Rutotech
International Limited
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
January 2011
1
HEALTH SAFETY AND ENVIRONMENT POLICY (HSE)
SAFETY POLICY
RUTOTECH INTERNATIONAL LIMITED recognizes the importance of health and safety
issues and is fully committed to developing an HSE policy and management system.
We have implemented a full HSE policy to ensure that our operations are done in a safe
manner.
Identification and awareness of RUTOTECH’s HSE issues is the responsibility of all
employees and associated consultants. All personnel have an obligation to apply
operating practices and procedures, which will ensure the safety and health of
themselves and their colleagues.
Employees and consultants are advised to make themselves aware and adhere to the
HSE policies of a Client, when visiting or working within the client's premises.
OBJECTIVES
RUTOTECH INTERNATIONAL LIMITED has identified the following key objectives to
serve as the core in-house Safety Policy:
 To comply with regulatory guidelines and industry standards. For example,
RUTOTECH INTERNATIONAL LIMITED adhere to the following Acts of Parliament:
 Health and Safety at Work etc Act 1974
 Factories Act 1961
 Mines and Quarries Act 1954
 Offices, Shops and Railway Premises Act 1963
 To reduce levels of all lost time accidents
 To report all safety incidents and issues
 To continually develop and improve the Safety Management System
 To develop an awareness of HSE issues in employees and consultants
 To continually improve HSE standards
SAFETY MANAGEMENT SYSTEM
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Responsibility
Rutotech International Limited's Directors and Managers are responsible for
commitment to this Policy by ensuring that resources are provided for all employees
and associated consultants to adhere to the Safety Management System.
Awareness and Reporting
All employees and associated consultants are made aware of RUTOTECH’s Safety
policy during induction to the company.
All employees and associated consultants are made aware of the need to complete an
Accident/Near-Miss Incident Report Form following an incident at RUTOTECH’s or a
client's premises.
Company HSE targets are discussed at quarterly Company Performance Meetings with
all employees in attendance. RUTOTECH’s performance in relation to these targets is
monitored and discussed.
Targets
Targets for the reduction of lost time accidents and the reduction of incidents are set
annually within the annual budget review. Examples of HSE targets set:
 Have no lost time accidents
 Responsibility: All employees and associated consultants
 Reduce incidents
 Responsibility: All employees and associated consultants
Audits
RUTOTECH’s performance in relation to these targets is discussed at quarterly
Company Performance Meetings. The Managing Director, in conjunction with
RUTOTECH’s Consultant Services Manager, will report on the progress towards these
targets and discuss awareness if the targets are not being met.
Incentives
RUTOTECH INTERNATIONAL LIMITED distributes company bonus to all employees if
all company budget targets are met. This includes performance, quality, safety and
environmental targets.
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CONTRACT MANAGEMENT SAFETY ISSUES
On award of a major contract, RUTOTECH INTERNATIONAL LIMITED will adopt key
HSE performance standards thus aligning themselves with those of our client.
To date, examples of alignment with our customers (Operator, Lead Contractor and
Sub-Contractor) has been through the development of interface documents which
define responsibilities and provide a formal record (as detailed in the points above)
that all aspects of managing health and safety are suitably cross-referenced between
the various Management Systems involved.
Although we have been successful in the development and application of these
interfaces according to recognized methodology, we recognize that there is a need for a
Safety Management System (SMS) interface which uses the most successful and
innovative approach of the companies involved with the objective to apply best HS&E
practices throughout the project.
We believe it necessary to implement a process of comparing the individual companies
approach to such topics as Risk Assessment, COSHH procedures, Incident Investigation
(Causation Analysis techniques), auditing and inspection procedures, etc. From this
comparison the technique(s) judged to be the most successful could then be adapted
across all companies participating in the project SMS interface to develop a common
safety culture with shared purposes, objectives, resources (training, etc.) and an
improved sense of ownership and identity of the SMS Interface which would be
demonstrable at all levels.
Through application of such a policy it is not intended to undermine the individual
companies working practices, but to provide, through consensus, the widest
application of those procedures shown to be the most successful. By definition, SMS
allows for continuous improvement and the adaptation of procedures to individual
contract/customer requirements. As individual companies gain expertise within
safety management over the duration of the project (and in other contracts/with other
customers) the SMS interface can be amended through such feedback to reflect these
experiences.
Hazard and Risk Management
In conjunction with existing hazard register documenting generic hazards inherent in
the scope of work being tendered, RUTOTECH INTERNATIONAL LIMITED will review
the ability to firstly comply with existing management controls and secondly take steps
to possibly further reduce the risks. New risks identified, once assessed, shall either be
prevented (engineered out) or managed through a combination of mitigation and
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control such that the risk is acceptable. The identification of risks and hazards will not
only be limited to personal safety but will also extend to include risks to the
environment as a result of RUTOTECH’s activities.
The foundation of any HSE management is the identification of risks from the
frequency, severity and type of near misses and accidents. A risk identification and
elimination program will be used from which a risk profile is generated identifying
areas of the operation in which more training and resources are required. Risk
assessments and hazard registers shall be reviewed and updated at specific intervals
and as changes occur.
Projects and Operations
A clearly defined and auditable process shall be documented which defines
RUTOTECH’s management of their activities with regard to planning, engineering,
execution and evaluation in such a way that RUTOTECH INTERNATIONAL LIMITED
does not exceed acceptable levels of risk. Thus technical and safety integrity can be
demonstrated and maintained throughout. Significant changes to approved written
programmes shall be documented by a formal process with QA/QC documentation
controls demonstrating these and previous management activities.
The servicing of any equipment used in the provision of the services performed by
RUTOTECH INTERNATIONAL LIMITED (including lifting equipment, protective
devices) will be undertaken in accordance with schedules that maintain the technical
integrity of the equipment. Where equipment repairs or re-manufacture of equipment
is required, then these shall be done to specifications which preserve the original
integrity or equipment manufacturer specification respectively.
Competence, Selection and Training
Following a review of RUTOTECH INTERNATIONAL LIMITED key roles and
responsibilities, senior management will select a team in order to meet the
requirements of the positions identified. This will be performed by review of CV’s,
relevant industry experience and interview. Training, development and competence
assurance programmes currently exist within the front line field activities performed
by RUTOTECH INTERNATIONAL LIMITED. In the strive for continuous improvement,
any changes to job holders current roles and responsibilities will be further assessed
and, where necessary, changes made to the training, development and competence
assurance controls.
Job descriptions and detailed roles and responsibilities will be developed for all key /
critical positions. Performance in these positions will be regularly appraised against
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agreed Standards of Performance and the results used to plan further development
and continuing improvements in performance.
Communications
RUTOTECH INTERNATIONAL LIMITED will provide for an open and effective
consultation medium with representatives from the workforce, suppliers and clients
management. This communication will be both informal and through a hierarchy of
HSE functions, which will also provide for the sharing of significant HSE experiences
and lessons learnt by all concerned.
Examples of these methods are:
 Safety bulletin boards, HSE alerts etc.
 Presentations within RUTOTECH INTERNATIONAL LIMITED
 A mechanism for continuous improvement that will provide opportunities for
