#2b: Shift leader / supervisor pack (Contractors and sub-contractors)
WHO DECIDES TO BREAK THE RULES,
DECIDES NOT TO WORK FOR MOL GROUP
„…The Life Saving Rules set out clear and simple “dos” and “don’ts” covering activities with the highest potential safety risk and apply to all employees and contractors. The best-performing companies operate within a simple framework of rules and trust their employees to do the right thing. Our Life Saving Rules will help us do the same. They are simple, sharp and do what they say
– save lives.
As our workers, leaders, managers, supervisors and contractors, I’m asking you to make a personal commitment to the Life Saving Rules too, make sure everyone understands and follows them.
Safety will always be our top priority and this shall be based on respecting each other and our rules. My message is a simple one - if you choose to violate the rules and do your job the unsafe way, then you choose not to work for MOL Group. We are determined to save lives.”
József Molnár
MOL Group CEO
T he Life Saving Rules are basic safety rules for high-risk works where failure to comply with the rules has the highest potential for serious injury or death. They also highlight simple actions individuals can take to protect themselves and others.
• None of the Life Saving Rules is new, they have already been valid through various legal and internal regulations.
• Most staff already comply every day.
• The aim is not to blame employees but to drive a culture of compliance. The focus is on modifying worker and supervisor behaviours in the workplace by raising awareness.
• Compliance is mandatory for everyone, MOL Group, contractor and sub-contractor employees alike.
• Failure to comply will result in disciplinary action.
17 fatalities*
NOW
Compliance with the LSR would have saved many of these lives
*Staff & contractor/sub-contractor employee fatalities 2008-2012
GOAL
Review & analysis of:
• MOL Group historical incident data (fatalities, serious or high potential incidents)
• OGP recommended practice
• Oil & gas industry practice
Criteria applied:
• Rules apply to at least 50% of fatal incidents
• Rules can be clearly defined and easily understood by staff & contractors
• Violation of the rules can be monitored consistently
Ignition source
Workforce and contractor personal accidents in the last
5 years
Permit to work
Workforce and contractor personal accidents in the last
5 years !
Gas testing
Workforce and contractor personal accidents in the last 5 years
Life Saving PPE
Workforce and contractor personal accidents in the last
5 years !
Energy isolation
Workforce and contractor personal accidents in the last
5 years
No alcohol or drugs
Workforce, contractor and 3rd party personal incidents in the last 5 years
March 2010
Contractor employee died in an explosion during a tank cleaning at Csepel logistics depot in Hungary.
June 2012
Two contractor employees were killed due to asphyxiation by nitrogen at TVK in Hungary.
January 2010
Slovnaft employee drowned in a service shaft at Slovnaft Refinery in Slovakia.
February 2012
Contractor employee fell from the canopy of a Tifon filling station in Croatia as he attempted to remove snow and suffered fatal injuries.
October 2008
Contractor employee was fatally injured by electric current as he was measuring electric motor at Slovnaft Refinery in Slovakia.
September 2012
Third party driver was killed in a road accident with a contractor tank truck at
Krk in Croatia.
Rule violators expose themselves or others to a higher risk of injury or
fatality.
All rulebreaking cases will be investigated thoroughly.
If the rule violator acted intentionally, the maximum appropriate disciplinary
action will be applied.
For employees of contractors or
sub-contractors, this can include removal from site and disqualification from future
Company work.
If a supervisor sets the
conditions for rule breaking or fails to follow through if one is broken, appropriate disciplinary action will apply.
1.
Do not smoke outside designated areas
2.
Verify energy is isolated before starting work
3.
Obtain and follow a permit to work
4.
Use correct lifesaving PPE whenever required
5.
Conduct gas tests whenever required
6.
Do not carry out work in trenches without effective shoring up
7.
Do not remove safety signs or override / disable safety-critical equipment
8.
Do not violate safe lifting rules
9.
No alcohol or drugs before and during working
10. Comply and intervene
As a supervisor / shift lead / foreman, I have to:
• Inform personnel about designated smoking areas;
• Ensure the permit to work is obtained if hot work is carried out;
• Inform personnel about hazards and rules of hot work.
