Lufkin QHSE 6 11 Mfinal Version

LUFKIN MIDDLE EAST
Lufkin Middle East Integrated

Quality/ EHS Manual
Integrated management system according to ISO 9001:2008, OHSAS 18001,ISO 14001
Talaat A.Kader
1/1/2012
Lufkin Middle East integrated Quality/ EHS manual according to ISO 9001:2008, ISO 14001:2004 and
OHSAS 18001:2007
0
Doc ID QHSE 01
Lufkin Middle East integrated issue 2
Lufkin Middle East Date 1/10/2012
management system QHSE
Prepared by Talaat Abdel Kader
Manual Reviewed by Anthony Beck
Approved by Dave Kennedy
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APPROVALS
Prepared By : TALAAT ABDEL KADER
APPROVED BY:
Dave Kennedy, President Date
Anthony Beck, Vice President Date
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REVISION AND APPROVAL RECORD
Revision Description Approved By Date

1 Original Release 1/1/2012
2 Issue 2 1/10/2012
This version replaces issue one of
the manual
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LUFKIN MIDDLE EAST FREE ZONE

MISSION STATEMENT
Lufkin Middle East Free Zone Company is the

pioneer company in distribution and service of
the artificial lift units in Egypt and Middle East.
It is committed to providing Quality Products
and Services that Meet or exceed our
Customers’ Expectations in a Safe Manner for
our Staff, our Customers and the
Environment
Dave M Kennedy Anthony Beck
General Manager General Manager
Eastern Hemisphere MENA region
Lufkin Industries Lufkin Industries
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QHSE POLICY
It is Lufkin’s policy to provide the highest quality

products and services to meet or exceed our
customer expectations. We operate worldwide in a
safe, responsible manner which respects the
environment and the health of our employees, our
customers and the communities in which we operate.
We will not compromise environmental, health or
safety values for profit or production.
We respect all local laws and regulations and we
constantly strive for incident prevention and
continuous improvement in our business to exceed
our customers’ expectations
Dave M Kennedy Anthony (Tony) Beck
Eastern Hemisphere Middle East, North Africa
Lufkin Industries Lufkin industries
January 2011
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QHSE PRINCIPLES
1. It is Lufkin’s policy to provide the highest quality

products and services to meet or exceed our
customer expectations.
2. Improvement has no limits.
3. All incidents are preventable; we work diligently to
prevent all incidents.
4. We comply with all local applicable laws, regulations
and set higher standards to achieve superiority in
safety and environment.
5. Training is genuine in Lufkin’s top management
objectives. All people are equipped with training to
improve the team skills.
6. Safety is more than program or procedures. It must
be more than all of that.

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MANAGEMENT REPREENTATIVE
Top management of Lufkin Middle East appointed Mr. Talaat
Akader, the company’s Quality/EHS manager as the
company’s management representative who, irrespective of
other responsibilities shall have the responsibility and
authority includes:.
1. Ensuring that the processes needed for quality
management system are established, implemented
and maintained,
2. Reporting to top management on the performance of
the QHSE management system and any need for
improvement
3. Ensuring the promotion of awareness of customer
requirements throughout the organization
4. Liaison with external parties on matter relating to the
quality, safety and environmental Management
systems.

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LUFKIN MIDDLE EAST QHSE CULTURE
Lufkin Middle East HSE Culture:
QHSE, is a line management responsibility, requires visible

commitment, leadership and involvement. Lufkin proactive QHSE
culture shall be understood, shared and practiced by all employees as
an integral part of everyday business. Fundamental to this culture is
our belief that all losses of people, property and process result from
management failure and are preventable. The culture within Lufkin is
treating the employees with dignity and respect. All employees are
encouraged to make contributions that give meaning to their lives. Top
management of the company is committed to declare that safety is a
tangible way to show that human beings really matter. Leadership
uses safety to make human connections across the organization.
Stamping out accidents, and declaring Zero incidents is a way to
show caring about people and this is the management by leadership

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Lufkin Corporate Organisation Structure
John F. (Jay) Glick

President &
Chief Executive Officer
Lufkin, TX
USA
Brian J. Gifford Alejandro Cestero C. D. “Bud” Hay

Mark E. Crews Scott H. Semlinger Christopher L. Boone
Vice President Vice President Vice President
Vice President Vice President Vice President
Human Resources General Counsel & Power Transmission
Oilfield Division Manufacturing Technology Treasurer and CFO
Lufkin, Tx Company Secretary Division
Lufkin, Tx Lufkin, Tx Lufkin, Tx
USA Lufkin, Tx Lufkin, Tx.
USA USA USA
USA USA
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1.0 Knowledge about the company
Lufkin Industries Inc. is a pioneer company that designs, engineers,

manufactures, sells, installs and services high-quality and high-value-added
oil field equipment and power transmission products across the globe.
Besides designing, manufacturing and marketing the industry standard
conventional, Mark II and other Rod lift pumping units that are used to lift
oil from wells; the Oilfield Division provides pumping unit services and well
automation products and services, through Lufkin Automation.
Lufkin Middle East (Egypt) is a service branch of Lufkin industries that sells
and service pumping unit throughout (Egypt) and Middle East. The Head
quarter of the company is located in Maadi while its warehouses, workshop
and distribution center is located in the free zone area in Nasr city. To this
end, Lufkin Middle East has developed documented integrated management
system according to ISO 9001:2008, ISO 14001: 2004 and OHSAS
18001:2007.
Lufkin Middle East respects and applies all regulatory requirements

concerning the products, environment, health and safety and exceeds local
regulations to achieve highest quality and safety degree.
------------------------------------------------------------
Dave Kennedy, President
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2.0 Integrated Quality/HSE Management systems
2.1 Scope and Purpose

The integrated management system manual (IMS) is the reference document
of Lufkin Middle East. It defines how the company is complying with the
requirements of the latest versions of ISO 9001:2008, ISO 14001:2004 and
OHSAS 18001:2007. All requirements of the standard are comprehensively
defined in this IMS manual, where required reference will be given to the
respective IMS procedures.
The scope of this IMS is to describe the IMS of Lufkin Middle East, which is
involved in the “distribution, sales, and installation& operation of Sucker
Rod pump” This Integrated management system (IMS) manual specifies
Lufkin Middle East integrated Quality management system (QMS),
Environmental management system (EMS) and Health and safety
management system (OHS) according to ISO 9001:2008, ISO 14001:2004
and OHSAS 18001:2007 respectively.
The system requirements of this manual aimed at achieving customer

satisfaction and exceeding customer expectations by providing Lufkin’s
products of high quality, just – in – time delivery without defects and
providing after shipping support and service for our customers. This manual
explains Lufkin Middle East tools and methodology of how the business is
managed. We adopt closed – loop process model methodology in managing
Lufkin Business by accurately identifying customer requirements, and
achieving customer satisfaction through all management team. Lufkin
Middle East adopts also continuous improvement approach in its activities
by providing the best products which cause no harm for people or
environment.
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2.2 General requirements
Lufkin QHSE is that part of overall management system which establishes,

documents and implements Lufkin quality policy, and related processes for
providing products and services which meet or exceed customer
requirements, Lufkin Middle East have adopted the process approach by
defining and managing process inputs, controls, and outputs to ensure
desired results are achieved, and interfaces between interrelated processes to
ensure system effectiveness is achieved.
Lufkin Management identified the company’s ‘core’ business processes”

which are ‘Customer Oriented Processes’, or COPs, which are in place to
meet the specific needs of our external customers. The basic sequence and
interaction of Lufkin Middle East COPs is depicted in the process mapping
graph. We have also developed “support Oriented processes or SOPs, to help
implement COPs in the most effective and efficient manner possible.
Lufkin Middle East developed ‘Management Oriented Processes’, or MOPs,

to help meet the specific needs of management to meet management
requirements and other external standards and regulatory requirements.
The overall sequence of QMS processes (i.e. COPs, SOPs and MOPs) are
depicted in Lufkin process mapping. Techniques and tools for process
management are discussed throughout this manual. Specific responsibilities
for and the sequence and interaction of our key QMS processes are detailed
in Operating Procedures (OPs).
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2.3 Permissible exclusion:
The following sub clauses of product realization (clause 7 of ISO 9001: 2008) have been
excluded from the scope of Lufkin Middle east.
Sub-clause 7.3 of design and development
The last sub-clause had been excluded from the scope of ISO 9001:2008 Quality management
system of Lufkin Middle East because Lufkin Middle east is a service company and it is not
involved in design and development.
2.4 References
As Lufkin is establishing integrated QMS/EMS management system, SO, the company is

adopting the following references:
1. ISO 9001: 2008 Quality management system- requirements

