Petroleum Development Oman LLC Revision: 1 April 09 Petroleum Development Oman L.L.C Letter of Assurance Introduction The statements relate to all PDO contracts held by the contractor. The statements are 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. Brevity is encouraged in both qualifications and any commentaries. Contractors shall submit a completed Contractor HSE Capability Questionnaire and submit it to PDO with the completed HSE Letter of Assurance. PDO reserves the right to verify/ audit statements. False statements may expose the contractor to penalties as stipulated in the contract. TABLE OF CONTENTS 1 Content .................................................................................................................................. 2 1.1 Hazard and Effects Management Process ........................................................................ 2 1.2 Life Saving Rules .............................................................................................................. 5 1.3 Road Safety ...................................................................................................................... 6 1.4 HSE Incident Management ................................................................................................ 8 1.5 Staff .................................................................................................................................. 9 1.6 Performance Reporting and Execution .......................................................................... 12 1.7 Sub-Contractors .............................................................................................................. 12 1.8 Asset Integrity - Process Safety Management ................................................................ 13 1.9 Health ............................................................................................................................. 13 1.10 Environment .................................................................................................................. 17 1.11 Other Issues ................................................................................................................... 20 Page 1 HSE Letter of Assurance . Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 1 Content 1.1 Hazard and Effects Management Process 1.1.1 Heath, Safety & Environment (HSE) Hazards & Effects Management Assessments have been performed and documented for each contract. Refer to: Section T-03 (previously Section T-04) – Data provided by the Tenderer – Technical Tender” 3.5 HSE Hazards & Effects Management Assessment HSE Hazards & Effects Management Assessment (Mandatory) Tenderer shall, as part of this technical submission, prepare and submit to the Company an HSE Hazards & Effects Management Assessment. This assessment shall provide: An assessment of the significant HSE hazards associated with the Work/Services. A description of how these hazards will be controlled, mitigated and managed from mobilisation through execution, demobilisation and site restoration. A description of the manpower that will be applied to manage the HSE hazards identified by the assessment, including names, qualifications and experience. The assessment shall be based on the guidelines stated in the PDO HSE Code of Practice (CP-122). A template for the completion of this assessment is provided in Appendix ‘B’: - HSE Hazards & Effects Management. PR 1171 “Contractor HSE management Part II – mandatory for Contracts and Contract holders.” 2.6.6 Hazards and Effects Management process. Hazards and Effects Management Process Contractor(s) shall: Provide a register of anticipated contract-specific hazards and effects identified by the detailed HEMP. From the assessment of hazards, identify risk reduction measures to control and recover, including: Page 2 work methods and work site procedures emergency response plans exposure reduction methods HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 1.1.2 Toolbox risk identification and control tools are in place and used for carrying out all task level toolbox talks. Refer to: PR 1172 Permit to work system manual, 6.10 Briefing the Work Party – the Toolbox Talk Briefing the Work Party – the Toolbox Talk Toolbox talks are short briefings given by either the Permit Applicant or Permit Holder to all who are involved in the work controlled by a permit. These briefings are given before the work commences. The Permit Holder is to ensure that the Work Party is fully aware of the Work Content and Precautions to be taken. Toolbox Talks are given for: All jobs. Routine jobs when personnel are unfamiliar with the location or the tasks to be undertaken. In cases where personnel may have difficulty reading or understanding the Permit, or Certificate, or safety conditions associated with a job. Toolbox talks: Discuss the hazards of the job. Explain the plan for the activity Identify individual responsibilities Review the procedures to be used during the work. Topics that are covered by Toolbox Talks include: The work to be undertaken at the work location. The work plan and worksafe methods to be used to do the work safely. What individuals in the work party will actually be doing during the completion of the work. Particular skills of individuals