Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION TABLE OF CONTENTS [Alt + Right/Left = Page Forward/Back] PURPOSE ..................................................................................................................................................................... 2 SCOPE .......................................................................................................................................................................... 2 APPLICATION ............................................................................................................................................................ 2 DEFINITIONS ............................................................................................................................................................. 2 1.0 STRUCTURE .................................................................................................................................................... 3 1.1 1.2 1.3 1.4 1.5 2.0 3.0 3.1 3.2 3.3 3.4 3.5 4.0 5.0 6.0 7.0 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8 7.9 8.0 9.0 Policy .............................................................................................................................................4 Principles ........................................................................................................................................4 Practices .........................................................................................................................................4 Procedures and Plans......................................................................................................................4 Office, Engineering, and Field Execution ......................................................................................4 COMMUNICATION ......................................................................................................................................... 4 Continual Performance Improvement ................................................................................................................ 5 Commitment and Policy.................................................................................................................5 Planning .........................................................................................................................................5 Implementation ..............................................................................................................................5 Measurement and Evaluation .........................................................................................................6 Review and Improvement ..............................................................................................................6 EXECUTION..................................................................................................................................................... 6 PRACTICES ...................................................................................................................................................... 7 CONTROL......................................................................................................................................................... 7 ROLES AND RESPONSIBILITIES ................................................................................................................. 7 Chief Executive Officer of P2S .....................................................................................................8 P2S Executives ...............................................................................................................................8 HSE Board .....................................................................................................................................8 HSE Management Team ................................................................................................................9 Sales and Marketing Employees ....................................................................................................9 Office Managers and Project/Site Managers................................................................................10 P2S Employees ............................................................................................................................10 Procurement and Contracts Employees .......................................................................................11 Contractors ...................................................................................................................................11 REFERENCES ................................................................................................................................................ 12 ATTACHMENTS ............................................................................................................................................ 12 P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 1 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION PURPOSE This practice provides a detailed description of structure of the P2S corporate Health, Safety, and Environmental (HSE) Management System. The Management System provides the framework for how HSE aspects in P2S’s offices and on P2S-managed projects will be addressed, beginning with a philosophy and commitment detailed in the HSE Policy and Principles and cascading to corporate practices and project/site-specific procedures and plans. P2S’s corporate culture, supported by the HSE Management System, gives priority to HSE for its employees and its stakeholders, and is fundamental for achieving profitability. The management system provides an integrated tool for implementing the company’s commitment to continually improving HSE performance. SCOPE This practice includes the following major sections: Structure