HSE و بهداشت حرفه ای

 

Guidelines for the Development and Application of

Health, Safety and Environmental
Management Systems

introduction

The ………. is the national project of the ……….Energy Organization of Iran, commissioned in 2003. It is concerned with all aspects of ……. production having national implications, and in particular with safety and health and environmental protection.

These Guidelines have been prepared to assist in the development and application of HSE (MS) in production operations. … Members have participated in the work, to ensure that their collective experience is used and that the Guidelines have wide acceptance.

Background

………production activities are subject to extensive legislation and regulation concerning Occupational Health and Safety (OHS). All operators have OHS strategies to satisfy their own operating and regulator requirements, and Safety Management Systems (SMS) are a principal component of such strategies. SMS guidelines have been developed by national and international regulations. There is wide recognition of the benefits of objective or goal-setting approaches to safety, a fundamental principle of the SMS approach which draws on the management principles of the International Standard on Quality Systems, ISO 9000. Similarly, environmental aspects are subject to extensive regulation and environmental Management Systems (EMS) is used to control and manage environmental impacts.

Although there are important differences in the detailed handling of safety and environmental issues, safety and environmental management are tending to converge towards the systems model of ISO 9000. Many companies operate joint Health, Safety and Environment Management Systems, and some recommended practice such as RP 75 exists, to assist those developing Safety and Environmental Management Programs (SEMP) in industries.

The requirements of health and safety and environmental protection are not always in harmony. For example, measures necessary to safeguard personnel in emergencies may have adverse environmental effects, and vice versa. However, joint consideration of health and safety and environmental matters provides a framework within which such Issues can be resolved, and an appropriate balance struck.

Purpose and Scope

 The HSEMS Guidelines have been developed by the Safety Analysis& Quality Assurance office (SA and QA office) to:

o   Cover relevant Health, Safety and Environment (HSE) issues in a single document be relevant to the activities of the …… industry worldwide.

o   Be sufficiently generic to be adaptable to different companies and their cultures.

o   Recognize, and be applicable to, the role of contractors and subcontractors.

o   Facilitate operation within the framework of statutory requirements.

o   Facilitate evaluation of operations to an international standard(s) as appropriate.

The Guidelines describe the main elements necessary to develop, implement and maintain an HSE (MS). They do not lay down specific performance requirements, but recommend that managers of …… set policies and objectives taking into account information about the significant hazards and environmental effects of their operations.

The Guidelines may be used as a template by any operating or contracting company seeking to help assure itself and others (such as regulators, neighbors, partners, clients, insurers) of compliance with stated HSE policies within an objective-setting management system. Furthermore, the Guidelines are intended to support, rather than to suggest replacement of, existing sound, workable and effective company systems and practices.

The phrase ‘the company should maintain procedures...’ is used throughout the guidelines; however, it is not intended to prescribe that written procedures are necessarily required for all practices. The HSE-criticality of a given operation or situation dictates whether it warrants a formally documented and controlled procedure. In many instances the existing company practices will be less formal but nevertheless fully acceptable. Assuring the suitability of all aspects of the HSE (MS) remains the responsibility of each company and the Guidelines should be read in this context of self regulation.

Health, safety and environmental management system model

 The model Health, Safety and Environmental Management System which Environmental Management forms the basis of these Guidelines is shown schematically in the figure at System Model the top of page 4. Although this indicates a sequence of the HSE (MS) elements, many of the stages will in practice be addressed at the same time or revisited at different times. Because the HSE (MS) will be a part of the overall management system, these Guidelines should strictly refer to the HSE Management j.-System, but for simplicity the term HSE Management System will be used throughout. This is for convenience and in no way implies that the HSEMS is distinct from the overall management system of the facility or company.

Fig.1: The Model Health, Safety and Environment System (HSEMS)

 

Structure of the document

The document has two main sections, ‘Guidelines’ and Supplementary’. The Guidelines describe the elements of the HSEMS model and their interrelationships. These—or similar—elements are described by some regulators and companies as ‘performance standards’. This term should not, however, be confused with ‘performance criteria’, which are lower-level specifications for the performance of operations.

The Supplementary section contains additional advisory material under the same headings, including examples of the manner in which the Guidelines may be applied. For convenience, the sections are numbered as in the Guidelines, but with the prefix ‘S’.