2. ISSO 9000:2005 Quality management system- fundamentals and vocabulary
3. ISO 9004:2009 Guidelines
4. ISO 14001:2004 Environmental management system
5. OHSAS 18001: 2007 Occupational health and safety management
6. OHSAS 18002: 2008 Guidelines
2.5 Terms and definitions
Lufkin integrated Quality/ HSE Management System (QSM) uses the same
internationally recognized terms, vocabulary and definitions given in ISO
9000:2005. In addition to that standard, we have also the following
definitions
Acceptable Risk. It is Risk that has been reduced to a level that can be
tailored by the organization having regard to its legal obligation and IMS
policy.
Audit. It I systematic, independent and documented process for obtaining
“audit evidence” and evaluating it objectively to determine the extent to
which “audit criteria” are fulfilled
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Incident. It is incident which has given rise to injury, ill health or fatality.
ALARP It means to reduce a risk to a level which is “as low as reasonably
practicable” and involves balancing reduction in risk against the time,
trouble, difficulty and cost of achieving it.
Continual improvement. Recurring process of enhancing the OH&S
management system (3.13) in order to achieve improvements in overall
OH&S performance (3.15) consistent with the organization’s (3.17) OH&S
policy (3.16)
Controlled document, the document which is prepared, reviewed approved,
distributed and revised in a controlled manner to ensure that the right
document will be available at the right time.
Corrective action to eliminate the cause of a detected nonconformity (3.11)
or other undesirable situation
Customer satisfaction customer's perception of the degree to which the
customer's requirements (3.1.2) have been fulfilled
Document information and its supporting medium. NOTE the medium can
be paper, magnetic, electronic or optical computer disc, photograph or
master sample, or a combination thereof.
External document, any document used as a reference apart from the
quality procedures e.g., service specification, ISO standards etc.
Hazard. Source, situation, or act with a potential for harm in terms of
human injury or ill health (3.8), or a combination of these. Hazard is the
potential to cause harm including injury/illness, property damage,
disruption of productive arrangements and adverse effects on the
environment. Examples include hydrocarbon under pressure, object at
height, electricity, toxic substances, radiation, noise, and vehicle in motion.
Hazard identification process of recognizing that a hazard (3.6) exists and
defining its characteristics
Ill health identifiable, adverse physical or mental condition arising from
and/ or made worse by a work activity and/or work-related situation
IMS integrated Management system for managing health and safety, environmental and
quality management system based on requirements of OHSAS 18001, ISO 14001 and ISO
9001 standards, i.e., the organization structure, responsibilities, policies, procedures and
resources for implementing Health, safety, environment and Quality Management.
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Interested party person or group, inside or outside the workplace (3.23),

concerned with or affected by the OH&S performance (3.15) of an
organization
Organizational structure is arrangement of responsibilities, authorities and
relationships between people.
Non-conformity non-fulfillment of a requirement
Occupational health and safety (OH&S) conditions and factors that affect,
or could affect the health and safety of employees or other workers (including
temporary workers and contractor personnel), visitors, or any other person
in the workplace (3.23).
OH&S management system part of an organization’s (3.17) management
system used to develop and implement its OH&S policy (3.16) and manage
its OH&S risks (3.21)
OH&S objective OH&S goal, in terms of OH&S performance (3.15), that an
organization (3.17) sets itself to achieve
OH&S policy overall intentions and direction of an organization (3.17)
related to its OH&S performance (3.15) as formally expressed by top
management
Organization, company, corporation, firm, enterprise, authority or
institution, or part or combination thereof, whether incorporated or not,
public or private, that has its own functions and administration. NOTE For
organizations with more than one operating unit, a single operating unit may
be defined as an organization.
Preventive action, action to eliminate the cause of a potential
nonconformity (3.11) or other undesirable potential situation NOTE 1 There
can be more than one cause for a potential nonconformity.
Procedure specified way to carry out an activity or a process
Process set of interrelated or interacting activities which transforms inputs
into outputs NOTE 1 Inputs to a process are generally outputs of other
processes. NOTE 2 Processes in an organization (3.3.1) are generally planned
and carried out under controlled conditions to add
Quality, degree to which a set of inherent characteristics (3.5.1) fulfills
requirements
Record, document (3.5) stating results achieved or providing evidence of
activities performed
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1. Lost time injury. A work related injury, which renders the injured
person unable to perform his regular job or Restricted Work on any day
after the day on which the accident occurred. Note: if, in a single
incident 20 people receive lost time injuries, then it is accounted as 20
LTI's (not 1 LTI). Lost Time Injuries are the sum of Fatalities (FAT),
Permanent Total Disabilities (PTD), Permanent Partial Disabilities
(PPD), and Lost Workday cases (LWC).
LTI = (FAT+PTD+PPD+LWC)
2. Lost work days (LWDs) a lost workday case is any work injury other
than a Permanent Partial Disability, which renders the injured person
temporarily unable to perform any Regular Job or Restricted Work on
any day after the day on which the injury was received.
3. Medical treatment case A work related injury, which results in neither
lost time nor restricted work but which requires treatment by or under
the supervision of, or from the specific order of, a medical doctor.
Risk, combination of the likelihood of an occurrence of a hazardous event or

exposure(s) and the severity of injury or ill health (3.8) that can be caused by
the event or exposure(s)
Risk assessment, process of evaluating the risk(s) (3.21) arising from a
hazard(s), taking into account the adequacy of any existing controls, and
deciding whether or not the risk(s) is acceptable
Environmental policy overall intentions and direction of an organization
(3.16) related to its environmental performance (3.10) as formally expressed
by top management
Environmental target detailed performance requirement, applicable to the
organization (3.16) or parts thereof, that arises from the environmental
objectives (3.9) and that needs to be set and met in order to achieve those
objectives
Internal audit systematic, independent and documented process for
obtaining audit evidence and evaluating it objectively to determine the extent
to which the environmental management system audit criteria set by the
organization (3.16) are fulfilled
prevention of pollution use of processes, practices, techniques, materials,
products, services or energy to avoid, reduce or control (separately or in
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combination) the creation, emission or discharge of any type of pollutant or

waste, in order to reduce adverse environmental impacts (3.7)
Environmental aspect element of an organization's (3.16) activities or
products or services that can interact with the environment
Environmental impact any change to the environment (3.5), whether
adverse or beneficial, wholly or partially resulting from an organization's
(3.16) environmental aspects (3.6)
Uncontrolled document, the document, preparation, review, approval,
distribution and revision of which are not necessary to be done in controlled
manner.
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3. 0 Lufkin Integrated management system (IMS)
Lufkin adopts an integrated Management system for managing health and safety,
environmental and quality management system based on requirements of OHSAS 18001,
ISO 14001 and ISO 9001 standards, i.e., the organization structure, responsibilities,
policies, procedures and resources for implementing Health, safety, environment and
Quality Management. Lufkin adopts also closed – loop process approach which is major
requirements of ISO 9001: 2008, OHSAS 18001, ISO 14001, and it is based on the rule of
Plan – DO – Check – Act or Deming PDCA circle which starts with planning of the
QMS /EMS systems and ends by continual improvement. It is as follows:
Lufkin Middle East Business plan
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Taking the PDCA cycle as a reference led to the identification of the

fundamentals on which IMS has been defined. These fundamentals are:
1. The QHSE Policy where Lufkin top management reports its
commitments towards QHSE performance continual improvement;
2. Identification of major processes, and supporting processes and
drawing the process mapping of all Lufkin processes and show the
process interactions.
3. The HSE risk assessment and the environmental impact evaluation of
Lufkin activities, including activities managed by contractors and
subcontractors;
4. Identification and planning of specific strategic QHSE objectives and
targets.
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5. Identification, dissemination and periodical updating of the legal and

non-legal requirements applicable to activities carried out;
6. Definition of Lufkin QHSE roles and responsibilities both at all levels of
the company.
7. Definition and implementation of the QHSE requirements for the
operational control of day-to-day activities;
8. Definition and implementation of training cycles (identification of needs,
planning and execution of training sessions, effectiveness verification)
to ensure competence and awareness of concerned personnel;
9. Identification, planning and implementation of all the surveillance,
monitoring, maintenance and review activities required to verify that
the QHSE management is in line with the defined IMS principles and
rules and is in compliance with the legal applicable requirements, and
necessary to guarantee the efficiency and efficacy of the system itself
10. Lufkin integrated management system (IMS) contains four levels of
documentations as follows:
 First level of documentation which contains Lufkin Integrated
Quality& environmental and safety policy
 Second level of documentation which System Guidelines
regulating the management activities required to guarantee the
IMS efficiency and effectiveness (e.g.: risk assessment,
improvement program, training, surveillance) and contains also
planning processes such as identification of major and supporting
processes,
 Third level of documentation Operational Guidelines setting the
minimum quality, health, safety and environmental requirements
to comply with while carrying out the day-to-day operational
activities;
 Fourth level of documentation, Project/Branch specific
procedures and working instructions tailoring at local level the
IMS according to country/branch/site/project specifies.
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By the application of the rule of PDCA on Lufkin IMS QHSE management

system we can explain Lufkin system and activities according to the following
Plan
1. Lufkin top management set the Lufkin mission statement
2. from the mission, the IMS policy is derived
3. from both mission and policy, the organization objectives are derived
4. from all the previously mentioned, we design both major and
supporting process go as follows;
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5.Sales department takes up bid for tender