involved. Access and Evacuation procedure refreshers. The work environment and any particular hazards that have controls. The work description of the Permit. The Job HSE Plan precautions, protection and Worksite preparations. The equipment involved. The materials to be used. Any isolations which need to take place. Any potential conflicting activities. Questions and discussion from all work party personnel. NOTE: A reference card (TRIC) for use by Permit Holders when giving Toolbox Talks is available, and shall be used. Page 3 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 1.1.3 HSE Management Plans have been developed for each contract. These describe the specific actions, programs and procedures that are being implemented to manage the Hazards associated with contract execution. Refer to: C9 HSE Specifications, 1.0 HSE Management System and HSE Management Plan HSE Management System and HSE Management Plan Contractor shall have a developed HSE management system covering all activities under the Contract that is compatible with Company’s HSE management system as described in CP-122. As part of Contractor’s HSE management system, Contractor shall develop a Contract HSE management plan describing the specific actions, programs and procedures that will be implemented by Contractor to manage hazards associated with the execution of the Services under the Contract. The HSE management plan shall be developed in accordance with the Contract HSE Management Procedure PR-1171, Part II. The Contract HSE management plan shall cover all Contract phases from mobilisation through execution, demobilisation and Site restoration. The requirements specified in this Section C9 apply regardless of the status of an activity (e.g. standing by or demobilised). Contractor shall ensure that any person, admitted to the Site by Contractor or Subcontractor shall comply with the relevant HSE Specifications herein. PR 1171 “Contractor HSE management Part II – mandatory for Contracts and Contract holders.” Contract-Specific HSE Management Plan Contractor(s) shall, following the Contract Award, kick-off Meeting and on site HSE Workshop, revise its original HEMP and from that develop the Contract-Specific HSE Management Plan. Contractor(s) shall describe how the HSE Management Plan will apply its established, generic programs to manage its activities in the specific contract. Contractor(s) shall identify the contract-specific work activities it will perform and the anticipated HSE hazards associated with the work. Contractor(s) shall clearly describe its plan (controls) for minimizing the potential effects of these anticipated hazards. The plan shall identify specific deliverables, targets, performance measures, monitoring programs, etc. When possible, responsibilities should be clearly assigned and completion dates specified. Contractor(s) shall submit the completed HSE Management Plan to the Contract Holder for approval. The approved HSE Management Plan shall become part of the contract documents. Contractor(s) shall obtain formal approval from the Contract Holder for any proposed deviations from or amendments to its HSE Management Plan. The HSE Management Plan should contain only measurable, quantifiable, contractspecific actions that will be taken during the life of the contract. The following outline is suggested: Page 4 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC 1.2 Revision: 1 April 09 Life Saving Rules 1.2.1 Contract representatives responsible for managing contracts have met with their PDO Contract Holders and agreed a plan for communicating the “Life-Saving rules” to the workforce. Refer to: PDO 12 Life-Saving Rules documentation for contractors. To be distributed by Contract Holders April- May 2009. 1.2.2 A robust ‘HSE Consequence Management System’ has been established and is being effectively implemented and enforced. Refer to: PDO HSE Campaign - Consequence management. There are serious consequences associated with breaking a Life-Saving Rule. Reported non-compliance with one of these Rules will be thoroughly investigated. If a rule-breaker is aware of the Life-Saving Rule or required procedure through training, experience or communication, and did not comply, the maximum appropriate disciplinary action will be applied: up to and including termination of employment for PDO employees; or removal from site and disqualification from future PDO work for employees of contractors or sub-contractors. If a supervisor sets the conditions for rule-breaking, or fails to follow through if one is broken, maximum appropriate disciplinary action will apply. Page 5 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC 1.3 Revision: 1 April 09 Road Safety 1.3.1 Gaps against SP 2000 latest revision have been identified and an implementation plan has been prepared and issued to PDO. Refer to: SP 2000 Road Transport Specification, and; Fax transmission dated 7th Jan, 2008 “Notification of Alterations to Document C-9 HSE Specification”. 