“Introducing a Technical HSE
Framework”
By:
Mr. Hjalmar Rodriguez
Acting Asst. Manager, HSE Professional Competence
HSE Regulations & Enforcement Directorate (DG)
Qatar Petroleum
19 June 2012
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HSE (DG) Directorate tasks
As per Decision No.5, DG Directorate key objectives (among others) are:
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To control the implementation of and compliance with the laws relating to health,
safety and environment…,
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To organize and update the data about laws and directives; and present proposals
regarding new laws or amendments to existing local laws as regards the HSE …,
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To review and approve HSE programmes ... To ensure their compliance with the HSE
law and the effectiveness of such regulations ...,
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To assure emergency preparedness plans for significant incidents are in place and
functional…,and
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To issue and receive reports about the contraventions of the applicable HSE laws, to
raise reports to the Minister of Energy and Industry on the state of compliance with
such laws ...
HSE (DG) Directorate tasks
Mandated Core Function:
“Assure HSE risk is regulated
and controlled”
HSE (DG) Directorate Roles
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Provide legal guidance, interpretation and direction on HSE regulations
Tasked with implementing the legal framework
Monitor implementation for securing industry HSE regulatory compliance with
regulations
Assess treaty provisions and provide guidance on the Ratification and/or Adoption
by the State of Qatar
Engage all stakeholders through a review and implementation of HSE strategies
Promote and monitor Sustainable and Clean Development
Safeguard Qatar’s Social and Economic Development
Promote HSE National Capacity Building as well as provide best practices and
training
DEVELOP HSE REGULATORY APPROACH with Policies, Regulations and
Guidelines.
Safety regulatory approach (Cont.)
LEGAL STANDING
• Decree Law No.4 of 1977 “Preserving Oil Wealth”.
• Decision No. 5 of 2005, Chairman Board QP assigning QP’s HSE regulatory role to
the Directorate.
CURRENT REGULATORY STATUS
• “Legal HSE Framework for the Oil & gas Industry” – issued to Energy and
Industry Sector Operators as a compilation of existing national legal regulations.
• “Legal Register” – listing Qatar’s legal regional/international obligations
(Directorate's responsibilities).
• Guidelines, standards etc. related to regulatory activities by DG.
• Recent instruction by H.E. Minister of Energy & Industry to reposition the Directorate
to a “Regulatory Authority” with focus on “SAFETY” for the Petroleum and Energy
Sector.
Technical HSE framework approach
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Meet the content/purpose of the existing laws of the State of Qatar
Focus on Prevention of Significant HSE Risk that impacts the State level –
PRIORITY,
Process Safety is a key industry focus (Major Accident Hazard Prevention),
Assure compliance with (regulatory) HSE obligations in close cooperation with
other relevant authorities establishing focal points, MOU, agreements, etc.,
Influence "World Leading – Best in Class” to those with “Significant Opportunities
for Improvement,”
Promote the compliance and continuous improvement of HSE practices as one
objective with aim to achieve shift in attitudes and requirements,
Promote an improvement mentality, not a compliance mentality,
Build on gathered supervision experience and lessons learned from the last few
years of industry engagement.
Technical HSE framework approach (Cont.)
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Risk based, it requires industry operators to reduce risks to a level that is “As Low as
Reasonably Practicable”(ALARP),
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Goal oriented rather than prescriptive or Goal based,
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Does not replace or supersede any existing regulatory requirements used in Qatar’s
Petroleum and Industry, or any existing functions of any of the other State statutory
authorities,
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Concentrates on the technical HSE issues that will form the foundation of the
operational and regulatory role for DG within the State of Qatar,
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Imposes additional requirements to Petroleum and Industry activities throughout the
entire life cycle of the project.
Technical HSE Framework
The framework focuses on the significant health, safety and environmental risks that
could impact Qatar’s energy industry.
THE GENERAL OBJECTIVES:
• To provide a foundation for the development of HSE regulations and supplementary
documents, such as Industry Guidelines/standards, in order to secure the HSE welfare
of persons at work and members of the public,
• To regulate Industry operators in order to reduce HSE risks to “As Low as Reasonably
Practicable”(ALARP) levels,
• To reduce the risks and consequences of a “Major Accident” ,
• To ensure a consistent use of international standards and best practices,
• To implement best recognized regulatory practices in all industrial activities, and
• To strengthen Qatar's preparedness and response capacity to deal with potential
emergencies
Technical HSE Framework
SCOPE:
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Independent regulation of relevant Qatari industry activities to protect life and
environment; to foster and encourage safety, safety culture and continuous
improvement of safety throughout the entire industrial sector.