6.Tender review meeting is held
7.Receive purchase order/ work order
8.From purchase order and work order, derive planning schedule based
on the available resources/ materials in the free zone.
9. The same planning schedule shall be distributed to all concerned
department (Purchasing department, free zone, operations department
if service is required)
10. Hazard identification and risk assessment for Lufkin products and
Lufkin services
11. Environmental aspects and environmental impact analysis
according to the local law and other requirements
12. Legal and other regulations
Resources management
 Availability of materials, work orders ( operations department, sales

department)
 QA plan & procedures ( operations department)
 Job safety plan& procedures
 Material requirements (operations & purchase dept.)
 Manpower requirements ( HR & operations department)
 Organization charts, resources, accountability and responsibilities
Do / check
All departments, including operations, sales, logistics, and finance

department shall check& monitor the work progress according to
planning schedule and record the shortfalls in the process.
 Operations supervisor shall record Non conformity for improvement and
shall keep the related records for the work.
 Finance & accounting department shall monitor the cost and claim the
monthly bills to clients for collecting payments.
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 Safety department shall provide procedures, equipment’s, and audit

and report the works done in safe manner.
 Control actions of all hazards and risks
 The quality plan should be kept by the operations manager to see if the work is carried
out according to the original plan or correcting the deviations if happens.
ACT
Corrective & preventive actions
 The non- conformities in work process shall be identified and concerned

departments find out the root cause to take corrective actions for
improvement.
 Incident investigation and reporting
 Root cause analysis of accidents , incidents and near misses
 Recommendation of corrective and preventive actions.
 Follow up and tracking the effectiveness of these actions
 Achieving continuous improvements through audits and management
reviews
 Audit plans should be designed at regular intervals.
 Management review should be planned at regular intervals to discuss
the effectiveness and efficacy of both corrective and preventive actions.
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Notes:
1. QHSE manager is appointed as management representative,
who is responsible for the implementation, control,
communication, internally and externally (with governmental
bodies in issues relevant to HSE.
2. He is directly reporting the performance of QHSE system to the
top management
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Lufkin Quality management system
Lufkin Middle East quality system is tailored to our processes, including all
customer and regulatory requirements. Requirements of ISO 9001:2008 that
are not applicable to the nature of our business are excluded from the scope
of our quality system. Lufkin Middle East is a service company, so all
activities of manufacturing, design are excluded from the quality system.
Lufkin quality system is based on the following processes according the pr
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Lufkin QMS Process Mapping

Management responsibility
Human resources
customer
Customer
Distribution
purchasing
Operations &
Storing
service
Finance management
Facility maintenance/service
1. Sales processes
1. Technical sales management
2. Purchasing ( local and international)
3. Storing
4. Distribution
5. Service
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From the process mapping figure, Lufkin Middle East is going as the
following:
The major Processes are the following:

1. Sales processes which consists of the following sub- processes:
 Tender process
 Order processing
 Contract review process
 Customer training process
 Customer complaints process
2. Technical purchasing process: this process relates to the ordering and
controlling the locally manufactured components of the pumping unit.
this process is related also to the control of the incoming products and
customer complaints and providing managing of bon- conforming
materials and root cause analysis and corrective actions and preventive
actions.
3. Purchasing and logistics: this process has the following sub-
processes:
 International procurement procedures.
 Local procurement
 Logistics shipping control
 Transport coordination
 Vendor evaluation
 Facility management
4. Storing, warehousing and distribution : these includes Lufkin
warehouses in the free zone area in Nasr city, where all local and
international purchases concerning the pumping unit is included and
there are 8 sub-processes to manage these major process
 Delivery shipments for manufacturing
 Delivery shipments after manufacturing
 Delivery shipments in Egypt
 Delivery shipments outside Egypt.
 Receiving foreign shipments
 Receiving shipments for repairing
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 Receiving shipments from local markets

 Delivery shipments out of country.
 All incoming inspection
 Issuing certificate of compliance ( COC)
5. Service management: this process is composed of two sub- processes,
which are:
 Workshop subprocesss
 Oil field services
5.1 workshop sub- process
 Equipment receiving, handling and data collection
 Pump inspection
 TAC inspection
 Pump repair and modification
 TAC repair
 New pump check and modification
 New TAC check and modification
5.2 oil field services:
 Unloading and downloading using crane operations
 Installation of pumping unit
 Down hole pump
 Pump unit maintenance
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4.0 IMS Documentation requirements

General
Lufkin established, documented, implemented, maintained and continually
improves IMS in accordance with the requirements of the latest versions of
ISO 9001, ISO 14001, OHSAS 18001 standards, to implement the IMS,
Lufkin:
a) Identified processes needed for the IMS.
b) Determined the sequence and interaction of these processes.
c) Identified HSE aspects/ hazards and assess the impact/risk of its
activities, products/ services and identified the proper control
measures.
d) Determined criteria and methods required to ensure the effective
operation and control of these processes, activities, products and
services.
e) Ensure the availability of resources and information necessary to
support the operation and monitoring of these processes.
f) Measures, monitors and analyses these processes and
g) Implement action plan necessary to achieve planned results and
continual improvements of these processes.
4.1 IMS Quality/HSE Manual

This manual is part of our QMS that defines the scope of our QMS and
documents the policy, procedures and processes needed to implement our
quality, safety and environmental policy and achieve our quality objectives.
This manual also documents justifications for exclusions from ISO
9001:2008 requirements and defines the overall sequence of and interaction
between our key QMS processes. For HSE there is no exclusion and all
clauses are clearly applied. This manual is declared for our employees as
guiding and also provided for our customer as an objective evidence of top
management commitment in the application of integrated quality,
Occupational health and environmental management system within the
company. In this manual we refer to the procedures and also to the major
and supporting processes
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4.2 Control of documents

Lufkin Middle East developed a system in the integrated management system
for the documentation and data control. All documents are properly reviewed
and approved before issue. The “control of documents and records
procedures” has been established to ensure that the latest issue documents
are in use and obsolete documents are promptly removed from the location
of use to avoid any unintended use of such documents. Also controls for
external origin documents have been established in order to ensure that
these documents are identified and are distributed as per the procedure.
This manual contains documented statements of our quality policy and
quality objectives and references documented procedures required to achieve
our integrated management system. And other documents needed to ensure
effective planning, operation and control of our key QMS/EMS processes.
The level and type of QMS documentation established for our business is
continually reviewed to ensure it remains appropriate for the complexity and
interaction of our processes and the competence of our employees. QMS/
EMS documents and data may be in hard copy or electronic media.
Lufkin depends on software system of documentation and records according
to BAAN system. The system is connected between Lufkin Egypt and Lufkin
corporate in the United States.
The Quality systems Manager/ management representative has overall
responsibility for ensuring that all QMS documents, including forms used to
create quality records, are controlled per procedures detailed in and
summarized below:
1. Approve documents for adequacy prior to issue.
2. Review, update as necessary and re-approve documents.
3. Identify the current revision status of documents.
4. Ensure that relevant versions of applicable documents are available at
points of use.
5. Ensure that documents remain legible, readily identifiable and
retrievable.
6. Ensure that documents of external origin (including customer
engineering standards/specifications) are identified and their
distribution controlled.
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7. Prevent the unintended use of obsolete documents, and to apply

suitable identification to them if they are retained for any purpose.
8. Criteria for the distribution of the IMS HSE documents shall be
identified and implemented in the light of ensuring at a minimum:
9. Controlled distribution of sensitive documentation;
10. Traceability of the distribution is carried out and maintained
updated;
11. Availability at points of use of updated versions for all concerned
personnel, including contractors and subcontractors;
12. Withdrawal of all existing obsolete versions of the documents
when an updated version is distributed.
Supporting documents: QP 300