1.3.2 All vehicles used in PDO contracts comply with the Roadworthiness Assurance Standard and have been inspected and certified by a RAS Approved Company. Refer to: SP 2000 Road Transport Specification, Appendix II, Assurance Standards (RAS) Inspection Scheme 8 Roadworthiness Compliance with RAS All vehicles used in PDO operations shall comply with the Roadworthiness Assurance Standard and be inspected and certificated as such by a RAS Approved Company. Exception: Rig Trailers do NOT require RAS inspection. Only ROP annual ROPp re-registration inspection by PDO. RAS Inspection Stickers i. A unique sticker shall be used as a visual evidence of a successful RAS inspection. The sticker shall include, as a minimum: Serial number of inspection Vehicle identification Contract Number (if applicable) Name of owner Date of inspection Date of next inspection Name of the inspector Provision to punch the next inspection due month and year and logo of the RAS Approved Inspection Company Stickers must be fixed to the vehicle at the time of the inspection, by the Inspector – they must not be handed to the vehicle driver/user. Stickers shall be colour coded in white and blue. Blue stickers are for Blacktop operation only, white stickers are for blacktop/graded road operation. Size of the sticker shall be approximately 9 cm x 6 cm. The position of the sticker shall Page 6 HSE Letter of Assurance Revision 1 Revision: 1 April 09 Petroleum Development Oman LLC be such that fading due to the sun is avoided (e.g. on the side of the dashboard at the driver side door). A typical format and design is given in Annex 4. ii. iii. Blank stickers shall be kept in a secure location prior to use Validity of RAS inspection shall be one year. 1.3.3 All drivers working on PDO contracts have a valid PDO Defensive Driving Permit. Refer to: SP 2000 “Road Transport Specification, 2.1 Requirements for Drivers Drivers shall have a valid: i. ii. ROP approved driving licence (see Table 1) PDO driving permit (see Table 2) New arrivals/visitors to Oman driving light vehicles on blacktop only shall be exempt from item iv above for 30 days Table 2: Driving Training Permits and Courses Permit Required Vehicle and Road Type Light Vehicle Blacktop Blacktop Light DD-01 Light Vehicle Graded Blacktop Light endorsed with Graded DD-01+DD-03 Heavy Vehicle Blacktop Blacktop Heavy* DD-02 Heavy Vehicle Graded Blacktop Heavy endorsed with Graded DD-02+DD-03 Bulk Tanker (Light or Heavy) Blacktop Light/Heavy/Graded as necessary, endorsed with Bulk Tanker DD-01/2/3 Bus (Light Heavy) Blacktop Light/Heavy/Graded necessary, endorsed with Bus DD-01/2/3 All Page 7 Course Required or as Assessment Drive: first one 12 months after obtaining DD-01, or DD-02, thereafter every two years. HSE Letter of Assurance +DD-04 +DD-05 DD-06 Revision 1 Petroleum Development Oman LLC 1.4 Revision: 1 April 09 HSE Incident Management 1.4.1 All HSE incidents are reported appropriately, investigated and learning’s are disseminated to both Management and the workforce. Refer to: PR 1418 Incident Notification, Analysis, Reporting and Follow-Up Procedure. Guidance to help ascertain compliance: All HSE incidents (including relevant Security incidents) are reported to the Business and appropriately investigated, including the reporting of incidents with ‘Significant Impact’ (defined as incidents with actual consequences rated 4 or 5 on the March 2006 PDO HSE Risk Assessment Matrix (RAM)), in accordance with the December 2007 'Incident Classification, Investigation and Reporting' guide. Action has been taken to implement incident review findings within agreed time frame To disseminate learnings a working internal-communications process must be put in place by the contractor, so that PDO is confident that critical information provided to a contract manager will reach the lowest levels of the contractor and subcontractor workforce – if applicable. Such a process must make provisions for the faithful translation of the information into the various languages spoken by the workforce and for the accessibility to equipment such as internet-enabled computers, video players, television screens, projectors, public-address systems, megaphones etc. at the worksite. 1.4.2 There are no follow up actions from subsequent review of Significant and High Risk Incidents that remain outstanding more than 12 months after the date of the review. Refer to: PR 1418 Incident Notification, Analysis, Reporting and Follow-Up Procedure. Significant Incident Incident with actual consequences rating 4 or 5 on the Risk Assessment Matrix High Risk Incident or High Potential Incidents 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. HRIs can be incidents that result in injuries, illnesses or damage to assets, the environment or company reputation, or they can be near misses. HRIs should be thoroughly investigated and the lessons learned applied to prevent future significant incidents. Note: HRIs are also referred to as Hi Potential incidents HIPO Page 8 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC 1.5 Revision: 1 April 09 Staff 1.5.1 All personnel have completed their HSE training requirements as per the agreed training matrix in the contract. Refer to: C9 HSE Specifications, 3.0 HSE Training HSE Training Contractor shall provide, as a minimum, HSE training for Contractor Personnel in accordance with the minimum HSE training requirements as listed in Appendix 1 of this Section C9. Contractor shall at all times maintain an up-to-date list of all Personnel employed under the Contract, and details of the training courses they have attended, including the attendance date. All Contractor Personnel shall have completed the training listed in Appendix 1 before commencement of the Services, unless stated otherwise in Appendix 1 or unless otherwise approved by the Contract Holder in writing. 