Communications Continual Performance Improvement Execution Practices Control Roles and Responsibilities APPLICATION This practice applies to all work activities and employees under the control of P2S and its contractors. DEFINITIONS ANSI Z-10 – American National Standards Institute standard for Occupational Health and Safety management systems. OHSAS 18002:2000 – Occupational health and safety management systems – Guidelines for the implementation of OHSAS 18001. ISO 14001:2004 – International Standards Organization standard designed to produce globally accepted systems for environmental management. Sustainable Development – Development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs (Brundtland Commission, 1987). ZERO ACCIDENTS Program – 12 high-impact injury reduction techniques that have consistently shown exceptional results when fully embraced, implemented, and audited by projects and offices. The 12 techniques are: - Contractor Management Pre-Project HSE HSE Education and Orientation New Employee Development HSE Awareness Program Substance Abuse Program Recognition and Rewards P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 2 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 1.0 Incident Reporting and Investigation Pre-Task Planning Management in Action Audit/Assessments Use of Networking and Resources STRUCTURE The structure of P2S’s HSE Management System incorporates several levels of control documents as shown in Figure 1. Figure 1 P2S HSEHSE Management System Management System The HSE Management System includes consideration of: Sustainable development Risk management Accountability to community Cross-discipline cooperation Best practices Requirements applicable to the scope of work (such as regulatory requirements, in-country standards, and contract requirements) P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 3 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 1.1 Policy The HSE Policy outlines P2S’s commitment and position on HSE management. The HSE Management System has been developed in response to this policy. 1.2 Principles The HSE Principles provide the fundamental precepts upon which the HSE Management System is based and executed. The Principles are contained in Attachment 02. 1.3 Practices Practices establish the performance requirements to be met by offices, engineering, and projects. HSE practices are available through KOL (Practice 000.653.0010, Health, Safety, and Environmental Management System – Table of Contents). 1.4 Procedures and Plans Procedures and plans are the implementation documents developed at the project level. Client procedures and plans may be substituted or tailored for a particular project if these meet or exceed P2S requirements and are required by the client. Where new or improved procedures have been developed, these should be forwarded to the P2S HSE Board to be considered for future inclusion in the corporate HSE Management System practices. A site-specific HSE “plan” is an overview of how the HSE program and procedures will be implemented. HSE plans are typically 50 pages or less. Modification of Practice 000.653.0020, Health, Safety, and Environmental Management System – Execution, is the preferred method to develop the site-specific HSE plan. However, the HSE section of the Project Execution Plan (PEP) can be considered the site-specific HSE plan. The site-specific HSE procedures supplement the PPM and describe in detail the HSE and security requirements to be implemented at the project site. Together, these 2 documents comprise the site HSE manual. 1.5 Office, Engineering, and Field Execution While it is recognized that there are different, but related, requirements and responsibilities for office, engineering, and field execution activities, the HSE Management System is designed to integrate these functions. 2.0 COMMUNICATION HSE management will communicate the HSE Management System to P2S employees and other stakeholders through training, KOL, printed documents, and other forms of communication. These communications will facilitate the effective use of the HSE Management System and promote a high level of awareness regarding HSE issues. P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 4 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 3.0 Continual Performance Improvement The HSE Management System is based on a continual improvement model, as contained in international standards such as ANSI Z 10:2005, OHSAS 18002:2000, and ISO 14001:2004. This model is shown in Figure 2. The basic elements in the model are described below. Figure 2 3.1 Continual Improvement Model for HSE Management Commitment and Policy This element establishes the P2S commitment to the process by providing a documented company HSE policy. The HSE policy is appropriate to the company’s business strategy and the P2S culture, and sets the direction of the HSE Management System. P2S is committed to providing a healthy and safe workplace for all people at each of its offices and projects, and to protecting the environment in accordance with applicable laws and our HSE Policy. P2S’s commitment is based on the principle that all accidents are preventable and risks will be controlled to a level that is “as low as reasonably practicable.” The unequivocal commitment to HSE by P2S management is a basic foundation of P2S Corporate values and culture and is reflected in the HSE Vision (refer to Attachment 03). 3.2 Planning This element provides strategic direction, objectives, goals, and execution strategies in order to plan how the policy should be implemented. 