: QP01 F02
: QP01 F03
4.3 Control of records
The management system believes that all records, which are part of the
integrated management system, are to be controlled through proper
documented system. IMS records pertaining to process and system are
indexed and systematically referenced for ease for retrieval, traceability and
conformity to requirements. Since IMS are objective evidence for
demonstrating the conformance with requirements, special considerations
shall be given for the proper filing of these records to eliminate any damage
or deterioration. Quality system Manager/ management representative has
overall responsibility for ensuring that all records required for the QMS
(including customer-specified records) are controlled and maintained to
provide evidence of conformance to requirements and effective operation of
the QMS. Records are retained for a period defined by the customer,
applicable regulatory requirements and/or Lufkin management, as
applicable, and then disposed of in accordance with applicable requirements.
Records may be in the form of hard copy or electronic media. Details
procedures necessary to control QMS records that, as a minimum, are
prepared to document:
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a) Results of processes performed, including identification of the

individual performing the activity.
b) Product/process evaluation/acceptance criteria.
c) Procedures, drawings or instructions used to perform an activity,
including revision or date of document.
d). Identification of material, parts, or equipment used in the making of the
product.
e) Personnel, material or equipment qualifications.
f) Pertinent technical records from sub-contractors.
Supporting documents : QP 01
: QP21F 01
5.0 Management responsibility
5.1 Management commitment

In Lufkin Middle East, Management is committed to implement QHSE
management system to achieve continual improvements. This was reflected
in providing all resources to achieve QMS/HSE system within the company.
The company General manager issued the mission statement, QHSE policy
and QHSE objectives which all include the commitment of the top
management to achieve quality / EHS management system within the
company. Lufkin quality policy statement documents and communicates the
importance of meeting or exceeding all applicable requirements (including
customer, regulatory and legal requirements) and the strategy of zero
incident goal is part of the policy of the company which reflects the utmost
commitment in achieving incident free workplace and also to overcome the
losses within our customer’s oilfield and the management is committed to
provide training to achieve continual improvement of our processes,
products, and services.
All managers demonstrate their commitment to the development and
improvement of the QMS through the provision of necessary resources,
through their involvement in the internal audit process, and through their
proactive involvement in our continual improvement activities – where
emphasis is placed on improving both effectiveness and efficiency of our key
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QMS/HSE processes. Lufkin Management, who is fully committed to

implement and continually improve the integrated management system in
the company, provides evidences of its commitment through:
1. Communicating to all employees the importance of meeting customer
requirements as well statutory and regulatory QHSE requirements.
2. Establishing IMS policy and IMS objectives.
3. Conducting periodic management review meetings.
4. Ensuring the availability of adequate resources, for the effective
implementation of integrated management system.
5. All existing and new employees will be inducted into the IMS policy,
objectives and requirements.
6. Internal IMS audits will be routinely conducted to ensure the system
compliance.
7. IMS policy statement is communicated to all employees, contractors,
and interested parties and available to the public.
5.2 Planning for Hazard/ aspects identification, impact/ risk assessment &
control (HSE 01)
Lufkin establishes, implement and maintains a procedure to identify the
occupational Health & Safety Hazards, the environmental aspects of its
activities. Products and series taking into account planned or new
developments, or new modified activities, products and services in order to
determine those which can have significant impacts/risks on people and
environment and set the necessary control measures.
The documented procedures “hazard/aspect identification, risk/impact
assessment and determining control takes into account:
 All routine and non-routine activities
 Activities of contractors, visitors having access to the workplace
 Hazards created outside the workplace affecting Lufkin employees/
contractors
 Changes or proposed changes in Lufkin organization that an cause
risk/impacts
 Modification in Lufkin IMS and its impacts
 Applicable legal and other requirements.
 Design of work areas, processes, installation, machinery/equipment,
operating procedure
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Risk management, is pre-emptive, rather than reactive measures. Hazard

analysis and risk assessment is simply a careful examination of what in our
location could cause harm to people or properties and environment. The
main objective of performing this task is identifying and evaluating a hazard
to determine the level of action required to reducing a risk to an acceptable
level.
Risk is defined as the probability and severity of accident or loss from
exposure to various hazards, including injury to people and loss of
resources.
Operational Risk Management (ORM) is simply a formalized way of
thinking about these things. ORM is a simple four - step process, which
identifies operational hazards and takes reasonable measures to reduce risk
to personnel, equipment and the four steps to do so and can be summarized
in the following items:
 Find any hazard to safety and health or affecting the properties of the
company.
 Decide how big a risk each one is.
 Make out what to do to get rid or lessen each hazard.
Risk assessment: is a process of identifying and evaluating to determine the
level of action required to reduce a risk to an acceptable level. It is nothing
more than a careful examination of what in the workplace could cause harm
to people so that we can weigh up whether the department has taken enough
precautions or required to take additional precautions to prevent harm
occurring.
Lufkin manage risk whenever we modify the way we do something to make
our chances of success as great as possible, while making our chances of
failure, injury or loss as small as possible. It’s a commonsense approach to
balancing the risks against the benefits to be gained in a situation and then
choosing the most effective course of action.
purpose of the Risk Registers is to provide an assurance process that
demonstrate appropriate and effective controls are in place.
Lufkin has developed this HSE Risk Assessment guideline to provide the
overall framework for the management of HSE risks within the business and
operations in order to identify, prevent, control and mitigate risks to
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personnel, property, the environment and public arising from processes,

activities and materials used or encountered in them.
Lufkin risk management approach:
Lufkin approach to the Risk Management can be summarized as follows:
 Risk Analysis: Systematic identification of the Hazards which may
affect or arise from Lufkin activities and from the materials which are
used or encountered in them;
 Risk Evaluation: Assessment of the associated risk arising from the
identified hazards;
 Risk Reduction/control: Identification and implementation of risk-
reduction measures in order to eliminate or at least reduce the risks
where this is deemed to be necessary;
 Documentation of the Hazards and Risks together with the risk-
reduction measures (Risk Assessment Report, Risk Register, and
Response Action Sheets).
The following Figure outlines Risk Management approach.
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Lufkin requires that residual risks associated with Facilities or activities

have been reduced to ALARP. The definition of ‘ALARP’ is:
“As low as reasonably practicable”
The ALARP level represents the point, objectively assessed, at which the
time, trouble, difficulty and cost of further reduction measures become
unreasonably disproportionate to the additional risk reduction obtained.
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Risk reduction
Risk reduction measures include preventative measures (reduction of the
likelihood) and mitigation measures (reduction of severity of consequences).
Risk reduction measures also include recovery preparedness measures
which address emergency procedures as well as restoration and
compensation procedures to recover.
Risk reduction measures introduce controls in order to reduce and/or, where
possible, to remove the risk.
The following concept is used to reduce risk:

1. Reduction: reduce the hazardous situations or the frequency or
duration of exposure;
2. Substitution: Substitute hazardous materials with less hazardous
ones;
3. Attenuation: using the hazardous materials or processes in a way that
limits their hazard potential;
4. Simplification: making the plant and process simpler to design, build
and operate.
Factors that will influence the selection of measures to reduce the risk
include:
 The technical feasibility of the risk reducing measures;
 The contribution of the risk reducing measures;
 The costs and risks associated with implementing the measure;
 The degree of uncertainty associated with the risk, or the risk-reduction
technique, including human factors.
Supporting documents LHSE 01
5.3 Legal and other requirements
In order to manage Health, Safety and Environment effectively, Lufkin will

implement procedures to keep itself fully updated on current and proposed
HSE legislation. Lufkin will ensure that it identifies and assesses legal and
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other requirements that are applicable to its operations. These requirements

shall be kept up-dated as necessary. A register of the legal and other
requirements on HSE will be completed so as to promote awareness and
understanding of these responsibilities. Copies of requirements (actual text,
summary or analysis, hard copies, electrical files, where appropriate) relating
to Health, Safety and Environment, applicable to operations shall be kept.
1. Legal requirements / Government regulations.
2. Project Specification.
3. Customer contracts
4. Best Practices (e.g. codes, industry association guidelines).The
management of HSE legal and non-legal requirements shall address, at a
minimum, the topics here below summarized.
Identification
HSE legal and other requirements applicable to all Lufkin Middle East
activities in Egypt and abroad shall be identified prior to the start-up of the
operations. Legal requirements of concern shall include but could be not
limited to:
1. Egyptian environmental law 4,1994, rules and standards where
applicable;
2. Egyptian labor law , chapter 5 concerning HSE legislation;
3. HSE provisions reported in permits, licenses or authorizations required
to operate.
Access
Identified applicable HSE requirements shall be collected in a logbook that
shall include, at a minimum, the followings:
 Requirement reference (code, issuing date etc.);
 A summary of the content of the requirement;
 Deadlines to comply with when applicable;
 Responsibilities in terms of activity to carry out to comply with.
1. The preparation and management of the procedures shall comply with

the minimum requirements set in the guideline “Documentation
management”;
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2. All concerned personnel shall be trained with respect to what addressed

by the procedures; training shall be planned and carried out in
compliance with the minimum requirements set in guideline “Training”;
Supporting
Supporting document HSE 022