1.5.2 A safety training observation programme (STOP), or Company approved equivalent, is being fully implemented in accordance with requirements. Refer to: C9 HSE Specifications, 9.0 HSE Safety Training Observation Programme (STOP) Safety Training Observation Programme (STOP) Contractor shall fully implement a safety training observation programme, or Company approved equivalent, in accordance with Company’s Specification SP-1259 STOP. SP 1259 Safety Training Observation Programme (STOP) Requirements for a Hazard Observation Programme In general, effective Hazard Observation Programmes have the following three prerequisites: Genuine management commitment Resourcing for suitable training of appropriate personnel Resourcing to carry out the activities required to implement the programme. Hazard Observation Programmes require the following activities: Make observations on a daily basis Carry out audits on a regular basis (or as specified by the individual programme) Communicate and discuss with personnel involved in process (to share learning between parties) Report findings (as specified by the individual programme) Analyse findings and formulate trends and conclusions Use trends and conclusions to improve existing processes and procedures Report on involvement rate and performance. 1.5.3 Competence Assessment and Assurance programs are in place and incorporate relevant HSE requirements. Refer to: PR 1171 Contractor HSE Management Part II – mandatory for Contracts and Contract holders, 2.6 & 2.7. Page 9 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Contractor(s) shall ensure that all employees (including sub-contractors) are competent to perform their work tasks, that relevant HSE training is provided, and that HSE requirements are incorporated into competency assessment and assurance programs. See EP 2005 -0120 checklist. 1.5.4 Contractor’s HSE Critical positions including Key HSE Personnel have been assessed against the relevant requirements and their competence has been verified, recorded and plans to address any competence gaps are in place. Refer to: PR 1171 Contractor HSE management Part II – mandatory for Contracts and Contract holders, 2.6 & 2.7. Guidance to help ascertain compliance: Individuals have been assessed against the relevant requirements, and their competence has been verified and recorded. Any competence gaps have been identified and managed taking into account the risk associated with the gap, the need to work without support and the competence of the whole team. The plan is agreed, documented and includes mitigation measures such as: - Modification of the activity Reallocation of the activity to someone who is competent Closure of the gap through training Provision of supervision and support. Contractor(s) shall propose the appointment of the HSE Key Personnel given in document C-09 HSE Requirements for Contract Holders review and approval. Individuals to fill the positions of Contractor HSE Adviser(s), Contractor Representative(s) and Contractor Site Representative(s) shall be classified as HSE Key Personnel under the contract. Minimum Competence for HSE Advisers HSE Advisers shall be knowledgeable in specific relevant safety techniques and have a working knowledge of the legal and contractual health, safety and environmental requirements that must be met. They must have the ability to communicate effectively at all levels of the Contractor’s organization. HSE Advisers shall demonstrate competence in the following areas: Page 10 Ability to communicate effectively in written and spoken English; Ability to conduct and report HSE audits; Training ability in incident prevention; Ability to conduct incident investigations and identify underlying causes; Knowledge of health requirements, rules and regulations, and ability to monitor compliance; Knowledge of environmental requirements, rules and regulations, and ability to monitor compliance and identify ways of reducing environmental impact; HSE Letter of Assurance Revision 1 Revision: 1 April 09 Petroleum Development Oman LLC Be fully conversant with techniques used in the management of hazards and advising on suitable measures which can be used for preventing and ultimately recovering from accident situations; Be able to facilitate and develop Contract HSE Management Plans; Be fully conversant with PDO HSE documents and emergency procedures. Contractor(s) shall confirm in the Tender document C-09 HSE Requirements that they will provide HSE Advisers that satisfy the minimum competence requirements. Attendance at the following PDO courses or approved equivalent is mandatory for all HSE Advisers: Permit to Work – Signatories LXE015 Road Safety Management LXE042 Light Vehicle Daily Checks LXE960 Heavy Goods Vehicle Daily Checks LXE955 Incident Investigation and Reporting LXE032 Managing HSE Workshop LXE008 Refer to PDO document SP-1157, Specification for HSE Training, for information on these courses. An HSE Adviser holding higher qualifications not currently recognized by PDO, might be exempted from some of the