1

PETRONAS TECHNICAL STANDARDS

HEALTH, SAFETY AND ENVIRONMENT

DOCUMENTING A HSE MANAGEMENT SYSTEM

AND HSE CASE

(GUIDELINE)

PTS 60.0303

JUNE 2006
Rev 1

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 2

PREFACE

Petronas Technical Standards (PTS) are based on the experience acquired during the involvement with the
design, construction, operation and maintenance of processing units and facilities. Where appropriate they are
based on, or reference is made to, national and international standards and codes of practice. The objective is to
set the recommended standard for good technical practice applied by PETRONAS in oil and gas production
facilities, oil refinery, gas processing, chemical plants, marketing facilities or any other such facility, and
thereby to achieve maximum technical and economic benefit from standardisation.

The information set forth in these publications is provided to users for their consideration and decision to
implement. This is of particular importance where PTS may not cover every requirement or diversity of
condition at each locality. The system of PTS is expected to be sufficiently flexible to allow individual
operating units to adapt the information set forth in PTS to their own environment and requirements.

When Contractors or Manufacturers/Suppliers use PTS they shall be solely responsible for the quality of work
and the attainment of the required design and engineering standards. In particular, for those requirements not
specifically covered, the Principal will expect them to follow those design and engineering practices which will
achieve the same level of integrity as reflected in the PTS. If in doubt, the Contractor or Manufacturer/Supplier
shall, without detracting from his own responsibility, consult the Principal or its technical advisor.

The right to use PTS rests with three categories of users:

1) PETRONAS and its affiliates.

2) Other parties who are authorised to use PTS subject to appropriate contractual arrangements.
3) Contractors/subcontractors and Manufacturers/Suppliers under a contract with users referred
to under 1) and 2) which requires that tenders for projects, materials supplied or generally
work performed on behalf of the said users comply with the relevant standards.

Subject to any particular terms and conditions as may be set forth in specific agreements with users,
PETRONAS disclaims any liability of whatsoever nature for any damage (including injury or death) suffered by
any company or person whomsoever as a result of or in connection with the use, application or implementation
of any PTS, combination of PTS or any part thereof. The benefit of this disclaimer shall inure in all respects to
PETRONAS and/or any company affiliated to PETRONAS that may issue PTS or require the use of PTS.

Without prejudice to any specific terms in respect to confidentiality under relevant contractual arrangements,
PTS shall not, without the prior written consent of PETRONAS, be disclosed by users to any company or
person whomsoever and the PTSs shall be used exclusively for the purpose they have been provided to the user.
They shall be returned after use, including any copies, which shall only be made by users with the express prior
written consent of PETRONAS. The copyright of PTS vests in PETRONAS. Users shall arrange for PTS to be
held in safe custody and PETRONAS may at any time require information satisfactory to PETRONAS in order
to ascertain how users implement this requirement.

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AMENDMENT RECORD SHEET

Chap. Section Description Issue Date Revision Date Approve

No. No. No. No. by:
(initial)
All All PTS 60.0205 1 June05 0 0 IGA
Documenting a
HSE
Management
System and HSE
Case
Chap. Section Description Issue Date Revision Date Approve
No. No. No. No. by:
(initial)
All All PTS 60.0303 2 June06 1 June IGA
Documenting a 06
HSE
Management
System and HSE
Case

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CONTENTS
PREFACE................................................................................................................................. 2
AMENDMENT RECORD SHEET........................................................................................ 3
CONTENTS ............................................................................................................................. 4
SUMMARY .............................................................................................................................. 7
1 INTRODUCTION............................................................................................................. 8
1.1 Background................................................................................................................... 9
1.2 Definition of a Management System ............................................................................ 9
1.3 Developing and Implementing the HSE Management System .................................. 10
1.4 Key Definitions .......................................................................................................... 10
2 PREPARATION AND DEVELOPMENT ................................................................... 12
2.1 General ....................................................................................................................... 12
2.2 Existing Quality Management (QM) Systems............................................................ 13
3 REVIEW POLICY AND OBJECTIVES ..................................................................... 15
4 Assessment of Criticality ................................................................................................ 18
4.1 Identifying HSE-critical Activities ............................................................................. 19
4.2 Specify Objectives of HSE-critical Activities and Means of Achieving Objectives ... 20
4.3 Define the Business Controls Needed to Assure that HSE Objectives are Achieved . 21
5 DEFINE SYSTEM REQUIREMENTS ........................................................................ 23
5.1 Organisation and Resources ....................................................................................... 23
5.2 Implementation Plan and Schedule ............................................................................ 25
5.3 System Appraisal........................................................................................................ 25
6 HSE CASES..................................................................................................................... 26
6.1 Guidelines for Preparation of the HSE Case .............................................................. 27
6.1.1 Management Commitment and Ownership of the HSE Case .............................. 29
6.2 Preparation of the HSE Case ...................................................................................... 29
6.2.1 Generic cases....................................................................................................... 30
7 DOCUMENTATION...................................................................................................... 31
7.1 Management Endorsement - Leadership and Commitment ....................................... 32
7.2 Preparation of the HSE MS Manual........................................................................... 33
7.3 Documenting the Case................................................................................................ 34
8 IMPLEMENTATION .................................................................................................... 36
8.1 A Culture Change ....................................................................................................... 37
8.2 Monitor Implementation and Operation of the HSE MS and HSE Cases.................. 37
9 ASSURANCE AND REVIEW....................................................................................... 40
9.1 Assurance of the HSE Management System and Proposed Corrective Actions and
Improvements ....................................................................................................................... 41
9.2 Management Review of the System and Proposed Corrective Actions and
Improvements ....................................................................................................................... 41
APPENDIX I - DOCUMENTING THE HSE MS Manual................................................ 43
I.1 Preparation of Part 1 - HSE Management System Elements...................................... 44
I.1.1 Section 1 - Introduction to the HSE Management System manual ...................... 44
I.1.2 Section 2 - Policy and strategic objectives .......................................................... 45
I.1.3 Section 3 - Organisation, responsibilities, resources, standards and
documentation................................................................................................................... 46
I.1.4 Section 4 - Hazards and Effects Management ..................................................... 48
I.1.5 Section 5 - Planning and procedures................................................................... 50
I.1.6 Section 6 - Implementation, monitoring and corrective action ........................... 52

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I.1.7 Section 7 - Auditing - including corrective action an improvement .................... 54

I.1.8 Section 8 - Management review - including corrective action and improvement55
I.2 Preparation of Part 2 The HSE Management System Activities Catalogue Activity
Record (Specification Sheet) ....................................................................................... 56
I.3 Preparation of Part 3 - References, Documents and Standards .................................. 57
I.4 Preparation of Part 4 - Shortfalls and Remedial Action Plan..................................... 57
APPENDIX II - SELF CHECK LIST FOR THE HSE MS............................................... 58
II.1 Reviewing the Documents: The HSE Management System Manual ......................... 58
II.1.1a Section 1a - Demonstrating leadership and management commitment ........... 59
II.1.1b Section 1b - Introduction to the HSE Management System Manual ..................... 59
II.1.2 Section 2 - Policy and strategic objectives .......................................................... 60
II.1.3 Section 3 - Organisation, responsibilities, resources, standards and
documentation................................................................................................................... 60
II.1.4 Section 4 - Hazards and effects management ...................................................... 61
II.1.5 Section 5 - Planning and procedures................................................................... 62
II.1.6 Section 6 - Implementation, monitoring and corrective action ........................... 64
II.1.7 Section 7 Assurance including corrective action and improvement................. 65
II.1.8 Section 8 - Management review - including corrective action and improvement66
II.2 Part 2 - The HSE Management System Activities Catalogue .................................... 66
II.3 Part 3 - References, Documents and Standards.......................................................... 67
II.4 Part 4 - Shortfalls and Remedial Action Plan............................................................. 68
APPENDIX III DOCUMENTING THE HSE CASE......................................................... 69
III.1 Preparation of Part 1 - Management Summary and Introduction ...................... 69
III.2 Preparation of Part 2 - Operation's HSE Management System .......................... 71
III.3 Preparation of Part 3 - Case Activities Catalogue.............................................. 73
III.4 Preparation of Part 4 - Description of Operation............................................... 75
III.5 Preparation of Part 5 - Hazards and Effects Analysis, Hazards and Effects
Register, HSE-critical Operations Procedures................................................................. 76
III.6 Preparation of Part 6 - Remedial Work Plan ...................................................... 80
III.7 Preparation of Part 7 - Conclusions and Statement of Fitness ........................... 81
APPENDIX IV THE HSE CASE CHECKLIST ................................................................ 83
IV.1 Part 1 - Management Summary and Introduction....................................................... 83
IV.2 Part 2 - Operation's HSE Management System .......................................................... 84
IV.3 Part 3 - Case Activities Catalogue.............................................................................. 85
IV.4 Part 4 - Description of Operation ............................................................................... 86
IV.5 Part 5 - Hazards and Effects Analysis, Hazards and Effects Register, HSE-critical
Operations Procedures.......................................................................................................... 87
IV.6 Part 6 - Remedial Work Plan...................................................................................... 91
IV.7 Part 7 - Conclusions and statement of fitness............................................................. 92
APPENDIX V - GUIDANCE FOR THE PREPARATION OF THE HSE
MANAGEMENT SYSTEM AND HSE CASE ACTIVITY SPECIFICATION SHEET93
V.1 Introduction ................................................................................................................ 93
V.2 What is an HSE Management System or Case Activities Catalogue? ....................... 93
V.3 Who should prepare the Activities Catalogue? .......................................................... 94
V.4 How are Business Processes and Activities Identified? ............................................. 94
V.5 To What Level should a Business Process be Broken Down? ................................... 95
V.6 How do you Know if an Activity is HSE-critical? ..................................................... 96
V.7 What Need to be Recorded for each HSE-critical Activity? ...................................... 97

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APPENDIX VI - GUIDANCE FOR THE PREPARATION OF AN HSE CASE

HAZARDS AND EFFECTS REGISTER.......................................................................... 105
VI.1 Introduction .............................................................................................................. 105
VI.2 What is a Hazards and Effects Register?.................................................................. 105
VI.3 Who should Prepare the Hazards and Effects Register? .......................................... 105
VI.4 What needs to be Recorded for each Hazard or Effect?........................................... 105

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SUMMARY

This PETRONAS Technical Standard is intended to provide guidance on the development,

introduction into a company, and documentation of a HSE Management System and HSE
Cases. Its target audience is those tasked with putting HSE MS and HSE Cases into practice
as well as managers who are responsible for providing the resources and for monitoring the
work. It is for use in preparing or subsequently improving a HSE Management System and
HSE Cases.

The material has been structured using a road map that simply follows the main steps
required of any OPU intending to implement the HSE MS and HSE Cases.

It should be read in conjunction with PTS 60.0101 HSE Management System Manual, which
provides the requirements for the HSE Management System.

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1 INTRODUCTION

This section of the HSE Manual provides guidance on developing and implementing
an HSE Management System in a PETRONAS Operating Unit / joint Venture
(OPU/JV). It is also aimed at helping in reviewing, updating, maintaining and
improving, the HSE Management System once implemented. The steps in the
implementation 'road map' shown in Figure 1.1 have been followed throughout.

Im plem entation R oad M ap

The HSE M S Chapter 1 In troduction and overview of H SE MS

Identify elem ents of H SE MS , evaluate

Preparation and And establish what changes or
Developm ent Chapter 2 Additions are needed
R ev iew existing policy and objectives,
U pdate or establish new ones as required.
Review policy and Identify facilities and operations which
Chapter 3 R equire a H SE C ase
objectives
Identify H SE critical activities inv olv ed in
The m anagement of H azards and Effects.
Assessm ent of Establish the m ethods and business
criticality Chapter 4 controls for each activity
Identify the resources, organization and
Schedule necessary to im plem ent the
Define system H SE MS and C ases. Identify requirem ents
Chapter 5 For the appraisal of the H SE MS to assure
requirem ent
That it is effective
For specific facilities / operations, apply
H EMP to all hazards, establish risk and
D em onstrate ALAR P. Establish the local
HS E Cases Chapter 6
H SE MS activities / tasks providing hazard
C ontrols. W ork with or involve contractors
As applicable H SE C ase
H SE MS Manual D ocument the local
D ocument the o/all Application of the
Docum entation Chapter 7 H SE MS developed H SE MS , activ ities
Per H SE MS Manual H azards and risk
Analysis
Put into place people, resources, procedures
And controls defined in the H SE Manual and
Im plem entation Chapter 8 C ase. Monitor progress and effectiv eness
Taking corrective actions as appropriate
Establish an assurance program for the
H SE MS and C ases. Perform assurance per
Assurance Chapter 9 program and follow up. Establish a m gt
And Review R ev iew program for the overall H SE MS .
Perform rev iews, recom m end and im plem ent
im provem ents
Fig 1.1

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1.1 BACKGROUND

Most OPU / JVs and contractors have put into place a type of policy framework for
improving HSE performance ('the Past' as shown in the diagram below). Many have
started to put into place quality- based Safety Management Systems and Safety
Reports especially after the promulgation of the legislation on Control of Industry
Major Accident Hazards- CIMAH, a daughter regulation under the Occupational
Safety and Health Act OSHA. At the same time, there has been a move toward
Environmental Assessment and Environmental Management Systems EMS (again
quality based) and formal consideration of Occupational Health Management via
Health Risk Assessment. This implementation section is aimed at those tasked with
bringing together the three strands of H, S and E into a single, common, integrated
HSE Management System as recommended by the Petronas Group ('the Future') (see
Figure 1.2).

This PTS is intended to assist the implementation of the HSE MS and HSE Cases in
PETRONAS OPU / JVs and it should be read in conjunction with PTS 60.0101 HSE
Management System Manual.

1.2 DEFINITION OF A MANAGEMENT SYSTEM

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A management system is defined as 'a structured set of controls for managing the
business'. The purpose of any management system is to ensure that the activities of a
company are planned, carried out, controlled and directed so that the business
objectives of the company are met. It should be understandable at the appropriate
levels in the company and documented so that it can be audited and verified as
effective. A management system should have a 'self-healing' quality or 'improvement
loop' within its construction. In simple terms it follows the basic Plan-Do-Check-
Feedback steps of any quality system. The PETRONAS HSE Management System
meets these requirements and consists of the main elements shown in Figure 1.3.

Figure 1.3 HSE Management System Model

Leadership and Commitment

Policy and Strategic Objectives

Organization, responsibilities
resources, standards and documentation

Hazards and effects management

Planning and procedures correction

Implementation monitor

Assurance Corrective Action and Improvement

Management Review Corrective Action and Improvement

1.3 DEVELOPING AND IMPLEMENTING THE HSE MANAGEMENT SYSTEM

Figure 1.1 shows the recommended steps in a 'road map' for developing and
implementing an HSE Management System conforming to the HSE Management
System model. Those OPU / JVs which have already built and implemented such a
system will need to repeat some or all of the steps periodically as part of their regular
review and update process to keep the system current and to introduce improvements.
The chapters in this PTS follow the steps shown in Figure 1.1. The actions required at
each step in the process are shown at the side of the 'road map' included at the start of
each chapter.

1.4 KEY DEFINITIONS

Definitions of key terms, used in this Section, are shown below. A glossary of all
terms used is attached.

The HSE Management System Manual: All essential elements of the HSE
Management System should be 'documented' in a HSE Management System Manual.

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The HSE Management System Manual is a company-wide-corporate-level document,

owned by the company's management. It has a similar status to other corporate
documents such as the financial Limit of Authorities Manual. The form of
documentation may be a printed book or an electronic data file for easy reference and
dissemination through Information Technology media. In the latter case a limited
number of registered paper copies should be printed for control purposes.

The HSE Case: The HSE Case is a facility or operation-specific demonstration of the
HSE Management System in action. It should show how the company's HSE
Management System objectives are reflected in practice and how local risk
management objectives are being achieved.

Both the HSE MS and the HSE Case are basically databases relating activities,
hazards and controls to meet company objectives. To apply necessary controls in
practice the Case and specific MS can be 'decomposed' to suit the various
organisational levels, using relevant database information.

The HSE Case should stand alone, concisely and clearly documented. References to
relevant supporting documentation are required and the HSE Case should provide a
readable digest of the main findings of all formal HSE assessments. The HSE Case
provides a 'route map' for anyone needing more information. It should record in a
simple, methodical and auditable manner all information relevant to the safety and
health of people, the conservation of the environment, and the protection of assets as
related to the facility or operation.

In addition to referring to a combined assessment of HSE aspects, extracts of the

HSE Case may be made to address the various aspects of HSE separately, according
to local OPU requirements, regulator demands or the like, e.g.:

a Health Risk Assessment Report

a Safety Case.

an Environmental Assessment.

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2 PREPARATION AND DEVELOPMENT

Implementation Road Map

The HSE MS

Preparation and 1. Collect and evaluate the elements of HSE MS

Development which already exists

2. List the policies, procedures, definitions of

responsibilities and plans relating to the
Review policy and
management of HSE which already exists
objectives
3. For existing Quality System, check:
Assessment of - accountabilities (responsibilities plus
criticality authorities) have been defined

- a competence assurance system is in place

both for OPU / JV staff and contractors
Define system
requirement - procedures are properly catalogued and are
up to date

- assessment for completeness and quality of

HSE Cases all information gathered. Identify any gaps
and, if significant, take appropriate action
e.g. prepare new policy orp procedure

Documentation

Implementation

Assurance
And Review

Fig 2.1

2.1 GENERAL

All OPU / JVs have a considerable amount of existing information relating to how
they manage HSE within their operations. None of this should be wasted. One aim of
the HSE Management System is to put all this information into a logical structure,
eliminating unnecessary overlap and filling any gaps, as shown in Figure 2.2. Thus
the starting point in preparing to implement any HSE MS or indeed any Management
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System is to take stock of what is available, evaluate its quality and review its
usability.

Figure 2.2 Putting the elements into a structure

Security
Policy
HSE Continuous
Road
Safety Alcohol Policy Policy Improvement
Plan & Drugs Mgt.
Policy
Audit policy
Plans link
Safety Process
Drills Safety (HSE Cases)

Task

No Structure Structure
The full suite of documents included in HSE Manual provides established OPU / JVs
with a suitable starting point for developing its specific HSE MS.

Guidance and examples relating to the various and necessary management system
elements can also be found in many existing Group and industry documents e.g.

PETRONAS Guidelines for Health, Safety and Environmental Planning in a New

Venture (under preparation). In addition to specific guidance this report will also
list a number of Group HSE publications relevant to new ventures.

PTS 60.0101 Health Safety and Environment Management System Manual

OGP Health Management Guidelines for Remote Land Based Geophysical

Operations (Ref. 5)

ISO 14690 (draft) HSE Management System Guidelines for Offshore Industry
(Ref. 6).

2.2 EXISTING QUALITY MANAGEMENT (QM) SYSTEMS

OPU / JV s with a quality system already in place, in accordance with an approved

quality standard, should have already developed many of the business controls and
basic feedback loops needed by the HSE MS. They should furthermore be clear as to
the importance of the role of procedures and of controlled documents in a quality
system. Most importantly the OPU / JV, will have few illusions as to the efforts
needed to implement the HSE MS and will be clear as to the benefits that can accrue
from such a quality based system.

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Experience has shown however that whilst quality management systems do have
many attributes needed for the HSE MS, they often lack the focus needed to
safeguard the operation adequately. They do not address hazards and effects nor in all
cases do they properly assess whether procedures are really required. There can be a
tendency toward a bureaucratic and over-proceduralized system.

The real test for procedures in the HSE MS and the hazards and effects analyses will
come during the activity since it is then that the worth or otherwise of a procedure in
regard to its usefulness in managing hazards and their effects will be assessed. Real
care should be taken, not just to assess whether existing procedures are up to date and
where they fit in the HSE MS but also to challenge whether they are really needed
and are contributing to the management of a HSE critical element of the business.

All relevant information and documents once gathered should be reviewed,

evaluated, applicable parts noted for use and any necessary revisions to existing OPU
documents carried out.

Having established the up to date list of policies, information regarding objective

setting, procedures (the controlled document library), agreements with government
agencies (covenants, etc) assess any gaps. If these gaps are significant then a new
policy or procedure may be required.

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3 REVIEW POLICY AND OBJECTIVES

Implementation Road Map

The HSE MS

Preparation and 1. Review existing policy and objectives in the

Development overall context of required risk management and
update as needed

2. W here no adequate policy exists, or where there

Review policy and
are gaps, create new or additional policy after
objectives having obtained the clear backing and
endorsement of Management
Assessment of
3. Update existing HSE strategic objectives and
criticality establish new ones where needed

4. Revisit policies once strategic objectives have

been accepted by management iterate
Define system between them
requirement
5. Identify critical facilities and operations that
require a HSE Case

HSE Cases 6. Establish clear, specific and practical timing and

planning assumption for both HSE MS and HSE
Case implementation

Documentation

Implementation

Assurance
And Review

Fig 3.1

The HSE Management System is a risk based objective setting system. The OPU / JV
management set its own specific goals against which the effectiveness of the HSE
Management System will be measured.

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The HSE Policy states intentions and principles, and provides a guide to managerial
action which documents the course to be adopted by the OPU / JV regarding it's
health, safety and environmental management. Strategic Objectives set goals which
the OPU / JV wishes to achieve and provide a basis for judging progress and
achievements.

In the past, policies have often been developed in isolation from the risk of the
operation (perceived or real) resulting in a mismatch between management wishes
and line implementation. It has been unclear how management policy on HSE is to be
implemented.

In establishing and/or revising the HSE Policy, reference should be made where
appropriate to the following:

- Petronas Group HSE Policy Statements

- Regulatory and Legal Requirements

- Linkage of HSE policies and objectives to the needs of the business, e.g.

- asset integrity

- loss prevention

- Specific HSE aspects which are known problem areas, e.g.:

- Drugs and Alcohol

- Waste management

- Security

- Road Safety, etc

HSE risk concentrating on those aspects which could impact the performance or
viability of the company, eg:

- continuous discharges (venting, flaring)

- pollution control

- asset damage and loss

- societal or reputation risk.

The OPU / JV HSE Policy should strongly underline management commitment to the
reduction of HSE risk to a level that is as low as reasonably practicable (ALARP) and
emphasise the company's pledge to continuous improvement of HSE performance. It

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is important that there is a consistency between the HSE Policy and identified
business risks.

(Guidance on the content of an HSE Policy and the setting of Strategic Objectives is
given in PTS 60.0101, Health Safety and Environment (HSE) Management System
Manual). It has been found particularly helpful to use the 'Risk Matrix', PTS 60.0401
Hazards and Effects Management Process, when considering the level of HSE risk. A
suggested matrix is given in Figure 3.2.