5.4 Customer focus
The objective of the Quality Management System (QMS) is to ensure and
enhance customer satisfaction. Key aspect of this policy is the determination
of customer requirements and the measurements of customer satisfaction. A
quality management principle is a comprehensive and fundamental rule or
belief for assessing an organization in defining, identifying, guiding and
validating organizational behaviors. Top management ensures a proper
customer focus is established and maintained through the following
activities:
Customer complaints and other customer input / feedback are continually
monitored and measured to identify opportunities for improvement. We
continually look for other ways to interact directly with individual customers
to ensure a proper focus to their unique needs/expectations is established
and maintained: e.g. customer audits, customer visits, trade shows, joint
planning sessions, etc. In addition, we have established an interactive web
site: www.Lufkin.com to provide customers with quick access to information
and points of contact within our organization. These customer focused
communications and interactions ultimately yield clear, explicit customer
requirements and expectations in the form of a contractual agreement or
customer order.
Customer and/or standards and other documents of external origin received

by the company, are distributed, reviewed and where necessary,
implemented in a timely manner (sales department SS01). The company
reviews customer requirements prior to accepting orders and prior to
accepting changes to existing orders. This process includes:
1. Determination that the customer’s requirements are clearly defined
(SS01)
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2. An assessment of company ability to meet the customer’s needs

(contract review (SS02)
3. Decisions regarding price and delivery
4. Negotiation and agreement with the customer on requirements, pricing,
and delivery.
5. Assessment and provisions for confidentiality
5.5 Quality/HSE policy:

The company is dedicated to the integrated quality/HSE policy which
ensures that its products and services fully meet the requirements of its
customers at all time. The goal of the company is to achieve a high level of
customer satisfaction at all times. Commitment to the implementation of
supporting managerial and business operational systems is essential to
realizing that goal. The quality policy is based on 3 fundamental principles:
1. Ensuring that we fully identify and conform to the needs of our customers.
2. Looking at our service provision processes, identifying the potential for
errors and taking the necessary action to eliminate them.
3. Everyone understanding how to do their job and doing it right first time.
5.6 objectives and targets
Lufkin established set objectives and targets to enable and prove to be

continually improving IMS performance. The management representative in
consultation with functional managers shall establish HSEQ objectives and
targets; this shall be done on a yearly basis. Based on the customer
requirements, identification & evaluation of HSE aspects/ impacts and risk
assessment, all significant environmental aspects and high grade of
associated risk are considered. More readily by the organization (sometimes
such objectives are referred to as being “SMART”).
It is also advisable that the organization records the background and reasons
for setting the objectives, in order to facilitate their future review.
Lufkin Middle East objectives and programs
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Objectives that are specific, measurable, achievable, relevant, and timely can
enable progress against the attainment of the objectives to be measured
From Lufkin risk assessment and hazard identification and from the
inventory of control actions within the company whether in the office or
customer – related oilfield we have set objectives to be achieved for our
employees:
1. Strike to reduce the probability of the accidents which have the

potential to cause injury, disablement & loss of life & property.
2. To achieve zero fatal incident in all functions in the free zone and oil
fields
3. Take measure to minimize health impairment of people involved in
carrying out the customer - field activities and also to enhance Lufkin
image within the oilfield activities.
4. To ensure compliance with all HSE related statutory laws, rules &
regulations and be a good responsible corporate for the application of
labor law and safety law 12/2003.
5. To educate the employees so that they can be aware of their own safety,
health & well-being as well as their responsibility towards the
environment. Our objectives is increasing training by 20% in
2012/2013
6. continuously improve our environmental performance by setting
objectives and targets against environmental law 4/1994,
All functional departments set KPIs to follow the and measure the overall
objectives of the organization and also to measure the departmental
objectives
5.7 Quality planning
The QMS planning process involves the establishment and communication of

our quality policy and objectives through issuance of this manual and its
associated procedures, and through the provision of resources needed for its
effective implementation. Accordingly, this manual constitutes our overall
plan for establishing, maintaining and improving an effective IMS. Our
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management review process and internal audit process (Section 8.2.2) ensure
the integrity of our IMS is maintained when significant changes are planned
and implemented that affect our key QMS processes.
Management has the responsibility and authority for ensuring that critical
processes have sufficient resources available to enable the Company to
achieve its business and quality objectives and enhance customer
satisfaction by including, as part of the OBP, capital resource plans as well
as plans for acquisition and training of human resources.
The results of the Business Planning process are documented as is the

Business Plan which is a confidential and controlled document. Plans are
reviewed and updated at least annually to reflect changes in the business
environment and the conditions imposed by that environment and to reflect
management’s requirement for continual improvement in the process
affected by the plans. Plans and objectives to improve performance are
established and reviewed as part of the Management Review process.
Objectives are measurable and consistent with the Quality Policy and
established procedures.
6.0 integrated management system organization

6.1 Resources, Roles, responsibilities, accountabilities and
Authority
Lufkin is committed to provide all types of resource for the effective
implementation and maintenance of effective IMS. Regular management
review meetings, internal IMS audits and corrective actions and preventive
actions system will identify such resources.
Adequacy of resources including trained personnel, equipment, and software
required to meet the customer requirements and to achieve effective IMS
performance are viewed periodically during the management review
meetings. Top management shall demonstrate its commitment by ensuring
the availability of resources essential to establish, implement, maintain and
improve the IMS OH&S management system.
Defining roles, allocating responsibilities and accountabilities, and delegating
authorities, to facilitate effective quality, OH&S management; roles,
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responsibilities, accountabilities, and authorities shall be documented and

communicated.
OHSAS 18001 and ISO 9001:2008 and also ISO 14001 requires that the
QHSE management appointee has to be a member of top management. The
OH&S management appointee can be supported by other personnel who
have delegated responsibilities for monitoring the overall operation of the
OH&S function. However, the management appointee should be regularly
informed of the performance of the system, and should retain active
involvement in periodic reviews and the setting of Quality & OH&S
objectives. It should be ensured that any other duties or functions assigned
to the top management appointee do not conflict with the fulfillment of their
OH&S responsibilities.
Appropriate resources shall be made available to establish, implement and
maintain the HSE integrated management system. Identification of resources
shall take into account the following items:
1. Human resources and training;
2. Infrastructure and technologies;
3. Information systems;
4. Financial and other resources specific to operations.
Resources allocation shall consider both the current and future needs when
predictable. Appropriate assignment of quality/ HSE responsibilities and
authorities within Lufkin Middle East at all levels and in all locations is
essential to ensure successful establishment, implementation and
maintenance of the HSE management system.
In the light of what above mentioned, Lufkin Organization Chart has been
defined and approved by the top management of the company. Appropriate
assignment of HSE responsibilities and authorities within Lufkin levels is
essential to ensure successful establishment, implementation and
maintenance of the HSE Management system.
HSEQ Roles and responsibilities of Lufkin Management staff

Senior management
1. Acts as the higher level authority in IMS related matters.

2. Authorize and endorses the IMS policy statement and IMS objectives,
IMS manual and organization policies.
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3.Review and approve training requirements and budget.

4.Implement approved changes to the organizational structure.
5.Review and approve Lufkin strategic objectives and targets.
6.Grant the authority for managing IMS audit program
7.Review the current level of management performance& outcome from
IMS committee to provide input for the continual improvement of the
IMS system.
8. Review and approve the required budget/ resources identified to meet
the requirements of the IMS.
9. Review progress reports and ensure that the planned IMS activities are
completed.
IMS management representative/HSEQ manager
1. Develop, update and communicate Lufkin IMS policies.

2. Develop IMS procedures and guidelines.
3. Develop, update, communicate & organize IMS and the annual
programs for implementation.
4. Plan, develop, coordinate, audit & promote Health and safety &
environmental protection in all aspects of Lufkin activities.
5. Set, communicate and update Lufkin HSEQ procedures, manuals and
guidelines to be in line with the applicable local & international
regulations, standards and ensuring proper implementation.
6. Assess and monitor the IMS.
7. Set, update & coordinate the implementation of IMS training program.
8. Set the IMS performance measures for the company based on the
annual IMS objectives and targets.
9. Administer the continual review of the system, including:
- Internal and external audits, continual improvement, customer
complaints, management review meetings and reports on the
performance of the IMS.
a. Ensure all staff is aware of their responsibilities in the area of IMS.
HR department
HR manager
1. Ensure that all HSEQ training requirements have been satisfied.