Terminology

Different health, safety and environmental management systems and strategies have been developed by different companies and Organizations, leading to a diversity of terminology. The terms which are used in this document, are defined in an Annex to the Guidelines section.
Particular attention should be paid to the definition and usage in these Guidelines of the terms ‘risk’, ‘hazard’, ‘performance criteria’, ‘audit’ and ‘review’. References in the Guidelines to a ‘company’ may be taken to refer to a particular facility or division operating a local HSEMS, as well to the corporate HSEMS. Most of these Guidelines refer to an operating Organization directly responsible for HSE management and performance. ‘Company’ also includes any contracting Organization which provides services to the E&P industry, and which wishes to develop and operate an HSEMS following these Guidelines.

Executive Summary of the HSEMS model

Key elements of the HSEMS model

The Guidelines describe a management system, outlined in the figure on
 page 4, for setting and implementing company policy and objectives on
health, safety and the environment. Key elements of the HSEMS are shown
in the table below.

 

 

Additional advisory material on each element is given in the Supplementary section beginning on page 29. 
 

1. Leadership and commitment

 

This section addresses the top- down commitment and company culture necessary for the success of the system

Senior management of the company should provide strong, visible leadership and commitment, and ensure that this commitment is translated into the necessary resources, to develop, operate and maintain the HSEMS and to attain the policy and strategic objectives. Management should ensure that full account is taken of HSE policy requirements and should provide support for local actions taken to protect health, safety and the environment.

The company should create and sustain a company culture that supports the HSEMS, based on:

o   belief in the company’s desire to improve HSE performance; motivation to improve personal HSE performance;

o   acceptance of individual responsibility and accountability for HSE performance;

o   participation and involvement at all levels in HSEMS development;

o   commitment to an effective HSEMS.

Employees of both the company and its contractors should be involved in the creation and maintenance of such a supportive culture.

 

 

2. Policy and strategic objectives

The company’s management should define and document its HSE policies and strategic objectives and ensure that they:

o   are consistent with those of any parent company; • are relevant to its activities, products and services, and their effects on HSE;

o   are consistent with the company’s other policies;

o   have equal importance with the company’s other policies and objectives;

o   are implemented and maintained at all organizational levels;

o   are publicly available;

o   commit the company to meet or exceed all relevant regulatory and legislative requirements;

o   apply responsible standards of its own where laws and regulations do not exist;

o   commit the company to reduce the risks and hazards to health, safety and the environment of its activities, products and services to levels which are as low as reasonably practicable;

o   provide for the setting of HSE objectives that commit the company to continuous efforts to improve HSE performance.

The company should establish and periodically review strategic HSE objectives. Such objectives should be consistent with the company’s policy and reflect the activities, relevant HSE hazards and effects, operational and business requirements, and the views of employees, contractors, customers and companies engaged in similar activities.

 

 

3. Organization, resources and documentation

 

3.1 Organizational structure and responsibilities

Successful handling of HSE matters is a line responsibility, requiring the active participation of all levels of management and supervision; this should be reflected in the Organizational structure and allocation of resources.

The company should define, document and communicate—with the aid of Organizational diagrams where appropriate—the roles, responsibilities, authorities, accountabilities and interrelations necessary to implement the HSEMS, including but not limited to:

o   provision of resources and personnel for HSEMS development and implementation;

o   initiation of action to ensure compliance with HSE policy;

o   acquisition, interpretation and provision of information on HSE matters;

o   identification and recording of corrective actions and opportunities to improve HSE performance;

o   recommendation, initiation or provision of mechanisms for improvement, and  verification of their implementation;

o   control of activities whilst corrective actions are being implemented;

o   control of emergency situations.

3.2 Management representative(s)

The company should stress to all employees their individual and collective responsibilities of HSE performance. It should also ensure that personnel are competent (see section 3.4) and have the necessary authority and resources to perform their duties effectively.

The Organizational structure and allocation of responsibilities should reflect the responsibility of line managers at all levels for developing, implementing and maintaining the HSEMS in their particular areas. The structure should describe the relationships between:

o   Different operating divisions.

o   Operating divisions and supporting services (whether the services are provided on the same facility or from a larger corporate Organization).

o   Onshore and offshore Organizations.

o   Employees and contractors.

o   Partners in joint activities.

3.2 Management representative(S)

A management representative or representatives should be assigned responsibility, authority and accountability for coordinating implementation and maintenance of the HSEMS. The representative(s) should be accountable to senior management, but the appointment(s) should not reduce the responsibility of individual line managers for implementing the HSEMS in their areas.