Figure 3.2 The risk assessment matrix

Consequence Increasing Probability

A B C D E
Never Heard Incident Happens Happe
Environ heard of of has several ns
People Assets Reputatio
n in incident occurred times severa
ment industry in in our per year l times
industry company in co. per
year in
locatio
n.
No No
No effect No impact
injury damage

Slight Slight Slight Slight

injury damage effect impact

Minor Minor Minor Limited

injury damage effect impact

Major Localised Localised Considera

injury damage effect ble impact

Single Major Major Major

fatality damage effect national

Multipl Major
Extensiv Massive
e effect
internatio
e damage nal
fatalities

In reviewing corporate policies and objectives, management will need to consider

overall risk levels and identify those operations and installations, required by the
OPU / JV, to have a HSE Case. It is best to concentrate on the highest risk areas first
and to establish a priority ranking of those facilities and operations that represent the
highest risk exposure to the OPU / JV; in terms of risk not only to people and their
safety but to the environment, to health generally and to the long term reputation of
the OPU / JV. At this stage what is required is a ranked short list of facilities and
operations that will have a HSE Case prepared together with an estimated completion
date and an agreed intent to allocate necessary resources.

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4 ASSESSMENT OF CRITICALITY

Implementation Road Map

The HSE MS

Preparation and
1. Establish an understanding of the various
Development activities and processes carried out in the
business

Review policy and 2. Test each activity identified to see if it is

objectives involved in the management of hazards and
effects

Assessment of 3. Reject those activities that are not HSE critical

criticality
4. Define the objectives of each HSE critical
activity

Define system 5. Describe the methods that are intended to be

requirement used to achieve the objectives if each HSE
critical activity

6. Describe the business controls per HSE critical

activity intended to be used to verify that the
HSE Cases activity is being properly managed

Documentation

Implementation

Assurance
And Review

Fig 4.1

Managing hazards and effects (risk) is already a routine part of day to day business
but may not be recognised as such. The HSE MS is concerned with providing
assurance that HSE risk is being managed to a level consistent with the intentions of
the HSE policy within the business. This is best achieved by quality managing those
normal business activities which when performed correctly, contribute to success

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both in terms of the business and of HSE management. Such activities are termed
HSE-critical within the HSE MS. When performed less than satisfactorily they
contribute to a loss of local control and to a potential accident (near miss) or in
extreme cases to a complete breakdown of control with much higher consequences
(or effects); generally recognisable as a serious accident. A very large amount of OPU
/ JV time and effort and hence cost is consumed annually in clearing up after such
events which are always a result of some hazard or effect being either mismanaged or
overlooked. The HSE MS recognises this and is built on the premise that effective
Health, Safety and Environmental management is best achieved by proactively
managing the operation's hazards and effects.

In general, for the HSE MS any activities which:

1. Identify hazards and effects

2. Assess their significance

3. Provide Control for hazards and effects or

4. Provide Recovery Preparedness in the case that control is lost are HSE-critical.

These four steps represent the Hazards and Effects Management Process (HEMP).
This is described in PTS 60.0401 Hazards and Effects Management Process.

Reasonable assurance that HSE-critical activities are being performed to

requirements should be provided by applying appropriate business controls as
described in the respective company business model.

4.1 IDENTIFYING HSE-CRITICAL ACTIVITIES

All activities should be described in terms of 'what is done' rather than 'how it is
done'. In the HSE MS the emphasis is on establishing and understanding the correct
way of carrying out the activities that are critical to the management of hazards and
effects. This understanding may be achieved by a business process analysis, by
reference to a business model or a combination of these. Criticality assessment in the
HSE MS is achieved by use of the Hazards and Effects Management Process (HEMP)
in the form of a number of questions:

i. Does this activity identify one or more hazards during the process of its
performance / execution? In other words, do you need to consider what can go
wrong i.e. is there any unacceptable outcome potentially associated with a
deviation / unexpected occurrence?

ii. Does this activity assess a hazard(s) for its effect(s)? In other words, do you ask:

a. Whether the consequence is acceptable should a deviation from plan happen

or something goes wrong?

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b. Calculate what is the probability / chance that something will go wrong?

c. Assess how severe the effects or consequences might be?

iii. Does this activity control a hazard(s) and or its effects? In other words, is this
activity one meant to prevent something from going wrong the outcome of which
might either be harmful to people, environment, assets or reputation of the
company?

iv. Is this an activity that recovers from a (initial) loss of control / deviation from
plan or mitigates / reduces its effects i.e. provide recovery or emergency
response in any form?

It is important to note that the so called 'white collar' planning activities that
provide essential controls needed during later phases of the operation are
definitely HSE-critical. They set the scene for an operation. They make provisions
for measures, by sound planning and design, that can manage the hazards
identified with an increased likelihood of an accident - free operation. For
example a seismic programme in a rain forest environment must make
preparations well ahead of time to bring both environmental and societal impacts
to the lowest practicable level. This is a planning activity and if not adequately
addressed can have serious repercussions not just on the local Petronas company
and contractors but internationally.

It is worth noting also that control activities like (HSE) audit and checking are
invariably not HSE-critical. They are important to the corporate management
system's integrity and represent vital controls within it. Some HSE Management
System owners do however require such activities to be included and quality
managed within the HSE MS. This means that management have intentionally
extended the scope of the HSE MS beyond the core 'critical few' activities. This
has in the past led to debate that it is possible therefore to define all activities as
HSE-critical.

Take care, the more activities included, the more bureaucratic it will become.

The HSE MS uses the strict definition of criticality to limit bureaucracy and
paper. Individual OPU/JV management must decide how extensive the system
needs to be. The advice is to start SMALL.

4.2 SPECIFY OBJECTIVES OF HSE-CRITICAL ACTIVITIES AND MEANS OF

ACHIEVING OBJECTIVES

The objective of a HSE-critical activity is to state its role as part of the management
of a hazard(s) and effect(s). It is in effect a justification of its criticality of why the
activity has been selected for inclusion in the HSE Management System.

In concluding that an activity is HSE-critical, it will have been agreed which of the
step(s) of the Hazards and Effects Management Process (HEMP) it covers. The

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hazard management objective should explicitly state which HEMP step(s) are
relevant.

Examples of objectives could be:

to identify new hazards and their effects

to identify the threat(s) that could release a known hazard(s)

to assess an identified hazard(s) for its effect(s)

to assess whether an identified hazard(s) can be eliminated using the basic

principles of hazard management

to establish a mechanism(s) / method(s) for Control (ling) residual hazards

to establish Recovery preparedness measures to recover from the release of

hazards or mitigate against its effects

Having defined what part an activity plays and why, it is then possible to describe
how the goals or objectives of the activity are to be achieved. These are the means or
methods by which the hazard management objectives of the identified HSE-critical
activities are achieved.

Examples of methods used to achieve objectives could be:

development and use of procedures to identify and assess hazards and effects, e.g.
execution of health risk assessments, HAZIDs and HAZOPs, environmental
assessments

development and use of plans and procedures to provide controls on hazards and
effects

development and use of plans and procedures to provide recovery measures in the
event of loss of control of a hazard or of a known effect

use of competent staff and contractors.

4.3 DEFINE THE BUSINESS CONTROLS NEEDED TO ASSURE THAT HSE

OBJECTIVES ARE ACHIEVED
Business controls for individual activities are established by those responsible for the
HSE-critical activity. These controls must be effective to meet the specified (hazards
and effects management) objectives.

The level of control will vary according to the criticality of the activity, the
competence requirements for the tasks involved and the degree to which the
circumstances can be predicted. Accountabilities for activities or tasks, and their
verification and authorisation (where considered necessary) should also be recorded.

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Examples include: - use of standards and codes, audits, review by department heads,
line supervision, site inspections and certification by third parties, etc.

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5 DEFINE SYSTEM REQUIREMENTS

Im plementation Road Map

The HSE MS 1. Strengthen the HSE organization as needed per

the implementation plan

Preparation and 2. Check if authority levels match HSE

Development responsibilities

3. Check if accountabilities are properly described

Review policy and in job description. If not, amend them and obtain
management endorsement
objectives
4. Define schedule for HSE MS implementation
Assessment of 5. Specify critical facilities, installations and
criticality operations requiring HSE Case

6.
Agree with Asset Holders and with Operations
Define system groups who are accountable for each case
requirement
7. Establish necessary resources, people, budget
and allocated time anticipated

HSE Cases 8. Appoint people and other required resources as

per implementation plan

9. Define schedule for each HSE Case

implementation with HSE Case developers and line
department
Documentation
10.agree formal and informal reporting relationship
to make the most efficient and effective usage of
allocated resources

Implementation 11. Agree with management on necessary

milestone reviews with respect to HSE MS and
HSE Case

Assurance 12. Appoint custodian for the HSEMS

And Review
13. Establish the organization for implementing the
HSE MS and maintaining it once implemented

Fig 5.1

5.1 ORGANISATION AND RESOURCES

To make the system work requires:

adequate people and other resources to be allocated to it with an appropriate

organisation structure and responsibilities defined

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a plan and schedule for initial implementation and for ongoing maintenance of the
system to be made and then followed

appraisal of the system to ensure effectiveness and to generate improvements to

keep the system current with changing circumstances and business needs.

HSE Cases are important to the full implementation of the HSE MS. They fulfil a
dual role:

- Firstly, they are a means of demonstrating the effectiveness of the overall HSE
MS by assessing the hazard controls in place and the resultant risks associated
with HSE incidents in specific facilities or operations and are part of the appraisal
process.

- Secondly, they clarify the links between hazard controls and the activities and
tasks which are necessary to provide and maintain those controls. They are a
means of deepening or extending the definition of the HSE MS locally and
providing the basis for local implementation of the HSE MS.

Whilst the HSE MS provides a quality structure within which all the existing HSE
management techniques and tools will fit, a concerted effort is usually required to
implement this into any OPU / JV as it will perceived as yet another add-on to an
already very challenging working environment.

It is usual for the HSE Manager or Adviser to act as custodian of the HSE MS on
behalf of the Chief Executive and for him or her, to be tasked with establishing the
HSE MS.

There is generally no distinction in the management of either Health, Safety or the

Environment. The same principles apply, although some differences may arise in
required techniques. It is vitally important that high quality advice is available to
assist the line in understanding the HSE issues they are accountable for at the
operational level. This requires HSE department / personnel to proactively work with
the line such that both the HSE as well as production goals are achieved.

Defining the organisation within an OPU / JV does not generally represent a problem.
There is almost always more than sufficient information. It is essential that the
responsibilities for HSE-critical activities, as described, are truly reflected in the
authority levels given and described in the relevant job descriptions.

Finally the required resources to implement the HSE MS and necessary HSE Cases
on the ground requires management commitment in the allocation of the already
scarce resources.

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5.2 IMPLEMENTATION PLAN AND SCHEDULE

Using relational database techniques, it is now possible to make efficiencies and to

reduce some of the routine and time consuming activities involved in preparing the
HSE MS and HSE Case.

A schedule is given below that shows realistic timings for the HSE MS and first HSE
Case using relational database techniques based on actual experience.

Figure 5.2 Schedule for HSE MS based on SMS experience

HSE Management System and HSE Case Programme

Months Man
HSE MS 1 2 3 4 5 6 7 8 9 10 11 12 months
Part 1 Policy, System Requirements 2
Part 2 Activity Catalogue 3
Part 3 Reference Docs 2
Part 4 Remedial Action Plan 1
Sub-total 8
HSE Case
Part 1 Management Summary 1
Part 2 Operations HSE MS 2
Part 3 Activities Catalogue 4
Part 4 Operations Description 6
Part 5 Hazard Analysis 6
Part 6 Remedial Work Plan
Part 7 Statement of Fitness
Sub-total 19

Ongoing support/Corporate Guidance

This schedule is typical for a major OPU/JV and a unique, large and complex facility.
It is also assumed that there is little learning available from previous Cases. This is
obviously not the situation with operational OPU/JVs and a much reduced effort can
be expected where generic data is used though the involvement of the users in the
preparation remains critical to the success of its implementation i.e. ownership to the
document and thus their applications and use

In areas where the operations are similar or facilities are of a standard design much of
the information should be reusable from Case to Case with the information taken
through with the potential users in the new facility for ownership to the documents.
If this is done the exercise will not be meaningful and the Case will fail to meet audit
criteria.

5.3 SYSTEM APPRAISAL

To ensure that the HSE MS functions effectively, it needs to be regularly and

routinely appraised at various levels. The most routine means of appraisal is to
monitor- the systems performance indicators by the system custodian and activities
by those accountable for those activities.

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This is described more fully in Chapter 8 Implementation. More formal means of

appraisal are by means of the audit and management review processes. These are
described more fully in Chapter 9-Assurance and Review.

6 HSE CASES

Im plem entation Road Map

The HSE MS

Preparation and 1. Define the terms of reference for the Case

Development
2. Define the activity task model. If there is
none available or the level of detail is
Review policy and insufficient, then use the business process
analysis and task breakdown technique to
objectives
develop one for the facility or operation

3. Review documents quality and relevance to

Assessment of
the facility and determine what is m issing
criticality
4. Apply Hazards and Effects Management
Process (HEMP) to establish risk levels in the
operation demonstrate ALARP
Define system
requirement 5. Include provisions in the contract regarding
contractors involvement in preparing HSE
Cases either when the Case is prepared
jointly or fully contracted out
HSE Cases
6. Issue HSE Case signed by the Asset Holder
or most senior person accountable for the
facility

Documentation

Implementation

Assurance
And Review

Fig 6.1

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Figure 6.2 Diagram showing top down versus bottom up Case development

Avoid Bottom up
LTIs
& top down Top down
& bottom up
Task focus

Objective Activity & task focus

Setting

Activity focus
Avoid
fatalities Top down
Low High

Complexity of the operation/facility

The question sometimes arises as to whether to develop the Case top down using highly
analytical techniques or bottom up with workforce involvement from the outset. There is no
fixed rule for this but one representation that provides a broad indication is given in Figure
6.2 Generally speaking the objective setting (shown as the vertical axis) determines the level
of detail required and the complexity of the operation or facility requiring the Case (the
horizontal axis) the emphasis required by 'top' as against other supervisory levels of
management. This in no way is meant to infer that senior and middle management
commitment can be lacking from either approach; it cannot.

6.1 GUIDELINES FOR PREPARATION OF THE HSE CASE

The purposes of the HSE Case are:

- to provide assurance of the effective working of the HSE MS at a site specific

level.

- to provide a simple, methodical and auditable reference document containing all

information relevant to the protection of people, the environment, assets
including resources and the reputation of the company

- to serve as a vehicle for the assessment of risk to the operation and to the business
as a whole, both at a local and also at an international level giving added
assurance that the reputation of the company is being (properly) protected.

The Case should be a 'living' document (effectively an OPU / JV or plant HSE

Management System) that is added to and amended throughout the life of the
operation. The Case can be used to demonstrate that:

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the company has, for the operation, an effective HSE Management System

all major hazards in and the effects on the operation (People, Assets, the
Environment and the company's reputation) have been identified, assessed,
controlled and recovery preparedness measures in place; and that

the risks have been evaluated and measures taken to reduce risk to a level that is
'As Low As Reasonably Practicable' (ALARP).

It also documents the programme of formal HSE assessments conducted by the

OPU/JV to assure itself that the operation meets its HSE risk objectives.

The HSE Case should demonstrate how the objectives of the OPU/JV HSE
Management System are being achieved. To accomplish this demonstration, the HSE
Case should clearly establish the intention of the operator with respect to:

compliance with all relevant statutory requirements

compliance with all relevant company requirements

identification and management of all hazards and effects with the potential to
cause a major accident, major* health impact or environmental damage

The word 'major' used here is not meant to infer that other more minor risks are to
be neglected merely that the minimum requirement is to consider major events.
The onus must be to set the objectives of the HSE Case and then to show clearly
that they have been met.

evaluation and reduction of risk to those affected by the operation to a level that is
as low as reasonably practicable (ALARP)

audit and review its operation with the intention for continuous improvement of
its HSE MS and HSE performance.

This should be presented in the form of specific objectives and related performance
and acceptance criteria (can be codes and standards) in use.

The HSE Case should describe the level of risk that is actually being achieved in
comparison with corporate risk objectives and how this is being measured and
monitored.

It should describe how the gap between intention and achievement is to be

eliminated, including the timeframe for this.

The HSE assessments undertaken as well as the results obtained should be described.
Findings should be measured against the HSE Management System objectives using
the performance and acceptance criteria established. Any shortfalls should be
recorded.

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The HSE Case should demonstrate that the operator is making efforts to continuously
improve on the management of HSE. The HSE Case should contain a plan to address
all shortfalls (gaps between intention and achievement) found in the HSE MS or
during the course of its preparation weaknesses in hazard control and or recovery
preparedness and their impact increasing the level of operating risk. This plan should
identify and prioritise all action items, establish accountable parties and target
completion dates.

The HSE Case needs to demonstrate that a risk management programme is in place. It
should establish the limits of safe operation permitted, if defences are reduced or
removed. It should also define safe limits during periods of escalated risk affecting
either the likelihood or consequence of an incident taking place. Preparation of a HSE
Case should be viewed as an opportunity to take stock as to the adequacy of the
operation and its management controls. The intent should be for people close to the
operation to have a hard look at things, where necessary recording any shortfalls or
deficiencies. It also presents an opportunity to clarify relationships with, and
responsibilities of, outside parties and record them for the benefit of all.

6.1.1 Management Commitment and Ownership of the HSE Case

Senior management commitment to HSE management should be the main driving

force behind preparation of a HSE Case but an effective HSE Case can only be
prepared by those directly involved with the specific facility or operation and owned
accordingly by those responsible for it. Thus line commitment reinforced and
encouraged by senior management is vital. The Case should be fully endorsed by, and
issued under, the signature of the asset holder or most senior person who is directly
accountable for the facility or operation.

6.2 PREPARATION OF THE HSE CASE

The first step in the preparation of the HSE Case is to define the terms of reference
that will apply drawing heavily on the planning previously created with management
support. Thereafter the basic activity model (activities and tasks) and hazard
hierarchy selection for the specific operation or facility should be defined.

The HSE Case should make use of existing documents used to manage HSE in the
facility or operation. This reference material should be listed, assembled and
reviewed for content and currency. Areas of obvious overlap or gaps should be noted
for remedial action.

The quality and content of all existing documentation should be reviewed (for
example reference documents, drawings, 'as-built', P&ID(s), vendor information,
information on chemicals and possible toxic agents, waste stream information,
quality information, files for action such as transport request files, permits to work,
governmental dispensation certificates, bills of lading, contracts).

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Many operations are carried out by contractors on behalf of the OPU/JV. In such
cases the HSE Case will be prepared by both OPU/JV and contractor, dependent
upon the nature of the contract and the operation. It must be recognised that the
OPU/JV and PETRONAS Group remain exposed when conducting operations
through the services of a contractor and that it is incumbent upon the company to
satisfy itself as to the competence and fitness for purpose of the contracted operation.

A joint and co-operative approach in no way releases the OPU/JV from the obligation
to protect itself contractually and to require by contract a Contractor to either assist in
preparing a HSE Case or to provide the entire HSE Case (when the operation is
wholly contracted out).

To assist OPU/JV in preparing HSE Cases for such contracted operations an

indication is given in this guidance material as to the contractor involvement
anticipated in the various parts of the HSE Case.

GENERIC CASES

A relational database technique (THESIS) could be sourced to provide the capability

to reduce the cost and time of producing a HSE case. It is also a possibility that
standard generic Cases could be developed per area of activity so that these could
be utilised wherever there are similar activities. Core HSE Cases can also be
produced for subsequent development into full HSE Cases.

The contents of the HSE Case are described in Appendix III. Also refer to
Contractor's Note at the end of each guidance section and to the Self Check listing
(Appendix IV).

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7 DOCUMENTATION

Implementation Road Map

The HSE MS

Preparation and HSE MS Manual

Development
1. Document the HSE MS ensuring that all
critical activities have been recorded and level
Review policy and of control is necessary and sufficient
objectives 2. Issue the final document once signed by the
MD / CEO
Assessment of
criticality

Define system HSE Case

requirement
1. Finalise and agree on the implementation
program for the HSE Cases with the line
department

HSE Cases 2. Allocate resource for HS Case development

3. Prepare and document the HSE Case

Documentation

Implementation

Assurance
And Review

Fig 7.1

As with any other quality system, there is no alternative to keeping a minimum set of
formal records in the HSE MS. It is important however to maintain a balance,
between a quality audit trail that provides transparent and clear assurance to all
stakeholders that the operations of the OPU/JV are being managed safely and
excessive bureaucracy. Broadly speaking the quality audit documents relate to policy
and process whilst the level of task definition required by the line will dictate how
much more documentation is needed for the workplace (see Figure 7.2).

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Figure 7.2 Quality documentation

Plan Extent of 'Quality'

Corporate
documentation
Feedback Do
Check

Plan
Process Feedback Do Procedural control
Check
Plan
Task Feedback Do Competence, skill,
work instructions, etc.
Check

Two types of documentation are required by the HSE MS. The HSE MS Manual
documents the overall HSE MS as applied corporately. HSE Cases (see Chapter 6)
document the application of HSE MS at a local facility or operation level. It is to help
in this process that information technology and relational database techniques have
been applied to the HSE MS and Case preparation and maintenance. The software
THESIS is aimed at providing both these deliverables. It is basically a local decision
as to how far decomposition of the quality system should be taken through
supplementary documentation, which expands an aspect on the HSE MS and HSE
Cases.

The functional requirements of the HSE MS are described in PTS 60.0101 HSE
Management System

7.1 MANAGEMENT ENDORSEMENT - LEADERSHIP AND COMMITMENT

To demonstrate visible senior management commitment and endorsement, the HSE

Management System (HSE MS) Manual should be issued under the signature of the
Chief Executive Officer (CEO) of the company, preferably by a foreword in the
Manual. The foreword should contain statements to the effect that the HSE
Management System describes the ways in which the CEO expects HSE to be
managed in the company. The CEO should be designated as the Owner of the HSE
Management System under whose direction the appointed Custodian (usually the
HSE Manager) is responsible for implementation, periodic review, and revision of
both the HSE MS and the HSE MS Manual.

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7.2 PREPARATION OF THE HSE MS MANUAL

The HSE MS Manual should, where possible, make use of existing documents for
managing HSE. As a first step to document the system, these references should be
listed, assembled and reviewed for content and currency. Areas of obvious overlap or
gaps should be noted for remedial action.

The contents of the HSE MS Manual are described in Appendix I.