suggestions to be made, assessed and implemented where appropriate
 Circulation of safety publications and in-house magazines/newsletters
 The use of an electronic mail system
Occupational Health and Safety
It will be RUTOTECH’s policy to promote a work place, which protects the health of the
workforce, contractors and the surrounding community. The emphasis will be through
prevention, education, voluntary participation and personal responsibility. Through
improvement of industrial hygiene, ergonomics and safety, the aim is to reduce work
related health risks. We will also promote fitness and well-being as a proactive
initiative for all employees who will be required to have a medical examination.
Environmental Protection
Environmental management is an issue of great complexity involving the whole
spectrum of human activities. Recognizing that we all share in environment protection,
RUTOTECH INTERNATIONAL LIMITED has made a pledge to improve its technology
and train its people to minimize damage to the environment.
As such, it will be RUTOTECH’s policy to conduct its operations in a manner, which
assures optimum protection of the environment. In addition to careful compliance with
relevant laws and regulations, efficient use of natural resources and waste reduction
are keys to achieving this objective. The policy commits us to provide regular training
to all employees, improve our technology and enlist the co-operation of our suppliers,
customers and neighboring communities to build better environmental practices.
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The policy will be further managed through:
 Periodic environmental audits of all sites to ensure compliance with and
continuous improvement of operating standards.
 Environmental impact assessments of new products, processes and operations.
Product Stewardship
RUTOTECH INTERNATIONAL LIMITED undertakes assessments of both hazards and
risks associated with all products used in the provision of services within their
industry activities. The assessment includes consideration of the potential
consequences for the user and the environment arising from the accidental release of
the products during transportation, storage and disposal.
Purchasing and Contracting
RUTOTECH INTERNATIONAL LIMITED will assess the capability of the supplier to
satisfy our requirements prior to commitment. The assessment and selection of
suppliers, and sub contractors when required, shall be based on the capability of the
HSE risk potential to the activities to be performed. Any assessments, in the form of
questionnaires and / or audits will include HS & E policies and management systems
with the aim of assessing whether these important matters are handled effectively and
the capability of the supplier / sub-contractor to satisfy HS & E Management System
requirements. Where required, as in the case of HSE risk potential being critically high,
mechanisms for monitoring performance shall be designed and appropriate to the
concerns identified to ensure good and improving performance is maintained. Poor
HSE performance shall merit consideration of early termination of any agreements.
Interface documents for the HSE system interfaces shall also be provided for those
identified as critically high.
Incident Investigation
All accidents and incidents with a seriously high potential will be reported and
investigated. Resources will be dedicated to facilitate the establishment of their basic
cause(s), which is fundamental to the identification of remedial measures required to
prevent recurrence. The level of investigation shall be determined by RUTOTECH
INTERNATIONAL LIMITED based upon the severity, or potential severity, of the event.
Results of investigations and the development of accident trends will be
communicated.
Emergency Preparedness
RUTOTECH INTERNATIONAL LIMITED will consolidate existing emergency response
plans within the organization in order to benefit from any synergy gained. The plans
will be appropriate to the responsibility of RUTOTECH INTERNATIONAL LIMITED and
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applicable to the types of operations being performed. RUTOTECH INTERNATIONAL
LIMITED workforce will comply with any requirements of the company’s emergency
response systems and will encourage active involvement in any training exercises or
drills taking place.
Self Regulation and Audit
Compliance with any management system can only be verified through self regulation,
inspections and audits. A detailed audit plan will be prepared to cover both office and
field activities performed by RUTOTECH INTERNATIONAL LIMITED. Audits shall be
carried out by auditors independent of the function being audited. Continuous
improvement shall be achieved by formally reviewing audit findings, implementing
appropriate action plans and following up to ensure effectiveness of those
improvement plans.
Performance Standards
Based on the performance standards and objectives of our client, RUTOTECH
INTERNATIONAL LIMITED will develop an HSE performance standard aligning with
those of the clients, and appropriate to the level of influence and responsibility of
RUTOTECH INTERNATIONAL LIMITED and applicable to RUTOTECH INTERNATIONAL
LIMITED activities. Regular review and audits of these standards will indicate the
degree of success.
ENVIRONMENTAL POLICY
RUTOTECH INTERNATIONAL LIMITED recognizes the importance of protecting the
environment and is fully committed to developing an environmental policy and
management system. We have implemented an environmental policy to ensure that
the impact of our operations upon the environment is reduced to a minimum.
Identification and awareness of RUTOTECH’s environmental impact is the
responsibility of all employees and associated consultants. All personnel have an
obligation to apply operating practices and procedures, which will ensure the
protection of the environment, and the safety and health of themselves and their
colleagues.
Employees and consultants are advised to make themselves aware and adhere to the
environmental policies of a Client, when visiting or working within the client's
premises.
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OBJECTIVES
RUTOTECH INTERNATIONAL LIMITED has identified the following key objectives and
to serve as the core of the in-house Environmental Policy:
 To comply with regulatory guidelines and industry standards.
 To reduce levels of energy consumption.
 To reduce levels of waste produced and recycle or reuse wherever possible.
 To continually develop and improve the Environmental Management System.
 To develop an awareness of environmental issues in employees and
consultants.
 To continually improve environmental performance.
ENVIRONMENTAL MANAGEMENT SYSTEM
Responsibility
Rutotech International Limited's Directors and Managers are responsible for
commitment to this Policy by ensuring that resources are provided for all employees
and associated consultants to adhere to the Environmental Management System.
Awareness
All employees and associated consultants are made aware of RUTOTECH’s
Environmental policy during induction to the company. Company Environmental
targets are discussed at quarterly Company Performance Meetings with all employees
in attendance. RUTOTECH’s performance in relation to these targets is discussed.
Energy Consumption and Waste Reduction Targets
Targets for the reduction of energy consumption and the reduction of waste produced
are set annually within the annual budget review. Examples of Environmental targets
set:
 Recycle as much as possible and as a minimum all paper in the office
 Responsibility: All employees and associated consultants
Audits
RUTOTECH’s performance in relation to these targets is discussed at quarterly
Company Performance Meetings. The Managing Director, in conjunction with
RUTOTECH’s Office Manager's, will report on the progress towards these targets and
discuss awareness if the targets are not being met.
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RUTOTECH
ENVIRONMENTAL AND WASTE
MANAGEMENT MANUAL
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TABLE OF CONTENT
Section No.
Title
Page
1
The General Environment
3
2
Environmental Management Policy Statement
3
3.
The Industrial and Oil Industry Environment
4
4.
Safe Handling of Chemicals
5
5.
Rutotech Operations and Waste Mgt
8
6.
Management of Discharges to Water and
7.
Emissions to Air
12
Pollution Prevention and Spill Response
14
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1.
THE General Environment
1.1
What is the environment
Environment is man's life support system consisting of air, water, land and all
plants, human beings and animals living there-in and the inter-relationship
which exists among them. The environment is therefore the structure around
which our lives and those of future generations are built. The environment
permits all the things we require for life, too much or too less of which is
adverse to our existence.
1.2
Why is the environment important?
The environment is important in terms of its function, characteristics, working
principles and sensitivities.