above requirements subject to the exemption provisions of SP1157. Contractor’s HSE Advisers shall be qualified in accordance with either of the following requirements: Professional HSE Adviser Professional HSE Advisers shall have a minimum of five years work experience, of which at least two years shall have been as an HSE Adviser. Work experience must be related to the activities to be carried out under the terms of the contract. HSE Adviser shall, as an alternative, have a minimum of two years work experience and be a member of an independent internationally recognized Professional Institution per the list below: IOSH: Member of the Institute of Occupational Safety and Health. DIPSM: Diploma in Safety Management, or Member of International Institute of Safety Management. RSP: Registered Safety Professional. Other per Approved List held by PDO’s CFDH for HSE (CSM) HSE Adviser seconded from Line Management Line Managers who are seconded to HSE might be acceptable as HSE Advisers provided that the proposed individuals have a minimum of three years experience on Page 11 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 PDO contracts at site supervisory level. Work experience must be related to the activities to be carried out under the terms of the contract. Proposed individuals who do not satisfy the criteria of three years experience on PDO contracts at site supervisory level shall be subject to review and approval by PDO’s CFDH for HSE (CSM) to determine acceptability to PDO. 1.6 Performance Reporting and Execution 1.6.1 The “Health and Safety Statistics – Monthly Return” has been completed and submitted; as required. Refer to: PR 1171 Contract HSE Management Part II – mandatory for Contracts and Contract holders, Appendix 4 Contractor(s) shall: Using the template in Appendix 4, report monthly HSE information to the Contract Holder. 1.6.2 Management has reviewed the findings and follow up from HSE Audits performed in accordance to the contract specific schedule for HSE audit and inspections. Refer to: PR 1171 Contract HSE Management Part II – mandatory for Contracts and Contract holders, 2.69 & 2.6.10 Audit Contractor(s) shall provide a contract-specific matrix showing the schedule for HSE audit and inspections. Appendix 2 might be of assistance to Contractors as well as Contract Holders. Review Contractor(s) shall describe the process for management review of contract-specific HSE performance 1.7 Sub-Contractors 1.7.1 Key sub-contractors have been assessed using the “Sub-contractor 10 Point HSE Checklist”. Progress against agreed improvement actions is being tracked using the Sub-contractor Tracking Tool. Refer to: Page 12 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Sub-contractor 10 Point HSE Checklist and Sub-contractor tracking tool (attached). 1.7.2 The Consequence management framework includes provisions for penalising Subcontractor that do not comply with PDOs HSE Specifications. Refer to: C9 HSE Specifications, 1.0 HSE Management System and HSE Management Plan C9, 8.0 HSE Non Compliance Penalties Contractor shall ensure that any person, admitted to the Site by Contractor or Subcontractor shall comply with the relevant HSE Specifications herein. 1.8 Asset Integrity - Process Safety Management 1.8.1 Any asset under operational control meets the requirements of Asset Integrity necessary to commence or continue operations. Guidance to help ascertain compliance: Asset Integrity is the ability of the asset to perform its required function effectively and efficiently whilst safeguarding life and the environment. The contractor must be able to demonstrate that for all the assets he uses in relation to the contract, the risk of a consequence category 5 or high risk event, as defined on the PDO RAM matrix, is as low as reasonable practicable 1.9 Health 1.9.1 Provision of and accessibility to appropriate, well equipped medical clinics and medical emergency response has been established and is in conformance with requirements. Refer to: SP 1230 Medical examinations, treatment and facilities, 4. Clinics. Contractors Contractors with camps or bases within 10 kilometres of the permanent accommodation for contractors (PAC) shall use the existing PAC clinics, providing the existing PAC clinic have adequate staff and resources to cope with the additional workforce) i.e as long as there is at least 1 extra nurse in the clinic for every additional 500 people. Contractors shall provide transport for any personnel that require a visit to the clinic. Minimum requirements for Camp/Worksite clinics are detailed in Appendix O. The site clinic shall have: Page 13 Access to TIER 2 MER Professionals Easy ingress/egress with stretcher HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Easy access to ambulance services 24 hours exclusive availability Adequate space to hold up 2 beds or more depending on the size of the work force, waiting area and working space as well as storage cabinets Adequate ventilation, illumination and temperature control Hand washing facilities Proper medical waste disposal system Lockable filing cabinet. Material Safety Data Sheet (MSDS) archive and other medical reference materials. Communication with site manager and Remote Medical support direct from site clinic Refrigerator for certain drugs