The HSE MS Manual is documented in four-parts as shown in Figure 7.3. It is not

necessary that this structure be followed rigidly as long as all the elements are
covered in a logical structure. The structure may be selected to be compatible with
other OPU / JV management systems, e.g. a Quality Management System.

Figure 7.3 THE HSE MANAGEMENT SYSTEM MANUAL

HSE - Management System Manual

Part 1 Part 2 Part 3 Part 4

Management HSE MS References, Shortfalls

System Activities Documents, and
Elements Catalogue Codes and Remedial
Standards Action Plan

Part 1 is the description of the HSE MS Elements and presents the OPU / JV policy,
strategic objectives, organisation, and the principal management controls and
programmes as they apply to HSE risk management. It sets the scene for the various
HSE Cases that will be prepared as demonstrations of effective HSE management at
the local or site-specific level. The various sub-sections within Part 1 are discussed in
detail in Appendix I.1.

Part 2 is the HSE MS Activities Catalogue and contains the detailed analysis of all
activities, which contribute to the management of hazards and effects. The Activities
Catalogue should be developed by the key persons involved in each of the business
processes. The techniques used to define HSE-critical activities and to document
them are described in detail in Appendix I.2.

Part 3 lists the documents referred to in Part 1 and Part 2 of the HSE MS Manual.
Guidance on content is given in Appendix I.3.

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Part 4 contains information on how any shortfalls and remedial action plans identified
are recorded and followed up. The list of shortfalls identified and the remedial action
plan may be included in the HSE Management System Manual, but are more
commonly parts of separate documents such as the HSE Plan or company business
plan. Guidance on content is given in Appendix 1.4.

The objective of the HSE Management System Manual is to document the quality
system used for managing HSE risk in the OPU / JV. It should refer to, rather than
repeat, existing procedures and systems. It provides a principal source of reference
for the HSE-critical aspects of:

routine or corporate level activities, such as planning, design, contracting, data

analysis, programme development, etc

familiarisation (new staff)

increasing awareness (existing staff)

hazards and effects management

audits

training

competence definition

job description preparation

incident investigation

HSE Management System review and improvement.

The Manual should enable all staff and any interested outside parties to understand
how HSE is managed throughout the OPU / JV business and should set out the
accountabilities of the various levels of senior and line management.

7.3 DOCUMENTING THE CASE

The HSE Case is constructed in seven linked parts as shown in Figure 7.4. It is not
necessary that this structure is followed rigidly as long as all the elements are covered
in a logical structure.

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Figure 7.4 The HSE Case

The HSE CASE

Part 1 Part 2 Part 3 Part 4 Part 5 Part 6 Part 7

Management Operations Hazards
Activities Description Identified
Summary and Effects Conclusions
HSE Catalogue of Shortfalls
Analysis
and Management Operation Hazards &
Introduction System
Effects Remedial Statement
Register Work Plan of Fitness
MOPO

Part 1 presents management endorsement of the HSE Case, a summary of the HSE
Case objectives, the main findings and operational risks, and provides a brief
introduction to the main document. Guidance on content is given in Appendix III.1.

Part 2 specifically describes those elements of the HSE Management System that are
directly applicable to the operation or facility. Guidance on content is given in
Appendix III.2.

Part 3 contains the quality record for those HSE-critical activities applicable to the
operation or facility. This is recorded in an operation specific Activities Catalogue
analysed to a level suitable to reflect the business controls relevant to that operation.
Guidance on content is given in Appendix III.3.

Part 4 provides a description of the operation or facility, as background information

to the hazards and effects analysis, to enable a clear understanding of HSE-critical
aspects. This will include, for example, safeguarding systems and emergency
response capabilities. Guidance on content is given in Appendix III.4.

Part 5 demonstrates that potential significant hazards and effects identified, and
provides the quality records of the manner a hazard is being managed and the
recovery measures should the hazard be released (the Hazards and Effects Register)
and details the limits of safe operation (the Manual of Permitted Operations). As such
it shows that the risk has been evaluated and understood, and that necessary controls
to manage the causes and consequences are in place. Guidance on content is given in
Appendix III.5 and Appendix IV.

Part 6 summarises any shortfalls identified, with a plan to resolve the findings and
thereby improve the operation. Guidance on content is given in Appendix III.6.

Part 7 states the conclusions reached in terms of the HSE Case objectives and ends
with a Statement of Fitness, which explains that the hazards and effects associated
with the installation or operation have been evaluated and measures have been taken
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to reduce the risks to the lowest level that is reasonably practicable. The Statement of
Fitness must affirm that conditions are satisfactory to continue the operation.
Guidance on content is given in Appendix III 7.

8 IMPLEMENTATION

Implementation Road Map

The HSE MS

Preparation and 1. Review the plan and establish realistic schedule

Development (contract out routine work and get own staff to
work on HSE MS and HSE Case)

2. Reconfirm Management Review and Support

Review policy and
program
objectives
3. Monitor results of HSE MS and HSE Case
implementation using management review
Assessment of meetings at key milestones and reports
criticality
4. Monitor effectives of HSE MS and HSE Case
against KPIs developed

Define system 5. Use HSE MS guidelines when dealing with

requirement contractors and JV partners

6. Ensure contractors are familiar with the HSE

Case and they work within the guidelines set ni
HSE Cases the cases

Documentation

Implementation

Assurance
And Review

Fig 8.1

Full implementation of the HSE MS means that people are doing what the
Management System says they should be doing, at all levels in the OPU / JV. This
involves performing the corporate level activities as defined in the HSE MS Manual

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such that they have the desired effect throughout the organisation. HSE Cases should
then be able to demonstrate how the HSE MS is applied at a local level in those
critical facilities or operations for which the HSE MS requires Cases to be prepared.
The HSE Cases then provide a second level of definition of critical activities that
have to be performed in the context of the local facilities or operations.

There is therefore no fixed sequence or rule for implementing the HSE MS

corporately (HSE MS Manual) or locally (HSE Case) first. In reality a HSE Case
represents a local continuity of the HSE MS and the sequence of development and
implementation should be defined in the OPUs implementation strategy.

The implementation strategy depends on what management expects of its HSE MS

and HSE Case teams. The timing, i.e. when will the system be up and running, the
deliverables of the system, the need for risks to be reduced to a level that is as low as
reasonably practicable, and the requirement for the OPU / JV to strive for continuous
improvement in HSE performance, should all be explained. It should also be clear
how they fit within the policy and objectives set by management. Those critical (in
risk terms) operations and installations required by the OPU / JV to have a HSE Case
should have already been outlined and a HSE Case schedule defined together with
key review milestones.

People appointed part-time to the implementation teams should be clear as to the

percentage of their time, which they are expected to provide to the HSE MS or Case
implementation effort. Finally, and most importantly, management must set up and
support, both a formal review mechanism and an informal arrangement that will
provide the team and key implementation personnel with essential support from all
levels of senior and line management.

8.1 A CULTURE CHANGE

It is stressed that the implementation of these systems is a culture change. This is

especially so for the HSE MS which contains the elements of health and
environmental management. These are often perceived by the line as much more
difficult to implement than safety and some resistance may be encountered. Hence
implementation effort will tend to take more, rather than less, management time.

The HSE MS is a quality system concerned with providing long term and continuous
HSE performance improvement. To do this it must become embedded into the
company culture and way of doing things. It must not be regarded as 'add on' or
something to be completed and then filed. It is for this reason that the HSE MS
cannot be regarded as yet another 'initiative' and that it must be strongly supported by
senior and middle management.

8.2 MONITOR IMPLEMENTATION AND OPERATION OF THE HSE MS AND

HSE CASES

The second element in implementing such a system involves the careful monitoring of
both the successes and the failures, not only of the implementation of the HSE Cases,

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but also of the HSE MS itself. Milestone reviews should be used to monitor progress
with the HSE MS implementation programme and regular reports to senior
management are recommended.

HSE MS monitoring should take recognition not only of reactive indicators; the
'learning from accidents' type of statistics like near-misses, lost time injuries,
fatalities, etc but also proactive (sometimes referred to as 'active') indicators like
successful emergency drills carried out within defined risk objectives, measurement of
the integrity of critical safeguarding systems, etc. Examples from the environmental
world include gas flaring rate monitoring as a function of production, oil in water
discharge, surface losses of drilling mud per 1000 m drilled.

In a properly operating HSE MS or HSE Case, local monitoring or 'audit' should

already identify any needed corrective actions and formal audits and management
reviews should provide a 'safety net' for those issues that may, for whatever reason,
escape this first line check and balance.

The implementation of the HSE MS (and of HSE Cases) involves 'energising' the
system and 'demonstrating' that the policy for HSE is adequately deployed throughout
the organisation. The principles outlined in the various Petronas HSE Guidelines
(Ref. 9) should be maintained, as should the link with quality and industry guidelines,
most notably the OGP Guidelines for HSE Management Systems (Ref. 5). This latter
reference is likely to continue to be of importance for many of the operations in
which Petronas through SIRIM is involved, in view of its wide acceptance by the
industry. It is clearly in Petronas's interest to ensure that all the operations in which it
has an interest meet the functional requirements of the HSE MS and HSE Cases
including those where there is only a minority interest. Reference to PTS 60.0101
Health Safety and Environment Management System Manual clearly shows the links
with the E&P Forum Guidelines adopted by the Petronas Group (Ref. 5).

The emphasis should remain with quality systems and with the application in a
practical and effective way of the hazards and effects management process. The third
element of the Petronas Group approach to HSE MS relates to integrating the quality
and hazards and effects management with the actual work being carried out. This
comprises identifying those activities that are truly critical to the management of
hazards and effects (as outlined in Chapter 4).

It has been found from experience that even when a OPU / JV starts out to merely
document hazards and effects and key management control procedures mention must
soon be made of HSE-criticality. There is generally however little clarity as to how
this is to be defined.

The intent of the HSE MS is to reduce risk to ALARP and to promote the continuous
improvement of HSE performance via the proactive management of hazards and
effects. Provided that this can be demonstrated, both corporately via the HSE MS and
locally, via the HSE Case, or equivalent then the functional requirements of the HSE
MS will have been met. The first indications that the system has been implemented
successfully will come from the trending of performance criteria in the form of

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proactive performance indicators and in the feed back given by the users at the
operational level, during management inspections, routine monitoring and in audit
findings.

Ultimately, in the longer term, we can expect that reactive indicators such as TRCF,
LTIF and fatality records will reduce and that the true benefits of quality management
systems as applied to HSE will become apparent.

To assist the implementation of the HSE MS and HSE Cases, self check lists have
been prepared and are included in the sections relating to documenting the HSE MS
and HSE Case (Appendices II and IV)

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9 ASSURANCE AND REVIEW

Implementation Road Map

The HSE MS

Preparation and 1. Review current assurance plan to integrate

Development HSE MS and HSE Case assurance processes

2. Establish schedule for HSE MS assurance

Review policy and and Management Review
objectives
3. Establish plan for HSE Case assurance and
Management Review agreed to
Assessment of
criticality

Define system
requirement

HSE Cases

Documentation

Implementation

Assurance
And Review

Fig 9.1

Assurance and management review provide the normal check and balance required of
any quality system. There is however, some overlap in the common usage of the
terms assurance and review. In the context of the HSE MS, assurance tends to be
directed toward measuring compliance with an accepted and known standard,
whereas management review tends to be concerned not only with compliance but also
overall HSE MS effectiveness.

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Thus it is important to carefully define the terms of reference of the assurance

programme and to establish, with broad management agreement, the schedule and
plans which should apply to both the HSE MS and associated Cases.

Encouragement should be given to the use of cross functional mini-reviews or peer

assurance where a line manager agrees with one of his counterparts to audit his
operation or vice versa. Great care should be taken to ensure adequate capturing of
'lessons learnt' and for lateral application.

Assurance and review corrective actions and follow up will need to be formally
logged and monitored through the Assurance Committee or equivalent. Many OPU /
JV use a middle management panel reporting to the Management Assurance
Committee in order to retain a degree of 'hands on' practical contact with audit follow
up action items and their supervision.

Finally it is important for there to be a mechanism in place to regularly review and

quality audit the HSE MS and associated Cases. A frequency of every three years is
recommended.

9.1 ASSURANCE OF THE HSE MANAGEMENT SYSTEM AND PROPOSED

CORRECTIVE ACTIONS AND IMPROVEMENTS

Assurance process will provide the key test as to whether the functional requirements
of the HSE MS and HSE Case have indeed been met in practice. There is no
substitute for 'vertical slice' HSE MS and HSE Case assurance carried out from senior
management levels through to the workplace, to test whether the management system
is indeed operating the way it is intended.

As a milestone toward quantified assurance, a set of weighted self checklists has been
prepared that can be used to help judge the quality of the HSE MS and of the HSE
Case documentation. These represent a first tentative step toward quantified
assurance and are intended for use by those involved in preparing the HSE MS and
HSE Case as a self check of the content and quality of the prepared documentation.
The HSE MS and HSE Case Self Check lists have been included in Appendices II
and IV.

9.2 MANAGEMENT REVIEW OF THE SYSTEM AND PROPOSED

CORRECTIVE ACTIONS AND IMPROVEMENTS

Management's role in ensuring the success of the HSE MS cannot be overstated. In

all cases where OPUs have succeeded in implementing the HSE MS and HSE Cases,
then management have given the necessary direction and commitment. They have
recognised that implementation is a real culture change and that it should be accorded
a high priority. It is apparent that success breeds success and that where OPU/JV
management have taken a proactive and positive approach, coupled with a long term
view, then that OPU/JV has benefited the most. It is unrealistic to expect instant
results but it is imperative that a management review schedule be used to reinforce

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the positive and to minimise the negative culture shock that can occur especially
during early implementation. Management reviews in this context should comprise
the full spectrum of management inspection techniques from the field inspection
through to the full management review expected of any quality management system.

Management will be heavily involved probably through the Management HSE

Committee or equivalent in monitoring and supporting the early implementation of
the HSE MS and HSE Cases. They will also often take part in field inspections which
can be used to reinforce the same essential message of commitment.

Management have a key role in the formal assurance and review process providing
for the planning, executing and endorsing of any corrective actions or shortfalls
encountered in either the HSE MS or HSE Cases. They will be involved, via the
usual assurance and review follow up processes, with monitoring and enforcing the
implementation of necessary corrective actions. Their role in supporting and
monitoring the follow up of action items both at line level and also as members of
monitoring committees is vital.

A key deliverable from the HSE MS and the HSE Cases is the Shortfall listing and its
associated corrective action plans - Remedial Work Plans. It is this element of the
system that will provide management with the required feedback from the operations.
With an effective HSE MS and live HSE Cases in place, management will be made
aware of the bad, as well as the good news. The HSE MS is intended to provide a
necessary flow of useful and meaningful information. If the news is bad, it is
management's responsibility to ensure that necessary resources are provided and
pressure maintained to ensure the necessary rectification of the situation. This is the
final task of management in assuring that their OPU / JV has an effective HSE MS
and that the HSE Case(s) provide the necessary assurance of a fit-for-purpose and
safe operation. This is the real proof that the company and its management have acted
with 'due diligence'.

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APPENDIX I - DOCUMENTING THE HSE MS MANUAL

Documenting the HSE MS should be carried out with a large degree of discretion and
restraint. The term 'describe the ........... ' is used in many places to provide direction as to
what is required in a particular section or part of the HSE MS. It is not intended to prescribe
extensive documentation when a brief reference or description would suffice. Likewise
'maintenance of procedures to.....' or 'the OPU / JV should maintain procedures for .....' are
not intended to prescribe that written procedures are necessarily required for all practices.
The HSE-criticality and objectives set will determine whether a formally documented and
controlled procedure is required. 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 including controls and documentation remains the responsibility of the company
and these Guidelines should be read in this context of self - regulation.

The HSE Management System Manual as described in this guideline appendix is

documented in four-parts as shown in Figure I.1. It is not necessary that this structure be
followed rigidly as long as all the elements are covered in a logical structure. The structure
may be selected to be compatible with other OPU management systems, eg a Quality
Management System. NB it is understood that certain hazards and effects can only be
managed by corporate management and companies are increasingly seeing the need to
establish a Part 5 'Corporate Hazards and Effects Register'. For further definition as to its
structure and contents refer to Appendix VI.

Figure I.1 The HSE Management System Manual

HSE Management System Manual

Part 1 Part 2 Part 3 Part 4

Management HSE MS References, Shortfalls

System Activities Documents and
Elements Catalogue Codes and Remedial
Standards Action Plan

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I.1 PREPARATION OF PART 1 - HSE MANAGEMENT SYSTEM ELEMENTS

The first part of the HSE Management System Manual is divided into the following
sections, reflecting the Model HSE Management System:

Section 1 - Introduction to the HSE Management System Manual

Section 2 - Policy and strategic objectives

Section 3 - Organisation, responsibilities, resources, standards and

documentation

Section 4 - Hazards and effects management

Section 5 - Planning and procedures

Section 6 - Implementation and monitoring

Section 7 - Auditing and

Section 8 - Management Review, (including corrective action and

improvement)

I.1.1 Section 1 - Introduction to the HSE Management System manual

This section of the manual defines the HSE Management System, its use and
benefits and describes the structure of the Manual. Include in this section:

DEFINITION, OBJECTIVES AND SCOPE OF THE HSE

MANAGEMENT SYSTEM

Describe the structure and purpose of the HSE Management System, its
relationships to the corporate management system and other management systems
in the company, its use of quality management principles and its coverage of
company activities.

STRUCTURE OF THE HSE MANAGEMENT SYSTEM MANUAL

Describe briefly what information is to be found in each of the Parts and main
sections of the manual.

HSE MANAGEMENT SYSTEM APPLICATION

Describe how the HSE Management System is to be applied in company

operations.

USE AND BENEFITS OF THE HSE MANAGEMENT SYSTEM MANUAL

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Describe the reasons for documenting the management system, how it is to be

distributed and used and the benefits of this.

HSE MANAGEMENT SYSTEM OWNER AND CUSTODIAN

Describe the roles of the HSE Management System Owner (CEO) and the
appointed custodian in issuing and periodically reviewing and revising the system
and manual.

REVIEW CYCLE

Describe the planned review cycle for the Manual and any specific events that
may trigger a review outside this cycle. As the HSE Management System is a
quality system, the Manual must be a controlled document subject to review on a
defined cycle basis.

I.1.2 Section 2 - Policy and strategic objectives

The HSE Management System is a risk based objective setting system and it falls to
the management of the company to set their own specific goals against which the
effectiveness of the HSE Management System should be aimed at and measured.
Include in this section:

POLICY FOR HEALTH, SAFETY AND PROTECTION OF THE

ENVIRONMENT

Describe the HSE Policy, its links to Petronas Guidelines for Business Conduct,
any specific local considerations, the responsibilities for issue, review and
revision. A copy of the current Policy should be included in the text or it should
be in a cross referenced appendix. Specifically address links to Petronas Group
principles, policies, standards, guidelines and procedures. Refer to PTS 60.0101
and to the OGP Guidelines for HSE MS (Ref. 5). Consider the risk matrix and
how it is applied in corporate activities and the assessment of appropriate
corporate risk tolerability levels.

OTHER HSE RELATED POLICIES

Such as Drugs and Alcohol, Security, Road Safety, Environmental (including

H&S) Assessment of New Projects and Activities Describe these policies and the
responsibilities for issue, review and revision. Current policies should either be
included in the text or clearly cross referenced if located in other corporate
documents.

HSE STRATEGIC OBJECTIVES

Describe the hazards and effects management and risk reduction objectives
against which the goal setting HSE Management System will be measured.

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Specifically address reduction of risks to a level which is as low as reasonably

practicable - ALARP and the requirement for continuous improvement.

REGULATORY AND LEGAL REQUIREMENTS

Describe the legal framework relevant to HSE, both national and local, within
which the company conducts its business. It is to be expected that local laws will
represent a minimum requirement and that company requirements will, in many
areas, be more demanding.

GROUP AND COMPANY HSE REQUIREMENTS

Identify and list the Group and Company guidelines, standards and reports
relevant to the establishing of HSE policies and objectives.

POLICY DISSEMINATION

Describe the means by which the policy and objectives are disseminated to all
staff and contractors.

I.1.3 Section 3 - Organisation, responsibilities, resources, standards and

documentation

The HSE Management System requires resources to be allocated to it and

responsibilities to be defined. Include in this section:

ORGANISATION DESCRIPTION AND KEY HSE RESPONSIBILITIES

Describe the company organisational structure, the key HSE responsibilities of

managers, line supervisors, employees and contractors' staff.

LINE RESPONSIBILITIES

Describe the means by which all personnel are involved in HSE matters including
the setting up of an interlocking HSE committee structure so that the HSE policy,
objectives and targets are fully communicated to the workforce.

HSE SUPPORT TO LINE MANAGEMENT

Describe the role of HSE advisers by defining job descriptions, training

requirements, competency and qualifications.
COMPETENCE OF EMPLOYEES

Describe the way the competence of employees is assured and documented so that
staff understand the HSE implications of their actions and that they are competent
to perform these actions to the required standard.

CONTRACTOR MANAGEMENT

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Describe the ways in which the company selects contractors and subsequently
manages HSE-critical interfaces. This sub-section should describe how the
company's HSE Management System provides for effective Contractor HSE
Management. HSE considerations used in selecting and reviewing the
performance of contractors should be described. Additionally any interfaces
between the company and contractors' HSE management should be addressed.

COMMUNICATION OF HSE ISSUES

Describe the structure for the discussion and communication of HSE issues
between workforce and line management and specifically address those methods
aimed at ensuring clear workforce involvement in hazards and effects
management; address the communication with external bodies and specifically
consider how areas of environmental risk and concern are handled by the
company.

TRAINING

Describe the ways in which training is provided for HSE-critical activities,

including technical training, HSE specific training, programmes of safety drills,
emergency drills, environmental workshops, spill response and other HSE
exercises, etc.

USE OF STANDARDS

Specifically address links with industry standards, Group principles, policies,

standards, guidelines and procedures. Refer to PTS 60.0101 Health Safety and
Environment Management System Manual and to the OGP Guidelines for HSE
MS (Ref. 5). Describe the company's use of standards in hazards and effects
management and the programmes in place to ensure that controlled standards are
being utilised. This sub-section should explain how the company identifies the
minimum required standards, design codes and acceptance criteria to be used
during the entire life cycle of the enterprise. It should describe how standards are
controlled, how the company reviews and incorporates new developments in
codes and standards for both new and existing facilities, and what role a standards
custodian plays.

DOCUMENT CONTROL

Describe how HSE Management System business controls are documented. An

HSE Management System provides a set of business controls that should be
formally documented so as to serve as a permanent reference for the
implementation and maintenance of the system. Consider how system auditors
will make use of it to verify that the system exists and that it is fit for its purpose,
given the nature of the hazards, environmental effects and risks involved. Part 3
of the HSE Management System Manual should contain a listing of all references
required.

