INTRODUCTION TO HSE CONCEPTS AND ELEMENTS

1.1 POLICY ON HEALTH, SAFETY AND ENVIRONMENTAL CONSERVATION

POLICY GUIDELINES

Health, Safety and Environment shall always be the focus in.  At all levels in the Company, from managers to each employee, all activities shall be performed in such a way that HSE is given the same priority other business activities.

HSE is a Management responsibility which follows the Company’s line organization in Divisions and Projects.  It shall be run in such a way that Health and Safety are promoted for all employees, a safe and beneficial working environment is provided, and the environment and property are protected.

The Objective Of HSE Includes The Following:

• Safety of human life and health, including the working environment
• Safety of the environment
• Safety of premises and materials
• Safety of documents and data
• Safety of the users of our products and services

No Activities Shall Compromise The Safety Of People And The Environment.

HEALTH

Companies seek to conduct their activities in such a way as to avoid harm to the health of their employees and others; and to promote. as appropriate. the health of their employees.

SAFETY

Companies work on the principle that all injuries should be prev­ented. and actively promote amongst all those associated with their ac­tivities the high standards of safety consciousness and discipline that this principle demands.

ENVIRONMENT

Companies pursue in their operations progressive reductions of emissions, Effluents and discharges  of waste materials that are known to have a negative impact on the environment. with the ultimate aim of eliminating them;

aim to provide products and services supported with practical advice which, when used in accordance with this advice, will not cause injury or undue effects on the environment; promote protection of environments which may be affected by the devel­opment of their activities and seek continuous improvement in efficiency of use of natural resources and energy.

1.2  BASIC ELEMENTS OF HSE

• Assess health, safety and environmental matters before entering into new I activities and reassess them in case of significant changes in circum­stances.
• Require contractors working on their behalf to apply health, safety and environmental standards fully compatible with their own.
• Recognize the concerns of shareholders, employees and society on health, safety and environmental matters; provide them with relevant information and discuss with them related company policies and practices.
• Develop and maintain contingency procedures,  in cooperation with authorities and emergency services. in order to minimize harm from any acci­dents.
• Work with governments and others in the development of improved regulations and industry standards which related to health , safety and environmental matters.
• Conduct or support research towards the improvement of health, safety and environmental aspects of their products. Processes and operations . 
• Facilitate the transfer to others. freely or on a commercial basis. of know­  how developed by companies in these fields

The responsibility for the quality of the local EP operational practice rests fully with the Management of the Operating Company, Against the back­ground of the available technology. the local culture and the developments in the national regulatory scene. local management is in the best position for appropriate Implementation of the above guidelines.

Experience over the years has demonstrated that proper management of Health, Safety and Environmental Conservation requires from Company Management attention similar to that given to other disciplines, such as Engineering, Operations. Finance. Planning. etc. For instance, high stand­ards of safety in engineering and throughout its operations and of clean -u. housekeeping should be Management objectives pursued with equal vigor as cost-effectiveness in operations.

In order to achieve a significant improvement in safety performance. a programmed for Enhanced Safety in EP operations worldwide was initiated in January 1984 with the full support of EP Management. Key elements of this structured approach are:

1.2.1 Visible Management Commitment To Safety: This is the most important single feature. Without initiative and continued support from manage­ment no safety effort can survive. The management of safety has to be seen as an essential part of a manager’s daily responsibilities, along with others such as sales. production, cost control, profitability and mor­ale.

1.2.2 Sound Safety Policy: Each company should develop its own safety policy to meet its own particular requirements. An effective safety policy will be concise. easily understood and available to everybody.

1.2.3 Safety To Be A Line Management Responsibility: In some companies the belief may still exist that the responsibility for safety lies mainly with the Safety Department or the safety officer. This is quite wrong.  The Safety Department has a vital role to play as a specialist adviser, but it can be neither responsible nor

1.2.4  Accountable For Safety Policy Or Performance. This responsibility lies with line management from chief executive to every level of supervisor.

1.2.5 Competent Safety Advisers : The role of the Safety Department is to advise, co-ordinate and monitor safety matters.  To do so effectively, it must contain adequate expertise, and be freely available to management at all levels. The Safety Department is normally staffed with safety profes­sionals and line staff on assignment.