Function
The environment is the support system for our life and that of future
generations.
The environment is the material base for all industrial activities.



Characteristics
The environment is continuous all over the world.
Impact on the environment is never localized.
The environment is resilient but dependent on time to re-establish itself.


Working principles
Everything is connected to everything in the environment.
Everything in the environment must go somewhere in the environment.

Sensitivity
Environmental sensitivity indicates how easily we can destroy the
characteristics of the environment, for example through pollution, or through
over-exploitation.
2.0
ENVIRONMENTAL MANAGEMENT POLICY STATEMENT
All operations of RUTOTECH shall be planned and executed in such a way as to
minimize any adverse effects or impact on the environment in which we work.
RUTOTECH shall promote and encourage plans, activities, and programmes
aimed at environmental preservation and protection.
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Staffs are encouraged to pay appropriate regard to the environment by
protecting it from adverse effect.
All wastes generated in course of our operations must be collected, handled,
treated and disposed of in an environmentally sound manner
Discharges of pollutants into air, or in water bodies are strictly prohibited.
All such disregard to environmental laws must be reported immediately.
This policy and manual aligns with the International Standard ISO-14001
specification for an Environmental Management System (EMS) covering
relevant environmental requirements, procedures, specifications, objectives
and targets that will be communicated to contractors. “The Environment is our
common Home” be a part to protect it.
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3.0







3.1




THE INDUSTRIAL AND OIL INDUSTRY ENVIRONMENT
The key characteristics and sensitivities of the Oil Industry environment are:
The main vegetation consists of mangroves, unique plants that are capable of
surviving in brackish water. Mangroves are robust, but not resilient. They can
tolerate a wide range of adverse conditions from our operations but, once they
are destroyed, they hardly recover.
It is a brackish riverine environment. The water is either neutral or very slightly
acidic and extremely hard in both dry and wet seasons. This also gives a wide
tolerance threshold which nevertheless can be abused with prolonged
discharges.
It is experiences high rainfall. This ensures adequate water for flushing and
dispersal.
It is a hot environment. The temperature especially during the dry season can
be very intense.
There are few people resident in these areas.
It has wide bio-diversity. This implies there is a wide range species of plants
and Animals most of which have not yet been fully understood.
It has a rich fish/marine life and has a limited oil and gas reserves, which can
only be produced for a finite time; not forever.
HOW IS THE ENVIROMENT AFFECTED BY RUTOTECH OPERATIONS
Our operations can either direct or indirect, impact on the environment.
The operation of equipment in our facility affects the environment. For
example, poor operation of the supply vessel can lead to too high levels of oil-inwater, or even to spills.
The maintenance of equipment in our facility affects the environment. For
example, a poorly maintained diesel engine will produce black smoke.
Our waste handling effects the environment. For example, we should not
dispose of used lube oil by letting it flow into the drain system or directly into
the sea. Instead, we should collect it for disposal in the used oil compartment of
the supply vessel.
Our environmental awareness affects the environment. This is reflected in
our own behaviour and in the attention we pay to the environmental
performance of others. For example, we should explain to contractors and other
visitors to the location what we expect of them in terms of environmental
protection.
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3.2