3.3 Implementation This element describes the use of the HSE Management System by P2S employees and contractors. P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 5 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 3.4 Measurement and Evaluation Measurement tools are used to confirm that the HSE Management System is being executed and implemented correctly. They also measure performance, monitor effectiveness, and evaluate changes to the system. Evaluation and feedback loops are an integral part of the HSE Management System. Measurement and evaluation tools include: 3.5 Audit – Auditing is the primary tool for measuring performance. The following audit protocols will be developed and executed: Systems audit – to measure implementation and effectiveness of the HSE Management System Compliance audit – to measure compliance with the HSE practices and projectspecific procedures Performance audit – to measure whether the expected performance level is being met Measurement Process – Performance measurement processes will be implemented to assess the overall effectiveness of the HSE Management System. These processes will include setting and measuring of strategies, objectives and goals, collation of statistics, recording of HSE initiatives, and skill base identification. Client Review – An evaluation process will be developed at the project or business line level to gain feedback from P2S clients. P2S Projects and Offices – Projects and offices will be given the opportunity to evaluate the effectiveness of the HSE Management System and to provide suggestions on continued improvements. HSE Alignment Process – HSE professionals involved in the alignment process before and during project startup have the opportunity to identify key areas of the project/site that require particular attention, and identify the need to adopt or create procedures that are tailored to the project/site. A feedback loop will be developed to capture such instances. Review and Improvement The HSE Management System will be reviewed at least annually to accommodate factors such as changing expectations, new objectives, new legislation, organizational changes, and results from continual improvement elements. 4.0 EXECUTION People at P2S workplaces are responsible, empowered, and accountable to work together as a team to execute HSE systems and processes. P2S will facilitate execution of the HSE Policy by: Adopting recognized standards, applicable codes of practice, and relevant statutory provisions as the foundation upon which P2S develops its own high standards P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 6 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION Incorporating recognized HSE standards into engineering and design processes, and into the work methods executed at P2S workplaces Embracing, implementing, and auditing conformance to the ZERO ACCIDENTSSM Program (refer to Practices 000.653.0020, .0100, and .1305). Providing effective training, efficient communication, and continual performance review inherent in the HSE Management System Establishing realistic and challenging tasks for employees and performance targets for P2S workplaces Setting company objectives and targets on an annual basis and assigning accountability for meeting these objectives and targets Preparing and implementing HSE documentation for every project/site in accordance with HSE Management System and client requirements Regularly auditing implementation of the HSE Management System in offices and on projects/sites, as well as project/site HSE plans and procedures developed to execute the HSE Management System Working with clients and contractors to continually improve HSE performance Developing communication and control networks Monitoring, measuring, and reporting of HSE performance Conducting training to help management, employees, contractors , and others to understand their responsibility with respect to HSE management, and to empower them to suggest improvements to their work processes Refer to Practice 000.653.0020, for a detailed discussion on executing the HSE Management System in offices, engineering disciplines, and on projects. 5.0 PRACTICES A complete list of HSE practices is provided in Practice 000.653.0010. P2S’s HSE practices reflect the activities, roles and responsibilities put into place to support the long term Vision for HSE within the company (refer to Attachment 03), the Objectives required in the shorter term (refer to Attachment 04), and the clear, measurable Goals that have been set to meet those Objectives (refer to Attachment 05). 6.0 CONTROL The P2S HSE Board has overall responsibility for drafting, reviewing, requesting/resolving comments, and issuing the P2S HSE Management System. The most current and official revision of the HSE Management System is the electronic copy, which is available to employees through the P2S KOL. 7.0 ROLES AND RESPONSIBILITIES This section describes the roles and responsibilities of employees with regard to the HSE Management System. P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 7 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 7.1 Chief Executive Officer of P2S The Chief Executive Officer is ultimately responsible for all HSE issues within P2S. This responsibility is communicated with the corporate commitment to maintain an appropriate HSE Management System and affect P2S HSE culture from the highest level. Roles Direct and endorse the HSE Policy, Principles, Vision, Objectives and Goals. Maintain P2S culture of high HSE standards. Endorse the HSE Management System. Review HSE performance. Issue the P2S HSE Annual Report. Responsibilities 7.2 Review HSE Policy. Foster a culture that encourages a high standard of HSE management. Direct that the HSE Management System be executed companywide. Commission reports as necessary to verify that the expected level of HSE performance is achieved. Review and approve the P2S HSE Annual Report. P2S Executives P2S executives have the responsibility to evaluate the HSE Management System and integrate into all areas of P2S’s business within their area of authority. Roles Direct, endorse, and execute the HSE Policy, Principles, Vision, Objectives, and Goals. Evaluate, promote, and execute the HSE Management System. Promote HSE culture. Responsibilities Promote employee feedback loops and provide management level feedback. Execute the HSE Management System in each business line. Allocate sufficient resources to allow implementation of the HSE Management System to meet the HSE Policy, Principles, and Objectives. 