3.3 Resources

Senior management should allocate sufficient resources to ensure the effective operation of the HSEMS, taking account of advice from the management representative(s), line management and HSE specialists. Resource allocation should be reviewed regularly as parts of the Review of the HSEMS (see section 7.2), of management of change (see section 5.4) and of risk management (see section 4).

Select appropriate staff

Identify competencies (abilities/ skills/ knowledge) required

Provide training if necessary

Review performance

 

 

 

 

 

 

 

 

3.4.1 General

The company should maintain procedures for ensuring that personnel performing specific assigned HSE-critical activities and tasks are competent on the basis of appropriate:

o   personal abilities,

o   skills developed through experience, and

o   acquired knowledge.

Systems for competence assurance should apply both to initial recruitment and to selection for new activities, and to both staff and contractors. The continuing competence of personnel to perform their duties should be regularly reviewed and assessed, including appropriate consideration of personal development and training required to achieve competence for changing activities and technologies (see section 3.4.2). Procedures for competence assurance include, amongst others:

o   systematic analysis of requirements for tasks;

o   assessment of individuals’ performance against defined criteria;

o   documented evidence of individual competence;

o   programmes for periodic re-assessment.

3.4.2 Training

The company should maintain procedures to ensure and increase competence through identification of training needs and provision of appropriate training for all personnel. Training may be provided through formal courses and/or through structured development in the workplace.

The extent and nature of training should be sufficient to ensure achievement of the company’s policy and objectives, and should meet or exceed that required by legislation and regulations. Appropriate records of training should be maintained (see section 6.3) and refresher training scheduled as required.

 

 

Systems should be developed to monitor the effectiveness of training programmes and to introduce improvements where necessary.

3.5 Contractors

The company should maintain procedures to ensure that its contractors operate a management system that is consistent with the requirements and provisions of these HSEMS Guidelines and that it is compatible with the HSEMS of the company. Procedures should facilitate interfacing of contractors’ activities with those of the company and with those of other contractors, as appropriate. This may be achieved by means of a specific interface document between company and contractor so that any differences may be resolved, and procedures agreed, before work commences. Although all the recommendations in these Guidelines may be applicable to the contracted Organization, the procedures should pay particular attention to the following:

o   Selection of contractors, including (amongst other considerations) specific assessment of their HSE policy, practices and performance and the adequacy of their HSEMS, commensurate with the risks associated with the services to be provided.

o   Effective communication (see section 3.6) of the key elements of the company’s HSEMS, and of the standards of worker and environmental protection expected from the contractor, including agreed HSE objectives and performance criteria.

o   Sharing by company and contractor of relevant information which may impact on the HSE performance of either.

o   The requirement that each contractor have an effective and relevant training programme which includes records and procedures for assessing the need for further training.

o   Definition of methods for monitoring and assessing contractor performance against agreed HSE objectives and performance criteria.

3.6 Communication

The company should maintain procedures to ensure that its employees, and those of its contractors and partners, at all levels, are aware of the:

o   Importance of compliance with the HSE policy and objectives, and their individual roles and responsibilities in achieving it.

o   HSE risks and hazards of their work activities and the preventative and mitigation measures (see section 4) and emergency response procedures that have been established (see section 5.5).

o   Potential consequences of departure from agreed operating procedures.

o   Mechanisms for suggesting, to management, improvements in the procedures which they and others operate.

Maintaining means of external communication in times of emergency is especially important and special contingency arrangements should be in place (see section 5.5).

The company should maintain procedures for communication of HSE information, consistent with its policy and with applicable legislation and regulations. The company should, whilst protecting confidential information, make available its HSE experience to employees, contractors, customers and companies engaged in similar activities to facilitate improvements in industry HSE performance.

Customers

Media

Labor Organization

COMPANY Board Management representatives All employees

Interest Groups

Regulators

Shareholders

Neighbors

Insures

Suppliers

Emergency services

Banks

Contractors

 

 

 

 

 

The company should maintain procedures for receiving and responding to communications from employees, contractors, customers, government agencies and the public concerning its HSE performance and management. Community awareness and consultation programmes should be maintained where appropriate, and their effectiveness monitored.