RUTOTECH’s responsibility in minimizing impacts on the environment
The responsibility for minimizing impact on the environment lies with
everyone in the Company employ. Although there may be aspects beyond your
control and authority level, you can all contribute to a better environment.
Some examples of what can be done include:
Read the Company and Clients’ HSE Policies, and ask your team leader or cocoordinator to explain what is not clear.
Know your operational controls.
Handle waste from your activities properly and in line with the procedures. It is
your responsibility to clean up any waste or pollution, even if it has not resulted
from your own activity.
We are to be observant and report anything that may constitute an
environmental risk to our team-leader/Supervisors. Ask questions or even stop
others who are performing environmentally unsound activities. The training on
General Environment that will be executed by RUTOTECH is meant to expose
the links between the environment and our jobs. By appreciating these links, we
will be motivated to initiate actions that will prevent, control and mitigate
environmental risks associated with our jobs. Beyond this, it should leave us in
a better position to instruct others.
4.0
SAFE HANDLING OF CHEMICALS
4.1
Introduction
Exploration & Production operations involve the use of chemicals of different
make and composition. Within the Company and Clients’ operations, policies,
guidelines and procedures are available to guarantee Health, Safety and
Environment as we work with chemicals. All these are embedded in the concept
of Safe Handling of Chemicals (SHOC).
In participating in the SHOC training, your learning objectives should include:
Understand the nature of chemicals used in Oil Industry.
Use chemicals with the desired benefits.
Ensure human safety before and after use of chemicals.
Prevent avoidable impacts on the environment.
Enhance reference and use of SHOC manual.
Understand and apply basic first aid in an emergency.
Improve chemical storage and retrieval system.
Comply with regulatory requirements.
1.
2.
3.
4.
5.
6.
7.
8.
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4.2
1.
2.
3.
4.
5.
6.
The Concept “Chemical”
Chemicals are synthesized or naturally occurring substances (solid, liquid or
gaseous) with unique properties. Within Company and Clients’ operations,
chemicals are simply industrial products used to facilitate specific processes in
its entire spectrum of operation. Important chemicals used Oil Industry
facilities include demulsifier, diesel, lube oil and cleaning agents.
A chemical is said to be hazardous if it has a real or potential ability to cause
health problems to man and animals and negatively affect the environment. Six
properties are associated with hazardous chemicals. It only requires a chemical
to possess one or more of these properties to be hazardous. These properties are:
Toxicity.
Irritation.
Asphyxiation.
Corrosiveness.
Flammability.
Explosiveness.
Our concern with chemical hazards is in the area of Safety, Health and the
Environment.
1.
Safety related chemical hazards present themselves through fire, explosion and
toxic fumes. The precautions to adopt here are to avoid open flames, sparks
and smoking near explosive chemicals and chemicals with great affinity for fire.
Fire extinguishers should be available, accessible and usable by all staff.
2.
Health related chemical hazards present themselves through inhalation, skin
contact, eye contact and in rare cases, ingestion. Precautions should include
use of appropriate PPE and availability of a competent first aider.
3.
Environmental related chemical hazards present themselves in the form of
toxicity, non-biodegradability and bio-accumulation. Precautions should
include avoiding contamination of soil and water and the use of
environmentally friendly chemicals.
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4.3
Basic First Aid Administration
Health
Hazard
Rating.
Corrosive
/Highly
Toxic
4.4
Inhalation
Skin
Eyes
Ingestion
Do not delay.
Remove victim
to fresh air.
Obtain
medical
attention
promptly.
Do not delay.
Wash with
water while
removing
clothing.
Obtain
medical
attention
promptly.
Do not delay.
Flush with water.
Obtain medical
attention
promptly.
Do not delay.
Obtain medical
attention
promptly. Do
not induce
vomiting.
Severe
Irritant/
Toxic.
Remove to
fresh air.
Wash with
water. Use
soap.
Do not induce
vomiting.
Slight or
no effect.
No specific
measure.
No specific
measure.
Flush with water.
Obtain medical
attention if eye
irritation persists.
No specific
measure.
No specific
measure.
SHOC process, tools and techniques
The SHOC process encompassed in the following four aspects:
1.
Procurement: Procurement is the action that brings a chemical into use in
Company operations. To procure a chemical, besides every other thing, the
following must be considered: - Environmental impact, Performance and Cost.
2.
Handling: After procurement comes usage. In using chemicals, factors to
consider that should guarantee safety to workers and protection for the
environment are The flash point of the chemical (this will advice where and
when to use such chemicals), proper and legible labelling for easy identification,
Personal Protective Equipment, storage and storage conditions, chemical
transportation and transfer process.
3.
Hazards: At any point in time, the real or potential health, safety and
environmental hazard of a chemical being used must be at the front of our mind.
This will ensure that we use adequate and appropriate PPE and prevent
avoidable contact with the environment.
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4.
Disposal: At the end of the day, we will be left with chemical waste after usage
and may be even from storage. We need to safely manage these wastes. Within
Company and client’s operations, the following chemical wastes management
measures are recommended: treatment, landfill, dilution and flushing,
stabilisation / encapsulation, containment and storage (where no disposal
method is available).
4.5
1.
2.
Chemical storage precautions
Keep dry.
Protect from light.
3.
4.
5.
6.
Fire proof (especially for combustible substances with flash point below 55oC)
Adequate ventilation.
Separate from incompatible chemicals.
For large volumes of liquid chemicals, a concrete floor should be designed for
accidental discharges to run off to a saver pit.
4.6
The SHOC manual and SHOC cards
The SHOC manual gives information on the properties and handling procedures
for all chemicals in Company and Clients’ operations. The SHOC manual consists
of numerous SHOC cards. A SHOC card lists the threats and hazards inherent in
the properties of a particular chemical and the precautions we must take in
using this chemical. The SHOC card is laminated and made available in SHOC
racks in all operational facilities.
Every chemical must have a SHOC card. It is your duty to refer to the SHOC card
when you are not sure before using any chemical. It is also your right to insist
on the SHOC card for a chemical from your supervisors if you must handle such
chemical. Beyond this, it your responsibility to inform your supervisor or
Environmental department of any chemical you know is in use but for which no
SHOC card has been prepared.
Being a field worker brings you in contact with chemicals one way or the other.
Working safely with these chemicals is an important factor being a good
worker. Every worker has a duty to himself to stay alive and healthy while on
the job and to preserve the integrity of the environment. Safe Handling of
Chemicals (SHOC) is an essential part of your daily work.
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5.0
RUTOTECH OPERATIONS AND WASTE MANAGEMENT
5.1
Introduction
Waste as a concept admits of several meaning depending on the context from
which we are looking at it.
Waste is defined as any unavoidable material resulting from an industrial
operation for which there is no economic demand and which must be disposed
of.
It is also described as an unwanted material that must be managed as a finished
product.
Waste is any material that is surplus to requirement and can no longer be used
as feed stock for a similar requirement.
Simply put, waste management is the conscious and deliberate effort at putting
away our wastes without re-contaminating the environment. Below, we will
treat the following aspect of waste management:
Segregation
Transport
Inventory and tracking