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2. Ensure that all roles, responsibilities, accountabilities are defined

within the job descriptions.
3. Ensure that the required competencies for the staff whose performance
affecting the product, customer satisfaction and service compliance are
well – defined.
4. Ensure that all HSEQ issues related to the office building are in place.
5. Ensure that the housekeeping in all Lufkin sites is met at the highest
standards.
Logistics department
Logistics and purchasing manager
1. Ensure that HSEQ requirements for contractors are included in all

stages of contract documents.
2. Consult with HSEQ department on HSEQ requirements on contractors/
consultants and outsourced providers.
3. Nominate qualified employee to be a department IMS coordinator.
4. Ensure that all contractors have been pre- qualified in HSEQ issues as
per Lufkin IMS procedures.
Operations manager/ supervisors
1. Develop and align the functional QHSE objectives in line with IMS
requirements, where applicable.
2. Identify the required competencies/ training for the staff from the
function.
3. Ensure that all corrective / preventive actions have been tracked and
closed out where applicable.
4. Define resources (personnel, services and materials) required and
develop and agree on action plan& budget.
5. Monitor and record IMS performance by the function where applicable.
Job description
Potential needs to draw up dedicated job descriptions in order to properly
describe skills and competences of QHSE key figures shall be evaluated, The
preparation and management of the job descriptions shall comply with the
minimum requirements set in the guideline “Documentation management”;
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The successful implementation of quality/ OH&S management system calls

for a commitment from all persons working under the control of the
organization. This commitment should begin at the highest levels of
management.
6.0 Resource management

6.1 Provision of resources
The Managing Director with input from all responsible managers, ensures,
appropriate resources, including trained employees and appropriate
equipment, facilities, support services and work environment needed to
implement, manage and improve an effective effective/efficient QMS/ HSE
and enhance customer satisfaction, are identified and provided through
Lufkin budgeting and other business management processes. The overall
philosophy in determining the resource requirements shall be:
1. Effective implementation and maintenance of integrated QMS/ EHS
and the needs for its continual improvement.
2. Enhancement of satisfaction level.
3. To maintain and improve the facilities and infrastructure for long-term
requirements
4. It shall be ensured that adequate resources are provided and are
upgraded, based on emerging requirements
6.2 Human resources
This output is recorded with reference to 6.3 Training Records. The Company
assigns qualified personnel to ensure that those who have responsibilities
defined in the quality system are competent on the basis of applicable
education, training, skills and experience.
The company operates a formal system to ensure that all employees within
Quality System are adequately trained to enable them to perform their
assigned duties. Training covers all aspects of running the business and
embraces management, performance and verification activities.
6.3 work environment
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Top management create and maintain a shared vision, shared values and an
internal environment in which people can become fully involved in achieving
the company’s objectives. Lufkin work environment encourage personal
growth, learning, knowledge transfer and team work and moreover providing
training in English language for all employees.
Lufkin Middle East ensures that the work environment has positive influence
on motivation, satisfaction and performance of people in order to enhance
the performance of people in order to enhance the performance in the
company. Suitable work environment, as a combination of human and
physical factors, includes the following:
 Safety rules guidance, including protective equipments
 Ergonomics
 Facilities for people in the company
 Heat, humidity, light, airflow and cleanliness.
6.4 competence, training and awareness

Training and competency form important keystone in the prevention of IMS
related problems within the workplace. The company should ensure that all
personnel are competent prior to permitting them to perform tasks that has
effect on customers. Lufkin set a system to ensure that any person under its
control whether employee or contractor performing tasks that can impact on
OH&S are competent on the basis of appropriate education, training or
experience and shall retain associated records. In addition to Lufkin internal
HSE Training, other external training will be attended as per clients HSE
Specifications and the Egyptian laws.
Training is a key factor in accident and pollution prevention. The aim of
Lufkin HSE training schemes is for all employees to:
1) Develop QHSE awareness.
2) Make staff knowledgeable and alert to the potential hazards within their
work environment.
3) Know how to implement and install and maintenance of the Sucker rod
unit of all its types properly and safely,
4) Be familiar with the use of protective clothing and equipment
associated with the work they do.
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5) Be familiar with the safe work practices set out for specific tasks
associated with their work.
6) Achieve an appropriate level of competency to enable them to do their
job safely.
7) Be aware of their safety responsibilities when supervising staff or
Subcontractors.
8) Necessary competence for personnel performing work affecting service
quality is determined and provided. Wherever gaps are noticed, the same
shall be made up through training or other alternative actions such as job
rotation etc.
6.4.1 Lufkin HSE training plan
The training program is designed to cover the hazards identified at the

locations and safe work practices that will be followed. Training requirements
specified for each of the safe work practices/activities detailed in this
procedure should be extracted to form the basis of the HSE training
programs specific to the site. The following are the training programs
provided for the employees:
Induction training:
1. HSE responsibilities for themselves and other persons working with
them.
2. Safety related sucker rod pumps ( General)
3. Lockout tag out focusing ( for automation engineers)
4. General information about hoisting and rigging and cranes works.
5. The correct Use of PPE.
6. Restricted Areas, Barriers Signs.
7. Tool Box Talks and Stand up Meetings.
8. Manual Handling.
9. Avoidance of Heat Stroke. (where applicable)
10. Fire Prevention and Fire Fighting Appliances.
11. Emergency plans.
12. Designated Smoking Areas.
13. Reporting Accidents, Incidents and Unsafe practices.
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At the end of induction training, new employees or subcontractors will be

required to sign a declaration that they are:
1. Fully qualified to carry out assignment and aware of necessary HSE
procedures.
2. Have the appropriate Personnel Protective Equipment.
3. Are familiar with the on-site emergency procedures
4. Are familiar with the hazardous areas at the site.
Tool box talks

1. Tool Box Training meetings during which, foremen and their work
group discuss matters relating to HSE are to be held at least once a
week to discuss HSE procedures, safety precautions and to promote
individual safety awareness. Where necessary, information to be
provided on circumstances of incidents and accidents.
2. To provide further impetus to Tool Box Training member of the Site
HSE Department.
3. Supervisors are required to implement HSE training programs to all
their personnel and provide comprehensive records of such training to
the operations manager and HSE Manager.
Refresher training
This course is held every year depending HSE performance Special HSE
training for all employees, Depending on Lufkin HSE register, all employees
involved in field operations or in the free zone are provided with the following
special training:
1. Safety around sucker Rod pump
2. Lock out tag out
3. Hazard identification and risk assessment
4. Fire protection and fire prevention
5. H2S training
6. Heat stress
7. Fall control
8. Hoisting and rigging
9. Crane safety
10. Electric hazards
11. Confined space
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12. Incident reporting classification

13. Defensive driving and safe driving techniques
14. First aid training
Where possible, training is conducted in-house, although for more specialist

skills external courses are utilized. The effectiveness of training is evaluated.
The training procedure also covers the induction of new employees which
includes an introduction to the company’s Quality Policy statement. Future
training needs are identified as part of the Management Review process.
HR &Training records:
Training records are maintained to demonstrate competency and experience.

The staff member’s manager should review the training records annually to
ensure completeness and to identify possible future training needs. Training
records will include as a minimum, the following information:
1. Curriculum Vitae ( CV)
2. Current Job Description
3. Copies of certificates for any training undertaken that year
4. Details of any relevant training conducted prior to appointment, which
may not be listed in the current CV.
5. Record of education, training, skills and experience shall be maintained.
6.5 Infrastructure
It is company policy to ensure that all assets and associated equipment are
adequately maintained and fit for purpose. The policy included these
activities:
- Facilities management, maintenance and repair
- Housekeeping/5Ss management
- Process equipment management, maintenance and repair
- Transportation and material handling equipment management,
maintenance and repair
- Information systems maintenance and repair
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Section seven- Integrated management system implementation and

operation
7.0 Communication, consultation and participation
The company shall also set a procedure for the following communications:
a) internal communication among the various levels and functions of the
organization;
b) communication with contractors and other visitors to the workplace;
c) receiving, documenting and responding to relevant communications
from external interested parties
The company’s communication processes should provide for the flow of
information upwards, downwards and across the organization. It should
provide for both the gathering and the dissemination of information. It
should ensure that IMS information is provided, received and understood by
all relevant persons. The organization should effectively communicate
information concerning its OH&S hazards and its OH&S management
system to those involved in or affected by the management system, in order
for them to actively participate in, or support, the prevention of injury and ill
health, as applicable.
7.1 Internal communication
Internal communication within LME exists through various forums such as