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HSE CASES

Describe how Cases are prepared and documented to demonstrate the extent to
which HSE objectives are being met in specific operations or facilities. Mention
any specific systems used to record, maintain and disseminate data collected.
Include references to Appendices, or other documents, for example the HSE Plan,
showing the production of required HSE Cases.

I.1.4 Section 4 - Hazards and Effects Management

This section should describe how the objectives of the HSE MS are to be achieved
through the management of hazards and effects (refer PTS 60.0401). The Hazards
and Effects Management Process (HEMP) shown in Figure I.2 provides a basic
structure but in reality each of the four main steps are overlapping and iterative. They
cannot be linear if the process of evaluating and controlling HSE risks is fully
addressed.

Figure I.2 Hazards and Effects Management Process

Hazards and Effects Management Process (HEMP)

Identify Are people, environment or assets exposed

to potential harm? Identify hazards and effects
resulting from company's operations
What are the causes, consequences and effects?
Assess How likely is loss of control?
What is the risk and is it ALARP?

Can the causes be eliminated?

Control What controls are needed?
How effective are the controls?
Can the potential consequences or effects
Recover be mitigated?
What recovery measures are needed?
Are recovery capabilities suitable and sufficient?

Include in this section:

HAZARDS AND EFFECTS MANAGEMENT

Provide an overview of the Hazards and Effects Management Process as applied

to company operations. Describe the requirement for the Hazards and Effects
Management Process to be applied to all company activities as a means of

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establishing criticality, assessing risks and evaluating the controls needed to be in

place. Include an assessment of HSE impacts or potential impacts on people, on
communities, on the environment and on assets over the full life cycle of the
operation. Address specific stages of the life cycle in more detail as required to
show an appropriate management of hazards and effects.

IDENTIFICATION OF HAZARDS AND EFFECTS

Describe the techniques for early identification, review and documentation of

hazards and effects, for example the requirements and timing for HAZID,
HAZOP (as appropriate), Health Risk Assessments, Environmental Assessments,
etc.

SCREENING CRITERIA

Describe the screening criteria to meet HSE policies and strategic objectives,
(where appropriate by comparison with applicable statutory requirements, codes
and environmental standards), making reference to the major hazards and effects
identification and evaluation techniques and to significant hazards and effects.

EVALUATION OF RISK

Describe the procedures and techniques used in the OPU / JV to assess risks from
hazards and effects and to put in place the controls (both likelihood reducing and
consequence reducing) needed to achieve HSE objectives. Describe the
relationships between controls and the activities performed to provide and
maintain these. Activities performed to identify hazards and effects, to evaluate
their associated risks, and to provide and maintain controls are HSE-critical
activities for which quality records should be recorded in the Activities Catalogue
in Part 2 of the manual.

RECORDING HAZARDS AND EFFECTS

Describe the requirement to record hazards and effects identified and the results
of all risk evaluations. Provide guidance on recording hazards and effects
applicable to different types of operation or facility for use in other operations or
facilities, whether new or existing, as part of the corporate learning and
improvement processes. Provide guidance on recording hazards and effects in
each phase of the life cycle of a development or operation for use in later phases
of the life cycle. Describe how hazards and effects which are controlled mainly at
a strategic level by corporate activities are recorded, for example, endemic
diseases, waste reduction programmes, gas venting/flaring, etc. Consider how
controls are communicated to the workforce and specified in terms that are
meaningful to those charged with the day to day management and operation of the
business (in terms of hazards and effects management).

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PERFORMANCE CRITERIA

Describe the requirement to establish and document appropriate performance

criteria and related indicators to provide assurance that activities are being
performed to standards necessary to achieve HSE risk management objectives.
These are to be documented together with the corresponding activities in Part 2.

RISK REDUCTION MEASURES

Describe the methods to be used to provide a tolerable level of risk in accordance

with company risk management objectives. Set out the need to assess where risks
can be further reduced in a cost effective manner to a level that is as low as
reasonably practicable (ALARP). This should be described in the context of
objective setting and continuous improvement.

DEMONSTRATION OF ALARP

Describe the requirement to demonstrate that HSE risks are as low as reasonably
practicable (ALARP) for all facilities or operations in which a significant HSE
risk or severe potential consequence exists in accordance with the HSE
Management System objectives. This demonstration should be by way of
preparation of HSE Cases.

RISK TO REPUTATION

Describe the risk not only in terms of risk to health, safety and the environment
but also in terms of risk to reputation. This represents a difficult area to evaluate
in that it is often driven by perceptions and almost always by societal issues. It
may well be that risk in scientific and provable terms may be reduced well below
the level where the ALARP criteria would be completely satisfied and yet overall
risk to the image or reputation of the company may still be high. Risk to
reputation cannot be ignored and advice should be sought from experts in the
Public Affairs field if there is any doubt.

I.1.5 Section 5 - Planning and procedures

This section should describe the OPU / JV use of various plans and procedures aimed
at achieving HSE Objectives and should identify the key HSE procedures used in the
OPU / JV. Include in this section:

PLANNING OF ACTIVITIES

State the requirement for adequate planning of all HSE-critical activities to

manage HSE risk. Describe any specific techniques used, for example Job Safety
Analysis, Health Risk Assessment, Environmental Assessment. Specifically
mention the need to have limits of safe operation established by, for example, a
MOPO (manual of permitted operations) or concurrent operations procedures, in
advance of activities which may increase HSE risk.

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HSE PLAN

Describe what the OPU / JV HSE Plan is, for example: action plans for
implementation, monitoring or improvement of the HSE MS and HSE Cases;
including drills, audits, HAZOPs, environmental assessments, waste reduction,
emission reduction and control, etc. Describe how often such a plan is produced,
who is responsible for its production and endorsement and how the objectives are
achieved. Consider the implementation of safety and health improvements and of
commitments made to implement environmental assessment findings including
plans for consultation with external stakeholders. Note that the HSE Plan should
initially drive the implementation of the HSE MS and HSE Cases but that with
time the HSE Plans should be absorbed into the HSE MS and the HSE Cases as a
part of the overall improvement process.

ASSET INTEGRITY

Describe and reference the procedures that are used to provide and maintain asset
integrity throughout the life cycle of an asset, for example, design, inspection,
maintenance, etc noting the close links between asset integrity and management
of HSE risks.

PROCEDURES AND WORK INSTRUCTIONS

Describe how the OPU / JV uses procedures and work instructions in hazards and
effects management. Describe their use in, for example, planning, operations,
monitoring, inspection, maintenance, job cards, job safety analysis, job hazard
analysis, waste disposal, and waste management. Consider how procedures
address the 'designing in', from the start, measures aimed at improving
environmental discharges and effects. Mention the part played by procedures and
work instructions in activity and task specifications. Describe the programmes in
place to ensure that procedures being used are controlled and that they are simple,
unambiguous, understandable and relevant. In particular consider how work
instructions and the product of techniques like job hazard analysis are
communicated to the workforce, e.g. by tool box meetings, review of hazards and
effects information with links to Permitry, etc ahead of job or task execution.
Include an explanation as to how HSE performance is communicated and
discussed in terms of performance indicators established during the hazards and
effects analysis.

MANAGEMENT OF CHANGE

Describe the systems and procedures used by the OPU / JV to manage risks from
hazards and effects that could arise from or be associated with all elements of
change. Include reference to procedures for controlling changes in all HSE related
documents, hardware, software, personnel, procedures and modes of operation.
Mention how information concerning changes is communicated to appropriate

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personnel and how it is meant effectively cover the 4 P(s) Plant, Process,
Procedures and People.

PERMIT TO WORK SYSTEM

Describe the permit to work system used by the OPU / JV, including how and
when it is applied. Describe how it relates to the control of operations within
limits defined by the Manual of Permitted Operations (MOPO). Explain how
procedural controls contained in the PTW and MOPO address environmental
effects and their controls.

CONTINGENCY AND EMERGENCY PLANNING

Describe the OPU / JV requirements for emergency response, contingency plans

and procedures, for example, Emergency H2S Procedure, man overboard
procedure, oil spill plans, etc. Describe the resources to meet those plans, for the
safe evacuation, escape and rescue of personnel, mitigation of effects to assets
and the environment following incidents. Emphasise the requirements for
exercises and drills, including their frequency, to ensure that all staff are
adequately prepared for any incidents and fully understand the roles that they are
individually and collectively expected to play.

I.1.6 Section 6 - Implementation, monitoring and corrective action

This section should describes the execution of HSE-critical activities and how the
OPU / JV measures and monitors their performance. This section provides a strong
linkage to Part 2 - the Activities Catalogue. Include in this section:

ACTIVITIES AND TASKS

Describe how critical activities and tasks are identified, how business controls on
them are established and accountabilities defined for their execution. Describe
how these activities are defined and specified to be performed to selected
standards and how these performance standards are set.

PERFORMANCE INDICATORS (PROACTIVE AND REACTIVE)

Describe the types of proactive and reactive performance indicators used in the
OPU / JV.

Describe proactive measurements which monitor achievement of risk objectives

and the extent of compliance with standards. Note that proactive indicators are
forward looking and predictive, aimed at raising awareness of the possibility of
incidents that could happen, for example analysis of trends, risk based
performance indicators, completion of environmental assessment and HAZOP
findings.

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Describe reactive measurements which monitor incidents and other evidence of

deficient HSE performance, for example, LTIFs, TRCFs, Total Recordable
Occupational Illness Frequency, sickness absence statistics, waste generated,
resource use, complaints received and followed up, control limits exceeded

Specifically mention that activity analyses carried out during establishment of the
Activities Catalogue provide an excellent opportunity for those involved to derive
suitable performance indicators for each activity, for example, production logs,
maintenance reports, the correctness and timeliness of corrosion monitoring,
number of audit items outstanding, items relating to design integrity, etc.

TASKS AND TARGETS

Describe the setting of HSE targets for the enterprise based upon the identified
key HSE objectives. Define how resources are allocated and actions cascaded
throughout the organisation to meet these targets. Mention that targets should be
based upon company policy and upon risk analyses and performance criteria
developed during the analyses and that they should aim for progressive
improvement over past performance.

Describe the setting of health, safety and environmental targets for individuals
derived from, and consistent with, the corporate HSE targets and objectives. The
targets should be relevant to risk levels and the job and interlock from level to
level in the organisation, e.g. the specific (and ambitious) effluent discharge limit
imposed on the operation by local management, based on legal limits (less
ambitious) and upon stricter OPU / JV criteria.

MONITORING PERFORMANCE

Describe the criteria by which HSE performance is measured against targets.

Describe means to monitor locally the HSE performance of the enterprise by
comparing actual performance in identified key risk areas with agreed targets.

RECORD/ANALYSE DATA

Describe the means by which data on all hazards and effects are collected,
recorded and disseminated and the analysis carried out, in order to identify
common failures and trends in HSE risk management, waste reduction,
procedures or hardware.

NON-COMPLIANCE AND CORRECTIVE ACTION

Describe the responsibilities and authorities for initiating investigation and

corrective actions in the event that non-compliance with the requirements of the
HSE Management System is identified. Non-compliance may be identified by
monitoring activities, adverse trends in performance indicators, non completion
of agreed and planned HSE improvements, failure to meet targets, from incident

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investigations (see below), or from other sources, e.g. inspections, observations,

etc.

INCIDENT INVESTIGATION AND REPORTING

Describe the way all incidents, including near misses, excursions from control
limits or environmental standards, complaints from the community, as well as
accidents, are recorded and investigated to identify immediate and underlying
causes.

INCIDENT FOLLOW-UP

Describe the procedures for carrying out follow-up actions to prevent recurrence
of incidents.

COMMUNICATION OF PERFORMANCE

Describe the means by which HSE performance is communicated to all staff and
external stakeholders (eg communities, government) on a regular basis. Such
communication is an essential part of the feedback process to improve motivation
and to promote further improvement of performance.

I.1.7 Section 7 - Auditing - including corrective action an improvement

This section shows the requirements and procedures in place to ensure regular and
independent audits of the HSE Management System and it's associated HSE Cases.
Include in this section:

ASSURANCE PLANNING

Describe the basis for planning and timing of assurance processes. Mention the
different types of assurance, e.g. of the management system itself or of specific
facilities or operations carried out under the management system (HSE Case
assurance). Note requirements for assurance to be internal or conducted by
external or third parties. Describe the various triggers for assurances outside the
normal planned sequence, such as systematic weaknesses indicated by a major
accident, exceptional conditions, etc.

ASSURANCE POLICIES AND PROCEDURES

State the relevant assurance policies and procedures. Where these are covered in
other documentation this item should provide a brief summary and provide a
cross reference for details.

CORRECTIVE ACTION PROCEDURES

Describe how corrective actions arising from assurances are agreed, prioritised,
carried out and monitored and eventually formally closed out as complete.

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COMMUNICATION OF LESSONS LEARNT

Describe the means by which the lessons learnt from assurances are
communicated across the OPU / JV to relevant personnel for follow up and
application in similar facilities, operations or activities.

I.1.8 Section 8 - Management review - including corrective action and improvement

This section shows the requirements and procedures in place to ensure regular
management review of the HSE Management System and it's associated HSE Cases.
Include in this section:

MANAGEMENT REVIEW PLANNING

Describe the basis for planning and timing of management reviews. Mention the
different types of management review, for example, of the management system
itself or of specific facilities or operations (management inspections, cross
discipline management inspections, etc.) Describe the various triggers for
management review outside the normal planned sequence, such as following
reorganisations, changes in the scope of activities, major modifications, new
appreciation of technology or as follow up to an incident, audit, etc.

MANAGEMENT REVIEW POLICIES AND PROCEDURES

State the relevant policies and procedures to be followed in management reviews.

Where these are covered in other documentation this item should provide a brief
summary and provide a cross reference for details.

IMPROVEMENT STRATEGY

Describe how information from assurance, incident investigations, drills,

shortfalls identified in the HSE Management System and HSE Cases, etc are
reviewed on a rolling basis for systematic improvement. Describe the process for
making changes and improvements to the HSE Management System, as well as
the procedures for finally incorporating these changes into HSE Cases as needed.
Describe how these improvements are covered in the OPU / JV HSE Plan.
Describe the use of a 'lessons learnt database' as a 'corporate memory' to facilitate
continuous improvement.

- COMMUNICATION OF LESSONS LEARNT

Describe the means by which the lessons learnt from management reviews are
communicated across the company to relevant personnel for follow up and
application.

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I.2 PREPARATION OF PART 2 THE HSE MANAGEMENT SYSTEM

ACTIVITIES CATALOGUE ACTIVITY RECORD (SPECIFICATION
SHEET)

Part 2 of the HSE Management System Manual contains the quality requirements for
corporate level HSE-critical activities, i.e. those involved in one of the steps of the
Hazards and Effects Management Process. Such HSE-critical activities should have
formal Activity Records prepared for them and be compiled into an Activity
Catalogue.

The Activity Catalogue makes HSE management objectives, responsibilities and

controls more explicit and visible. It stabilises business processes, ensuring that
control is more consistently applied over time and that there are clear links identified
from the policy through to supervisory level.

Include in Part 2:

FOREWORD

Describe the purpose of part 2 and how it is to be used.

Describe the roles of the process custodians and activity owners and their
responsibilities to endorse the Activity Records.

Describe the required review cycles for Activity Records, how and when they
should be revised and the need for re-endorsement as and when process custodian
or activity owners change.

STRUCTURE OF THE ACTIVITY LISTING

Describe how the listing of HSE-critical activities was arrived at, noting the use
of any OPU/JV business model, the Business Model, an OPU specific business
process analysis or simply a brainstorming of activities, as appropriate

Describe how these activities have been grouped and numbered for reference,
relating the numbering system to any 'parent' system such as a business model, if
used.

CATALOGUE OF ACTIVITY RECORDS (SPECIFICATION SHEETS)

Prepare an (HSE Management System) Activity Record for each HSE-critical

activity. The Activity Records provide an outline of essential competencies,
define accountabilities and allow a clear audit trail throughout the HSE
Management System. Activity Records should be prepared by those persons
involved in, and recognised as accountable for, the specific business process(es)
under review. A control copy of the Activity Record should be printed out and
endorsed by the persons accountable for each activity and the process of which it

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is a part. Endorsed activity specification records (Specification Sheets) in

compiled form constitute the Activities Catalogue.

For a more complete discussion on how to identify HSE-critical activities and the
data to be recorded in an HSE Management System Activities Catalogue see
Appendix V.

I.3 PREPARATION OF PART 3 - REFERENCES, DOCUMENTS AND

STANDARDS

Part 3 of the HSE Management System Manual draws together into a comprehensive
list all the documents and standards referred to in Parts 1 and 2, together with:

- a description of their purpose,

- revision date,

- their custodians and review cycle;

- cross referenced to the appropriate activities, hazards and effects.

In addition, as HSE Cases are developed and site specific controlled documents
identified these should be included in Part 3 of the HSE Management System Manual
where they can be relevant to other operations. For example a OPU / JV with no H2S
in its operation upon encountering H2S at a specific operational site would prepare a
set of H2S procedures that must then be included in the Corporate reference
documentation so that it can later be laterally applied in the company should this be
required.

I.4 PREPARATION OF PART 4 - SHORTFALLS AND REMEDIAL ACTION

PLAN

Part 4 of the HSE Management System Manual should state the requirement for all
shortcomings identified when preparing the HSE Management System, through
audits and reviews, etc to be recorded and remedial action plans developed to correct
them. Part 4 should describe where these shortcomings and remedial action plans
reside. It should also define responsibilities for monitoring remedial action plans and
for ensuring that remedial actions are carried out according to plan. Progress of HSE
Management System remedial actions may be included as a part of an integrated
tracking system, which also covers audit and review action items.

The list of shortfalls identified and the remedial action plan may be included in the
HSE Management System Manual, but are more commonly parts of separate
documents such as the HSE Plan or OPU / JV business plan for ease of updating or
for organisational reasons.

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APPENDIX II - SELF CHECK LIST FOR THE HSE MS

II.1 REVIEWING THE DOCUMENTS: THE HSE MANAGEMENT SYSTEM

MANUAL

This Self Check Listing is intended to assist in the initial quality review of the HSE
Management System and the HSE Case. As outlined in the HSE MS Manual, both
the HSE MS and the HSE Case are based upon quality principles: the essential

Plan Do Check Feedback loop and the application of the Hazards and Effects
Management Process (the so called HEMP).

Guidance contained in the preparation of documents in the HSE MS Manual has been
translated and rewritten here in the form of Self-Check lists. These can be used to
assess whether or not the base documentation contained in the HSE MS and the
various HSE Cases adequately cover the initial requirements of the HSE MS Manual.
In respect to the HSE MS, documentation is the primary focus. In the HSE Case
however the focus is both on the documentation and also on the Case's ability (on
paper at least) to provide assurance to an objective third party assessor that there is
sufficient substance in the Case for either acceptance or further compliance auditing.

A management system is defined as 'a structured set of controls for managing the
business (or part of the business)'. The purpose of any management system is to
ensure that the activities of a company are planned, carried out, controlled and
directed so that the business objectives of the company are met. It should be
understandable at the appropriate levels in the company and documented so that it
can be audited and verified to be effective. A management system should have a 'self-
healing' quality or improvement 'loop' within its construction. In simple terms each
activity follows the basic Plan-Do-Check-Feedback quality loop.

These self-check lists cannot provide any assurance that principles and intent are in
fact translated effectively into supervisory or workplace practices. This can only be
assessed realistically by a 'vertical slice' assurance that checks implementation of
policy and principles into practice.

NB If any section scores less than 50 per cent of the marks possible then the HSE MS
or HSE Case should be returned to the author for review and correction.

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II.1.1a Section 1a - Demonstrating leadership and management commitment

Table II.1a

1a. Is there a foreword or letter in this section signed by the CEO or

MD indicating his personal commitment to the HSE MS? 25
1b. Is mention made of a Strategy committing firstly the rest of the
Management Team and secondly the OPU / JV to implement the
HSE MS and HSE Cases?
2. Is it clear that the organisational and management structures are
being put into place to assure the safety of the OPU / JVs 20
operations with respect to HSE risk?
3. Are there plans for HSE MS and HSE Case implementation
incorporated in the Corporate HSE Policy and Strategic HSE 25
Objectives?
4. Are there clear statements that the OPU / JV has committed or is
Committing the level of resourcing needed to implement HSE MS 15
And HSE Cases?
5. Is there a clear vision statement with regard to where the HSE MS
fits in respect to its role in promoting structured management 15
systems as a wedge for quality and operational improvement?
100

II.1.1b Section 1b - Introduction to the HSE Management System Manual

Table II.1b

1. Does this section define the HSE Management System, its use and 10
benefits and describe the structure of the Manual?
2. Are the relationships to the corporate management system and other
management systems in the OPU / JV described? 10
3. Are the roles of the HSE Management System Owner (CEO) and the
appointed custodian in issuing and periodically reviewing and 30
revising the system and manual described and approved?
4. Are the relationships with corporate business and HSE objectives 10
clear?
5. Is the use of quality management principles referenced? 10
6. Is the HSE Manual a controlled document subject to review on a
defined cycle basis. 10
7. Is the planned Review Cycle for the HSE manual described?
(maximum interval of 3 years) 10
8. Does the introduction provide an adequate 'road map' to the 10
information to be found in each of the Parts and main sections of the
manual?
100

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II.1.2 Section 2 - policy and strategic objectives

The HSE Management System is a risk based objective setting system and it falls to the
management of the OPU / JV to set their own specific goals against which the effectiveness
of the HSE Management System should be measured.

Table II.2

1. Is the Policy for HSE included either in its entirety or as an 10

Appendix?
2a. Are the OPU / JV's HSE strategic objectives described? 20
2b. Are references made and is it intended to use PETRONAS Group
guidelines and standards, etc when HSE Policies and Objectives are
established?
3. Has the OPU / JV a plan (with clear targets) for the establishment of 10
HSE MS for the company and HSE Cases for its critical operations
and facilities?
4. Are national and local regulatory and legal HSE requirements within 5
which the OPU / JV conducts its business described?
5. Are legal regulations accepted as the minimum requirement? 15
6. Is there a requirement for the OPU / JV to reduce the risk in all its 15
operations to a level that is 'as low as reasonably practicable'
(ALARP for short)?
7. Is the principle of continuous improvement in HSE performance 15
explicitly endorsed?
8a. Are the HSE Policy and strategic objectives intended to be fully 10
disseminated to all staff including Contractors?
8b. Is there a plan showing how this will be achieved?
100

II.1.3 Section 3 - Organisation, responsibilities, resources, standards and

documentation

The HSE Management System to be effective requires resources to be allocated to it and

responsibilities to be defined.