5.2
Waste management policies
The Company waste management policies include a policy statement that “we
will reduce solid waste streams (particularly hazardous wastes) progressively
to a practical minimum and that “we will manage and dispose of wastes in a
controlled and environmentally acceptable manner”. This implies that we will
take all practical and cost effective measures to minimize the generation of
waste by employing the four Rs (Reduce, Re-use, Re-cycle, and Recover) through
process optimization or redesign, efficient procedures and good housekeeping.
5.3
Waste Streams
5.3.1 Classification
The classification of waste streams from the Northern Swamp Area compressor
stations and flow stations is based on the physical nature of wastes - i.e. whether
gaseous, liquid or solid - and also on source of generation.
1.
Gaseous waste
 Flare
 Combustion engines
 Vents
 Fugitive emissions
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2.
Liquid waste
 Vessel and process relief drains
 Process liquid leakages.
 Storm/Surface water drainage.
 Spent lubricating oils.
 Spilt and leaked liquid fuels and chemical additives.
 Chemical additive residues.
 Oily sludge.
 Domestic sewage.
 Paints and related chemical residues.
3.
Solid waste
 Empty drums
 Domestic wastes
 Pigging wastes
 Medical wastes
 Contaminated soil
 Batteries.
1.
2.
3.
Another way to classify waste is to distinguish between:
Domestic waste (including office and house hold waste).
Hazardous waste.
Industrial waste (i.e. waste generated during industrial activity which is neither
domestic nor hazardous).
5.3.2 Hazardous Waste
Hazardous waste is defined as any liquid, solid or gaseous waste which because
of its quantity, physical, chemical or infectious characteristics, can result in
hazards to human health or the environment when improperly treated, stored,
transported or disposed of. A material can therefore be said to be hazardous if it
is reactive, corrosive, ignitable and/or toxic. Hazardous waste at Oil
Industry includes:
 Batteries
 Contaminated soil
 Spent lube oil
 Oil filters
 Oily debris
 Paint
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Special requirements for the management of hazardous waste are specified in
the DPR Environmental Guidelines and Standards (EGS). They include that the
waste producer keeps a register of detailed material data.
5.4
Waste Segregation
Wastes generated should be segregated at site using the coloured bins. All staff
must be able to segregate any waste generated at the facility. Staffs are required
to be conversant with the different colours used for the bins/containers for
effective segregation of waste. It is the responsibility of the Team
Leaders/Supervisors to ensure that all wastes generated are disposed in the
right bins. The team Leaders/Supervisors should carry out routine checks to
ensure that segregation is carried out at source. Segregation should be a key
performance indicator in staff appraisal. Below is the approved colour scheme
for all classes of waste generated in Company operations, which is also
applicable to Client’s operations.
5.5
Improvement Programme
5.5.1 Waste transportation
Segregated waste is collected from Company and Clients’ facilities in the Work
Area on a routine basis. Waste is then taken to the approved transfer station
and from there, taken to respective sites for ultimate disposal. HSE Supervisors
routinely audits the waste collection process and final disposal to manage Oil
Industry waste from cradle to grave.
5.5.2 Oily sludge storage facility
Oily waste such as debris from vessel cleaning and polluted surfaces has been
dumped indiscriminately previously. This is not an environmentally acceptable
solution, because the oil will most likely be washed out by rain and
subsequently flushed into the ground or rivers where it may pollute the
groundwater river water. In addition, this practice does not meet the strict
requirements of the DPR for the disposal of oil-polluted soil. Oily waste is now
being stored for final disposal at Clients’ approved Thermal Desorption Unit
(TDU) facility.
21
SEGREGATION OF WASTES AT SOURCE
Black bin
General wastes,e.g packaging
materials, rags etc
Green bin
Food/Garden wastes
Blue bin
Burnt electric bulbs & Glass waste
Black plastic
bags/Grey bin
Paper waste: to be shredded
White bin
IT consumables, e.g toners
cartridges/computer tapes
Red bin
Dangerous wastes, e.g paints,
asbestos, aerosol cans, etc
Brown bin
Waste plastic containers
Figure 5.4: Colour scheme for waste segregation
5.6
Waste inventory
It is the responsibility of the Team Leaders/Supervisors to inventorise the
segregated waste generated and report it on his monthly report to the Base
operations Managers. The quantities of waste generated, disposed of, and the
balance left at site shall be reported. It is the responsibility of the Base operations
Managers to plan with the Clients by entering the data on the Report Form and
submit same for necessary action.
The reason for the monthly waste reporting is to keep track of the amount waste
generated, to enable target setting, and to monitor our performance against
targets.
22
5.7
Waste Consignment Notes (WCN)
To ensure that waste collected from Company’s operations is disposed of at
designated waste management facilities and in the same condition and quantity,
all waste shall be accompanied by a Waste Consignment Note (WCN). The WCN
is a form that contains the description and quantity of waste and the disposal
facility. The form comes in four sheets – a white master sheet, and blue, pink and
yellow copy sheets.


A WCN note shall be completed, signed and kept for each waste shipment.
WCNs shall be used by everyone who produces, handles, transfers and receives
waste in all Company and Clients’ facilities.
They assist in monitoring waste from "cradle to grave".
They also provide evidence of responsible waste management - i.e. "duty of care"
The WCN is the enabling document for transfer of waste, to waste disposal
facilities. The procedure for using this document is stated below.
Dispatcher fills WCN in quadruplicate.
Dispatcher retains the yellow coloured sheet of the WCN
Dispatcher sends the pink coloured sheet to Company’s responsible HSE Officer.
Dispatcher sends blue and white sheets of the WCN together with the waste
shipment.
Receiver at disposal facility fills both white and blue copies, retains white and
sends blue copy back to dispatcher through the driver.