meetings, internal circulars, letters, interactions and consultations which
shall also be utilized for communication regarding the effectiveness of QMS/
OH&S and EMS. Means of communication such as fax message, electronic
data transfer etc. have been established for speedy transfer of information to
management and Govt. authorities regarding HR, Safety and environment, as
appropriate. It shall be ensured that all communications on matters relating
to QMS and quality of service are effective and on time, to bring out best
possible response.
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It is important to effectively communicate information about OH&S risks and

the OH&S management system at various levels and between various
functions of the organization.
All managers and supervisors, are responsible for establishing internal
communications as needed to convey to their employees the relevance and
importance of their activities; typically this information is conveyed through
management team meetings and cross- functional improvement.
Communications regarding how employees contribute to the Achievement of
objectives is also conveyed and reinforced during employee performance
reviews. All personnel are aware of their responsibilities and lines of
communication according the declared organization chart
The Company has developed a system for handling customer inquiries,
feedback and complaints. Customer complaints are handled through internal
audit process (refer to Section 8.2.2), continual improvement and
corrective/preventive action process (refer to Section 8.5) and regular formal
and informal communications and all to be reviewed periodically in
management review meeting
The internal information are transmitted to all personnel as follows:
1. The Safety Manager posts information on safety bulletin boards
throughout the facility to convey information regarding the status of
the Safety and Environmental Management Program, and related
statutory/regulatory requirements.
2. The Human Resources Manager posts information on employee
bulletin boards throughout the facility to convey information regarding
employee benefits, programs, involvement opportunities, and
applicable statutory/regulatory requirements.

7.2 External communication
It is important to develop and maintain procedures for communicating

with contractors and other visitors to the workplace. The extent of this
communication should be related to the OH&S risks faced by these
parties. The organization should have arrangements in place to clearly
communicate its quality and OH&S requirements to contractors. The
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procedure(s) should be appropriate to the OH&S hazards and risks

associated with the work to be performed.
In addition to communicating OH&S performance requirements, the
company has defined processes for communicating efficiently and
effectively with its customers and other interested parties. Lufkin
implements and maintained processes to ensure adequate understanding
of the needs and expectations of its interested parties, and translation into
requirements for the company. These processes include identification and
review of relevant information and actively involve customers and other
interested parties. Examples of relevant process information include but
not limited to:
a) Customer requirements
b) Contract requirements
c) Processes due to regulatory requirements
The communication should include information about any operational
controls related to the specific tasks to be performed or the area where the
work is to be done. This information should be communicated before the
contractor comes on-site and then supplemented with additional or other
information (e.g. a site tour), as appropriate, when the work starts. The
organization should also have procedures in place for consultation with
contractors when there are changes that affect their OH&S
7.3 product/ service realization
Lufkin has established documented quality plans and procedures that

describe work methods, the controls applied and the records required Lufkin
QHS identifies, plans for and documents our product and service realization
processes to ensure consistency with all applicable requirements, including
customer requirements and related quality objectives and requirements for
specific products/services, and any/all applicable statutory/legal
requirements. The outputs of product/service realization planning include
the specific methods, facilities, and equipment, people and
materials/support services needed to achieve all desired results for a
particular product, service, or contract. Essentially, the outputs of the
quality planning process applicable to all products/services are work
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instructions and other data in job packs are provided to operations manager
and supervisor or located in work areas where needed.
When requirements are not adequately addressed in the standard

documentation/data, or as required by the customer, the Quality Manager/
operations manager has overall responsibility for developing and
implementing a quality control plan to address additional requirements or
controls needed to verify work for the specific process, product or contract in
question; The outputs of quality planning (i.e. job packs, control plans, etc.)
are carried out in accordance with planned monitoring and measurement
activities (Section 8.2), which may also include the use of appropriate
statistical techniques
7.2 Planning for service realization
Quality planning is required before new products or processes are implemented. The output of
quality planning includes documented quality plans, processes, procedures and design outputs.
In Lufkin demand creation is performed by sales department. Lufkin provides products and
service. This process starts by the contract review process (SS0001), where the contract is
reviewed by all Lufkin departments to make sure the company has the ability to provide the
product or service according to customer requirements. Upon approval of the customer
requirements, work order is passed to operation department in the case of service delivery.
The operation department is then performing the job plan which includes the following:
1. The customer name
2. The task to be performed
3. Location
4. The crew formation
5. Supervisor
6. Tools required to perform the job
7. Timing of startup
8. Timing of finishing
9. Safety tools
10.Hazard associated with the job
11.Actions to avoid hazards.
In case of product requirements, the output of contract evaluation and approval of the product
requirements, sales people translate customer requirements into product specifications, and
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then create Purchase order and the Logistics departments create the job plan which contains
the following:
1. Sales order
2. Shipments
3. Local fabrication
4. Free zone storing capacity
In case the customer takes orders for existing products or services which the customer selects
from a catalogue, no special planning may be needed other than the creation of work orders.
7.4 Customer related processes

The company has established formal procedures to review and record all
enquiries and orders to ensure that all contractual requirements are defined
and can be met (tender evaluation). Where necessary, enquiries are
discussed with the customer and the resolution recorded. Subsequent orders
are reviewed to ensure that:
a. Product requirements are defined
b. Any additional or charged requirements are identified and resolved with
the customer
c. The work-load is planned taking account of such issues as time
constrains, resources and specified requirements. Order amendments are
treated as part of the on-going process control and appropriate records are
maintained. To ensure that the contract requirements are adequately
defined, Lufkin established the following:
1. The conditions of use are clearly specified within the standard operating
and maintenance manual.
2. The requirements are specified in terms of the features and
characteristics that will make the product and the service fit for its
intended use.
3. The quantity, price and delivery are specified.
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7.5 Review of customer requirements
Lufkin sales department established a process for customer requirements

review. The process is named as “SS01 contract review”. These processes
review the customer requirements before acceptance the order to make sure
that the company has the capability to meet customer requirements. Lufkin
sales team review customer requirements prior to the decision or
commitment to supply a product to the customer (e.g., submission of a
tender, acceptance of a contract or order)., because The acceptance of a
contract is a binding agreement on both sides to honor commitments.
Therefore, the period before the submission of a tender or acceptance of a
contract or order is a time when neither side is under any commitment and
presents an opportunity to take another look at the requirements before legal
commitments are made. Customers will convey their requirements in various
forms. Many organizations do business through purchase orders or simply
order over the telephone or by electronic or surface mail. Some customers
prefer written contracts. Others prefer a verbal telephone agreement.
However, a contract does not need to be written and signed by both parties
to be a binding agreement. Careful examination of customer needs and
expectations is needed in order to identify all the essential product
requirements. Regulatory requirements may apply to health, safety and
environmental compatibility and these often require accompanying
certification of compliance. Lufkin provides a certificate of compliance with
its products shipped to customers.
7.6 Contract amendment

An order or contract amendment is a change that corrects errors, rectifies
ambiguities or otherwise makes improvements. As orders and contracts are
primarily a source of reference, it is necessary to ensure that only agreed
amendments are made and that any provisional amendments or disagreed
amendments are not acted on or communicated as though they were
approved. Otherwise, the basis of the agreement becomes invalid and may
result in dissatisfied customer or an organization that cannot recover its
costs. In SS01, Lufkin introduced the procedures of amending any
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ambiguities within the contract or within the order before acceptance

because Lufkin is seeking to achieve customer satisfaction.
7.7 Lufkin order processing (SS02)

Lufkin established effective order processing process to deal effectively with
all customer’s order, contracts, enquiries or any other requirements. As
previously mentioned, requirements determination has been established by
communications between the customer and Lufkin sales officers, contract
and order review has been established also by Lufkin sales team in addition
to the participation of all other management team, so, it is effective to
establish the order processing system which include the following
 Order or contract registration
 Order or contract acknowledgement -------- informing the customer that
the order has been received and that the company intends or does not
intend to offer a bid or supply a product or service.
 Requirements determination
 Requirements review
 Order or contract acceptance
 Order or contract communication
7.8 Purchasing
The company’s policy on purchasing is to ensure that suppliers are able to perform
effectively. Appropriate records are maintained. New suppliers are assessed by placing a trial
order, except where the supplier is specified by the customer. A vendor Approval form is
completed for each supplier. There are four key processes in the procurement cycle which
should be managed effectively.
1. The specification process which starts once the need has been identified and ends with a
request to purchase.
2. The evaluation process which starts following the request to purchase and ends with the
placement of the order or contract.
3. The surveillance process which starts following placement of order or contract and ends
on delivery of supplies.
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4. The acceptance process which starts following delivery of supplies and ends with entry
of supplies onto the inventory or acceptance by the final receiver then payment of
invoice.
In Lufkin the purchasing process is divided into the following sub processes:
Supplier evaluation for all local, international, transportation and shipping
suppliers and we have approved supplier list from the headquarters for
international vendors
PL-1 supplier management
PL-2 local purchasing
PL-3 international procurement
PL-4 shipping management
PI-5 transportation services
PI-6 facility maintenance management
PI-7 Administration
7.8.1Lufkin purchasing process
Procedure
1. Evaluating and selecting suppliers
All new suppliers are evaluated prior to being placed on our approved vendor
list by placing a trial order. The vendor must be approved by the top
management represented by the general manager, prior to a purchase order
being issued and this for the purchasing special materials affecting the
customer’s processes.
2. Supplier Evaluation Criteria
Criteria used for evaluating suppliers include:
- Years in business
- Type of business
- Review of sample products
- Review of pricing
- Review of delivery capability
- Review of payment terms
- Review references from other business
3. Periodic Re-evaluation of Vendors
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Supplier tracking information is reviewed during Management Review meetings to monitor