3.7 Documentation and its control

3.7.1 HSEMS documentation

  The company should maintain controlled documentation to:

o   Record the HSE policy, objectives and plans.

o   Record and communicate key roles and responsibilities.

o   Describe HSE management system elements and their interactions.

o   Cross-reference related documentation and describe links with other aspects of the overall management system.

o   Record the results of HSE evaluation and risk management.

o   Record relevant legislative and regulatory requirements.

o   Record, where necessary, procedures and work instructions for key activities and tasks.

o   Describe emergency plans and responsibilities, and the means of responding to incidents and potential emergency situations.

Such documentation should cover:

o   The company.

o   Organizational divisions and business units.

o   Individual functions and operations (e.g. facility design, exploration, land acquisition, drilling).

o   Contractors and partners.

3.7.2 Document control

The company should maintain procedures for controlling HSEMS documents to ensure that:

o   They can be identified with the appropriate company, division, function or activity;

o   They are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel prior to issue;

o   Current versions are available at those locations where they are needed;

o   When obsolete, they are promptly removed from all points of issue and points of use.

Documentation should be legible, dated (with dates of revision), readily identifiable, numbered (with a version number), maintained in an orderly manner and retained for a specified period. Policies and responsibilities should be established for the modification of documents, and their availability to employees, contractors, government agencies and the public.

 

4. Evaluation and risk management

 

 

4.1 Identification of hazards and effects

The company should maintain procedure to identify systematically the hazards and effect which may affect or arise from its activities and from the materials which are used or encountered in them. The scope of the identification should cover activities from inception (e.g. prior to acreage acquisition) through to abandonment and disposal.

The identification should include consideration of:

o   Planning, construction and commissioning (i.e. asset acquisition, development and improvement activities).

o   Routine and non-routine operating conditions, including shut-down,
maintenance and start-up.

o   Incidents and potential emergency situations, including those arising
from:

•  Product/material containment failures.

•  Structural failure.

•  Climatic, geophysical and other external natural events.

•  Sabotage and breaches of security

•  Human factors including breakdowns in the HSEMS.

o   Decommissioning, abandonment, dismantling and disposal.

o   Potential hazards and effects associated with past activities.

Personnel at all Organizational levels should be appropriately involved in the identification of hazards and effects.

 

4.2 Evaluation

Procedures should be maintained to evaluate (assess) risks and effects from identified hazards against screening criteria, taking account of probabilities of occurrence and severity of consequences for:

o   People.

o   Environment.

o   Assets.

It should be noted that any evaluation technique provides results which themselves may be subject to a range of uncertainties. Consequently formal risk evaluation techniques are used in conjunction with the judgment of experienced personnel, regulators and the community. Risk evaluation should:

4.3 Recording of hazards and effects

o   include effects of activities, products and services;

o   address effects and risks arising from both human and hardware factors;

o   solicit input from personnel directly involved with the risk area;

o   be conducted by qualified and competent personnel;

o   be conducted according to appropriate and documented methods;

o   be updated at specified intervals.

Evaluation of health and safety risks and effects should include, where appropriate, consideration of:

o   Fire and explosion.

o   Impacts and collisions.

o   Drowning, asphyxiation and electrocution.

o   Chronic and acute exposure to chemical, physical and biological agents.

o   Ergonomic factors.

Evaluation of acute and chronic environmental effects should include, where appropriate, consideration of:

o   Controlled and uncontrolled emissions of matter and energy to land, water and the atmosphere.

o   Generation and disposal of solid and other wastes.

o   Use of land, water, fuels and energy, and other natural resources.

o   Noise, odor, dust, vibration.

o   Effects on specific parts of the environment including ecosystems.

o   Effects on archaeological and cultural sites and artifacts, natural areas, parks and conservation areas.

4.3 recording of hazards and effect

The company should maintain procedures to document those hazards and effects (chronic and acute) identified as significant in relation to health, safety and the environment, outlining the measures in place to reduce them (see sections 4.5) and identifying the relevant HSE-critical systems and procedures.

The company should maintain procedures to record statutory requirements and codes applicable to the HSE aspects of its operations, products and services and to ensure compliance with such requirements.

4.4 Objectives and performance criteria

The company should maintain procedures to establish detailed HSE objectives and performance criteria at relevant levels.
Such objectives and performance criteria should be developed in the light of policy, strategic HSE objectives, HSE risks, and operational and business needs. They should be quantified, wherever practicable, and identified with defined timescales; they should also be realistic and achievable.
As a follow-up to risk evaluation (see 4.2), the company should maintain procedures to set performance criteria for HSE-critical activities and tasks, which stipulate in writing the acceptable standard for their performance. It should also, at specified intervals, review the continuing relevance and suitability of the criteria.