1.
2.
3.
4.
5.
5.8
The Waste Tracking System (WTS)
The WTS is a computerized system that combines the functions of keeping a
waste inventory and the WCN system.
RUTOTECH improvement initiative is ongoing to segregate waste and to put a
regular waste collection service in place. The amount of waste shipped from any
given site shall be recorded, and the total volumes reported accordingly at the
end of each month. A Waste Consignment Note shall accompany every waste
shipment.
23
6.0
MANAGEMENT OF DISCHARGEs to Water and Emissions to Air
6.1
Discharges to water
6.1.1 Environmental effects
Discharges to water are liquid effluents we discharge to the environment during
our normal or abnormal operations. The major sources of discharges to water
in Area of Operations are:
 Discharges from Support Vessels.
 Sewage from the houseboats/living quarters
 Domestic wastewater (laundry / kitchen)
In addition we may have incidental discharges such as oil or chemical spills.
Discharges to water may cause reduced growth or even the death of flora and
fauna, reduced fish catch and polluted drinking water for any given neighboring
communities.
6.1.2 Legal requirements
The relevant environmental legislation on management of discharges to water
is mainly the Department of Petroleum Resources (DPR) Environmental
Guidelines and Standards (EGS). The discharge limits for discharges to tidal
brackish environments are:
Table 6.1: DPR limits for discharges to Water
Pollutant
Units
Discharge limit
pH
Temperature
C
6.5 – 8.5
40
Oil and grease
Salinity as Cl-
Mg/l
Mg/l
20
2000
Turbidity
NTU
15
Total Dissolved Solids (TDS)
Total Suspended Solids (TSS)
Mg/l
Mg/l
5000
50
In addition, the DPR EGS require the installation of a biological waste water
plant to treat sewage from any given production installations, which also
applies to our vessels/houseboats. In case there is any chemical aftertreatment, the residual chlorine in the discharges shall be between 0.8 and 2.0
mg/l. In other words, there shall be enough chlorine to ensure that bacteria in
the sewage are killed, but not too much chlorine, to ensure that the receiving
environment is not damaged.
24
6.1.3 Operational control of Waste Discharge Tanks on Board Vessels
The Waste Discharge Tank is the facility that is designed to discharge,
contaminated water/oil to the environment on board a supply vessel.
 During servicing of boat engines and rotating equipment the spent lube oil
should not be drained via the open drain system but collected in receptacles
and discharged into the Waste Discharge Tank.
 Used lube oil filters should be placed upside down on a drain pan to allow the
remaining oil to drain. The oil shall then be collected and discharged in the
Waste Discharge Tank.
 Technicians must always check for leaks at the inlet manifold, vessels, piping
etc and report findings immediately to the Crew Leader.
 Technicians must operate the facility in accordance with the given Plant
Operating Manual and Integrated Operations Standards.
6.2
Emissions to air
6.2.1 Environmental effects
Emissions to air involve the release of gasses to the environment during normal
operations, abnormal operations, or incidents. Major emission sources in our
Operational Area are:
 Combustion in gas engines driving compressors and generators
 Combustion in Diesel (emergency) engines
 Venting from relief valves
 Venting of instrument gas
 Venting of gas from gas-lift lines damaged by corrosion or sabotage or theft.
The environmental impacts of our emissions are:
 Air pollution and associated potential health problems resulting from emissions
of NOx, SOx, CO, volatile hydrocarbons, and particles (soot).
 Global warming because of the increased level of greenhouse gasses in the
atmosphere. Hydrocarbon gasses such as methane, released during venting, are
powerful greenhouse gasses.
 Acid rain because of the dissolving of emission components in water.
A related significant environmental effect of gas flaring is the waste of natural
resources.
25
6.2.2 Legal requirements
FEPA has recommended guidelines for ambient air quality in Nigeria. DPR, the
governing organisation for the oil industry, does not set emission limits, except
for the requirement of a smokeless flare. The smokiness of the flare can be
expressed on a scale from 0 to 5 as the Ringelmann number, and the DPR EGS
require a Ringelmann number not exceeding 2. In addition they stipulate limits
for heat and noise of the flare, and they give requirements for monitoring of
emissions.
6.2.3 Operational control
The most important operational control of the emissions is to avoid
misconfigurations and operational failures of equipment.
6.2.4 Improvement programme
Emissions to air from support vessel engine form one of the most significant
environmental effects of our operation, and therefore it plays a major role in
our environmental improvement programme.
The components of the Facilities Upgrade aiming at the reductions of emissions
to air are:
 Facilities to capture all relief valve emissions.
 The replacement of instrument gas by instrument air, to reduce venting.
 The installation of continuous metering to quantify volumes of gas released
more accurately than we can do at present.
26
7.0
POLLUTION PREVENTION AND SPILL RESPONSE
7.1
Introduction
In the E&P industry, oil spills, discharges to water, emissions to air and
chemical waste are the main sources of pollution. Although it may not be
possible to eliminate all pollution from the business, our Environmental
Management Systems shall focus on preventing pollution from incidents and
minimising pollution from continuous discharges and emissions. In addition, we
need to have emergency plans and procedures in place to minimise the
pollution from incidents, might they occur.
7.2
Pollution
7.2.1 Causes of Pollution
Pollution may be as a result of:
 Equipment failure.
 Human factors.
 Sabotage.
 Natural factors.
Pollution is also caused by the little things we do unobserved like the careless
dumping of refuse, channeling of waste oil into public drains (that eventually
empty into rivers), bush burning, wrong handling of chemicals, etc.
7.2.2 Consequences/Implications of pollution
 Environmental degradation.
 Economic implications.
- Reduced crop yield.
- Re-localization / reduction / extinction of game in our forests and aquatic life.
- reduced agricultural output (income) for the affected communities.
- Costs of pollution control to government and industries.
 Social implications.
- Health implications.
- Psychological implications.
7.2.3 Pollution prevention
Every activity and action taken to prevent the occurrence of pollution incident
is what is known as pollution prevention. In RUTOTECH operations, such
actions include:
27
 Use of well-trained personnel.
 Use of equipment and materials that are fit for purpose.
 Regular inspection and preventive maintenance of equipment and materials to
detect or prevent defects.
 Replacement of equipment and materials at the expiration of their service.
 Inspection of plants, equipment, etc regularly.
 Awareness training.
7.2.4 Improvement programme
Specific improvement objectives in RUTOTECH operations Programme related
to spill prevention and response are:
 To implement an improved preventive maintenance programme system.
 To construct appropriate secondary containment for oil and chemical storage at
our facilities and Supply Vessels.
7.3
Oil spills
7.3.1 Oil spill response levels
Oil spills are classified according to volume so that a clear indication of
response competence level required for each tier is mapped out.
7.3.2 Oil spill response
Despite the various preventive measures, pollution still occurs one way or the
other. Controls to prevent the extent of the impact involve:
 Oil / Chemical Spill Contingency Plan activation.
 Containment.
 Recovery.
 Clean-up and disposal of residual oil / debris from the environment.
 Remediation / Rehabilitation.
How to Respond to Emergencies:
Corporate emergency response procedures are documented in the RUTOTECH
HSE Contingency Plans and Procedures.
Containment is the phase that has to do with limiting and confining the spread
of a spill. The equipment used here is the boom. Booms are floating devices
used to block oil from spreading in the event of a spill.
28