As a supervisor / shift lead / foreman, I have to:
• Be aware and inform personnel of the hazardous energy sources at the work site;
• Confirm all hazardous energy sources have been isolated and isolations are in place, for example: blinds, fuse locks or valve handle locks;
• Confirm no stored energy or other hazards remain;
• Confirm that it is safe to start work.
A permit to work must always be obtained prior to starting the following activities and followed throughout the job*: (1) Confined space entry, (2) Hot work, (3) Critical lifting, (4) Work at height
and/or over water, (5) Ground disturbance, (6) Maintenance works of particularly increased risk
or conditions (e.g. simultaneous operation, work on live high voltage system/equipment, opening of vessel/equipment with hazardous content, overriding safety critical equipment/system, high pressure cleaning etc.)
As a supervisor / shift lead / foreman, I have to:
• Confirm that the requirements of the permit to work are in place;
• Ensure that a watchman is always present when people are in a confined space;
• Confirm that gas testing is carried out as per permit to work;
• Confirm that it is safe to start to work.
*: This list is to be considered as minimum, further activities may be under permit to work obligation as defined locally. Performing a work different from what the permit to work was issued for is considered as working without a permit to work.
Personal Protective Equipment termed ‘life saving’ are personal fall arrest systems and personal
respiratory protection equipment (except dust masks). A personal fall arrest system must be used when working outside a protective environment with a fall hazard over 2 metres.
As a supervisor / shift lead / foreman, I have to:
• Make sure that the specific life saving PPE is available and personnel are trained;
• Confirm that suitable anchor points are available if personal fall arrest system is to be used;
• Confirm that it is safe to start work at height or in the hazardous or potentially hazardous atmosphere.
As a supervisor / shift lead / foreman, I have to:
• Confirm that gas testing is carried out by trained personnel as per permit to work;
• Ensure that enough calibrated gas detectors are available;
• Request more gas tests if necessary to keep the workers safe;
• Confirm that it is safe to start work.
As a supervisor / shift lead / foreman, I have to:
• Ensure that any pits or trenches deeper than 1.2 metres are sloped or protected by shoring;
• Ensure that any pits or trenches deeper than 1.2 metres are considered as confined spaces.
Examples of safety-critical equipment include isolation devices/emergency shut-down valves, lock out/tag out devices, trip systems, relief valves, fire and gas alarm systems, certain level controls, alarms, crane computers.
As a supervisor / shift lead / foreman, I have to:
• Be aware and inform personnel of the safety-critical equipment in the work place;
• Confirm that authorisation of overriding / disabling safety critical equipment does not put the safety of personnel, asset or the environment to risk;
• Ensure necessary temporary control measures are in place when safety critical equipment is overridden / disabled.
As a supervisor / shift lead / foreman, I have to:
• Ensure a signaller is appointed whenever necessary (eg. blind lifting, critical lifting*);
• Make sure the lifting area is secured with tapes or barriers;
• Make sure the lifting path is clear;
• Ensure that rigging and lifting are both performed by competent persons;
• Confirm that proper rigging equipment is used;
• Ensure that nobody walks under a suspended load;
• Stop lifting in the event of loss of communication.
*: Some lifting activities involve increased hazards (like lifting heavy loads close to crane capacity or over critical technological areas), these are called critical lifting.
As a supervisor / shift lead / foreman, I have to:
• Assign work to people who are fit to work;
• Immediately remove people from the work who are under the influence of alcohol or drugs.
Keeping the Life Saving Rules will save lives. One who chooses not to keep the Life Saving Rules chooses not to work for MOL Group.
As a supervisor / shift lead / foreman, I have to:
• Provide a safe workplace and assign safe work in line with the Life Saving Rules;
• Inspect the Life Saving Rules are followed;
• Intervene if somebody violates the Life Saving Rules and apply consequences.
Know the Life
Saving Rules: purpose; application; reporting; investigation; consequences.
Ensure and verify that your and your sub- contractors personnel have been trained.
Keep your team engaged with the LSR, always recognize positive
behavior.
Lead through personal example.
Ensure and verify that the
LSR are applied in a fair way.
Verify, measure and continuously improve
compliance.
• Discuss each rule with your team and ask them to relate the Rules to what is important in their particular work area, e.g. working at height.
• Be clear that your expectation is that everyone, including you, will follow the Rules.
• Express that involvement of your subordinates in system operation is essential.