4.5 Risk reduction measures

The company should maintain procedures to select, evaluate and implement measures to reduce risks and effects. Risk reduction measures should include both those to prevent incidents (i.e. reducing the probability of occurrence) and to mitigate chronic and acute effects (i.e. reducing the consequences). Preventative measures such as ensuring asset integrity (see section 5.2) should be emphasized wherever practicable. Mitigation measures should include steps to prevent escalation of developing abnormal situations and to lessen adverse effects on health, safety and the environment and, ultimately, emergency response measures to recover (see section 5.5). Effective risk reduction measures and follow-up require visible commitment of management and on-site supervision, as well as the understanding and ownership of operations personnel.

 In all cases consideration should be given to reducing risk to a level deemed as low as reasonably practicable’ reflecting amongst other factors local conditions and circumstances, the balance of cost and benefits and the current state of scientific and technical knowledge.

 Procedures should be in place to:

o   Identify prevention and mitigation measures for particular activities, products and services which pose potential HSE risks.

o   Re-appraise activities to ensure that the measures proposed do reduce risks, or enable relevant objectives to be met.

o    Implement, document and communicate to key personnel interim and permanent risk reduction measures, and monitor their effectiveness.

o   Develop relevant measures such as plans for emergency response (section 5.5) to recover from incidents and mitigate their effects.

o   Identify hazards arising from risk prevention and mitigation and recovery measures.

o   Evaluate the tolerability of consequent risks and effects against the screening criteria.  

 

 

5. Planning

5.1 General

The company should maintain, within its overall work programme, plans for achieving HSE objectives and performance criteria. These plans should include:

o   a clear description of the objectives;

o   designation of responsibility for setting and achieving objectives and performance criteria at each relevant function and level of the organization;

o   the means by which they are to be achieved;

o   resource requirements;

o   time scales for implementation;

o   programmes for motivating and encouraging personnel toward a suitable HSE culture;

o   mechanisms to provide feedback to personnel on HSE performance;

o   processes to recognize good personal and team HSE performance (e.g. safety award schemes);

o   mechanism for evaluation and follow-up

5.2 Asset integrity

The company should maintain procedures to ensure that HSE-critical facilities and equipment which it designs, constructs, procures, operates, maintains and/or inspects are suitable for the required purpose and comply with defined criteria. Pre-procurement and pre-construction assessment of new facilities and equipment should include explicit assessment of appropriateness to meet HSE requirements and should emphasize design as the best preventative measure to reduce risk and adverse HSE effects.

Procedures and systems for ensuring asset integrity should address (amongst other factors) structural integrity, process containment, ignition control and systems for protection, detection, shutdown, emergency response and life-saving.

Deviation from approved design practices and standards should be permitted only after review and approval by designated personnel and/or authorities, and the rationale for the deviation should be documented.

5.3 Procedure and work instructions

5.3.1 Developing procedures

Activities, for which the absence of written procedures could result in infringement of the HSE policy or breaches of legislative requirements or performance criteria, should be identified. Documented procedures or standards should be prepared for such activities, defining how they should be conducted - whether by the company’s own employees, or by others acting on its behalf-to ensure technical integrity and to transfer knowledge effectively.

All written procedures should be stated simply, unambiguously and understandably, and should indicate the persons responsible, the methods to be used and, where appropriate, performance standards and criteria to be satisfied.

 Procedures are required for procurement and contracted activities, to ensure that suppliers and those acting on the company’s behalf comply with the company’s policy requirements that relate to them.

5.3.2 Issuing work instructions

Work instructions define the manner of conducting tasks at the work-site level, whether conducted by the company’s own employees or by others acting on its behalf. In the case of HSE-critical tasks, which have the potential for adverse HSE consequences if incorrectly performed, these work instructions should be documented and communicated to relevant personnel.

5.4 Management of change

The company should maintain procedures for planning and controlling changes, both permanent and temporary, in people, plant, processes and procedures, to avoid adverse HSE consequences.