Table II.3

1. Is there a clear description/requirement for HSE Cases to be prepared 5

and documented to demonstrate the extent to which HSE objectives
are being met in specific operations or facilities?
2. Is it a OPU / JV requirement for HSE matters to be a line 5
responsibility?
3. Are the means for achieving line responsibility for HSE described? 5
4. Is the requirement for an interlocking HSE committee structure fully 5
described in the section on organisation (to enable HSE policy,
objectives and targets to be fully communicated to the workforce)?

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5. Does the structure for communicating the HSE MS to others 10

specifically address methods aimed at ensuring clear workforce
involvement in hazards and effects analysis and management?
6. Is the role of HSE advisers defined in terms of job descriptions, 5
training requirements, competency and qualifications?
7a. Is it the intention that a minimum quality requirement be imposed 5
on those staff and contractors carrying out indirect safety or HSE-
critical support activities? i.e. those activities (like design) which
can 'set the scene' in Tripod terms for a possible accident.
7b. Is such a requirement adequately described?
8a. Is there a system for assuring (and documenting) the competence of 10
those employees who are expected to perform direct safety or HSE -
critical tasks? By this we mean those tasks whereby an incompetent
action may directly result in a significant loss (in terms of injury to
people, damage to the environment or to the asset, or to the
business).
8b. Are the means to achieve these competencies described?
9. Does the competence assurance system clearly indicate the standard 5
expected of those people undertaking directly HSE-critical
activities?
10. Are the ways in which training is provided for corporate HSE- 5
critical activities, including technical training, HSE specific
training, programmes of safety drills, emergency drills, spill
response and other HSE exercises, etc described- cross ref.?
11. Are the HSE considerations used in selecting and reviewing the 10
performance of contractors described in the OPU / JV 's HSE
Management System? .
12. Are ways in which the OPU / JV selects contractors and 5
subsequently manages HSE-critical interfaces described?
13. Are the procedures whereby the OPU / JV provides for effective 5
Contractor HSE Management cross referenced?
14. Does this section describe how standards are controlled and how 10
the OPU / JV reviews and incorporates new developments in codes
and standards for both new and existing facilities?
15. Is the OPU / JV's use of standards in hazards and effects 10
management described?
100

II.1.4 Section 4 - Hazards and effects management

This section should describe how HSE risk management objectives are to be achieved
through the management of hazards and effects using the Hazards and Effects Management
Process (HEMP).

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Table II.4

1. Is there an overview of the Hazards and Effects Management 5

Process (as applied to OPU / JV operations) contained within the
HSE MS?
2. Are the risk reduction measures as outlined in accordance with OPU 10
/ JV risk management objectives?
3. Is the need for assessment and cost - effective reduction of risks 10
company-wide to a level that is as low as reasonably practicable
(ALARP) described?
4. Is careful consideration given to both likelihood reducing and 15
consequence reducing controls needed to achieve HSE objectives?
5. Are the hazards and effects that are controlled mainly at a strategic 15
level i.e. by corporate activities recorded? (For example, endemic
diseases, waste reduction programmes, gas venting/flaring, etc)
6. Does the HSE MS establish and document appropriate performance 10
criteria and related indicators for the HSE MS?
7. Are the objectives and the requirement for an assessment to be 10
made of HSE impacts or potential impacts on people, on
communities, on the environment and on assets over the full life
cycle of an operation clearly described?
8. Are the objectives and the requirement for the Hazards and Effects 10
Management Process to be applied to all OPU / JV activities fully
described (as a means of evaluating risks and the controls needed
to be in place)?
9a. Are the procedures and techniques for early identification, review 10
and documentation of hazards and effects described? For example
requirements and timing for HAZOPs, Health Risk Assessments,
Environmental Assessments, etc stipulated?
9b. Are such procedures and techniques to be followed through the
life-cycle of the operation?
10. Is the requirement for recording all identified hazards and effects 5
and also the results of all risk evaluations described?
100

II.1.5 Section 5 - Planning and procedures

This section should describe the company's use of various plans and procedures aimed at
achieving HSE Objectives and should identify the key HSE procedures used in the OPU / JV

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Table II.5

1. Is the requirement for planning of all HSE-critical activities to 5

manage HSE risk detailed?
2a. Is the requirement for an annual OPU / JV HSE Plan or equivalent 5
described?
2b. Is there a description as to its contents and use?
3. Does the HSE Plan include action plans for implementation, 5
monitoring and improvement; including drills, audits, HAZOPs,
environmental assessments, waste reduction, emission reduction
and control, etc?
4a. Is specific mention made of the need to have limits of safe 10
operation established for use throughout the OPU / JV's operation?
4b. Is there a corporate requirement to prepare a MOPO (manual of
permitted operations) for each HSE Case?
5. Are concurrent operations procedures required by the OPU / JV to 10
be prepared in advance of activities which may increase HSE risk?
6. Are the procedures that are used to provide and maintain asset 10
integrity throughout the life cycle of an asset, described? (For
example, covering design, inspection, maintenance, etc and noting
the close links that exist between asset integrity and management of
HSE risks).
7. Is the permit to work system as used by the OPU / JV, described 10
including how and when it is applied?
8. Are the systems and procedures for managing all elements of 10
change that may affect hazards and effects management described?
(NB these should include the 4 P(s) - Plant, Process, Procedures and
People).
9. Is it clear how information concerning changes is communicated to 5
appropriate personnel?
10. Is it clear how the company intends to use procedures and work 5
instructions in hazards and effects management? In, for example,
planning, operations, monitoring, inspection, maintenance, job
cards, job hazard analysis, etc.
11. Are there intended to be programmes in place to ensure that 5
procedures being used are controlled and that they are simple,
unambiguous, understandable and relevant?
12. Are the OPU / JV requirements for emergency response, 10
contingency plans and procedures, for example, H2S plan, man
overboard procedure, escape and rescue of personnel, mitigation of
effects to assets and the environment following incidents, oil spills,
etc described?
13. To ensure that all staff are adequately prepared for any incidents 5
and fully understand the roles that they are individually and
collectively expected to play, are the requirements for exercises
and drills adequately explained?
14. Are specific techniques referenced, for example Job Safety / 5

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Hazard Analysis, Unsafe Act Auditing (Dupont STOP) and their

application described, etc?
100

II.1.6 Section 6 - Implementation, monitoring and corrective action

This section should describe the execution of HSE-critical activities and how the OPU / JV
measures and monitors their performance, it also provides a strong linkage to Part 2 - the
Activities Catalogue.

Table II.6

1a. As described is target setting intended to be based upon company 15

policy and key HSE strategic objectives and
1b. Are they to be aimed at progressive improvement over past
performance?
2. Are the means described by which data are collected, recorded and 10
disseminated and analyses carried out, in order to identify common
failures and trends in HSE risk management, waste reduction,
procedures or hardware?
3a. Is it clear how HSE MS critical activities are to be defined and 10
specified?
3b. How they are to be performed, to what standard and how such
performance standards are set?
4. Is it clear how resources are allocated and actions cascaded 5
throughout the organisation to meet HSE targets?
5. Is the setting of HSE targets for individuals derived from, and 5
consistent with, the corporate HSE targets and objectives?
6. Is it intended that the HSE targets for individuals be relevant to the 10
job, based on risk and interlock from level to level in the
organisation?
7. Are the various types of proactive and reactive performance 5
indicators used by the OPU / JV described?
8. Are proactive measurements, which monitor achievement against 15
objectives, and the extent of compliance with standards, outlined ?
(Note that proactive indicators are forward looking and predictive,
aimed at raising awareness of the possibility of incidents could
happen, for example, monitoring risk management controls,
analysis of trends, etc)
9. Are reactive measurements outlined which monitor incidents and 5
other evidence of deficient HSE performance? (For example, LTIFs,
TRCFs, waste generated, resources used, TROIFs, etc)
10. Is there a corporate requirement for incident investigation and 5
reporting? (Including near misses, exceeded control limits,
complaints from the community, as well as accidents).
11. Are the requirements for recording and reporting specific data 5
corporately to service companies and the procedures and tools used

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for this task, described?

12. Are the procedures for carrying out follow-up actions to prevent 5
recurrence of incidents described?
13. Are the means for communicating HSE performance to all staff 5
and external parties (communities, etc) on a regular basis described?
100

II.1.7 Section 7 Assurance including corrective action and improvement

This section shows the requirements and procedures in place to ensure regular and
independent audits of the HSE Management System and its associated Cases.

Table II.7

1. Are the relevant assurance policies and procedures referenced or 10

described?
2. Are the criteria to determine when assurances should be carried out 10
described?
3. Is the assurance programme structure described showing how it will 10
provide adequate coverage of the business?
4a. Are the different types of assurance covered? (From the 25
management system audit itself through to the assurance of specific
facilities or operations carried out under the management system
incl. HSE Case assurances, also the distinction with respect to
externally and internally led assurances).
4b. Does the assurance plan provide an adequate coverage of the
business?
5. Is the frequency and scope of assurance defined? (i.e. when they 15
should take place, e.g. at intervals required by regulations, or after
reorganisations, changes in the scope of activities, systemic
weaknesses indicated, major modifications, major incidents, new
appreciation of technology, etc)
6. Is there a requirement for an assurance corrective action procedure 15
and does it describe how corrective actions arising from shortfalls,
identified in the HSE Management System, HSE Cases, drills,
audits, etc are intended to be agreed, prioritised, carried out,
monitored and eventually formally closed out as complete?
7. Are the means for communicating lessons learnt from assurance 15
process across the OPU/ JV to relevant personnel for follow up and
application in similar facilities, operations or activities described?
100

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II.1.8 Section 8 - Management review - including corrective action and improvement

This section shows the requirements and procedures in place to ensure regular management
reviews of the HSE Management System and its associated Cases.

Table II.8

1. Are the relevant management review policies and procedures 10

referenced or described?
2. Is the frequency and scope of reviews defined? (i.e. when they 15
should take place, e.g. at intervals required by regulations, or after
reorganisations, changes in the scope of activities, major
modifications, major incidents, new appreciation of technology, etc)
3. Is there an explanation of the structure of the review programme? 15
4. Does the review programme provide adequate coverage of the 10
management systems and processes?
5. Have the plans for review and improvement of the HSE Management 10
System and Cases been described?
6. Is there an improvement strategy that describes the process for 25
making changes and improvements to the HSE Management System,
as well as a procedure for finally incorporating these changes into a
'lessons learnt database' and into Cases as needed?
7. Are the means for communicating lessons learnt from reviews across 15
the OPU / JV to relevant personnel for follow up and application in
similar facilities, operations or activities described?
100

II.2 PART 2 - THE HSE MANAGEMENT SYSTEM ACTIVITIES CATALOGUE

Part 2 of the HSE Management System Manual contains the quality requirements for
activities involved in the application of the Hazards and Effects Management Process at the
corporate level. These activities are referred to as HSE-critical and should have formal
Activity Specifications prepared for them.

Formal Activity Specifications make HSE management objectives, responsibilities and

controls more explicit and visible. They stabilise business processes, ensure that control is
more consistently applied over time and maximise linkage between all levels in the OPU /
JV.

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Table II.9

1a. Is there a requirement for HSE-critical-activity quality records either 20

electronically or on paper?
1b. Is there an Activities Catalogue or equivalent within the HSE MS
2. Is it intended that the HSE MS activity quality record provide an 25
outline of essential competencies, defined accountabilities and that it
allows a clear audit trail through the HSE Management System?
3. Is it clear, how the listing of HSE-critical activities is arrived at 5
including reference to a Business Model, an OPU specific business
process analysis or simply a brainstorming of activities, as
appropriate?
4. Is the purpose of activity management and how it is to be used 15
explained including the roles of the process custodians and activity
owners and their responsibilities to endorse the Activity
Specifications?
5. Are the required review cycles for Activity Specifications described 15
including, how and when they should be revised and the need for re-
endorsement as and when process custodian or activity owners
change?
6. Are control copies of quality records for each of the HSE-critical 20
activities formally endorsed by the persons accountable for each
activity and the process of which it is a part?
100

II.3 PART 3 - REFERENCES, DOCUMENTS AND STANDARDS

Part 3 of the HSE Management System Manual draws together into a comprehensive list all
the documents and standards referred to in Parts 1 and 2, together with a description of their
purpose, revision date, their custodians and review cycle; cross referenced to the appropriate
activities, hazards and effects. In addition, as Cases are developed and site specific controlled
documents identified these should be included in Part 3 of the HSE Management System
Manual.

Table II.10

1. Is there a single controlled listing of all controlled documents relevant 50

to the HSE MS and to the associated Cases?
2. Is there a formal procedure for incorporating HSE Case controlled 25
documentation into the HSE Manual Reference Documents and
Standards?
3. Is there a clear review cycle requirement for all documents relevant to 25
the HSE MS and a formal change control procedure for these
documents described?
100

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II.4 PART 4 - SHORTFALLS AND REMEDIAL ACTION PLAN

Part 4 of the HSE Management System Manual should state the requirement for all
shortcomings identified through preparing the HSE Management System, through assurances
and reviews, etc to be recorded and remedial action plans developed to correct them.

Table II.11

1. Is there a requirement for all shortcomings identified through the 25

preparation of the HSE MS and Cases to be recorded and for a
remedial action plan to be developed to correct them?
2. Is there a requirement to detail the responsibilities for monitoring 25
remedial action plans and for ensuring that remedial actions are
carried out according to plan?
3. Is it clear how the progress of the HSE Management System remedial 25
actions is intended to be monitored? (For example is it included in an
integrated tracking system which also covers audit and review action
items?)
4. Is it clear how the shortfalls identified in Cases are included into the 25
HSE MS remedial action plan as appropriate?
100

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APPENDIX III

DOCUMENTING THE HSE CASE

Documenting the HSE Case should be carried out with a large degree of discretion and
restraint. The term 'describe the ........... ' is used in many places to provide direction as to
what is required in a particular section or part of the Case. It is not intended to prescribe
extensive documentation when a brief reference or description would suffice. Likewise
'maintenance of procedures to.....' or 'the OPU / JV should maintain procedures for .....' are
not intended to prescribe that written procedures are necessarily required for all practices.
The HSE-criticality and objectives set will determine whether a formally documented and
controlled procedure is required. 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 and associated Cases including controls and documentation remains the
responsibility of the company and these Guidelines should be read in this context of self -
regulation.

The Case described in this guideline is constructed in seven linked parts as shown in Figure
III.1. It is not necessary that this structure is followed rigidly as long as all the elements are
covered in a logical structure.

Figure III.1 The HSE Case

The HSE CASE

Part 1 Part 2 Part 3 Part 4 Part 5 Part 6 Part 7

Management Hazards
Operations Activities Description Identified
Summary and Effects Conclusions
HSE Catalogue of Shortfalls
Analysis
and Management Operation Hazards &
Introduction System
Effects Remedial Statement
Register Work Plan of Fitness
MOPO

III.1 PREPARATION OF PART 1 - MANAGEMENT SUMMARY AND

INTRODUCTION

Part 1 of the Case contains a Management Summary and an Introduction.

The Management Summary provides a brief overview of the Case findings, a
summary of the objectives established by operations management (based upon the
HSE Management System objectives), and an endorsement of the Case by
management and all parties associated with its compilation, review and validation.

Part 1 may also include a description of historical HSE performance in the facility or
operation by way of background to the objectives and targets set, and providing a

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baseline for future comparison over time of how the HSE Management System is
actually performing in the operation. Include in this section:

INTRODUCTION

Provide a brief synopsis of the facility or operation covered by the HSE Case,
noting in particular the limits of coverage and main interfaces with activities
outside the scope of the HSE Case. The name, description, location and
function of each facility, or operation, covered by the HSE Case should be
described. State whether the focus of the HSE Case is on an integrated HSE
Case or on elements of health, safety, or the environment. Describe the current
and past HSE performance of the facility or operation, noting any significant
events, as a basis for comparing future performance.

STATEMENT OF OBJECTIVES FOR PREPARING THE CASE

Provide a brief summary statement of the objectives of preparing the HSE Case,
e.g. to meet legislation, assure risks ALARP, demonstrate HSE risk
management in high risk/high potential consequence facility or in a facility
which is critical to the business, safeguard the operation against a PPD and
fatality, any major effect on the environment or reputation.

STATEMENT OF CRITERIA USED TO MEASURE ACHIEVEMENT

OF OBJECTIVES

Provide a brief statement of the criteria used to determine whether the HSE
Case objectives are met.

CONCLUSIONS AGAINST OBJECTIVES

Provide a summary of the main conclusions of the HSE Case in relation to

meeting the defined objectives. Mention any major shortcomings found,
remedial works and temporary measures recommended to enable continued
operation.

STATEMENT OF HOW RECOMMENDATIONS AND REMEDIAL

WORK ARE TO BE ADDRESSED

State how the recommendations of the HSE Case and any remedial actions are
to be put in place, noting any target dates or schedule for the main remedial
works.

SUMMARY OF METHODOLOGY USED

Provide a brief description of the methods used in preparation of the HSE Case,
note the use of syndicates, work groups, facilitators, consultants, experts,
quantitative methods, physical effects modelling, etc as appropriate.

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DEFINITION OF CASE OWNER AND CUSTODIAN

State who is the owner of the HSE Case, (normally the asset holder of a
facility), and the HSE Case custodian to whom maintenance of the case is
delegated.

REVIEW CYCLE

State the HSE Case review cycle and identify the person responsible for
maintaining the HSE Case and ensuring its review at specified intervals.

CASE CONTENTS

Provide a brief explanation of the contents of each part of the HSE Case as an
overview of where specific information may be found.

Contractor's Note: This part of the HSE Case is jointly prepared by the OPU / JV
and the Contractor.

III.2 PREPARATION OF PART 2 - OPERATION'S HSE MANAGEMENT

SYSTEM

Part 2 of the HSE Case documents the quality system used for managing HSE risk in
the specific facility or operation covered. It translates the material given in the HSE
Management System Manual Part1 from the corporate level, to a demonstration of
practice at the level applicable to the management of the specific facility or operation.
For some operations, e.g. new ventures seismic surveys of limited scope, there may
initially be little or no difference between corporate-level and operation-level
material. Part 2 should then demonstrate the operation specific application of the
systems described in the HSE Management System Manual.

As the Operation's HSE Management System reflects the corporate HSE

Management System, much of the guidance on content given in Appendix I applies
here. Part 2 should however detail local interpretation of corporate policies and
objectives, contact persons, relevant meetings, controls and plans, e.g. contingency
plans. It should relate, and be cross referenced to, appropriate parts of the hazard
analysis and installation description. References should be as specific as possible.
Documents, standards, procedures, etc which are referenced in the HSE Case should
be controlled documents with unambiguous titles and document numbers.

Table III.1 provides a comparison of the types of information covered in the HSE
Case and how this relates to similar types of information in the HSE Management
System Manual.

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Table III.1 Information in HSE MS and HSE Cases

HSE Management System HSE Case Part 2

Manual Part 1
Corporate HSE Policy and other policies Corporate HSE Policy and other OPU / JV
relevant to HSE management in the OPU / policies relevant to facility or operation's
JV. HSE management, plus any additional
policies specific to the facility or operation.

HSE Objectives for the OPU / JV HSE Objectives and targets applicable to the
facility or operation.
Corporate level definition of Organisation, Organisation, Responsibilities, and
Responsibilities, Resources, relevant to Resources, relevant to HSE management
HSE management. within the facility or operation.
Requirements for Hazards and Effects The specific application of Hazards and
Management to be applied to all OPU / JV Effects Management in the facility or
activities as applicable. This would cover operation. This includes, ie risk assessments,
activities such as planning, design, etc., environmental assessments, health risk
which set the scene for HSE risks in assessments and classification of HSE-
current or future facilities or operations. It critical activities and procedures, etc needed
would also cover those activities carried to provide controls on HSE risks in the
out by the OPU / JV where no HSE Case facility or operation.
is deemed necessary.
Corporate level Planning of activities and Planning of activities and procedures used
provision of Procedures for management within the facility or operation to reduce risk
of HSE risks in the OPU / JV. This would to people, the asset, and to the environment,
also cover corporately providede.g. reduce emissions and waste streams.
emergency response (firefighting, oil spill Also define interfaces with corporate level
response, medical facilities, etc.,) and standard procedures with appropriate cross
crisis management plans which serve all referencing to hazards and effects analysis.
facilities and operations in the OPU / JV. Ensure that interfaces with, and dependence
Corporate level generic procedures use upon, corporately provided resources and
throughout the OPU / JV and in all HSE facilities are described, e.g. emergency
Cases where relevant. response plans should be highlighted.
Implementation, Monitoring andImplementation, Monitoring and corrective
corrective action as applied to corporate action as applied to the activities defined
level activities defined within the HSE within the Operation's HSE Management
Management System. Activities will tend System. Activities will tend to be defined at a
to be defined at a high level and aligned more detailed level and aligned with the
with the organisation, responsibilities, andorganisation, responsibilities and
accountabilities of corporate staff. accountabilities of staff within the facility or
operation.
Audit and Management Review Audit and review requirements as defined
requirements as defined at a corporate within the scope of the facility or operation.
level and applicable generally to all OPU /
JV operations.

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Interfaces between those activities that take place within the facility or operation and
those that are carried out corporately should be highlighted, e.g. where support
services are provided from a Head Office central organisation. Assumptions made,
when preparing the risk assessments, regarding how local emergencies would
interface with Corporate systems should be described. Any such assumptions made
regarding the coverage of emergency response provided by the corporate HSE
Management System should be verified.

Contractor's Note:
Where the operation covered by the HSE Case is contracted out, this Part of the HSE
Case is primarily concerned with the contractor's HSE Management System. To this
should be added any additional requirements from the company's HSE Management
System and an explanation as to shared facilities between the OPU / JV and any
involved contractor. Key interfaces between the contractor and the OPU / JV should
be highlighted and the responsibilities of each party defined.

III.3 PREPARATION OF PART 3 - CASE ACTIVITIES CATALOGUE

Part 3 of the HSE Case contains the quality requirements for activities involved in the
application of the Hazards and Effects Management Process in the facility or
operation. It translates the material given in the HSE Management System Manual
Part 2 from the corporate level to a level applicable to the facility or operation. The
HSE Case covers only those activities actually taking place in the operation under
consideration. The method used to establish the linkage to the plant or operation will
vary from OPU / JV to OPU / JV. A method that works well for a process plant is to
divide the operations activity analysis by area or location. As a general rule the HSE
Case analysis documented in the HSE Case Activities Catalogue should show that
controls are in place and that the working practices and procedures are both suitable
and sufficient. Include in Part 3:

FOREWORD

Describe the purpose of Part 3 and how it is to be used.