Recovery is the act of collecting as much of the (contained) oil as possible.
Equipment for this includes:
Skimmer boats to collect oil in large creeks.
Portable skimmers, to collect oil in smaller creeks.
Pumps to transfer/pump the collected oil to storage tanks.
Tanks and barges for storing recovered oil.
Clean-up and disposal of oily debris is a legal obligation. Although the work is
normally performed by expert’s input. The oily debris should not be disposed of
in the sea, as was often done in the past, but should be collected for responsible
disposal.
Remediation / Rehabilitation of the impacted area are also a legal obligation.
29
RUTOTECH
JOURNEY MANAGEMENT
POLICY AND PLAN
30
INTRODUCTION
Application and Scope
This Operating Manual details the method by which individual journeys shall be
managed so as to reduce the risks associated with road transport. It also provides
criteria for deciding which journeys require management.
1.1.1.1 Basic Principles of Journey Management
Journey management is carried out to ensure that journeys are authorized and
that any risk to health, safety or the environment is identified, assessed and
controlled.
The responsibility for journey management shall be with the supervisor operating the
journey. The supervisor managing the journey is called the journey Manager
It is not possible to specifically address every possible type of transport because of the
variety of transport operations. In the event of any uncertainly over how to or who
manages the journey, the relevant supervisors shall decide who best can control the
journey, concentrating on the basic principle in paragraph 2 above.
RUTOTECH shall always be responsible for making sure that subcontractors comply
with this Operating Manual. RUTOTECH shall take care to brief the management and
supervisor of these subcontractors companies as necessary.
DEFINITIONS
The word Journey shall mean any journey carried out in the pursuit of
RUTOTECH business whether by her or its subcontractors which is required by
RUTOTECH to be managed in accordance with this manual.
Journey Management: shall mean the actions taken by a person to authorize, plan,
monitor, and close-out a journey so that any risk to health, safety or the environment is
identified, assessed and controlled, and so that recovery measures are made available
should the journey not be completed as planned for any reason.
Journey Plan: shall mean the document which details the timings and route of the
journey, including rest stops, the vehicle and the driver and passengers.
Home Base: shall mean the operating base where the driver and vehicle are normally
based, and from where the outward journey starts.
The Authorising Person is a manager or department head that guarantees the
integrity of the journey management system of the company or department.
31
The Journey Manager is the person who plans, monitors, and closes out the journey.
The Journey Manager also initiates any relevant accident or man-lost procedures in the
event of an accident or a vehicle becoming overdue
RUTOTECH
JOURNEY MANAGEMENT POLICY
It is the objective and intention of RUTOTECH to manage all her journeys in such
a manner that all accidents are reduced to the bearest minimum. This is in view
of the fact that operations during job execution might involve movement of
personnel, equipment and materials from one place to another. In most cases,
vehicle involve in transportation could cause accidents that may result death
and material loss worth millions of naira. For this course therefore, all journey
shall be manage as follows:
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.
x.
A journey logbook shall be kept by drivers, departure point destination point
and aim of movement shall be indicated and duty signed by an authorized
signatory.
Vehicle moving from one place to another shall be reduced at a time in other to
avoid irrelevant movements.
Any vehicle leaving work premised must be entered into movement register.
Approval must be granted for any vehicle bid for assignment.
Heavy-duty vehicles shall not be allowed to be driven at night.
Drive-Right monitoring system (IVMS) shall be installed in all vehicles for speed
management.
Radio shall be installed for easy of communication during errands.
All movement shall be arranged in such a way that all persons going to the same
route will board one vehicle.
All drivers must be DDC certified and their efficiency guaranteed.
Drivers must ensure that arbitrary stop on the way for lifts are avoided.
Management priority and goals are to ensure that all journeys undertaken are
free of vehicle thefts, accidents and personnel abscond from duty.
Signed……………………………
Managing Director
32
JOURNEY MANAGEMENT RESPONSIBILITIES
General
The following people are involved in a journey, each with certain responsibilities:

The Authorising Person

The Journey Manager

The driver

The passenger (s)
Responsibilities of the Authorising Person

The Authorising Person is a manager or department head who
guarantees the integrity of the journey management system of the
company or department.

The Authorising Person is responsible for appointing supervisors as
Journey Manager and for ensuring that they are fully aware of their
responsibilities.

There can be more than one Authorising Person in the company or
department, but their identity and function shall be understood by all
supervisors and other Journey Managers.

The Authorising Person is responsible for compliance with this manual
by his subordinates, and for arranging for the briefing of supervisors and
drivers.
Responsibilities of the Journey Manager

The Journey Manager is responsible for the planning, monitoring, and
analysis of a journey. The Journey Manager remains responsible for the
vehicle and driver until they return to the home base, unless the vehicle
and driver are retained by another location for other work. The
responsibility for the driver and vehicle must then be accepted by a
Journey Manager at that other location.

The Journey Manager is responsible for Initiating any emergency
procedures (such as man-lost, accident, etc.) when he is notified of an
accident or the vehicle becomes overdue, by contacting the relevant
emergency control Duty Officer.

Where a journey would end after normal working hours, the journey
manager shall hand over the responsibility of managing the journey at
33
the close of work to a competent person on duty (i.e. Duty
Supervisor/Dispatcher) as agreed with the driver the planning phase of
the journey. The journey manager shall ensure that the person is
sufficiently briefed about the journey and given the journey plan.

When the Journey Manager is changed within the normal working hours,
the driver shall be informed at the earliest opportunity.
Responsibilities of the Driver

To drive only if authorized and fit to drive and to wear seat belt and to
ensure all passengers wear seat belts.

For the condition of his vehicle, load and for driving safely and in
accordance with the Journey Plan.

The driver shall not depart until he has received and understood the
Journey Plan, together with the manifest and any relevant SHOC Card (if
the load is hazardous).