The procedures should be suitable to address the HSE issues involved, according to the nature of the changes and their potential consequences, and should address:

o   Identification and documentation of the proposed change and its implementation.

o   Responsibility for reviewing and recording the potential HSE hazards from the change or its implementation.

o   Documentation of the agreed change and implementation procedure, including:

 

• Measures to identify HSE hazards and to assess and reduce risks and effects;

• Communication and training requirements;

• time limits, if any;

• Verification and monitoring requirements;

• Acceptance criteria and action to be taken if breached.

o   Authority for approval to implement the proposed change.

Procedures should describe how the company will interpret, and assess the implications of, new or amended legislation, and how revised regulatory requirements are to be incorporated in the HSEMS.

Separate plans should be established in respect of the HSE management of new operations (relating, for example, to acquisitions, developments, divestments, products, services or processes), or of modified operations where the modification introduces significantly different HSE concerns, to define:

o   HSE objectives to be attained.

o   Mechanisms for their achievement.

o   Resource requirements to achieve HSE objectives.

o   Procedures for dealing with changes and modifications as projects proceed.

o   Corrective mechanisms which should be employed should the need arise, how they should be activated and how their adequacy should be measured.

5.5 Contingency and emergency planning

The company should maintain procedures to identify foreseeable emergencies by systematic review and analysis. A record of such identified potential emergencies should be made, and updated at appropriate intervals in order to ensure effective response to them.

The company should develop, document and maintain plans for responding to such potential emergencies, and communicate such plans to:

o   command and control personnel;

o   emergency services;

o   employees and contractors who may be affected;

o   others likely to be impacted.

Emergency plans should cover:

o   Organization, responsibilities, authorities and procedures for emergency response and disaster control, including the maintenance of internal and external communications.

o   Systems and procedures for providing personnel refuge, evacuation, rescue and medical treatment.

o   Systems and procedures for preventing, mitigating and monitoring environmental effects of emergency actions.

o   Procedures for communicating with authorities, relatives and other relevant parties.

o   Systems and procedures for mobilizing company equipment, facilities and personnel.

o   Arrangements and procedures for mobilizing third party resources for emergency support.

o   Arrangements for training response teams and for testing the emergency systems and procedures.

To assess the effectiveness of response plans, the company should maintain procedures to test emergency plans by scenario drills and other suitable means, at appropriate intervals, and to revise them as necessary in the light of the experience gained.

Procedures should also be in place for the periodic assessment of emergency equipment needs and the maintenance of such equipment in a ready state.

6. Implementation and monitoring

 

6.1 Activities and tasks

Activities and tasks should be conducted according to procedures and work instructions developed at the planning stage—or earlier, in accordance with HSE policy:

o   At senior management level, the development of strategic objectives and high-level planning activities should be conducted with due regard
for the HSE policy.

o   At supervisory and management level, written directions regarding activities (which typically involve many tasks) will normally take the form of plans and procedures.

o   At the work-site level, written directions regarding tasks will normally be in the form of work instructions, issued in accordance with defined safe systems of work (e.g. permits to work, simultaneous operations procedures, lock-off procedures, manuals of permitted operations).

Management should ensure, and be responsible for, the conduct and verification of activities and tasks according to relevant procedures. This responsibility and commitment of management to the implementation of policies and plans includes, amongst other duties, ensuring that HSE objectives are met and that performance criteria and control limits are not breached. Management should ensure the continuing adequacy of the HSE performance of the company through monitoring activities (see section 6.2).

6.2 Monitoring

The company should maintain procedures for monitoring relevant aspects of HSE performance and for establishing and maintaining records of the results. For each relevant activity or area, the company should:

o   identify and document the monitoring information to be obtained, and specify the accuracy required of results;

o   specify and document monitoring procedures, and locations and frequencies of measurement;

o   establish, document and maintain measurement quality control procedures;

o   establish and document procedures for data handling and interpretation;

o   establish and document actions to be taken when results breach performance criteria (see sections 4.4, 4.5 and 6.4);

o   assess and document the validity of affected data when monitoring systems are found to be malfunctioning;

o   Safeguard measurement systems from unauthorized adjustments or damage.

Procedures are required for both active and reactive monitoring. Active monitoring provides information in the absence of any incident, ill-health or damage to the receiving environment. It includes checking that HSEMS requirements (e.g. procedures) are being complied with, and that objectives and performance criteria are met. Reactive monitoring provides information on incidents (including near-miss incidents, ill-health or environmental damage) that have occurred and provides insights into the means of preventing similar incidents in the future.