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Specified functions of the Directorate will include:
i.
Regulate designated activities of petroleum and industry sector with respect to
HSE,
ii.
Monitor and enforce compliance of undertakings with their duties under Law No.
4 (1977), Law No. 8 (2004), Decision No. 20 (2005) and Law No. 30 (2002), all
relevant laws and ministerial decisions,
iii. Investigate and report to the Minister on Petroleum and industry incidents,
iv. Issue acceptance letter to the relevant licensing authority for the issuance of
Permits, and
v. Provide safety information.
Technical HSE Framework
APPLICATION:
The scope of this framework includes the following:
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Oil and gas operations (upstream and downstream) within concession areas
(onshore & offshore),
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Chemical and Petrochemical industry,
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Major storage and processing sites for hydrocarbon, petrochemicals/chemicals or
other dangerous/toxic products,
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Pipelines Transportation Systems, containing hydrocarbons, chemicals or other
hazardous materials and/or handling high pressure,
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Construction of hydrocarbon and chemical facilities and processes (onshore &
offshore)
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Power Generation, but not distribution,
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Refining of metals (Steel and Aluminum) ,
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Marine – Oil tankers, LNG Carriers, MODU/Jack-up rigs, production and storage
vessels (FSO/FPSO), supply and boats & vessels.
Technical HSE Framework components
THE COMPONENTS include:
1.
A Statement of Strategic Intent
2.
ALARP Demonstration
3.
Agreed Interfaces, Co-operation & Co-ordination with Regulatory Authorities
4.
DG’s Role in the Licensing process
5.
Compliance Assurance System
6.
Incident Investigation System
7.
Reporting and Published HSE Information System (not everything will be shared with
everybody)
8.
Enforcement System
9.
Continuous Improvement System
Technical HSE Framework elements
STANDARDS & CODES OF PRACTICE
SPECIFIC DG PROCEDURES AND GUIDELINES
MARINE
ENVIRONMENT
OCUPATIONAL HEALTH
OCCUPATIONAL SAFETY
THIRD PARTY CERTIFICATION
ASSET INTEGRITY
WELL DESIGN & CONSENT
OFFSHORE INSTALLATIONS
MAJOR HAZARDS
TECHNICAL HSE FRAMEWORK
Int’l Standards :
• e.g. ISO, IEC
• e.g. CEN (Europe)
• e.g. ANSI/API (US), DIN
(Germany) or NEN (NL)
Industry Standards:
• OGP, IADC, IMCA, API
• Nogepa, OLF, UK oil &
gas
Technical HSE framework components
INDUSTRY REGULATION, INTERFACES AND CO-OPERATION
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Should focus on safety, without disregarding any case related to the areas of
health and environment. Primary focus will be on preventing major incidents.
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Strong working relationships shall be established with other government HSE
Regulatory duty holders (i.e. MoE, MoL, SCoH) to avoid duplication and to
complement their activities.
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It is consistent with other best practices and other regulatory regimes which
minimizes duplication of regulatory activities.
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Interfaces, Cooperation & Coordination
with Regulatory Authorities
MoEI
ENVIRONMENT
ENVIRONMENT
MoEI
ASSET
INTEGRITY
WELL DESIGN &
CONSENT
OFFSHORE
INSTALLATIONS
MoEI
MARINE
MoEI
OCCUPATIONAL
SAFETY
SCoH
3RD PARTY
CERTIFICATION
LICENSING
AUTHORITY
SAFETY
MAJOR
HAZARDS
REGIME
OCCUPATIONAL
HEALTH
HEALTH
HSE REGULATIONS
MoEI
MoL,
Civil
Def.
Ports,
MoI
MoE
Technical HSE framework components
DG’S ROLE IN THE LICENSING PROCESS
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DG will regulate designated Petroleum and Industry activities through the Ministry
of Energy and Industry licensing system
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Petroleum and industry Operator will only be able to undertake activities upon
approval of a license to be issued by the relevant regulatory body upon DG’s
acceptance of a pertinent Major Hazards Report (MHR) or Safety Case (SC).
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Technical HSE framework components
COMPLIANCE ASSURANCE SUPERVISION
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Monitor the compliance of operator(s) in accordance with Technical HSE
Framework and its associated regimes, permits or licenses and the general duties
of the Operator as per existing HSE regulations of the State.