• Talk about how you will respond in the workplace if team members break a Life Saving Rule.
• Be clear: if following a Rule means a job can’t be done, find alternative safe solution to complete the work. Encourage them to stop the work rather than break the Life Saving Rule or make a shortcut.
• Familiarize yourself with the rules.
• Try to use the slides as help rather than reading from the slide.
• Think about the type of questions your team may ask you (and the answers you’ll give), as well as how to encourage discussion and engagement.
• Put special focus on the reporting and investigation of rule violations, this topic will always be in the center of attention.
• Tell your team how you are ‘living’ the Rules yourself. What do YOU intend to change? How will
you behave differently?
• Explain how you intend to recognize positive behavior.
SYSTEM or UNINTENTIONAL ERROR
System error
Routine error
Benign contravention
Poor awareness / understanding
Slips and lapses
Violator did not receive documented training or followed instructions, procedures that led to the violation.
This type of error has been made by the employee or group of employees as accepted way of doing the job.
Violator thought it was better for the company to do it that way or considered the job could not be done if the procedures were followed.
The violator demonstrates poor risk awareness and/or understanding of the impact his/her actions have.
Actions that did not proceed as planned, e.g.
something was done twice, the wrong way or a step is forgotten.
Reckless contravention
DELIBERATE VIOLATION
Malicious
Contravention or sabotage
The person thought it was better for them personally to do it that way, e.g. getting a longer work break, getting away earlier, etc.
The person committing the violation acted so with intentional negligence of the consequences or to cause harm.
SYSTEM or UNINTENTIONAL ERROR
System error
No disciplinary consequences are
applied*
Routine error
DELIBERATE VIOLATION
Reckless contravention
Malicious
Contravention or sabotage
Strictest disciplinary consequences are applied
Benign contravention
Poor awareness / understanding
Slips and lapses
Progressive disciplinary consequences are applied
*: If no other causes are identified during the investigation. Inadequate instructions, procedures etc. that caused the violation must be corrected to prevent reoccurrence.
Action
Immediate
Longer term
Example Action executor
Expulsion until correction
(suspended work)
(eg. until wear the lifesaving
PPE)
Ban the employee (eg. proven alcohol comsumption)
Auditor and site responsible operator
Contractor owner
1
• Life Saving Rule violation is reported
• Investigation team is nominated*
2
• Establishing the causes
3
• Investigation team recommends consequence*
4
5
• Additional changes to systems, procedures are recommended if necessary
*: Team nomination is necessary only in cases where consequences involve serious consequences, such as contract termination or as defined locally.
Smoking out of the designated smoking area
Penalty amount
50 000
HUF/Pers.
Expulsion until correction
(suspended work)
-
Energy isolation missing
200 000
HUF
X
Contractor / Subcontractor Staff
Working without work permit
Not using/wearing the life-saving protective equipment
Failure in performing the prescribed gas concentration test(s)
200 000 HUF
50 000
HUF/Pers.
50 000
HUF
Protection against collapse is missing
50 000
HUF
Safety equipment and signs are removed or missing
200 000
HUF
Violation of regulations relevant to lifting operations
10 000 –
200 000
HUF
Proven consumption of alcohol or drug
50 000
HUF/Pers.
X X X X X X -
Ban the relevant shiftleader
-
Ban for 1 year for MOL
Group sites.
Ban for 1 year for
MOL Group sites
(if the PPE was not ensured).
Ban for 1 year for MOL Group sites (if the equipment was not ensured).
-
-
Ban the relevant employees
Ban the relevant employees for 1 year for MOL Group sites.
-
Ban the relevant employees for 1 year for MOL
Group sites.
(if the employee not used the PPE).
Ban the relevant employees for 1 year for MOL
Group sites.
(if the employee not used the equipment).
-
Ban the relevant employees for
1 year from
MOL Group sites.
Visit the Life Saving Rules Contractor Information Site for:
• Visuals, handouts (Posters, flyers and training booklet)
• Training materials (Manager, Supervisor and Employee packages)
• Frequently Asked Questions
Contact your local SD & HSE for any inquiries:
[Name, phone, email]
WHO DECIDES TO BREAK THE RULES,
DECIDES NOT TO WORK FOR MOL GROUP