6.3 Records

The company should maintain a system of records in order to demonstrate the extent of compliance with its HSE policy and its requirements, and to record the extent to which planned objectives and performance criteria have been met.

Procedures should be maintained to ensure the integrity, accessibility and control of such records which should include relevant contractor and procurement records, the results of audits and reviews (see section 7), training records (see section 3.4.2) and employee medical records.

The retention times of records should be established and recorded, and procedures should be maintained regarding their availability and confidentiality.

6.4 Non-compliance and corrective action

 The company should define the responsibility and authority for initiating investigation and corrective action in the event of non-compliance with specified requirements relating to the HSEMS, its operation or its results. Situations of non-compliance may be identified by the monitoring programme through communications from employees, contractors, customers government agencies or the public, or from investigations of incident (see sections 6.5 and 6.6).

The company should maintain procedures for such investigation and corrective action, by which the management of the individual function or activity concerned, in consultation with the management representative, should:

o   Notify the relevant parties.

o   Determine the causation sequence and likely root cause.

o   Establish a plan of action or an improvement plan.

o   Initiate preventive actions commensurate with the nature of the non compliance.

o   Apply controls to ensure that any preventive actions taken are effective.

o   Revise procedures to incorporate actions to prevent recurrence, communicate changes to relevant personnel and implement them.

 

Determine the causes

Plan action

Initiate preventive actions

Apply controls

Revise procedures and communicate changes

 

 

 

 

 

 

 

 

 

 

 

6.5 Incident reporting

The Organization should maintain procedures for the internal recording and reporting of incidents which affected, or could have affected, HSE performance, so that the relevant lessons can be learned and appropriate actions taken (see section 6.6).

There should be a defined mechanism for the reporting of incidents to regulatory bodies, to the extent required by law or to such greater extent as the policy of the company on external communication may require.

6.6 Incident follow-up

Both the immediate circumstances of the incident, and the underlying HSEMS weaknesses which caused it, should be identified to enable judgments to be made by those responsible for authorizing the necessary follow-up action.

 The mechanism and responsibilities for follow-up of incidents should be clearly defined. The mechanism should be broadly similar to the procedures for implementing corrective action in cases of non-compliance with the HSEMS (see section 6.4).

 The defined responsibilities for follow-up of an incident should be appropriate to the severity of its real or potential consequences.

 

 

 

7.1 Auditing

The company should maintain procedures for audits to be carried out, as a normal part of business control, in order to determine:

o   Whether or not HSE management system elements and activities conform to planned arrangements, and are implemented effectively.

o   The effective functioning of the HSEMS in fulfilling the company’s HSE policy, objectives and performance criteria.

o   Compliance with relevant legislative requirements.

o   Identification of areas for improvement, leading to progressively better HSE management.

For this purpose, it should maintain an audit plan, dealing with the following:

o   Specific activities and areas to be audited. Audits should cover the operation of the HSEMS and the extent of its integration into line activities, and should specifically address the following elements of the HSEMS model:

 

•  Organization, resources and documentation;

•  evaluation and risk management;

•  planning;

•  implementation and monitoring.

o   Frequency of auditing specific activities/areas. Audits should be scheduled on the basis of the contribution or potential contribution of the activity concerned to HSE performance, and the results of previous audits.

o    Responsibilities for auditing specific activities/areas.

Audit protocols and procedures should be established and maintained.

The following points should be covered:

o   Allocation of resources to the auditing process.

o   Personnel requirements and specifically that the audit team has:

 

•  Adequate independence from activities audited to enable objective and impartial judgment;

•  The necessary expertise in relevant disciplines;

•  Support, if necessary, from a wider range of specialists.

o   Methodologies for conducting and documenting the audits, which may involve the use of questionnaires, checklists, interviews, measurements and direct observations, depending on the nature of the function being audited.

o   Procedures for reporting audit findings in a controlled manner to those responsible for the activity/area audited, who should take timely action on reported corrective actions and opportunities for improvement (see section 6.6). Reporting should address:

 

•  Conformity or nonconformity of the HSEMS elements with specified requirements;

•  Effectiveness of the implemented HSEMS in enabling objectives and performance criteria to be met;

•  Implementation and effectiveness of corrective actions from previous audits;

•  Conclusions and recommendations.

 

o   System for auditing and tracking implementation status of audit recommendations.

o   Distribution and control of audit reports.