Accommodation for Tier 2 MER Professional immediately adjacent to the site clinic Toilet PDO, Contractors and subcontractors Clinics PDO, contractors and sub-contractors shall: maintain, update and store medical records of all employees collect, collate and report health surveillance data retain health surveillance records for a minimum of 30 years from the date of employment Medical records of all individuals, including specific details of all medical examinations, shall remain confidential. A clinic shall be provided by a contractor who has a camp or base in the Interior that: accommodates an average of 100 or more people per month (or part thereof, if the duration of the Contract is less than one month), and is more than 10 kilometres from the PAC. A clinic shall be provided by the contractor for an average of less than 100 people per month if: Page 14 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 the contractor's work is classed as posing a high risk on the basis of Health Risk assessment the contractor's camp or base is remote (a distance of 20 minutes or more by road) or more than 10 kilometres from the nearest clinic. Two or more contractors in adjacent camps shall be permitted to share a clinic providing the clinic has adequate staff and resources to cope with the additional workforce and subject to prior approval from their Contract Holders. 1.9.2 Medical examinations including Fitness to Work (FTW) are carried out in accordance with PDO medical examination standards, by ministry of health and PDO approved medical staff. Refer to: SP 1230 Medical examinations, treatment and facilities, 7. Medical Examinations General The contractor shall arrange and pay for pre-employment and routine medical examinations of all contractor staff to be engaged under a contract to perform work or services for PDO and staff seconded to PDO under a contract. No contractor staff shall be seconded to the Company until approved by PDO's Chief Medical Officer. All medical examinations shall be conducted either by a PDO Medical Officer or a PDOapproved Medical Practitioner (refer to Appendix L). All medical examinations shall be conducted in accordance with PDO and Shell group Medical Fitness Standards and in accordance with the requirements of Omani Labour Law. Certificate of Fitness All employers should ensure that a current valid certificate of fitness is maintained for each worker. It is the responsibility of the employer, and of the individual, to take all reasonable and practical steps to maintain valid certification. Following evacuation from a worksite for medical reasons, the individual must not return to the worksite unless certified as medically fit to return to work. 1.9.3 Catering contractors and sub-contractors are HACCP certified (or PDO recognised equivalent) in each food production operation. Refer to: SP 1232 Public Health, 2.3.6. Codex HACCP Food Safety Management System Page 15 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Codex HACCP Food Safety Management System Catering contractors and sub-contractors shall be HACCP certified, put in place, apply and maintain permanent procedures based on the Codex Hazard Analysis and Critical Control Points (HACCP) Food Safety Management System, in each food production operation. Each caterer shall provide a competent food hygiene officer with Advanced Food Hygiene and advanced HACCP certificates by an internationally recognised training organisation. The following principles of HACCP must be applied: 1. Identify the hazards 2. Identify the Critical Control Points (CCPs) at the steps at which control is essential to prevent or eliminate a hazard or reduce it to acceptable levels. 3. Establish critical limits at CCPs which separates acceptability from unacceptability. 4. Implement effective monitoring procedures at CCPs 5. Establish corrective actions when a CCP is out of control. 6. Establish verification procedures. 7. Establish documents and records commensurate with the nature and size of the operation. (Documents must be kept up to date and retained for an appropriate period) The system must be reviewed if the product, process or any step is modified. Good hygiene practices and pre requisite programs should be documented, carried out and monitored. 1.9.4 Camp facilities for permanent and mobile camps meet PDO’s minimum requirements. Refer to: SP 1232 Public Health, 2.2. Camp facilities. Camp Facilities In permanent camps a minimum total area of 4 square metres (m2) per person shall be provided, and a minimum separation distance of 2 metres between beds. A maximum of 4 persons shall occupy a room or cubicle at any one time. In mobile camps a minimum total area of 3 square metres (m2) per person shall be provided, and a minimum separation distance of 1 metre between beds. A full length cupboard (locker) shall be provided for each occupant. Beds with firm springs or suitable hard-board (without curvature) shall be provided and fitted with a suitable mattress of at least 6 cm thickness, a blanket, two sheets, two pillows and two pillow cases. Page 16 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Bed linen shall be washed at least once a week. Any evidence of bed bugs shall be reported immediately to the camp supervisor. Provisions should be made for adequate heating of accommodations during cold weather conditions. All sleeping accommodation shall be air-conditioned. Where sleeping accommodation is provided in temporary transportable units such as porta-cabins, heating shall be provided in accordance with SP-1277 and SP-1285(B) Porta-cabins shall also be installed/ secured in accordance with SP-1277 and SP-1285(B) Sufficient natural and artificial light (minimum 150 Lux intensity) shall be provided in all rooms. 