title of the Legislation/ Regulation & Effective date

State the title of the legislation/regulation as published along with the date when it became effective

1

Approvals

Ref. No.

Serial number in order

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APPENDIX - 1

Template for HSE Compliance Register 11