 

7. 2 Reviewing

 

The company’s senior management should, at appropriate intervals, review the HSEMS and its performance, to ensure its continuing suitability and effectiveness. The review should specifically, but not exclusively, address:

 

o   The possible need for changes to the policy and objectives, in the light of changing circumstances and the commitment to strive for continual improvement.

o   Resource allocation for HSEMS implementation and maintenance.

o    Sites and/or situations on the basis of evaluated hazards and risks, and emergency planning.

The review process should be documented, and its results recorded, to facilitate implementation of consequent changes.

Reviews should be used to reinforce continuous efforts to improve HSE
performance.

 

 

 

 

 

For the purposes of these HSEMS Guidelines, the following definitions apply	Annex: definitions
accident	See ‘incident’
as low as reasonably practicable	To reduce a risk to a level which is as low as reasonably practicable’ involves balancing reduction in risk against the time, trouble, difficulty and cost of achieving it. This level represents the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained.
company	An Organization engaged, as principal or contractor, directly or indirectly, in the exploration for and production of oil and/or gas. For bodies or establishments with more than one site, a single site may be defined as a company.
environment	The surroundings and conditions in which a company operates or which it may affect, including living systems (human and other) therein.
environmental effect	A direct or indirect impingement of the activities, products and services of the company upon the environment, whether adverse or beneficial.
environmental effects evaluation	A documented evaluation of the environmental significance of the effects of the company’s activities, products and services (existing and planned).
hazard	The potential to cause harm, including ill health or injury; damage to property, plant, products or the environment; production losses or increased liabilities.
health, safety and environmental (HSE-) critical	Designates activities, personnel or measures that have been identified as vital to ensure asset integrity, prevent incidents, and/or to mitigate adverse HSE effects.
health, safety and environmental (HSE) management audit	An independent, systematic and documented process of objectively obtaining and evaluating verifiable evidence to determine: • whether the HSEMS and its results conform to the audit criteria; • whether the system is implemented effectively; and • whether the system is suitable to achieve the health, safety and environmental policy and objectives.
health, safety and environmental (HSE) management documentation	The documentation describing the overall health, safety and environmental management system, and making reference to the procedures for implementing the company’s health, safety and environmental management plan.
health, safety and environmental (HSE) management plan	A description of the means of achieving health, safety and environmental objectives.
health, safety and environmental (HSE) management review	The formal review by senior management of the status and adequacy of  the health, safety and environmental management system and its implementation in relation to health, safety and environmental issues, policy, regulations and new objectives resulting from changing circumstances.
health, safety and environmental management system (HSEMS)	The company structure, responsibilities, practices, procedures, processes and I resources for implementing health, safety and environmental management.
health, safety and environmental (HSE) strategic objectives	The broad goals, arising from the HSE policy, that a company sets itself to achieve, and which should be quantified wherever practicable.
health, safety and environmental (HSE) policy	A public statement of the intentions and principles of action of the company regarding its health, safety and environmental effects, giving rise to its strategic and detailed objectives.
health, safety and environmental (HSE) management	Those aspects of the overall management function (including planning) that develop implement and maintain the HSE policy.
incident	An event or chain of events which has caused or could have caused injury, illness and/or damage (loss) to assets, the environment or third parties. (The word ‘accident’ is used by some writers and Organizations to denote an incident which has caused injury, illness and/or damage, but the term a/so has connotations of ‘bad luck’ in common speech, and is therefore avoided by others. In these guidelines, only the term ‘incident’ has been used—in the above sense which embraces the concept of ‘accident’.)
maintain (procedures)	The term ‘maintain’ as used in these Guidelines should be understood to mean ‘establish and maintain’ if the procedure which is to be maintained does not yet exist.
monitoring activities	All inspection, test and monitoring work related to health, safety and environmental management.
performance criteria	Performance criteria describe the measurable standards set by company management to which an activity or system element is to perform. (Some companies may refer to performance criteria as ‘goals’ or ‘targets )
practice	Accepted methods or means of accomplishing stated tasks
Procedure	A documented series of steps to be carried out in a logical order for a defined operation or in a given situation
Risk	The product of the chance that a specified undesired event will occur and the severity of the consequences of the event.
screening criteria	The values or standards against which the significance of the identified hazard or effect can be judged. They should be based on sound scientific and technical information and may be developed by the company and industry bodies, or provided by the regulators.