The Activity Specifications provide documentation of controls at the appropriate

level, ie at the level of accountable line supervision. In this context accountability is
defined as responsibility plus sufficient delegated authority.

Describe the roles of the process custodians and activity owners and their
responsibilities to endorse the Activity Records. Endorsement signifies acceptance of
accountability for the activities.

Describe the required review cycles for Activity Records, how and when they should
be revised and the need for re-endorsement as and when process custodian or activity
owners change.

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STRUCTURE OF THE ACTIVITY LISTING

Describe how the listing of HSE-critical activities was arrived at, noting the use of
any business model, business process analysis or simply a brainstorming of activities,
as appropriate.

Describe how these activities have been grouped and numbered for reference, relating
the numbering system to any 'parent' system such as a business model,

Highlight interfaces between activities covered by the HSE Case and activities
covered only by the corporate HSE Management System.

The level of business process (activity and task) analysis depends upon the operation
and upon existing working practices. In all cases supervisory staff need to have an
understanding of the tasks carried out in their area of responsibility. Such an
understanding will often exist already and be confirmed in standing instructions and
work instructions. Where this is the case, the hazards and effects encountered in the
work situation should be cross-checked with the activities, to gain assurance that all
hazards and effects are being effectively managed. In cases where task definition is
less clear, much is to be gained by carrying out the analysis to task level. Workplace
tasks require sound craft practices or working instructions and such an analysis often
reveals shortfalls in understanding and procedural control especially where there are
interfaces involved. Involving the workforce in this process and in identifying for
themselves the relevance of standing procedures and the rationale for existing
recommended work practices promotes good craftsmanship and provides a real sense
of ownership. Tasks should be aggregated to the supervisory level where documented
control should be demonstrable.

CATALOGUE OF ACTIVITY RECORDS (SPECIFICATION SHEETS)

Prepare an HSE Case Activity Record for each HSE-critical activity. The Activity
Records provide a definition of quality assurance aspects, an outline of essential
competencies, define accountabilities and allow a clear audit trail throughout the HSE
Case. Activity Records should be prepared by those persons involved in, and
recognised as accountable for, the specific activities under review. A control copy of
the quality record of the specification for each of these activities should be printed
out and properly endorsed by the persons accountable for each activity and the
process of which it is a part. Activity specification records (Specification Sheets)
endorsed by the appropriate activity and process owners, once compiled form the
Case Activities Catalogue.

The Activity Records can then be used as the information database from which
information can be extracted which is both relevant and usable at the workplace. NB
it can be seen that in carrying out a full assessment of a HSE-critical activity, hazards
and effects relevant to that activity will be identified and assessed and controls will
be described. It is hence important to log such hazards and effects information as the
activity analysis proceeds and to enter it later into the Hazards and Effects Register.

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Some companies, in addition, produce task definition specification records. These

can be simpler than the Activity Records in that they do not require the same level of
verification or business control. These task records, plus the relevant information
regarding hazards and effects identified as being relevant to the tasks, provide and
ensure that the working level information has a good linkage with the workplace.
Task specifications are then cross referenced in the Activity Records. The Case does
not necessarily require such task sheets, but the Activity Record does need to refer to
a competent set of work instructions and procedures.

For a more complete discussion on HSE-critical activities to be documented and how

to prepare a HSE Case Activities Catalogue see Appendix V.

Part 3 is often the most suitable place for highlighting the HSE-critical Operating
Procedures, i.e. those procedures crucial to the management and control of the
hazards and effects within the operation. See discussion in III.5.3.

Contractor's Note:
Dependent upon the nature of the contract, the Activities Catalogue for the HSE Case
may be mostly produced by the Contractor or by the OPU / JV. The HSE
Management System Activities Catalogue can provide a key bridging document
between OPU / JV and contractor.

Since many of the OPU / JV's activities are conducted on its behalf by contractor's, it
is essential that the OPU / JV and Contractor jointly produce the Activities
Catalogue.

The Contract remains the primary point of reference between the parties but for
contracted out activities and for those interfaces between the Contractor and OPU /
JV, the Activities Catalogue will provide a complete vehicle for referencing the
Contractor procedures and standards and for negotiating the way in which the work is
to be carried out.

III.4 PREPARATION OF PART 4 - DESCRIPTION OF OPERATION

Part 4 of the HSE Case should describe the essential features relevant to the HSE and
emergency management of the facility or operation. This enables an understanding of
how major hazards and effects, discussed in Part 5, could affect the facility or
operation and its HSE systems. Design features for HSE enhancement should be
clearly documented (e.g. design and operational levels of critical equipment, fire
pump flow rates, ESD system specifications, etc). Include in Part 4:

OUTLINE OF OPERATION

Provide a simple, accurate outline of the operation and all associated facilities. When
an operation comprises several entities then each entity should be described
separately. There should also be reference to any temporary facilities.

HSE-CRITICAL CONTROLS

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Reference and where necessary describe all systems and procedures that are in
place to control, reduce the likelihood of loss of control, mitigate and prepare for
recovery from hazards and effects. The description should include all systems
required by regulatory requirements. The description should be able to
demonstrate that equipment and operations which must remain operational during
an emergency are protected and will be functional during any accidental event for
which they are required.

ILLUSTRATIONS

Provide visual aids in the form of drawings, 3-D perspectives, maps, photos, Process
Flow diagrams, Hazardous Area Classification drawings, evacuation routes, etc in
support of the description.

Contractor's Note:
Where the operation is fully contracted out then this Part will be entirely produced by
the Contractor.

III.5 PREPARATION OF PART 5 - HAZARDS AND EFFECTS ANALYSIS,

HAZARDS AND EFFECTS REGISTER, HSE-CRITICAL OPERATIONS
PROCEDURES

Part 5 of the HSE Case should demonstrate that all potentially significant hazards and
effects have been identified, the risks from the hazards and effects evaluated and
understood, and that controls to manage risks of the hazards and effects are in place.

Part 5 contains three sections:

Hazards and Effects Analysis

Hazards and Effects Register

HSE-critical Operations Procedures; (can also be in Part 3 of the Case)

III.5.1 Hazards and effects analysis

The first section of Part 5 is a summary of those investigations carried out as part of
the Hazards and Effects Analysis into all types of accident scenarios, hazardous
conditions, environmental effects. Such studies include the structured review
techniques described in Volume 3 and summarised in PTS 60.0401 Hazards and
Effects Management Process. These include:

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HSE

Hazards and Effects Studies

Comparison with Standards Studies

Qualitative Risk Assessment Studies

Cause & Consequence Analysis

Quantitative Risk Assessment Studies

Non-hydrocarbon Event Analysis.

Health Risk Assessments

Human Error Analysis

Layout Methodology

HAZID, HAZOP and SAFOP Studies

Temporary Safe Refuge Survivability Analysis

Escape, Evacuation and Rescue Analysis

Emergency Systems Survivability Analysis

Smoke Ingress Analysis

Failure Modes and Effects Analysis

Fire-Pran

Fire and Explosion Analysis

Environmental Profile Studies

Environmental Assessments (EA)

Social Impact Assessments

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Environmental Risk Studies (Predictive Analyses)

Such studies should be fully referenced so that they may be accessed if required. A
summary of the main findings from these studies should be included in the HSE
Case.

This section provides evidence, that a full and systematic check has been made for
hazards and effects and that potentially significant hazards and effects have been
analysed in terms of associated risks. It demonstrates that an appropriate level of HSE
risk reduction has been achieved, that acceptance standards have been met and that
the risk is as low as reasonably practicable (ALARP for short). Details of analysis
methods are given in other sections of the HSE Manual.

During these analyses it is important to log assumptions and risk parameters so that
appropriate performance indicators for the operation or facility can be established.
The principle should be to monitor design assumptions and to provide warning when
risk parameters and hence overall risk levels are changing. For example if an
operation assumes a level of discharge which in actual operation is exceeded more
often than had been assumed then it would be reasonable to state that either the
original environmental risk had been underestimated or risk levels had for some
reason increased since start up.

Contractor's Note: For an operation or facility/vessel, etc operated by a contractor it

is clearly incumbent upon the contractor to properly evaluate hazards and effects
relevant to his operation. The Contractor should provide in the HSE Case a list of
methods used, studies carried out with key results. Studies should be retained by the
Contractor and be available to OPU / JV technical and HSE auditors when requested.
A client company has the right of access to all evaluations and risk assessments and it
is up to the contractor to provide all necessary information needed to support the
analysis.

III.5.2 Hazards and effects register

The Hazards and Effects Register is a communication document that should be

readily understood by contractors and OPU / JV staff alike. It is a quality record,
which demonstrates that all the hazards and effects (in terms of the objectives
established for the HSE Case) have been identified, are understood and are being
properly controlled. It demonstrates that the facility, 'as built' and 'as will be operated',
or the operation 'as planned', is adequately defended and preparations are in place to
handle any consequence that could result if control is ever lost. The purpose of the
Hazards and Effects Register is to present in a clear and concise form, the results of
the analysis made of each hazard or effect present at, or resulting from, the facility or
operation. Completion of the Hazard Register will document for each hazard or
effect:

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IDENTIFICATION of where and when the hazard or effect is encountered in, or

results from, the facility or operation

IDENTIFICATION of the probable accident initiating events (threats) that

could 'release' the hazard or effect, or cause emission control limits to be
exceeded

IDENTIFICATION of possible consequences that would result if control of the

hazard or effect is lost or emission control limits exceeded

IDENTIFICATION of escalating factors that would increase the likelihood of,

or severity of consequences of an incident or continuous emission

An assessment of the worst case risk associated with the hazard or effect (no
defences) and an assessment of the risk carried by people and the installation once
this risk is defended against, i.e. the residual risk

A description of the controls required for each and every threat or initiating event
identified. The degree of control applied to each threat should meet OPU / JVs
acceptance criteria. Any threat not controlled in accordance with the acceptance
criteria should be included in the Remedial Work Plan as a shortfall.

A description of the recovery methods and facilities required to mitigate and

recover from each consequence identified. The recovery preparedness measures
should include active, passive and operational preparedness measures. The degree
of preparedness for each consequence should meet OPU / JV's acceptance
criteria. Any consequence not prepared for in accordance with the acceptance
criteria should be included in the Remedial Work Plan as a shortfall.

(The Hazards and Effects Register should also cater for the routine or intermittent
releases that cause effects above ALARP and above acceptance standards such
that they should be reduced to the 'No Effect Level' (NOEL). Such releases will
be addressed through long term plans at the corporate as well as the facility level.
These plans should identify 'What', 'How', 'When', and 'Who' is responsible for
reducing the level and also be clearly aligned with targets and resources for
implementation.)

A cross reference to installation activities accountable for performing and

assuring the above requirements are in place and performing to standard.

Contractor's Note:
The Hazards and Effects Register should be understandable at all levels of the
operation. It is a vital communication document and should, in a contracted out
operation, be prepared by the Contractor. The client company should provide the
Contractor with a part-complete Hazard Register showing those hazards and
effects already identified and request via the contract conditions that Contractor
complete all assessment, control and recovery sections using Contractor's own

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procedural references, etc. Contractors should also be requested and it should be a

contractual condition that they provide information in accordance with the
Hazards and Effects Management Process for all hazards and effects newly
identified by him.

III.5.3 HSE-critical operations procedures

This section of Part 5 covers mandatory HSE-critical Operations Procedures.

Activities Records should refer to specific procedures which are critical to the
management of HSE risks - the 'HSE-critical Operations Procedures'. These
procedures will often already exist in some form as a part of the operating procedures
and simply require to be flagged and for a listing to be produced. Include in this
section:

Key hazard control and recovery procedures for the operation

Describe the detailed procedures for operating, monitoring and inspecting key
items of plant, including baseline inspection data and acceptance criteria for
specific equipment or facilities.

Describe emergency and contingency plans and procedures including training and
testing methods.

Each procedure should include a statement of the hazard management objectives

and the design assumptions inherent in its preparation. An example of an HSE-
critical Operations Procedures is 'Procedure for entry into Confined Spaces'

Contractor's Note:
Procedures used in a contracted out operation will usually be Contractor's own
procedures. Thus, this part of the HSE Case should be prepared by both
Contractor and OPU / JV.

III.6 PREPARATION OF PART 6 - REMEDIAL WORK PLAN

The preparation of a HSE Case is a fact finding process used to determine conformity
at the installation/operational level to the various elements of the OPU / JV HSE
Management System and the acceptance criteria for hazard and risk management.
The Case should contain a demonstration of commitment to improvement by
providing a plan, known as the 'Remedial Work Plan', to resolve the shortfall findings
of the assessments and thereby improve the safety of the installation/operation.
Expected contents of Part 6 would include:

a status report list of all findings of the Case, and also findings from subsidiary
studies or similar e.g. assurance that have not been satisfactorily resolved

a plan to ensure resolution of any shortfalls in the installation/operation HSE

Management System

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a plan to ensure resolution of any shortfalls in the management of hazards and

effects

a plan to ensure resolution of any risk reduction recommendations

The plan should show action parties, a priority rating and completion dates.

Contractor's Note:
This will be a jointly prepared part of the HSE Case in a contracted out situation.
The management of HSE requires to be conducted in a spirit of co-operation
between company and contractor and in an environment where information can
be freely exchanged. Thus the emphasis from the outset should be to provide an
open working relationship between contractor and OPU / JV. This should be
based upon agreement that such co-operation is mutually beneficial. However
such an approach may be difficult to achieve by requests alone and it is vital that
the contract include the necessary conditions to require the Contractor to
contribute to the preparation of an adequate HSE MS and to HSE Cases.

III.7 PREPARATION OF PART 7 - CONCLUSIONS AND STATEMENT OF

FITNESS

Part 7 of the HSE Case presents the conclusions concerning meeting the objectives of
the HSE Case in as simple a fashion as possible. In particular it notes those events
that were assessed as large risk contributors.

This part shall also contain a Statement of Fitness for the operation or facility. Such a
statement may take the form of the following example:

Given the findings of the hazards and effects analysis and the measures already taken,
or in hand, to lower risk associated with the operation, it is concluded that this HSE
Case demonstrates that, to the extent reasonably possible:

(1) there is [or will be by {give date}] a management system in place for the
operation, adequate to enable the company to comply with all relevant statutory
and OPU / JV provisions in relation to [name of operation] and any activity in
connection with it

(2) there are adequate arrangements in place for the assurance and review of that
management system at appropriate intervals

(3) all hazards and effects with the potential to cause major harm to people or the
environment have been identified, assessed, controlled and that plans are in place
for recovery in the event control is lost; and

(4) risks have been evaluated and measures taken to reduce HSE risks to a level that
is as low as reasonably practicable.

In view of the above, the operation/installation is considered safe to operate.'

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NB this 'Statement of Fitness' has the same standing as the 'Letter of Representation'
for business controls.

Contractor's Note:
The Statement of Fitness must be jointly agreed by both OPU / JV and Contractor but
the Client OPU / JV should recognise where the Contractor is carrying out operations
on behalf of PETRONAS.

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APPENDIX IV

THE HSE CASE CHECKLIST

The purpose of the HSE Case is to provide assurance of the effective working of the HSE
Management System at a site specific level. It also provides a simple, methodical and
auditable reference document containing all information relevant to the safety of the
operation's personnel, environmental and resource protection. The HSE Case is to be a
'living' document that is added to and amended throughout the life of the operation.

IV.1 PART 1 - MANAGEMENT SUMMARY AND INTRODUCTION

Table IV.1

Is the HSE Case endorsed by management and all parties associated with 10
its compilation, review and validation?
Is it clear who is the Owner of the HSE Case, (normally the asset holder of 5
a facility)?
Is it clear who is the HSE Case Custodian - the person to whom 5
maintenance of the HSE Case is delegated?
Is there an overview of the HSE Case findings? 5
Is there a brief synopsis of the facility or operation covered by the HSE 5
Case with, in particular, the limits of coverage and main interfaces with
activities outside the scope of the HSE Case indicated?
Is there a brief summary statement of the objectives of preparing the HSE 10
Case, e.g. to meet legislation, to assure that risks are reduced to ALARP,
to demonstrate HSE risk management in high risk/ high potential
consequence facility, facility critical to the business, etc?
Are the objectives as stipulated based upon the HSE Management System 10
objectives?
Does the HSE Case provide a brief statement of the criteria, which should 5
be used to determine whether the HSE Case objectives are met or not.
Does the HSE Case include clearly expressed acceptance criteria in terms 5
of the number of barriers, recovery preparedness measures and escalation
controls that can be used to determine whether the level of control is
suitable and sufficient?
Is there a summary of the main conclusions of the Case in relation to 10
whether it meets the defined objectives or not?
Has the current and past HSE performance of the facility or operation with 5
any significant events, been included as a basis for comparing future
performance?
If major shortcomings have been found, and remedial works and 15
temporary measures recommended to enable continued operation, do these
appear adequate and are they properly referenced? Is there a plan to put
recommendations and remedial actions in place with target dates, action
parties and priority rating?
Is there a brief explanation of the contents of each part of the HSE Case as 5

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an overview and 'road map' as to where specific information may be

found.
Is there a clear HSE Case review cycle? 5
100

Contractor's Note:
This part of the HSE Case is prepared by the OPU / JV and the Contractor since it should
reflect the measures taken by both parties to ensure a satisfactory level of HSE management
in the operation.

IV.2 PART 2 - OPERATION'S HSE MANAGEMENT SYSTEM

Part 2 of the HSE Case documents the quality system used for managing HSE risk in the
specific facility or operation covered. It translates the material given in the HSE Management
System Manual Part1 from the corporate level, to a demonstration of practice at the level
applicable to the management of the specific facility or operation. For some operations, e.g.
new ventures seismic surveys of limited scope, there may initially be little or no difference
between corporate-level and operation-level material. Part 2 should then demonstrate the
operation specific application of the systems described in the HSE Management System
Manual.

Table IV.2

Does the HSE Case include the corporate HSE Policy and relevant site 5
specific policies?
Are the local HSE objectives and targets clearly linked to the Policy and 5
Strategic Objectives of the OPU / JV?
Are the Organisation, Responsibilities, Resources, etc relevant to HSE 5
management within the facility or operation described?
Are interfaces with the HSE MS described (e.g. in respect to dependence 5
on emergency response and preparedness, shared facilities, etc)?
Have site specific locally applicable HSE acceptance criteria in terms of 5
required levels of control been established?
Have site specific locally applicable HSE targets based upon risk been 10
established?
Are risk assessments and activity definitions required to provide the 10
essential controls in respect to the HSE risks within the facility or
operation described?
Is the planning of activities outlined together with the relevant procedures 10
needed within the facility or operation?
Is there a clear description of how implementation, monitoring and 10
corrective actions are carried out within the locally specific Operations
HSE Management System?
Are interface activities with the corporate organisation, e.g. design 5
integrity provided by a central design office, etc identified?
Are audit and review requirements defined for the facility or operation in 15
the HSE Case?

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Are the local site specific system and procedures for managing elements 5
of change affecting hazards and effects management described with
reference to the HSE MS?
Are procedure which are intended to manage asset integrity described and 5
in line with HSE MS?
Are site specific HSE targets linked all the way to HSE MS corporate 5
targets?
100

Contractor's Note:
Where the operation covered by the HSE Case is contracted out, this Part of the HSE Case is
primarily concerned with the contractor's HSE Management System. To this should be added
any additional requirements from the OPU / JV's HSE Management System and an
explanation as to shared facilities between the OPU / JV and any involved contractor. Key
interfaces between the contractor and the OPU / JV should be highlighted and the
responsibilities of each party defined.

IV.3 PART 3 - CASE ACTIVITIES CATALOGUE

Part 3 of the HSE Case contains the quality requirements for activities involved in the
application of the Hazards and Effects Management Process in the facility or operation. It
translates the material given in the HSE Management System Manual Part 2 from the
corporate level to a level applicable to the facility or operation. The HSE Case covers only
those activities actually taking place in the operation under consideration.

Table IV.3

Is the purpose of the Activities Catalogue and how it is to be used 5

described?
Is there a clear audit trail throughout the HSE Case? 15
Have the workforce been involved in the activity and task analysis? 10
Is documented control demonstrable at the supervisory activity level? Are 15
there Activity Specifications providing documented control at the
appropriate level? (i.e. at the level of accountable line supervision? N.B.
In this context accountability is defined as responsibility plus sufficient
delegated authority)
Is it clear how and when Activity Specifications should be reviewed and 5
revised?
Is the need for re-endorsement described? (e.g. as and when process 5
custodian or activity owners change)
Are interface activities i.e. activities covered only by the corporate HSE 5
Management System highlighted in the HSE Case?
Have hazards and effects encountered in the work situation been cross 10
checked with the activities?
Are essential competencies, and accountabilities referenced in the 5
Activity Specification?
Have Activity Specifications been prepared by those persons involved in, 10

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and recognised as accountable for, the specific activities?

Has a control copy of the quality record of the specification for each of 5
these activities been printed and properly endorsed by the persons
accountable for each activity and the process of which it is a part?
Are the control copies of the activity quality record up to date? 10
100

Contractor's Note:
Dependent upon the nature of the contract, the Activities Catalogue for the Case may be
mostly produced by the Contractor or by the OPU / JV. The HSE Management System
Activities Catalogue can provide a key bridging document between OPU / JV and contractor.
Since many of the OPU / JV activities are conducted on its behalf by contractors, it is
essential that the OPU / JV and Contractor jointly produce the Activities Catalogue.

The Contract remains the primary point of reference between the parties but for contracted
out activities and for those interfaces between the Contractor and PETRONAS, the Activities
Catalogue will provide a complete vehicle for referencing the Contractor procedures and
standards and for negotiating the way the work is to be carried out.

IV.4 PART 4 - DESCRIPTION OF OPERATION

Part 4 of the HSE Case should describe the essential features relevant for HSE and
emergency management of the facility or operation. This enables an understanding of how
major hazards and effects, discussed in Part 5, could affect the facility or operation and its
HSE systems.

Table IV.4

Has a simplified outline of the operation been included within the scope 10
of the HSE Case?
Does the description include all systems required by regulatory 10
requirements, e.g. cranes, pressure vessels, and relief systems required to
be inspected by either regulator or third party certifying authority?
Have all associated facilities within the scope of the HSE Case been 10
covered?
Are all systems and procedures that are in place to control, reduce the 10
likelihood of loss of control, mitigate and prepare for recovery from
hazards and effects referenced?
Is there a clear breakdown of the facility or operation plot plan in terms of 10
supervisory control and/or locations?
Does the description demonstrate to the extent possible that all equipment 10
and operational facilities which must remain available during an
emergency are protected and that they will remain operational during any
accidental event for which they are required?
Have specific design features been included as HSE enhancements? If so 10
are they clearly detailed?
Have the major hazard inventories and the key safeguarding systems been 10

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clearly described and their locations identified?

