PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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. Page 1 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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: Continual Improvement Policy Review Planning Checking Implementation & Operation 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 CP107, 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. Page 2 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) Introduction 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. Organization, 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). 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. → → → Page 3 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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 8. Page 4 Introduction PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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 Organization, 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. Organization, 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. 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 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 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 Page 5 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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. 2. 3. 4. OVERVIEW: This explains the “WHY” or purpose of the Process in the overall HSE MS. REQUIREMENTS: This explains “WHAT” is required to be implemented in the HSE MS Process. PROCEDURES: This explains “HOW” the HSE MS Process / activity is to be implemented or conducted. 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: Page 6 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) Introduction 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. 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. Management System (EDMS) is used for document control. PDO‟s Electronic Document 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. Page 7 PDO HSE MANAGEMENT SYSTEM MANUAL (CP-122) 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 Page 8