7.3 HSE Board The P2S HSE Board is the global leader of Corporate HSE. The Board provides leadership and support to P2S’s HSE professionals, projects/sites, and clients worldwide. P2S’s organization charts are maintained on the P2S P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 8 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION News Online Home Page, including the organization chart for the HSE Board. The HSE Board Charter is included as Attachment 06. Roles Represent P2S on HSE issues companywide. Represent Corporate HSE at executive management level. Direct the HSE Management System. Responsibilities 7.4 Report company HSE performance. Develop, approve, and communicate HSE initiatives. Review and comment on revisions to the HSE Management System. HSE Management Team The HSE Management Team acts under the leadership of the HSE Board. The team advises and assists offices and projects in the implementation and monitoring of the HSE Management System. Roles Provide high-quality HSE management services to P2S. Responsibilities Provide HSE advice and assistance. Maintain and continually improve the HSE Management System. Advise P2S employees and contractors of their HSE responsibilities. Provide audit protocols and audit staff. Conduct audits. Identify HSE training needs and provide appropriate training. Prepare and review HSE documentation, as required. Monitor the effectiveness of the HSE Management System. Report office and project HSE performance. Liaise with client representatives and regulatory bodies on HSE issues as required. 7.5 Sales and Marketing Employees Sales and Marketing employees have a role in communicating the HSE Management System to clients in order to show P2S excellence in HSE management. Roles Promote P2S’s HSE Management System. Liaise with the HSE Management Team on HSE issues. Responsibilities P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 9 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION Communicate information about the HSE Management System effectively to clients. Consult with Corporate HSE for information and assistance in preparation of applicable documentation, such as tender bids. 7.6 Office Managers and Project/Site Managers Managers are responsible for HSE management within their area of authority. Roles Ensure project team members are trained on the HSE Management System. Ensure implementation of the HSE Management System. Liaise with HSE professionals for advice and assistance. Manage HSE in project/site or office groups with assistance from dedicated HSE professionals. Responsibilities Oversee the production and implementation of an HSE Management Plan and projectspecific HSE procedures for each office or project/site using the HSE Management System as the “template.” Identify and manage HSE risk. Report and be accountable for HSE performance. Promote and support personal stop-work authority. 7.7 P2S Employees HSE demands individual participation at all levels of the P2S organization and on projects/sites. Employees are expected to engage in HSE activities in their workplace. Roles Comply with the requirements of the HSE Management System, or project-specific HSE procedures, as applicable. Contribute to a P2S culture of high HSE management principles. Responsibilities Maintain a high degree of professional competency, personal initiative, and communication effectiveness. Assist with HSE Management System execution and provide feedback where appropriate. Perform work in the safest manner practicable. Assist in identifying training needs and undertake training as required. Exercise personal stop-work authority when appropriate. P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 10 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 7.8 Procurement and Contracts Employees Roles Uphold the requirements of the P2S HSE Management System. Responsibilities Communicate HSE requirements to suppliers. Flow down requisite HSE requirements to suppliers in contractual documentation; refer to Practice 000.653.1003, Contractor Selection and Alignment. 7.9 Contractors Roles Uphold the requisite HSE requirements as flowed down in contract documents. Responsibilities Maintain high standards of HSE management. Communicate and cooperate with P2S on HSE issues. Refer to P2S HSE professionals where clarification of practices, procedures, or plans is required. Adopt P2S project-specific HSE procedures, or develop and submit their own system for review and comment. Perform work in the safest manner practicable. Assist in identifying training needs and undertake training as required. Exercise personal stop-work authority when appropriate. P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 11 of 12 Origination Date: October 7, 2011 Revision Date: Release Authorized by: Danny Trahan, Safety Director June 2012 Manual Rev 4 HEALTH SAFETY & ENVIRONMENTAL MANAGEMENT - DESCRIPTION 8.0 9.0 REFERENCES Document ID Document Title 000.653.0020 Health, Safety, and Environmental Management System – Execution 000.653.1003 Contractor Selection and Alignment 000.653.1305 Inspections/Assessments and Audits ATTACHMENTS Attachment No. Attachment Title Attachment 02 Health, Safety, and Environmental Principles Attachment 03 Health, Safety, and Environmental Vision Attachment 04 Health, Safety, and Environmental Objectives Attachment 05 Health, Safety, and Environmental Goals Attachment 06 Health, Safety, and Environmental Board Charter P2S Health, Safety & Environmental Copyright © 2012, P2S. All Rights Reserved. Page 12 of 12