Have suitable visual aids in the form of drawings, 3-D perspectives, maps, 10
photos, Process Flow diagrams, Hazardous Area Classification drawings,
evacuation routes, etc been provided in support of the description?
Have all drawings included in the HSE Case been validated and are they 10
up to date?
100

Contractor's Note:
Where the operation is fully contracted out then this Part will be entirely produced by the
Contractor.

IV.5 PART 5 - HAZARDS AND EFFECTS ANALYSIS, HAZARDS AND EFFECTS

REGISTER, HSE-CRITICAL OPERATIONS PROCEDURES

Part 5 contains three sections:

Hazards and Effects Analysis

Hazards and Effects Register

HSE-critical Operations Procedures; (can also be in Part 3 of the Case)

IV.5.1 Hazards and effects analysis

The HSE Case should demonstrate that all potentially significant hazards and effects have
been identified, the risks from the hazards and effects evaluated and understood, and that
controls to manage risks of the hazards and effects are in place.

Table IV.5

SCORE FOLLOWING QUESTIONS AS SHOWN BELOW:

Is it clear that the design integrity has been validated, e.g. by HAZOPs 25
and process studies, etc? (relevant to a plant or the facility)
Are design checks up to date, e.g. taking account of all plant changes? 15
Are all HAZOP corrective actions closed out from the design or 10
modification phase?
Have the major risk contributors been clearly defined? 15
Have acceptance standards been set? 15
Have acceptance standards been met? 15
Is the process used for arriving at control of all hazards and effects 10
described for all major hazards and accident scenarios?
Have adequate risk reduction measures been identified and implemented 25
and has the risk been reduced to a level that is as low as reasonably
practicable (ALARP for short)?
Does the operator's hazard analysis process cover the elements of hazard 25

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identification, threat and consequence identification, risk assessment,

necessary controls and an independent review of the analysis results?
Is there a summary of those investigations carried out as a part of the 15
Hazards and Effects Analysis into accident scenarios, hazardous
conditions, environmental effects, etc?
Have appropriate performance indicators based upon these risk studies 25
been established for the operation or facility?
Are design assumptions being monitored to provide warning when risk 15
parameters and hence overall risk levels are changing?
Are the assumption made in the development and application of the 15
hazard analysis laid out and do they appear reasonable consistent with
best practice?
Was a systematic hazard identification approach followed? Has hazard 15
elimination been considered before control of hazards?
Does the hazard analysis approach used meet the performance objectives 15
of the Operation's HSE MS?
Was the data used to identify hazards relevant to and valid for the 15
particular facility?
Has the operator demonstrated that sufficient analysis has been carried out 10
and that analytical tools have been used within their operational limits?
Have the type and extent of the studies completed addressed all the major 15
incident scenarios that have been identified?
Have adequate sensitivity analyses been conducted to determine the 15
critical assumptions made in respect to major hazards and effects?
Has the hazard analysis been undertaken by a competent analyst (s)? 15
Has the operator demonstrated that adequate provision has been made to 15
protect the employees from the consequences of major accident
scenarios?
Has the hazard and risk assessment studies considered emergency 15
communications and emergency power?
Have scenario based design methods been used, e.g. fire risk analysis? 25
Has the hazard analysis considered incident scenarios in which the chain 20
of command is broken?
400

Contractor's Note:
For an operation or facility/vessel, etc operated by a contractor it is clearly incumbent upon
the contractor to properly evaluate hazards and effects relevant to his operation. A client
company has the right of access to all evaluations and risk assessments and it is up to the
contractor to provide all necessary information needed to support the analysis.

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IV.5.2 Hazards and effects register

The Hazards and Effects Register is a communication document that should be readily
understood by contractors and OPU / JV staff alike. It is a quality record, which
demonstrates that all the hazards and effects (in terms of the objectives established for the
HSE Case) have been identified, are understood, are being properly controlled. It
demonstrates that the facility, as built and as will be operated, or the operation as planned, is
adequately defended and prepared to handle any consequence that could result if control is
ever lost. The purpose of the Hazards and Effects Register is to present in a clear and concise
form, the results of the analysis made of each hazard or effect present at, or resulting from,
the facility or operation.

Table IV.6

Have acceptance criteria been described and applied to each of the 5

hazards identified in the hazard register or equivalent and are they
appropriate?
Has a baseline survey (Environmental Assessment and Health Risk 5
Assessment) been carried out to establish health and environmental
concerns?
Have measures for controlling health risks been described? 5
Have measures for controlling environmental effects been described? 5
Are hazards and effects clearly recorded including, how identified, how 5
and where the hazard or effect is encountered, or if it results from, the
facility or operation?
Do hazard control measures as described reflect regulatory requirements, 5
organisational objectives and good industry practice?
Have probable accident initiating events (threats) that could 'release' the 5
hazard or effect, or cause continuous emission beyond control limits been
identified and recorded?
Have the barriers required for each and every threat or initiating event 5
been identified, recorded and measured against the acceptance criteria for
the location?
Have possible consequences that would result if control of the hazard or 5
effect were lost, or emission control limits exceeded, been identified and
recorded?
Have the recovery measures - methods and facilities required to mitigate 5
each consequence been identified and recorded and measured against the
acceptance criteria for the location?
Has an assessment of the worst case risk associated with the hazard or 5
effect (no defences) and an assessment of the risk to people and the
installation (were the unlikely event to take place and the hazard be
released, i.e. the residual risk) been made?
Is there a demonstration that, for all high potential consequences, 5
measures are in place to ensure that the initiating event frequency (top
event) is as low as reasonably practicable?
Have escalation factors that would increase the likelihood of occurrence, 5

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or the severity of the consequences of an incident or continuous emission

beyond control limits been identified and recorded?
Have control measures been prioritised, i.e. prevention, control, 5
mitigation, recovery, remediation?
Does the hazard record cross reference the installation activities 5
accountable for performing and assuring that controls are being applied in
line with the standards set?
Are those personnel responsible for identifying hazards, assessing risk 5
and implementing control measures identified?
Is the maintenance of the hazards and effects register described in the 5
HSE Case?
Does the system for updating the hazards and effects register require that 5
it be reviewed and updated by the Operator as a consequence of a major
event or change or review?
Is the hazards and effects register site specific and sufficiently detailed for 5
the workforce to understand?
Is the hazards and effects register in a form that can be readily understood 5
and used by the workforce?
100

Contractor's Note:
The Hazards and Effects Register should be understandable at all levels of the operation. It is
a vital communication document and should in a contracted out operation, be prepared by the
Contractor. The client company should provide the Contractor with a part-complete Hazard
Register showing those hazards and effects already identified and requesting Contractor to
complete all assessment, control and recovery sections using Contractor's own procedural
references, etc. Contractors should also be requested to provide information in accordance
with the Hazards and Effects Management Process for all hazards and effects newly
identified by him.

IV.5.3 HSE-critical Operations Procedures

This section of Part 5 should specify the HSE-critical Operations Procedures. Activities
Specifications should refer to specific procedures which are Critical to the management of
HSE risks - the 'HSE-critical Operations Procedures'. These procedures will in almost all
cases already exist in some form as part of operating procedures. It is for this reason that
some OPU / JV have chosen to include the HSE-critical Operations Procedures in Part 3 of
the Case and make reference to them in Part 3 of the HSE Management System.

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Table IV.7

Is there a listing of the HSE-critical operations procedures or equivalent? 20

Are the detailed procedures and criteria for operating, monitoring and 30
inspecting key items of plant, including baseline inspection data and
acceptance criteria described and cross referenced?
Are emergency preparedness and contingency plans and procedures 10
including training and testing methods described?
Is the information presented in a form usable by the workforce or are 10
extracts of the up to date Case made for use by them?
Is there a description of the permit to work system and other isolation 20
procedures?
Is there a system to control changes to these procedures? 10
100

Contractor's Note:
Procedures used in a contracted out operation will usually be Contractor's own procedures.
Thus, this part of the Case should be prepared by both Contractor and OPU / JV.

IV.6 PART 6 - REMEDIAL WORK PLAN

The preparation of a HSE Case is a fact finding process used to determine conformity at the
installation/operational level to the various elements of the OPU / JV HSE Management
System and the acceptance criteria for hazard and risk management. The HSE Case should
contain a demonstration of commitment to improvement by providing a plan, known as the
'Remedial Work Plan', to resolve any shortfall findings of the assessments and thereby
improve the safety of the installation/operation.

Table IV.9

Is there a requirement for a Remedial Work Plan to correct all shortfalls 25

identified in the HSE Case?
Is there a status report list of all findings of the HSE Case? 15
Have findings from subsidiary studies or similar (e.g. audits) that have not 15
been satisfactorily resolved been listed and fully addressed in the Remedial
Work Plan?
Is there a plan with action parties, priority rating and completion dates to 15
ensure resolution of any shortfalls in the installation/operation HSE
Management System?
Is there a plan with action parties, priority rating and completion dates to 15
ensure resolution of any shortfalls in the management of hazards and
effects;
Is there a plan with action parties, priority rating and completion dates to 15
ensure resolution of risk reduction recommendations?
100

Contractor's Note:

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A jointly prepared part of the HSE Case in a contracted out situation.

IV.7 PART 7 - CONCLUSIONS AND STATEMENT OF FITNESS

Part 7 of the Case presents the conclusions concerning meeting the objectives of the HSE
Case in as simple a fashion as possible. In particular it notes those events that were assessed
as large risk contributors.

This part shall also contain a Statement of Fitness for the operation or facility. Such a
statement may take the form of the following example:

'Given the findings of the hazards and effects analysis and the measures already taken, or in
hand, to lower risk associated with the operation, it is concluded that this HSE Case
demonstrates that, to the extent reasonably possible:

(1) there is [or will be by {give date}] a management system in place for the operation,
adequate to enable the company to comply with all relevant statutory and OPU / JV
provisions in relation to [name of operation] and any activity in connection with it

(2) there are adequate arrangements in place for the audit and review of that management
system at appropriate intervals

(3) all hazards and effects with the potential to cause major harm to people or the
environment have been identified, assessed, controlled and that plans are in place for
recovery in the event control is lost; and

(4) risks have been evaluated and measures taken to reduce HSE risks to a level that is as
low as reasonably practicable.

In view of the above, the operation/installation is considered safe to operate.'

Table IV.10

Does the HSE Case contain a 'Statement of Fitness' or equivalent, e.g. 'a 50
letter of assurance' signed by the accountable person for the asset or
operation and accepted by Senior Management?
Is there sufficient evidence (on paper from the HSE Case document) that 50
the shortfalls found by the Case analysis are sufficiently minor that the
operation can continue safely?
100

Contractor's Note:
The Statement of Fitness must be jointly agreed by both OPU / JV and Contractor but the
Client PETRONAS company should recognise where the Contractor is carrying out
operations on behalf of PETRONAS.

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APPENDIX V - GUIDANCE FOR THE PREPARATION OF THE HSE

MANAGEMENT SYSTEM AND CASE ACTIVITIES
CATALOGUE

V.1 INTRODUCTION

This appendix provides guidance on the methods that may be used to identify 'HSE-
critical' activities and to document them in an HSE Management System or HSE
Case Activities Catalogue. Whilst the Activities Catalogue may be compiled and
maintained manually, an Information Technology package, 'The Health, Environment
and Safety Information System' tool, THESIS, is available to assist in structuring the
process of preparing Activity Specification Sheets (and Hazard Register Sheets).
THESIS stores all data gathered during the process of building a HSE Case into a
relational database structure and may be used for printing the Activities Catalogue, or
sorting this data into other output reports as required by the operation. The following
description of the process applies whether THESIS is used or not, but the
documentation stage will of course be different.

V.2 WHAT IS AN HSE MANAGEMENT SYSTEM OR CASE ACTIVITIES

CATALOGUE?

The OPU / JV documented HSE Management System should provide a quality record
for all the HSE-critical activities of that OPU / JV, i.e. those activities actually
involved with the management of hazards and effects. These records describe the
objectives, methods, controls, etc associated with that activity. They are collated in a
document called the HSE Management System Activities Catalogue. Similarly, HSE
Cases will contain similar records (previously referred to as Specification Sheets) for
all HSE-critical activities applicable to specific facilities or operations. These are
collated in a document called the Case Activities Catalogue.

The main differences between the HSE Management System Activities Catalogue
and those for HSE Cases are mainly the level of definition of activities, as explained
in V.4 and V.5 below, and the scope of activities covered by the respective
catalogues.

The terms Activities Catalogue, Activities Record (or Specification Sheet) will be
used in the remainder of this appendix to apply to either the HSE Management
System or HSE Case documents as the principles used in both are essentially
identical. Where specific differences apply for one or the other they are clearly
identified.

A foreword to each group of related activities in the Activities Catalogue should

contain a description of the business processes to explain the inter-relationship of the
various activities.

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V.3 WHO SHOULD PREPARE THE ACTIVITIES CATALOGUE?

Activities Catalogues are best prepared through a series of working groups. Each
group should meet as needed to complete one or more Activity Records. Facilitation
during the process of building the Activities Catalogue is usually needed. The
meetings should therefore be facilitated by a member of an HSE Management System
team, or line person familiar with the process of creating an activity sheet, and should
be attended by personnel familiar with and, preferably, responsible for the element of
the business to be addressed (e.g. drilling, operations, maintenance, etc).

V.4 HOW ARE BUSINESS PROCESSES AND ACTIVITIES IDENTIFIED?

In order to prepare the Activities Catalogue it is necessary to have a complete list of

the activities carried out within the business.

The break-down of any business into a comprehensive and coherent set of processes
and activities can be difficult, because companies tend to be organised along
functional rather than business process lines.

The Business Model is a data base of all the processes and activities within a generic
company. Its application therefore forms a useful basis for the preparation of the HSE
Management System Activities Catalogue.

It can be beneficial, however, to actually carry out business process analysis, as this
can result in improvements to the business as well as a greater understanding of the
business amongst the team members.

If business process analysis is to be carried out the approach in the workshop should
be first to select a business process (e.g. plant maintenance). Those persons
responsible for, or involved in, that particular business process then describe it in
terms they understand and that are relevant to the company. Often flow-charting of
the process will assist in understanding the flow of information.

Training and facilitation in business process analysis is usually needed at the start of
the workshop.

It has been found that the actual work of business process analysis is most effective
when carried out in short periods of activity followed by documentation of results.
For example, evaluation of the process in the morning followed by recording of the
results in the afternoon has been found to work well.

Whether business process analysis is carried out or not, the result should be a list of
activities, which together comprise the business process.

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V.5 TO WHAT LEVEL SHOULD A BUSINESS PROCESS BE BROKEN DOWN?

V.5.1 HSE Management Systems Manual and Cases

It is possible to break down activities into constituent tasks and to assess each
individual task. Clearly this would be a major undertaking. The question of how far
to break down an activity or process is therefore a particularly valid one. There is no
simple answer to this question and each activity should be considered on its own
merits, taking into account the degree of complexity and risk associated with that
activity. As a guideline, however, it is important that the activities should be
documented at a level where accountability for the activity can be realistically placed
with a single individual. (It is no good saying that the Managing Director of a OPU /
JV is responsible for HSE; although this is true; there would then be only one
Activity Record or Specification Sheet covering the whole OPU / JV.)

Experience has shown that it is often useful to break down activities to one level of
detail lower than is ultimately required to be documented. At the management system
level this might be a department or section head. For a HSE Case, accountability for
an activity is usually established at the supervisor or foreman level where
accountability can reasonably be placed with an individual.

V.5.2 HSE Cases

The level of analysis depends upon the operation and upon existing working
practices. In all cases supervisory staff need to have an understanding of the tasks
carried out in their area of responsibility. Such an understanding should exist already
and be confirmed in standing instructions and work instructions. Where this is the
case, the hazards and effects encountered in the work situation should be cross-
checked with the activities, to gain assurance that all hazards and effects are being
effectively managed.

In cases where task definition is less clear, much is to be gained by carrying out an
analysis to task level. Workplace tasks require sound craft (work) practices or
working instructions and such an analysis often reveals deficiencies in procedures,
i.e. those activities carried out where there are interfaces involved. Involving the
workforce in this process and in identifying for themselves the rationale for existing
good craft (work) practices and the relevance of standing procedures, provides a real
sense of ownership.

Tasks should then be aggregated to the supervisory level where documented control
should be demonstrable. An Activity Record per set of tasks provides a key linkage
with the workplace and also with the corporate business model. In a relatively
straightforward operation this generally means about 20 activities or less. Task
definition can be made simpler than for an Activity in that they do not require the
same level of verification or business control. These task sheets, plus the relevant
information regarding hazards and effects identified as being relevant to the tasks,
provide and ensure that the working level information has a good linkage with the
workplace. Tasks are then cross referenced to the appropriate activity. The HSE Case

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does not necessarily require such task definition within the document, but activities
do need to refer to a competent set of work instructions and procedures.

V.6 HOW DO YOU KNOW IF AN ACTIVITY IS HSE-CRITICAL?

To understand what is meant by HSE-critical one should first understand hazards and
effects management. The HSE Management System is based upon the principle that
all hazards and effects within the business must be understood and suitably
controlled. If hazards and effects management objectives are achieved then the
operation will be, by definition, safe for both people and the environment.

There are four essential steps that must be carried out to manage a hazard
successfully.

These are:

systematic identification of hazards and effects

assessment of the significance of hazards and effects

implementation of suitable hazards and effects controls; and

planning for recovery in the event of a loss of control.

These four steps are called the 'Hazards and Effects Management Process' (HEMP).
Any activity in which one of the HEMP steps is carried out is considered to be 'HSE-
critical'.

REPUTATION

Risk is the summation of immediate and anticipated risk outcomes (estimated and on
the basis of scientific evidence) and also importantly the perceived risk as seen by
other stakeholders. Risk to reputation often relates more to environmental risk than to
other risk areas although health and sometimes safety suffer in similar ways. The
basic considerations are the same as for safety and health but evaluation should be
based upon not only hard scientific evidence but also on perceptions of risk and on
societal expectations or norms. This is a difficult area and caution is advised. If in
doubt seek advice from Public Affairs.

HEMP is applied by asking a series of questions of each activity in the company

business model.

i. Does this activity identify one or more hazards during the process of its
performance / execution? In other words, do you need to consider what can go
wrong i.e. is there any unacceptable outcome potentially associated with a
deviation / unexpected occurrence?

ii. Does this activity assess a hazard(s) for its effect(s)? In other words, do you ask:

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a. Whether the consequence is acceptable should a deviation from plan happen

or something goes wrong?
b. Calculate what is the probability / chance that something will go wrong?
c. Assess how severe the effects or consequences might be?

iii. Does this activity control a hazard(s) and or its effects? In other words, is this
activity one meant to prevent something from going wrong the outcome of which
might either be harmful to people, environment, assets or reputation of the
company?

iv. Is this an activity that recovers from a (initial) loss of control / deviation from
plan or mitigates / reduces its effects i.e. provide recovery or emergency
response in any form?

Any yes answer to the questions above identifies the activity as HSE-critical and
qualifies it for inclusion in the Activities Catalogue.

These criteria can usually readily determine whether an activity is HSE-critical. If

there are difficulties in agreeing whether or not the activity is HSE-critical it should
be included.

It should be stressed that HSE-critical activities are not limited to those which deal in
a direct way with a hazard or effect (e.g. handling explosives or operating plant).
Those planning activities which, if not carried out correctly, could lead to a hazardous
situation are equally important. Pre-planning represents a vital part of HSE
management.

Similarly, and in particular for the corporate HSE Management System, activities
which establish HSE policies and objectives are HSE-critical as they apply to all
hazards in establishing the framework for identification, assessment, control and
recovery. Monitoring HSE performance may be considered HSE-critical depending
on circumstances.

Some HEMP steps will span a number of activities. A typical example is the
preparation of hazard control and recovery procedures; these are typically planned
during one activity but executed in other subsequent activities.

A formal check that for each hazard or effect all four steps of the HEMP (identify,
assess, control, recover) have been covered is an essential part of demonstrating the
completeness of the hazards and effects management.

V.7 WHAT NEED TO BE RECORDED FOR EACH HSE-CRITICAL ACTIVITY?

Each HSE-critical activity should be recorded for control purposes. The form of
recording is not as important as the need for completeness of the information
recorded. OPU / JV may choose to use a format that is compatible with their other
management systems, eg a product quality management system. THESIS records the
information in a relational database structure which can be sorted to produce reports

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in any logical layout or format containing all or only part of the data recorded for
each activity.

The extent of information to be documented is given below together with a more

detailed discussion of the important aspects and the practical issues that may arise
when developing input for each activity in the Activities Catalogue.

Figure V.1 shows how the information for each activity may be presented. The
Activity Record layout shown is available as one of the standard reports

Figure V.1 AN EXAMPLE OF AN ACTIVITY RECORD OR

SPECIFICATION SHEET

(INSERT Activity Specification Sheet here)

V.7.1 Description of the HSE-critical activity

The description of the activity should come from the OPU / JV's business processes
which have been identified as HSE- critical.

V.7.2 The Hazard management objectives of the activity

In determining that an activity is HSE-critical it will have been agreed which of the
steps of the Hazards and Effects Management Process (HEMP) are covered by the
activity. The hazard management objective should explicitly state which HEMP
step(s) are relevant. Concise, clear and where possible measurable objectives are
essential.

The following might apply to an activity concerned, for example, with the detailed
design of a facility:

Identify new hazards and effects

Assess hazards and effects including those already in the Hazards and the Effects
Registers

Eliminate hazards or effects where possible and detail Controls of residual

hazards and effects and detail plans for mitigation and Recovery from release of
hazards and/or excursion from tolerable environmental effects.

Identify potential construction hazards and effects

Assess hazards and effects and where possible eliminate them

Document residual hazards and effects and incorporate appropriate controls in the
construction procedures.

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Operations Procedures to be specified for the control of all residual hazards and
effects.

The message here is that every effort should be taken to design hazards and effects
out, to clarify any residual hazards and effects in terms of control and recovery, and
to prepare for operations.

This information would be printed in box 4 of the report sheet shown in Figure V.1.

V.7.3 Methods to be used to achieve objectives

The method or means by which the hazard management objectives of the HSE-
critical activities identified above are to be achieved should be explicitly defined
here. An example might be:

Hazards and effects identification will be carried out by experienced engineers,

specialists and operators following procedures in Company Design Standard
ABC.123 which refers to appropriate design codes. (Standard ABC.123 covers
procedures for HAZOP, HAZID, SAFOP, FIREPRAN, etc Standard ENV 345 covers
procedures for Environmental Assessment; brainstorming; checklists, etc).

