Petroleum Development Oman LLC
Revision: 1
Sept 09
Petroleum Development Oman L.L.C
Guidance Notes for Completion of
Contractor HSE Letter of Assurance
Introduction
Contractors’ Chief Executive Officer (CEO) shall submit a HSE Letter of Assurance (LOA)
every year before 1 February to Petroleum Develolpment Oman (Company) in accordance
with the guidelines stated herein. The LOA is a confirmation from the CEO, with or without
qualifications, that the current implementation status and integrity of Contractor’s HSE
management system meets the Contract requirements. Each Contractor is required to
submit one LOA only to cover all contracts with Company that are operational on 1 January
of that year.
The statements shall be in bold type and where necessary are followed by explanatory
guidance in italics. Contractors’ 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, Contractors’ 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 HSE LOA (on attached template) and addressed to
the following :
To:
Naaman Al Naamani
MSEM, HSE&SD Manager, Petroleum Development Oman
P.O. Box 81, Post Code 100, Muscat, Sultanate of Oman
CC:
Saif Al Hinai
OND, Oil Director – North
CC:
Hamad Al Khalfeen
MSE/1, Head Safety
CC:
Contract Holder
Company reserves the right to verify/ audit statements. False statements may expose
Contractor to penalties as stipulated in the Contract.
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HSE Letter of Assurance
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TABLE OF CONTENTS
1.
Hazard and Effects Management Process
3
2.
Life Saving Rules
3
3.
Road Safety
3
4.
HSE Incident Management
4
5.
Staff
5
6.
Performance Reporting and Execution
6
7.
Sub-Contractors
6
8.
Asset Integrity - Process Safety Management
6
9.
Health
6
10.
Environment
7
11.
Other Issues
8
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Hazard and Effects Management Process
1.1
Heath, Safety & Environment (HSE) Hazards & Effects Management
Assessments have been performed and documented for each contract.
Refer to:
PR 1171 “Contractor HSE management Part II – mandatory for Contracts and
Contract Holders.”, 2.6.6 Hazards and Effects Management process.
1.2
Toolbox talk addresses the potential hazards to be encountered in the
execution of the activity’s scope of work and is being applied effectively.
Refer to:
PR 1172 Permit to Work Procedures, 6.10 Briefing the Work Party – the Toolbox
Talk
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
PR 1171 “Contractor HSE management Part II – mandatory for Contracts and
Contract Holders.”
2
Life Saving Rules
2.1
Contract Managers responsible for respective contracts have met with their
Contract Holders and agreed a plan for communicating the “Life-Saving rules”
to the workforce.
Refer to:
PDO’s 12 Life-Saving Rules documentation for contractors.
2.2
A robust ‘HSE Consequence Management System’ has been established and is
being effectively implemented and enforced.
Refer to:
PDO’s HSE Campaign - Consequence management.
3
Road Safety
3.1
Updated requirements in the latest revision of SP2000 Rev 3.0 have been
identified and an implementation plan has been prepared and issued to
Company.
Refer to:
SP 2000 Road Safety Standard, and C-9 HSE and; Fax transmission dated 20th
August 2009 “Notification of Alterations to Document C-9 HSE Specification”.
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3.2
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Confirm that the journey management processes are complied with, assured
and corrective actions taken, recorded.
Refer to:
SP 2000 Road Transport Specification, Appendxi 3
3.3
Confirm that the requirements of the commuting policy are being implemented,
that assurance is in place and remedial actions acted upon and recorded.
Refer to:
SP 2000 Road Transport Specification, and; Fax transmission dated 7th Jan, 2008
“Notification of Alterations to Document C-9 HSE Specification”.
3.4
All vehicles used in PDO contracts are certified by a RAS approved company
and undergo daily, weekly and monthly preventative maintenance checks to
ensure continued roadworthiness.
Refer to:
SP 2000 Road Transport Specification, Appendix II, 8 Roadworthiness Assurance
Standards (RAS) Inspection Scheme
3.5
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
3.6
Confirm that the requirements of the SP2001 Load Specification are complied
with, that assurance takes place and remedial actions acted upon and
recorded.
Refer to:
SP 2001 “Load Safety and Restraining
4
HSE Incident Management
4.1
All HSE incidents including near misses are reported appropriately ,
investigated and learning points 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:
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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.
4.2
Implementation of corrective actions resulting from the investigation of
Significant, High Risk and High potential incidents are reviewed by
management. No actions from such incidents remain outstanding for more
than 6 months after the date of the review.
Refer to:
PR 1418 Incident Notification, Analysis, Reporting and Follow-Up Procedure.
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Staff
5.1
All personnel have completed the required HSE training as per the agreed
training matrix in the contract.
Refer to:
C9 HSE Specifications, 3.0 HSE Training
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)
SP 1259 Safety Training Observation Programme (STOP)
5.3
Competence Assessment and Assurance programs are in place and
incorporated relevant HSE requirements.
Refer to:
PR 1171 Contractor HSE Management Part II – mandatory for Contracts and
Contract holders, 2.6 & 2.7.
5.4
HSE Critical positions in Contractor’s Organisation 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:
-
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Modification of the activity
Reallocation of the activity to someone who is competent
Closure of the gap through training
Provision of supervision and support.
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Performance Reporting and Execution
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
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, 2.6.9 & 2.6.10
7
Sub-Contractors
7.1
HSE pre-qualification assessment is applied to all sub-contractors, and as a
minimum includes the criteria in PDO’s 10 point HSE checklist. Progress
against improvement actions is being tracked at an agreed frequency.
Refer to:
Sub-contractor 10 Point HSE Checklist and Sub-contractor tracking tool (attached).
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 and 8.0 HSE Non-Compliance Penalties
8
Asset Integrity - Process Safety Management or
movable equipment
8.1
Any asset under operational control meets the requirements of Asset Integrity
necessary to commence or continue operations. All HSE critical equipments
(cranes, trucks, pressure vessels etc) are identified and maintained in
accordance to the requirements outlined in the preventative maintenance
schedule, and including the manufacturer’s requirements.
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.
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Health
9.1
Provision of and accessibility to appropriate, well equipped medical clinics has
been established and is in conformance with requirements.
Refer to:
SP 1230 Medical examinations, treatment and facilities, 4. Clinics
9.2
Medical emergency response has been established and meets with the
requirements of Minimum Health Management Standards.
Refer to:
SP 1230 Medical examinations, treatment and facilities, 4. Clinics
9.3
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
9.4
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
9.5
Camp facilities meet for permanent and mobile camps meet PDO’s minimum
requirements.
Refer to:
SP 1232 Public Health, 2.2. Camp facilities.
10 Environment
10.1 Movement of hazardous waste from site to disposal area has an auditable
chain of custody and the waste generator can provide the necessary evidence
that the waste was properly disposed.
Refer to:
SP 1009 Specification for Waste Management, 2.2 Deliverables
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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
10.3 Chemical storage is performed in accordance to Company’s requirements.
Refer to:
SP 1194 Specification for Chemical Management, 4.0 Storage of Chemicals
10.4 Sewage treatment and Reverse Osmosis plants are licensed and
within their respective license limitations.
operate
Refer to:
SP 1006 Specifications for Aqueous Effluents and Accidental Releases to Land and
Water Section, 2.5 Performance Standards
11 Other Issues
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::
‘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.
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