1.2.6 High, Well Understood. Safety Standards: The establishment and application of safe technical practices is a fundamental requirement for good safety performance. The success of these standards, which include 0per­ating procedures. safety rules and regulations. standards of housekeeping, etc., depends on the extent to which people abide by them. A man­ager or supervisor must act when standards or rules are not followed, . otherwise the credibility of the standards will be in doubt.

1.2.7 Techniques To Measure Safety Performance: The lost time injury (LTI ) frequency rate is one measure of safety performance. Details of this and other criteria used can be found in the 'Guide for Reporting Accidents and Injury Data.

1.2.8  Realistic Safety Targets And Objectives: The setting of safety performance targets that are seen to be both reasonable and achievable is essential and should be included in the company's safety plan. Typically a certain percentage annual reduction in frequency rate can be a target while the long-term objective is to achieve an accident-free performance. Clearly the target for fatalities, both for company and contractors' employees should be zero.

1.2.9 Audits Of Safety Standards And Practices: Regular audits of performance versus standards are necessary to satisfy. Management on the actual quality of its operations. Efforts should be made to increase the effec­tiveness of auditing by structuring the content, coverage and participa­tion of each audit and by the adoption of procedures to monitor timely implementation of audit recommendations. In addition, there should be auditing for unsafe acts and conditions.

1.2.10 Effective Safety Training : An Enhanced Safety Management program requires a concentrated. effort to ensure staff are made fully aware of the program and of the philosophy behind it. Achieving acceptance of the philosophy down the line and by contractors is the biggest challenge for management. A major program of training sessions, presentations, workshops and discussions is required.

1.2.11 Thorough Investigation And Follow-Up Of Injuries And Incidents: The res­ponsibility {or accident investigation lies with line management not with the Safety Department. The main question that management should answer is: "What failed in our management system that allowed this accident to occur.

1.2.12 Effective motivation and communication: The success of an Enhanced Safety Management program depends on people - how they are mo­tivated and how they communicate with each other. Communication starts with senior managers who must be willing to devote sufficient time and attention to convince the organization of the importance of safety, and continues through out the organization so that supervisors at every level are communicating safety directly to their subordinates.

Safety should be given the same priority and managed In the same way as  productivity and cost control. Activities should only be undertaken when a safe manner has been established for execution. It is only through active and visible Management commitment to attainable goals for safe and clean prac­tices that the commitment of the workforce and of the lower management! supervisory levels. essential for success, can be expected.

As detailed in the following Sections, safe and clean practices require proper engineering design, adequate procedures and dedicated training. The Sa­fety / Environment department staffed by specialist personnel and line staff on assignment, assists and advises Management and technical departments in their line responsibility for safety and the environment. The department also assist with necessary in-house design reviews, performance analysis and monitoring, review and updating of safe design and operating procedures, hands-on training, etc. and develops and implements separate programs to achieve an attitude of safety/environmental consciousness amongst  employees.

The company occupational health focal point or occupational health depart­ment advises Management in their line responsibilities for occupational  health and assists Management with respect to the implementation of an  occupational health program' consisting of ,two key elements: health pro­tection and health promotion. Both Occupational Health and Safety/Environ­mental departments should report directly to Company Management.

Every effort should be made to minimize occurrence of accidents and occu­pational diseases by preventive measures. However, in the event of an ac­cident occurring, Company contingency plans and emergency measures should aim at limiting the consequences as far as possible. Detailed proce­dures are then activated to safeguard life, assets and the environment. Reg­ular exercises and drills will ensure the competent, action of staff during such circumstances. Technical back-up as advice, guidance, training or  assist­ance on health, safety and environmental control management is available from functional sections in the Health, Safety and Environment department , which can draw a1so on further corporate expertise ( toxico­logical, ecological, medical, occupational hygiene, etc.).         

1.3 THE INTERNATIONAL REGULATORY SCENE

Governments worldwide have become increasingly aware of their responsibilities to protect their citizens and environments against undue hazards and pollution. As a consequence, the regulatory field is in a state of continual change.