Analysis will be carried out using design codes and computer programs following the
procedures in Company Design Standard ABC.345.
Hazards and effects requiring control through operator interface will be assessed and
appropriate procedures developed, (or existing procedures modified), following
Company Standard XYZ.456 for development and revision and approval of operating
procedures.

Other examples of methods used to achieve objectives could be:

Policy development (e.g. transportation policy), supervision, inspection, reviews,

instruction, competence development and assurance, plans, techniques, etc.

This information would be printed in box 5 of the report sheet shown in Figure V.1.

V.7.4 HSE-critical inputs and outputs

There will be a number of inputs to the activity, not only in terms of hardware, but
also as information. Some of these inputs will be the product of other HSE-critical
activities, and will therefore be defined within the HSE Management System. For
example, the Process Flow Diagram and Hazards and Effects Register would be
inputs to the detailed design activity described above. Once revised (new information
input or existing information updated) the Hazards Register, or the Environmental
Effects Register would be one output from this activity; others could be, draft
operating procedures, etc.

Other inputs and outputs might be:

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Field Development Plan,

Environmental Baseline Survey,
Maintenance Plan,
Environmental Management Plan,
Competence Register,
Operating manuals,
Permit to Work Plan,
Inspection and maintenance reports,
Process Flow Diagrams,
Process and Instrumentation Diagrams,
Cause and Effect drawings,
Seismic proposal data,
Scouting Reports,
Contracts,
HAZOP report,
Purchase specifications for HSE-critical components, etc.

It should be possible to track HSE-critical information through the business processes

via the described activity inputs (suppliers) and outputs (customers), i.e. they should
be in a traceable or written form.

This information would be printed in boxes 6 and 7 of the report sheet shown in
Figure V.1.

V.7.5 Form of recording activity

Documentary evidence resulting from the activity appears here. Some of this
documentation may often be the same as the output in Box 7 of Figure V.1.

Additional examples are:

Project specifications,
tender documents,
contracts,
project close out reports,
quality system checklists,
drilling prognosis,
maintenance reports,
90-day plan, etc.

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This information would be printed in box 8 of the report sheet shown in Figure V.1.

V.7.6 Methods of verifying objectives are completed to standard

Controls for individual activities are established by those responsible for the HSE-
critical activity. The controls should be limited to those necessary to ensure that the
activity is carried out to meet the specified hazards and effects management
objectives. The HSE Management System or Case should document the controls that
have been selected for the particular activity and these can be referred to when the
effectiveness of the controls is reviewed / assessed as part of the assurance process.

The level of control will vary according to the criticality of the activity, the
competence requirements for the tasks involved and the degree to which the
circumstances can be predicted, amongst other things. For example, accountabilities
for activities or tasks, and their verification and authorisation (where considered
necessary) should be recorded. Examples include: use of standards and codes,
assurances, review by department heads, inspection and certification by third party,
etc.

V.7.7 Reference documents

Any document that is used in performing the HSE-critical activity should be

recorded. All such references should be controlled documents subject to
approval/revision in accordance with company procedures as described in the HSE
Management System Manual (Refer Chapter 7 and Appendix I).

Documents pertaining to the methods used to achieve objectives (see 7.3 above)
should be cross-referenced in this box. Documents referenced as HSE-critical inputs
or outputs (see 7.4) and as forms of recording the activity (see 7.5) should be either
repeated or cross-referenced here.

Examples include:

API standards and codes of practice,

manuals,
computer programs,
Operating Philosophy, etc.

This information would be printed in box 10 of the report sheet shown in Figure V.1.

V.7.8 Note of shortcomings

Any deficiencies, shortcomings or areas for improvement which have been noted in
respect to the manner in which the activity is carried out or in the information which
is required for its completion should be recorded. An example of a shortfall could be:
no preventive maintenance philosophy exists

This information would be printed in box 11 of the report sheet shown in Figure V.1.

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The person responsible for resolving the shortfall should later be identified, together
with an agreed target completion date and an assessment of priority in a remedial
action plan developed on completion of the HSE Management System manual or
Case.

V.7.9 Tasks, execution party and competence required

Tasks required to complete the activity, the person(s) accountable for the tasks and
the competence requirements for undertaking the tasks involved should be recorded.

This information would be printed in boxes 12, 13 and 14 of the report sheet shown
in Figure V.1.

V.7.10 Hazards and Effects Register cross reference

The co-relationship between the activity and the hazards and effects contained in the
Hazards and Effects Register i.e. how this activity contributes to the effective
management of the specific hazard or effect should be recorded.

A manager is generally responsible for all the HSE hazards and effects relevant to his
particular area of responsibility. This does not however rule out the possibility of
recording hazards and effects which may be considered relevant to the business as a
whole and which are essentially controlled at a corporate rather than a facility or
operations level. Some environmental effects may typically be in this category, e.g.
land take and gas flaring. The plant supervisor seldom has any control over whether
his or her plant has a flare or a vapour recovery system. Whether gas is flared or not
is generally an economic and policy matter squarely in the hands of corporate
management. To take account of this possibility a Part 5 to the HSE MS Manual
Hazards and Effects Register (corporate) would seem both logical and appropriate.

This information would be printed in box 15 of the report sheet shown in Figure V.1.

V.7.11 Performance indicators and performance targets

Business process analysis is incomplete without the establishment of performance

criteria and indicators. The HSE MS and HSE Case are geared to the management of
hazards and effects. Performance criteria and indicators are not strictly HSE alone,
but provide an indication as to whether the whole business activity or operation is
being carried out properly. The syndicate sessions used for analysing the business
process or activity provide the correct forum for agreeing appropriate, meaningful
performance indicators.

Performance indicators should be measurable or quantifiable in some way that may

indicate that the activity is being performed to the required standard. Often a single
indicator on its own is insufficient or inconclusive, hence a target for the completion
of the Activity Specifications should be to agree with the process owner and the
activity owner a minimum of three performance indicators per activity, or in some

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cases activity groupings. One or more performance indicators showing an adverse

situation or trend should cause the activity or process owner to investigate and
implement corrective action as required. Some performance indicators may be
quantifiable in absolute terms and hence performance targets may be established.

For example:

Indicator : emergency shutdown valves tested according to schedule

Target : more than 98 per cent of valves tested on schedule.

Indicator : emergency shutdown valve test failure rate

Target : less than 1 per cent of tests fail.

This information would be printed in boxes 16 and 17 of the report sheet shown in
Figure V.1.

V.7.12 Process custodian and activity custodian

External control is to be provided over each individual business process by having a

nominated custodian or owner. (The field development plan process, for instance,
might be under the custodianship of the Petroleum Engineering Manager). The
custodian should ensure that:

the HSE management objectives of the process are fully understood by those
involved in it

the HSE-critical activities and selected controls are sufficient to meet the
objectives

those involved are committed to meeting the objectives by means of the selected
activities and controls; and

the process (e.g. getting the field development plan ready) remains effective.

The custodian is responsible for setting and monitoring performance criteria, ensuring
that audits/reviews are carried out and that corrective action is taken as often as
considered necessary to assure the effectiveness of the process.

In this regard performance indicators are of vital importance, and should be agreed to
(and preferably derived by) those accountable for individual activities, up to senior
management level. These indicators should be developed as one of the routine
business controls. They are the key to the day-to-day effectiveness of the HSE
Management System since loss of control resulting from poor feedback can have fatal
consequences. (The best time to develop these indicators is whilst preparing the HSE
Management System Activities Catalogue.)

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The HSE Management System recognises that directly measurable indicators, for
example the number of trip and relief valve tests compared with plan, response to
safety-related engineering change proposals, etc can provide an important signal well
ahead of any accident or mishap.

Following the initial review to create the HSE Management System Activities
Catalogue, the custodian should undertake periodic reviews to ensure continued
effectiveness of the process, to improve the process and to set new targets. His role
should be seen, where possible, as the chairman of a team made up of those involved
in the process, where action is determined jointly.

Since the custodian carries considerable responsibility, it is essential that he is vested

with the appropriate authority. His relationship with senior management and with
those involved in the process is delicate and often crosses organisational boundaries.
This interface management is essential to the success of the business process
approach.

Information on the process custodian and activity custodian together with their
signatures or note of their approval of each activity specification would be printed in
the sub-boxes to boxes 1 and 2 of the report sheet shown in Figure V.1.

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APPENDIX VI - GUIDANCE FOR THE PREPARATION OF AN HSE CASE

HAZARDS AND EFFECTS REGISTER

VI.1 INTRODUCTION

This appendix provides guidance on recording the results of the analysis made of
each hazard or effect present in a facility or operation in a Hazards and Effects
Register. Where possible practical advice is given on problems that HSE
Management System teams have experienced in the past in compiling Hazards and
Effects Registers.

VI.2 WHAT IS A HAZARDS AND EFFECTS REGISTER?

A Hazards and Effects Register is a quality record which demonstrates that all the
hazards and effects (in terms of the objectives established for an HSE Case) have
been identified, are understood, and are being properly controlled. It demonstrates
that the facility, 'as built' and 'as will be operated', or the operation 'as planned', is
adequately controlled and that preparations are in place to handle any consequence
that could result, if control is ever lost. The purpose of the Hazards and Effects
Register is to present in a clear and concise form, the results of the analysis made of
each hazard or effect present in, or resulting from, the facility or operation.

VI.3 WHO SHOULD PREPARE THE HAZARDS AND EFFECTS REGISTER?

Hazards and Effects can be identified and assessed by working groups similar to
those used for the preparation of Activities Specifications. Each group should meet as
needed to assess one or more hazards or effects. Facilitation during the process of
building the Hazards and Effects record is usually needed. The meetings should
therefore be facilitated by a member of an HSE Management System team, or line
person familiar with the Hazards and Effects Management Process (HEMP), and
should be attended by personnel who are knowledgeable of the location, area or
operation in which the hazards and effects are to be addressed (e.g. drilling rig, gas
plant operations, maintenance, seismic survey, etc).

The identification and analysis of some hazards and effects may require specialist
input. Ideally major hazards and effects for which control is largely provided by
location, layout, design and provision of hardware should be identified and analysed
and properly recorded during the design and construction stages of a project. For
existing facilities, the current situation and condition may need to be re-assessed and
recorded. Some hazards and effects, or event scenarios, may be such that risks can
only be reliably evaluated by specialist structured analysis techniques such as Health
Risk Assessment, Quantitative Risk Assessment (QRA) or Environmental
Assessments. Specialists, in-house or contracted, may be needed to apply these
techniques properly and cost effectively. A summary of the results of these analyses
should be recorded in the Hazards and Effects Register in the same way as for other
analysis results.

VI.4 WHAT NEEDS TO BE RECORDED FOR EACH HAZARD OR EFFECT?

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Each hazard or effect identified as being encountered or involved with a facility or

operation (subject to the scope and objectives established for the HSE Case) should
be recorded together with the associated assessments, control and recovery measures
in place or required to be in place and an evaluation of risks.

The form of recording is not as important as the need for completeness of the
information recorded. OPU / JV may choose to use a format that is compatible with
their other management systems. The extent of information to be documented is
given below together with a more detailed discussion of the important aspects and the
practical issues that may arise when developing input for each hazard or effect.

Figure VI.2 shows how the information for each hazard or effect may be presented.

Figure VI.2 An Example of a Hazard Register Sheet

(Insert picture of a Hazard Register document)

VI.4.1 Hazard (agent or effect) description - the hazard hierarchy

Describe the hazard (agent or effect) identified for which information is to be

recorded by broad groupings (e.g. hydrocarbons, elevated objects, high pressure
fluids, extreme temperatures, biological hazards, toxic substances, land take) and
sub-groups, (e.g. high pressure gas, oil, LPG, hot surfaces, specific bacteria or
parasites). A hazard hierarchy that includes health agents and environmental effects
and sources of these has been prepared. This can be used as a starting point in
identifying and classifying hazards. Other operation specific hazard hierarchies, for
example an OGP hazard hierarchy is available.

This information would be printed in boxes 1 and 2 of the report sheet shown in
Figure VI.2.

VI.4.2 Assessment of hazard

This describes where and when the hazard is most likely to be encountered and the
possible hazardous events that could result from loss of control (in terms of the
specific hazard's potential to cause harm, including ill health and injury, damage to
property, plant or the environment, production losses, increased liabilities, or damage
to reputation). A cross reference should be provided to the activities which identify
this hazard as present in the facility or operation.

This information would be printed in boxes 3 and 4 of the report sheet shown in
Figure VI.2.

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VI.4.3 Top event

Describe here the event or situation that represents the release of the hazard or
deviation from defined control limits (continuous exposures or continuous
discharges). If this event or situation can be prevented by active controls (see VI.4.6
threat controls) no scenario can develop which could lead to a consequence or effect
as defined by HSE Case objectives.

This information would be printed in box 5 of the report sheet shown in Figure VI.2.

VI.4.4 Locations associated with hazard (or effect) and acceptance criteria

List locations that have the same acceptance criteria, control and recovery
requirements for the hazard (or effect). Definition of an acceptably managed hazard
(or effect) will vary from location to location because the possible consequences from
loss of control may be different.

For each location, define the level of HSE performance deemed acceptable for a
given period of time or phase of activities. Criteria may include a range of
considerations or values that may be defined in both qualitative or quantitative terms.
Acceptance Criteria also define what is deemed suitable and sufficient control of
threats and suitable and sufficient recovery preparedness. For example in drilling
operations a stipulated number of barriers or controls (usually 2 or 3) are required to
be in place before an operation may proceed. This specified number of controls is the
acceptance criterion for the particular hazard and location under review.

This information would be printed in box 6 of the report sheet shown in Figure VI.2.

VI.4.5 Threats

Identify and describe the possible causes of release the hazard or deviation from
control limits, resulting in the Top Event defined in VI.4.3. These are threats.
Hazards, threats and top events are logically related. For example:

Hazard Threat Top event

'oil under pressure' (in 'corrosion' 'loss of containment'
piping)
'elevated load' 'inadequate sling 'fall to lower level
strength'
'hot surface' 'insulation damage' 'exposure to'
'oil in effluent water' 'instrument failure' 'exceeded control limits'

Describe the likelihood or frequency that the threats release the hazard. This may be
done either quantitatively if sufficient data is available, by reference to incidents in
similar facilities or operations or based on the judgement of experienced personnel.
These likelihood(s) or frequencies should be expressed in terms which can be related
to the acceptance criteria described in VI.4.4.
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A cross reference should be provided to the activities that assess the hazard and
threat. This information would be printed in box 7 of the report sheet shown in Figure
VI.2.

VI.4.6 Threat controls

Describe the threat controls - Threat controls, commonly referred to as barriers, are
pro-active and prevent threats from releasing the hazard or causing deviation from
control limits. Barriers include, guards or shields, separation, energy reduction or
administrative controls, and specific controls, procedures, work instructions, design,
competence, standards, control systems, etc. Any shortfalls in meeting acceptance
criteria should be highlighted and recorded, see VI.4.13. A cross reference should be
provided to the activities providing or maintaining threat controls.

This information would be printed in box 8 of the report sheet shown in Figure VI.2.

VI.4.7 Consequences

Describe the possible consequences or potential effects that could result if the hazard
is released or control limits are exceeded. Consequences or effects are logical and
credible outcomes of scenarios starting with the top event which follow different
escalation sequences according to the availability and (in)effectiveness of recovery
measures, see VI.4.9. Loss of containment (Top Event) of hydrocarbon gas could
result in, for example, rapid detection, shutdown, limitation of volume, no ignition
and consequently a minor release to the atmosphere. Alternatively it could result in,
for example, failure or delay in detection, continued release, ignition, explosion and
consequently major damage, injuries or fatalities, etc.

This information would be printed in box 9 of the report sheet shown in Figure VI.2.

VI.4.8 Risk assessment

Assess the risks associated with various possible consequences. As a minimum the
worst case, most severe, consequences should be determined both with all available
recovery measures in place and working and with all possible recovery measures
either not available or not working. Both likelihood (probability or frequency) and
severity elements of risk should be assessed. In all cases the likelihood of a
consequence or effect cannot be greater than that assessed for the top event, see
VI.4.5. The severity of a consequence will depend on the scenario development and
which recovery measures are (partially) effective. The scenario development will also
affect the likelihood of the final consequence as each effective recovery measure
reduces the likelihood that the scenario will develop further. If few recovery measures
are possible or they are unreliable, this points to the control of risks being highly
dependent on pro-active threat controls which reduce the likelihood of the top event
occurring.

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Some risks or complex scenarios may require the application of structured review
techniques by specialists, for example, health risk assessments, quantitative (safety)
risk assessments or environmental assessments. However, many hazards can be
adequately assessed by appropriately experienced staff by comparisons, reference to
statistics or judgement.

Risks may be expressed quantitatively, if the assessment method is quantitative, but

for most hazards a qualitative risk assessment may be adequate. A risk matrix similar
to that shown in Figure VI.1 is considered a useful way of presenting the risks for
most hazards and such a matrix is used in THESIS. Both axes of the matrix and the
'shaded' zones may be defined to be consistent with the ways in which acceptance
criteria have been expressed.

Risks to people, assets, and the environment should be assessed separately. A leak or
spill may be of little direct consequence for people, but may be of greater
consequence for the environment. A fourth risk group is allowed for in THESIS
which may be user defined for other risks such as potential damage to company
reputation. This information would be printed in box 10 of the report sheet shown in
Figure I.2

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Figure VI.1 An Example of a Risk Matrix

Consequence Increasing Probability

A B C D E
People Assets Environ Reputati Never Heard of Incident Happens Happen
ment on heard of incident has several s
in in occurred times per several
industry industry in our year in times
company co. per
year in
locatio
n.
No No No
No effect
injury damage impact
Slight Slight Slight Slight
injury damage effect impact
Minor Minor Minor Limited
injury damage effect impact
Consider
Major Localised Localised
able
injury damage effect
impact
Single Major Major Major
fatality damage effect national
Major
Multiple Extensive Massive
internati
fatalities damage effect
onal

VI.4.9 Recovery

Describe the recovery preparedness measures that are required to meet the acceptance
criteria. These are the technical, operational and organisational measures which are
needed to prevent a top event from developing further, hence mitigating the
consequences or effects and recovering a degree of control. These recovery
preparedness measures are essentially reactive as they respond to a situation which
has occurred and are intended to block further development of the accident scenario
and to provide for emergency management.

Recovery preparedness measures include active systems which detect and abate
incidents (for example, gas and fire detection, shutdowns, sprinkler systems, etc);
passive systems which contain (or restrict) an incident and provide protection for
people and essential equipment (for example, fire and blast walls, protective coatings,
drain systems, tank bunds, catchment basins, etc); operational and organisational
systems for emergency management (for example, contingency planning, training,
drills, Medevac, firefighting, oil spill response, etc)

Any shortfalls in meeting acceptance criteria should be highlighted and recorded, see
VI.4.13. This information would be printed in box 11 of the report sheet shown in
FigureVI.2.

VI.4.10 Escalation factors

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Describe the factors or conditions, which could lead to loss of barriers or loss of
recovery preparedness measures. These factors escalate the probability of a top event
and/or escalate the likelihood or severity of consequences or effects if the top event
occurs.

Escalation factors include: abnormal operating conditions, for example, concurrent

construction or maintenance, operating outside the design envelope, etc
environmental variations, for example, high winds, waves, tides or rainfall; failure of
controls, for example, improper maintenance, damage as a result of another event
(fire, explosion, etc) introduction of an ignition source, etc human error, for example,
lapses, rule violations, etc or absence of controls (threat controls and recovery
measures) due to technical feasibility, policy (burn-down philosophy) or excessive
cost.

A cross reference should be provided to the activities involved in identifying or

assessing escalation factors.

This information would be printed in box 12 of the report sheet shown in Figure VI.2.

VI.4.11 Escalation controls

Describe for each escalation factor the controls that should be in place to 'stand-in' for
the defeated barrier or recovery preparedness measure. Many escalation factor
controls will be similar to threat controls, see VI.4.6. Other significant controls on
escalation factors such as concurrent activities (production/drilling
operations/construction/ maintenance), operations outside the design envelope, severe
weather, etc are limitation of activities in accordance with the Manual of Permitted
Operations (MOPO) and issue of permits to work (PTW) which are a means of
implementing the MOPO. Escalation controls which are dependent on the MOPO
should be highlighted for later verification of MOPO coverage.

Any shortfalls in escalation controls should be highlighted and recorded, see VI.4.13.
A cross reference should be provided to the activities providing or maintaining
escalation controls.

This information would be printed in box 13 of the report sheet shown in Figure VI.2.

VI.4.12 Reference documents

List and number all the documents, procedures, standards, specifications, studies,
assessments, etc used or referred to in developing the information entered for the
hazard or effect being recorded. Barriers, recovery preparedness measures and
escalation controls should be cross referenced to these references.

This information would be printed in box 14 of the report sheet shown in Figure VI.2.

VI.4.13 Shortfalls

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Record all the shortfalls or deficiencies identified with respect to management of the
hazard or effect being recorded as noted in VI.4.6, VI.4.9 and VI.4.11. These
shortfalls should later be collated in the HSE Case summary of shortfalls and
remedial actions and an action plan, priority rating, action party and timing assigned
and agreed.

This information would be printed in box 15 of the report sheet shown in Figure VI.2.

VI.4.14 Custodian and authorisation

The HSE Case owner and custodian should assure that the information recorded for
the hazard or effect has been checked and found to be, as far as is practicable,
factually correct and consistent, both internally and with other parts of the HSE Case.
They should then endorse the risk assessment made and any shortfalls identified and
authorise inclusion of the information in the Hazards and Effects Register by signing
control copies of Hazards and Effects Register records. The HSE Case custodian is
responsible for monitoring the validity of the information recorded over time and
ensuring that it is periodically reviewed and updated as necessary. If either the HSE
Case owner or custodian changes, the Hazards and Effects Register information
should be reviewed and endorsed by the new incumbent.

Information on the HSE Case owner and custodian with their signatures or note of
their approval of each Hazard Register record would be printed in the sub-boxes to
boxes 1 and 2 of the report sheet shown in Figure VI.2.

REFERENCES

1 Occupational Health Management Guidelines, PTS 60.1000

2 Environmental Management Guidelines, PTS 60.3001

3 HSE Management System Manual, PTS 60.0102

4 OGP Health Management Guidelines for Remote Land Based Geophysical Operations

5 ISO 14690 (draft) HSE Management System Guidelines for Offshore Industry

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