To contact the Journey Manager at certain times or places during the
journey or at destination, as agreed with the Journey Manager before
departure.

The driver shall contact the Journey Manager if there are any problem or
difficulties en-route, and when he returns to home base.
Responsibilities of the Passenger

To wear seatbelts

To ensure no unauthorized passengers are carried in the vehicle.

To ensure driver adheres to the journey plan.

To ensure the driver operates within national and RUTOTECH speed
limits, and in a safe manner, taking note of prevailing weather
conditions.

Passengers shall not pressurize or divert the driver to change from
Journey Plan except for safety reasons
THE JOURNEY MANAGEMENT SYSTEM
Qualification of Journeys
The following journeys shall (as a minimum) be managed according to the provision of
this manual:




All journeys involving medium and heavy vehicles
All inter-state journeys
All journeys which exceed 100 km round trip.
All journeys at night outside RUTOTECH base
34
All Journeys at night shall be authorised by the Managing Director, or the Duty
manager. Journeys not covered by the above still require to be authorized, planned and
recorded.
Management of the Journey
Each journey shall have a Journey Manager.
Each journey shall have a written Journey Plan. A copy of the Journey Plan shall be
given to the driver. The master copy shall stay with the Journey Manager.
The Journey Manager shall:

verify that the journey is necessary and obtain permission if the journey
required higher authority

verify that security of personnel and vehicle is assured

Check the suitability of the vehicle type, and that the inspection certificate
is still valid.

Check that the driver has completed his daily checks and reported any
defects with the vehicle or the load.

Check that the proposed Journey Plan will not violate RUTOTECH policy on
drivers hours and rests, especially checking the timing of rest stops.

Ensure appropriate points where the driver shall call the Journey Manager
are included in the Journey Plan where appropriate.

Check that the driver is licensed (Nigerian Driver’s license) and qualified
(SPDC driving permit) to drive the vehicle, and that the driver is familiar
with the vehicle.

Check that the driver knows what to do if there is an accident or an
emergency during the journey.

Provide adequate food, water and where necessary accommodation for the
journey or provide enough money for the driver and passengers.

Discuss the Journey Plan with the driver.

De-brief the driver at the final completion of the Journey.
The Journey Plan
The Journey Plan can be in any format or size, but the following information shall
be included:


Purpose of journey
Registration number and type of vehicle
* Driver details
* Number of passengers/ cargo on manifest.
* Departure point
* Actual departure date and time
* Planed route with name or time of each rest point
* Destination and contact name and telephone number
* Estimate duration and distance of journey
* Name of Journey Manager and contact telephone numbers.
35
*
If part of the journey is to be done at night, the reason why, and attach the
written authorization.

Tick-boxes to show that:
* A SHOC Card has been issued if Hazardous Materials are carried,
* Vehicle condition has been checked
* Drivers license/permit checked
* Welfare items required
The Journey Plan does not need to be faxed or sent to any other party, unless it is
specifically requested.
The master copy of the Journey Plan stay with the Journey Manager Journey Plans shall
be kept for a minimum of 3 months for reference purpose.
ROAD TRANSPORT
To ensure accident free operation, the management of RUTOTECH maintains the
following land and water transport objectives:
 Minimize exposure by engaging in an unauthorized trip.
 Identify specific relevant transport hazards and provide mitigating.
 Establish compliance with the use of appropriate PPE by each passenger before
departure.
TO ALL VEHICLE/CRAFT OPERATORS
Before you start your journey, follow the under listed points.
1. Ensure you are AUTHORIZED to take your journey on RUTOTECH’s business.
2. Ensure you have valid statutory documents (driver’s license, vehicle
particulars, etc.)
3. Agree on a journey plan and instruction (written)
4. Log name of authorized and time of authorization.
5. Carry out routine pre-start checks.
6. Ensure you and your entire passengers wear seat belt before driving
BE ALERT ALWAYS, PAY ATTENTION TO MAKE THE JOURNEY INCIDENT FREE.
36
GENERAL DRIVERS RESPONSIBILITIES
Before driving the Company’s vehicle the driver must adhered to the following:Driving permit and all statutory licenses must be obtained.
Must have attended D. D. C. I & D. D. C.II
Must not carry passengers
Must not take alcohol
Must maintain Authorized speed limit.
JOURNEY PRE – START CHECK LIST:
VEHICLE
GOOD
POOR
BAD
REMARK
TYRE / BRAKE, CONDITION
JACK WHEEL SPENNER
ENGINE OIL / FUEL LEVEL
BATTERY ACID CONDITION
VEHICLE BODY CONDITION
SIDE MIRRORS
FIRE EXTINGUISHER
PORTABLE TOLL BOX
FIRST AID KIT
FUEL / WATER LEVEL
WIPERS CONDITION
SEAT BELT CONDITION
HORN CONDITION
FAN BELT CONDITION
VEHICLE PARTICULARS
RADIO
37
RUTOTECH
ROAD JOURNEY MANAGEMENT FORM
DATE:
VEHICLE REG NO:
JOURNEY SERIAL NO:
TIME:
User Name
Job Title
Purpose of
Journey / Destination
ROUTE AGREED--------------------------------------------------------------------------Vehicle Checked Y/N
Hazard Analyzed and HSE Briefing Y/N
Estimated Distance
Km Reading
Arrival Time
Authorized By:
Name:
Signature:
Date:
38
RUTOTECH
MARINE JOURNEY MANAGEMENT FORM
Journey Number:
Dept:
Take-off location:
Vessel Name/fleet No.
Purpose of Journey:
Final Destination:
Pre-Trip Instruction
Agreed Route:
Vessel/Name
Estimated Duration Hrs.
Date / Time out
Date / Time in
Total Outstation
Vessel Type
Hazard Analyzed/HSE
briefing Y/N
Authorized
Passengers/Cargo
Valid Certification Checked
Y/N
Estimated Distances Nm
Hazard Analysis
Location:
Hazard:
Control:
Post Trip Observations:
Note: NO NIGHT SAILING AFTER 06.00 PM.
Quartermaster Details:
Journey Authorized by:
Name:
Name:
Company:
Destination:
Signature:
Signature:
39
40