1.10 Environment 1.10.1 Movement of the waste chemical are accompanied by both the approved Chemical Disposal Advice Form and a Waste Consignment Note. Refer to: SP 1009 Specification for Waste Management, 2.2 Deliverables Records: Records shall be maintained to document the implementation of this Specification. Records shall also be maintained to document waste management practices. (refer to CP 122 HSE Management System Manual, Part 2, Chapter 6, section 4). a) Waste Consignment Note A Waste Consignment Note shall be raised by the waste generator for hazardous and non-hazardous wastes (Figure 1). A Waste Consignment Note shall accompany a waste load and shall be signed when the waste has been received at the disposal location. A signed copy shall then be returned to the ‘Waste Originator’ as proof that the waste arrived safely at the correct place. The Waste Contractor will provide the Waste Originators with a monthly summary of waste received. b) Chemical Disposal Advice Form Discrete chemicals identified as ‘waste chemicals’ require a Chemical Disposal Advice Form (see Figure 2). The originator of the waste chemical is to fill in a Chemical Disposal Advice Form. Once approval of the Form has been obtained, the waste chemical can be moved from the waste originator to the designated disposal site. Movement of the waste chemical must be accompanied by both the approved Chemical Disposal Advice Form and a Waste Consignment Note. 1.10.2 Wastes are segregated at source and kept segregated until collected for disposal. Refer to: SP 1009 Specification for Waste Management, 2.6 Performance Standards N. B.Dependant on type of waste… sample domestic & office non-hazardous and hazardous wastes. Page 17 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Domestic and Office Waste Domestic waste which include kitchen refuse and tree/grass cuttings, and Office Waste shall be segregated at source for recyclable materials prior to transportation to a dedicated licensed waste facility for recycling. The remainder of the domestic and office waste shall be disposed of in PDO waste management facility or a dedicated MECA approved sanitary landfill site. Hazardous Wastes Ministerial Decision MD 18/93 ‘Regulations for the Management of Hazardous Waste’, defines hazardous waste as any liquid or solid waste, which because of its quantity, physical, chemical or infectious characteristics, can be hazardous or potentially hazardous to human health, to plants or animals and to air, soil or water. It includes explosive, radioactive, flammable, toxic and corrosive substances which may cause disease, as well as any substances identified as hazardous by the Ministerial Decision. General Requirements Ministerial Decision MD 18/93 requires: The waste generator to obtain a licence from the MECA and to apply best available technology relevant to production and operational procedures to minimise the generation of hazardous waste, including the application of any recycling procedures (Articles 2,3 and 7). That no hazardous waste be mixed with any other category of waste (Article 4). That no hazardous waste be discharged to a common or other internal or external sewerage of other drainage system without a licence from the MECA (Article 4). Every hazardous waste generator to complete a waste consignment note for each category of hazardous waste before it leaves the generator’s land or premises (Articles 5 and 13). Hazardous waste to be appropriately labelled and packed (Article 6; see also SP1194 for further details) That prior to removal, hazardous waste shall be stored in storage facilities licensed by the MECA (Article 8) Hazardous waste to be transported by transporters licensed by the MECA (Article 9). All hazardous waste pre-treatment sites shall be licensed by the MECA. All hazardous wastes received at a pre-treatment site shall be accompanied by a waste consignment note (Articles 2 and 5). All hazardous waste landfill sites shall be licensed by the MECA. All hazardous wastes received at the landfill site shall be accompanied by a waste consignment note (Articles 2 and 5). That no hazardous waste shall be imported or exported from the Sultanate of Oman without a permit from the Minister (Article 15). 