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Include a process of inspection, supervision, verification and performance
reporting requirements by Directorate (DG) personnel.
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The frequency of supervision visits shall be based on the size and nature of the
operation, number of personnel, past audit outcomes and perceived safety risk of
the Operators.
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Propose enforcement actions and compensations determined by law, in the event
that an Operator is not complying with its obligations and its approved permit (s).
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Technical HSE framework components
INCIDENT INVESTIGATION SYSTEM
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Decision No. 5 (2005) by the Chairman of Board of Directors of QP placed the
responsibility on DG to investigate serious industrial accidents, and to head
investigation committees in this regard.
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Under this framework, Industry Operators shall notify DG of any major incidents
(i.e. phone call, email, and fax).
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DG may in co-operation with other Governmental Agencies investigate certain
incidents .
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Directorate (DG) may:
– Request the Industry Operators to furnish a Incident Report; and/or
– Appoint a designated staff to investigate the incident; and/or
– Issue an improvement notice, a prohibition notice, a notice requiring the
Industry to revise procedures and systems
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Technical HSE framework components
CONTINUOS IMPROVEMENT SYSTEM
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Based on measurement of the HSE outcomes and overall safety performance of
industry operators.
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Inputs to the continual improvement process:
– HSE Performance reporting by Qatar’s industries,
– Findings and recommendations from the supervision and verification process,
– Information and outcomes from enforcement actions,
– Administrative areas that requires attention,
– Areas of duplication regarding inspections and reporting,
– Identified common HSE trends within industry,
– Information from co-operation and co-ordination of regulatory activities,
– Lessons learned from incident investigations.
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Technical HSE Framework Highlights
GENERAL COMMENTS:
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Operators welcomed publication of the Technical HSE Framework and its regimes:
– Clarification of the role of HSE-DG in regulating Major Accident Hazard
Management, Offshore Installations, Well Integrity/Consent, Asset Integrity
Management and Third-party Certification.
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Potential opportunity to share operator's experience with DG in Major Hazard,
Well Consent and Asset Integrity Management:
– Upfront conformation of Working Groups with Industry in developing
documents.
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Many comments in clarification and restructuring of document.
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Technical HSE Framework Highlights
SPECIFIC COMMENTS:
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Third Party Certification should not be considered as a Third Party Verification
Regime.
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Provision of requirements on emergency response coordination and management
at individual level and then city level (ref: MHR).
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Some existing industries do not comply with current codes of practice and
standards.
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DG cannot require a regulated entity to “exceed” a standard without setting a new
standard.
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Specific obligations and details in regimes (e.g. to obtain a permit, license and to
report incidents to DG) should not be part of THSEF.
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Technical HSE Framework Highlights
SPECIFIC COMMENTS:
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Consider excluding pandemic, epidemic, disease and food poisoning on major
scale as major accident hazards.
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Suggest that off-shore facilities are separated from on-shore facilities in terms of
regulative requirements:
– Reason being - Offshore Safety Cases are normally vigorous documentation of
compliance that an operator meets requirements for integrity for helicopter.
transport, accommodations, safety critical elements, etc.
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Consult with Operators for the development of procedures, as well as the
enforcement system to get valuable feedbacks on areas of concerns from the
operator:
– Incident Reporting and Investigation,
– HSE-MS,
– Risk Acceptance Criteria, as part of Risk Management.
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Technical HSE Framework Highlights
SPECIFIC COMMENTS:
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Consider including Security of Offshore and Onshore facilities in the scope of this
Framework.
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Care should be taken in defining the frequency, depth and issuance of licenses
and permit renewal.
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Potential involvement of External consultant in development of implementation
documents (guidelines, reporting tables, working instructions etc.) – under process
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Linking “Report” Acceptance to existing MoE&I Licensing Process:
– Need for resources to cope with the review and assessment.
– Potential delays in projects due to slow/late licensing process.
– DG would have to get the right expert resources to be able to satisfy the
demand.
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Expected (Planned) Activities
1.
Conformation of working groups with subject matter experts (SME’s) from
industry
2.
Review and feedback for Offshore Installations Regime and Well Integrity and
Well Consent Regime.
3.
Finalization of 2 remaining regimes (as per plan).
4.
Host a 2nd Workshop.
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Concluding statement:
“The State of Qatar will continue to build upon its role in the regional
and international community as a stable and reliable partner in
Energy and Industry Sector by implementing HSE culture based on
the highest international standards and best approach.
The HSE (DG) Directorate will do its outmost best to contribute to this
effort”
Thank you for your attention!