The petroleum industry has created several agencies to formulate and re­present the industry position in international developments, i.e, E&P Forum, OCIMF, IPIECA and CONCAWE (see GLOSSARY OF ACRONYMS) which have come to

play an important role in the field of health, safety and envi­ronment. The industry has published many guidance documents which have been made available to governments and to the public, These documents can influence governmental attitudes and regulatory activities, Internationally,  IMO, ILO and UNEP are the leading worldwide agencies with regulatory impact. with bodies like EEC and NW European Conference, forming a re­gional substructure. The IMO is a UN legislative body for maritime matters. Located in London it has a membership of some 120 governments.

 Subjects covered by IMO  activities relating to exploration and production have been:        

• Maritime Safety Committee: Safety of Life at Sea Convention (SOLAS), Safety Code for Mobile Offshore Drilling Units (MODU), Safety Zones, Emergency 'preparedness, Survival! Training, Life-Saving Appliances Certification of Crews, etc.
• Marine Environmental Protection Committee: MARPOL, Oil/Water Monitors,  Ballast -Water Reception Facilities. Use of Dispersants, Dis­charges from Offshore Platforms. etc.

The International Labour Office (ILO) in Geneva, contributes mainly to the health and safety regulatory field. Safe conditions at the work place. safety codes. reporting and accident statistics, are major areas of concern. Its influence is towards providing national labour unions with goals, standards, codes of practice. etc.

UNEP is the UN agency to promote worldwide environmental awareness and protection. Regional action plans to unite nations in the protection of a com­mon sea area have been initiated from its Geneva office, e.g. for the Medi­terranean, the Gulfs area. the South China Sea, and the Caribbean. The UNEP Paris office for 'Industry and Environment' provides, in close co-operation with industry. active guidance to governments on issues of environmental concern, such as the environmental effects of drilling mud discharges, the use of dispersants in oil spill combat and acid rain.

At the regional level, in several areas of the world, governments have come together to jointly agree on measures that will improve the quality of life in their area of concern. Examples are : codes of  safe working practice in industry , training and certification requirements, emission limits, requirements for environmental impact assessment, the identification of  blacklisted substances.

Where possible, the petroleum industry endeavors to provide timely technical recommendations. This is normally done through contributions from, for instance, E & P Forum, OCIMF or CONCAWE. Sometimes, however, there is also dedicated regional industry co-operation which can address specific concerns, such as the North Sea Operations’ Clean Seas Committee.

Whatever the international / regional arrangements may be, it remains the prerogative of the national government to set its own standards and requirements for industry operations  within its jurisdiction. Major accidents, such as Piper A Alexander kielland “ Exxon Valdez” and “ Ocean Ranger “ often trigger specific national precautionary measures such as increased stringency in certification requirements or emergency measures, special shipping lanes and requirements for unlimited compensation.

The Cullen inquiry into the Piper A disaster is having a major impact on the regulation of  the petroleum industry as a whole , particularly in the UK and Western Europe. It is also expected that the principles formulated by the Inquiry will affect the legislation for the petroleum industry in many other parts of the world.

These principles are:

1. The Industry Is Responsible For Its Own Safety Management.

       This Requires Competent management of the business in general, not technological solutions to specific problems.

2. The Regulator Should Set The Objectives To Be Achieved , Not Prescribe The Means To Achieve Them

• This approach requires the operator to identify the means to achieve the objectives, It  
• promotes a constructive dialogue and ensures that the objectives remain visible. It 
• encourages fit for purpose designs and procedures subject to constant pressure for improvement.

3.   The Operator Will Implement Safety Management Systems

The operator will be required to demonstrate that it has systems in place to manage the safety aspects of its business effectively, particularly  with respect to the safe design and operation of its installations, and to verify that the systems are safe design and operation of its installations, and to verify that the systems are working effectively.  The regulator will audit both the systems and the verification ( internal audit ) process.

4. All Installations Will Be Subject To Formal Safety Assessment

The operator will be required to demonstrate for each installation that ha­zards have been systematically identified and eliminated where possible and that the means to control the remaining hazards, including contingency plans, are in place

1.4   CODES AND STANDARDS FOR SAFE DESIGN AND PRACTICE

Codes and standards for safe design and practice are issued ( and sometimes enforced ) by a number of bodies. 

The intent is to aid the designer and to assure the operator and the public, that installations and operating practices minimize the risk of mishaps.

Design and operational standards and specifications are intended to embody the entire engineering knowledge and experience, within the framework of codes and regulations.  They provide the basis for a uniform minimum level of engineering quality, and serve as a reference level for the necessary audits.