1.10.3 Chemical storage is performed in accordance to PDO requirements. Refer to: SP 1994 Specification for Chemical Management, 4.0 Storage of Chemicals Page 18 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Storage Locations Bulk Chemicals Tanks containing chemical liquids shall be spaced and positioned such that they present no danger to personnel and surrounding installations. They shall be clearly identified, placed on an impermeable base, and surrounded by protective bunding that will contain any spillage and prevent leakage beyond the base, in accordance with PDO-ERD-09-02. Packed Chemicals All chemicals must have secure packages (drums, bags, sacks, etc.) to prevent spoilage as a result of outside contamination or spillages. Chemicals in permanent locations shall be stored on hard standing and provided with containment, such that accidental spillage will not result in pollution of the soil. Chemicals stored in temporary locations, such as drilling sites, are excluded from this requirement, but shall have some form of containment in case of spillage. Hazardous chemicals shall be protected from the elements (i.e. sun, rain, storm, etc.). Incompatible chemicals (see SHOC Card, Section 8 for details) shall not be stored together such that potential dangerous reactions could take place, even if the storage is temporary. Redundant chemicals and/or chemicals awaiting disposal shall be stored in separate storage areas. Such areas shall be clearly signposted, constructed and maintained in the same way as the normal storage areas, as indicated above. Storage Procedures All storage of chemicals shall be organised such that the "first in/first out" (FIFO) principle (i.e. older stock to be consumed first) is adhered to. This requires good housekeeping of the storage area and accessibility of the material to be taken first. Regular inspections of the chemicals being stored (packaging as well as product) must take place to ensure that: no leakage of the chemical will occur in the period until the next inspection and; the chemical is still fit for purpose over the period until the next inspection. If the chemical has been in storage for a long period of time and no off-take has taken place over the past year(s), further storage of the chemical should be questioned. The following steps shall then be taken: The Chemical Initiator, together with the Specialist Production Chemist (TKC/ TKL) shall establish whether the chemical could be used at another location in PDO. If yes, the chemical must be consumed at this alternative location to prevent deterioration. If it has a different use, then it shall be screened prior to being used at the new location. If not, proceed according to the Specifications for reuse, recycle and/or disposal as outlined in SP 1009 Waste Management. Segregation of Incompatible Chemicals Segregation of dangerous goods while in storage shall be in accordance with section 2.6.2 above. Page 19 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 Every dangerous substance or article while in storage must be accompanied by a SHOC Card. SHOC card must be clearly displayed for each chemical at its storage location.n 1.10.4 Sewage treatment and Reverse Osmosis plants are licensed and operate within their respective license limitations. Refer to: SP 1006 Specifications for Effluents and Accidental Releases to Land and Water Section, 2.5 Performance Standards Sewage Treatment Plants (STPs) A STP shall be used if the waste from more than 150 people is received, as required by MD 421/98. The management of sewage effluent for STPs is controlled by MD 159/2005 and MD 145/93. The water quality requirements for the discharges are detailed in Appendix A of this specification. Controls for the acceptable reuse of the resulting water and sludge are identified in Appendices B and C respectively. The following is a summary of the main requirements from MD 145/93. Please refer to MD 145/93 for further details at Permits are required to discharge either waste water or Sludge (Article 2) The waste water shall at all times be within the limits detailed in Appendix A (Article 5) The sludge must not exceed the limits set in Appendix B (Article 6) Sludge exceeding the requirements of Appendix B shall be disposed of in a sanitary landfill or to other facilities, but only with the prior approval of the Ministry (Article 7). Where toxic substances and/or biological inhibitors are present in the industrial waste stream, pre-treatment or isolation shall be carried out. Effluent Discharges – Others The disposal of other aqueous effluent discharges are dependant on the location and degree of the contamination. If the effluent is to be discharged to land then the quality of the water shall satisfy the water quality standards as identified in MD 145/93. Where the water is to be disposed of to the marine environment the effluent shall meet the water quality standards as per MD 159/2005. In the event that the water quality standards are not met then the effluent discharge should be segregated and undergo treatment so as not to impact on the receiving environment. This applies, but is not exclusive to the following effluent discharges: Reverse Osmosis Plants Maintenance Operations Hydrotest Water. 1.11 Other Issues 1.11.1 There are no other materially significant HSE issues related to the organisation’s activities that have not been addressed by these HSE assurance statements. Guidance to help assertain compliance:: Page 20 HSE Letter of Assurance Revision 1 Petroleum Development Oman LLC Revision: 1 April 09 ‘Materially significant’ means issues that put at risk the meeting of the HSE objectives or targets of the organisation covered by these assurance statements, or which could give rise to risk of reputation damage, and which should be drawn to the attention of the Contract Holder & Contract Owner. Page 21 HSE Letter of Assurance Revision 1