vendor performance. The Managing Director may remove a vendor from the ‘approved’ list if
the supplier’s performance is deemed unacceptable.
4. Issuing Purchase Orders (PO)
Only those employees who have been trained in this procedure may purchase goods and
services from outside suppliers. Purchase orders are issued using the computer system. No
verbal purchase orders used. Purchase orders contain the following information, at a
minimum:
- Purchase order number
- Supplier name, address, phone number
- Date issued
- Payment terms
- Shipping method
- Quantity of items ordered
- Part numbers of items ordered (if applicable)
- Description of items ordered
- Pricing of items ordered
- Delivery requirements
- Signature of buyer
PO’s may be sent to suppliers via fax, mail or email. Buyers may advise a supplier of a PO by
telephone in addition to the written PO being sent.
5.Verification of purchase products:

 Lufkin established the procedure (FZ-08) for inspection of all the purchased products. The
procedure of inspection and verification of the incoming product uses the approach of
decision based on facts, which states that all purchased products especially those which
affects the provision of Lufkin products or services should be verified before storing in
Lufkin warehouses and before shipping to the customer.
 Sequence of receiving inspection:
1. Receiving inspection is performed on all incoming shipments, consisting of a
visual inspection checking the following:
2. Verify product numbers, description and quantities match purchase order.
3. Verify vendor paperwork accurately matches shipment
4. Product and packaging are free of damage
5. Quality checks
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6. Evidence of receiving inspection is provided by the receiver writing ‘received’ then

initialing and dating the vendor packing list. Product received and accepted by the
Company is identified with a number unique to each product. Only inspected and
accepted products are put into the storage area. Nonconforming product is placed in the
‘HOLD’ area. Receiving personnel enter the received shipment information into
computer system (where PO generated). The received PO is attached to the packing slip
and given to the Accounting department, where is kept on file.
7.4.1 supplier management
The process for selection of suppliers varies depending on the nature of the products and
services to be procured. The more complex the product or service, the more complex the
Process. In Lufkin, the process of supplier evaluation has been put into effect to control the
major suppliers and the criteria to choose the suppliers depends on the following”
1. Quality of goods ( A)
2. Delivery time keeping ( B)
3. Meeting quality requirements (C)
4. Prices (D)
Final evaluation is carried out according to the following equation
E: the supplier performance = A+B+C+D

E
Final evaluation equation F = ______________________________
Total number of supplies per year

7.7 product identification and traceability
 Lufkin has established a framework for identification and traceability of
all key activities and services.
 All contracts are uniquely numbered for their inception to their
completion. all incoming and outgoing correspondence is identified with
unique number on BAAN system.
 All assets or material purchased for or on behalf of Lufkin are identified
with a unique number given by Baan system which is used within
Lufkin corporate and its affiliates.
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7.9 Planning service provision
Once the service order has been created, operation manager initiate service quality plan which
include the following:
 Define the service objectives and targets;

 Define the stages in the process to achieve these objectives;
 define the inputs and outputs for each stage in the process;
 Define the resources required to generate these inputs and outputs;
 Define the methods to be used to operate any equipment and generate the inputs and
outputs;
 Define the methods of measuring stage outputs;
 Define the methods of ensuring the integrity of these measurements;
 Define the information and resources required for each stage to be performed as
planned;
 Define the actions to be taken when problems are encountered;
 Define the information provided to service users that indicates the operation and
availability of the service; and
 Define the precautions to be observed to protect health, safety and environment
7.8 Operational control
Lufkin Rules and procedures (HSE written programs and operations control)
This clause of OHSAS 18001 and ISO 14001 relates to the actual
performance of tasks to which OHS hazard and risk is attached, and for
which controls may be needed to eliminate or control risks. Essentially
operational controls are developed from the outcome of risk assessment.
Operational controls can take many forms and can include training,
preventive maintenance or documented procedures. The need for separate
procedures, work instructions, safe systems of work etc., as a means of risk
control needs to take into account the risk levels and the competence level of
the personnel involved. All activities that affect the IMS are planned and
controlled through system documents, which contains enough information
so that staff can perform a task correctly under normal or abnormal
operating conditions including emergency situations.
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For those operations and activities, the organization shall implement and
maintain:
 operational controls, as applicable to the organization and its activities;
 the organization shall integrate those operational controls into its
overall OH&S management system
 controls related to purchased goods, equipment and services
 controls related to contractors and other visitors to the workplace
 documented procedures, to cover situations where their absence could
lead to deviations from the OH&S policy and the objectives
Lufkin set approved manual for operations and safety to be applied by skilled
operators. It includes all safe work procedures concerning installation,
maintenance and operating Sucker rod units in oilfields. These rules and
procedures had been developed on the basis of site job requirements and any
applicable regulatory requirements and also according to Lufkin Middle East
risk assessment techniques. These approved manuals are as follows:
Mark 2 pumping units
Conventional & reverse Mark pumping units
All other manuals for installation , maintenance and operations
In addition to manuals, Lufkin implemented process picture mapping for all

processes in the field to make sure that all processes are carried out in the
outmost safety as follows:
1. OFS-BAK- 001 horse head removal
2. OFS-BAK- 002 walking beam removal
3. OFS-BAK- 003 equalizer removal
4. OFS-BAK- 004 pitman arm removal
5. OFS-BAK- 006 counter weight removal
6. OFS-BAK- 008 wire line removal
7. OFS-BAK- 009 stroke length change
8. OFS-BAK- 025B inspection of pumping units
9. OFS-BAK- 012 gear reducer
10. OFS-BAK- 012A gear reducer installation
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11. OFS-BAK- 014 Motor swap

12. OFS-BAK- 015A remove unit ladder
13. OFS-BAK- 015 install unit ladder
14. OFS-BAK- 025 inspection pumping unit
15. OFS-BAK- 026 balance of unit
16. OFS-BAK- 031A well pump Respace off
17. OFS-BAK- 031B well pump Respace on
18. OFS-BAK- 037 wrist pin knockout tool
19. OFS-BAK- 043 wireline shop saw operation
20. OFS-BAK- 044 Torque gun operation
Operating criteria should be specific to the Lufkin, its operations and

activities, and be related to its own OH&S risks, where their absence could
lead to deviation from the OH&S policy and objectives. Equipments having a
direct effect on the HSEQ are properly maintained in order to ensure
integrity of its process capability.
Operational controls should be reviewed on a periodic basis to evaluate their
ongoing suitability and effectiveness. Changes that are determined to be
necessary should be implemented. In addition, procedures should be in
place to determine circumstances where new controls and/or modifications
of existing operational controls are needed. Proposed changes to existing
operations should be evaluated for OH&S hazards and risks before they are
implemented.
When there are changes to operational controls, the organization should
consider whether there are new or modified training needs. All equipment
shall be subject to receiving inspection and calibration/ maintenance where
applicable. Only equipment which has been authorized for use by the
appropriate supervisor and functional manager shall be used in the relevant
processes.
Functional manager shall ensure that functional operating procedures and
system safety rules to use for concerned operations are clearly defined,
communicated and implemented.
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Functional manager shall ensure that only competent personnel operate the
concerned equipment and appropriate documented operating procedures are
available for reference.
Non conformance shall be reported to the functional manager (supervisor)
and corrective action implemented. Non conformance and consequent
corrective action shall be recorded on a corrective/ preventive action report
(CPAR).According to our scope of work, Lufkin Middle East have
implemented the following safe job procedures and written programs:
1. Hazard identification and risk assessment ( LHS 01)

1. Defensive driving for all Lufkin employees. ( LHS 02)
2. Hydrogen Sulfide ( H2S) safety program (LHS 03 )
3. Lockout/ Tagout. (LHS 04)
4. Confined space. (LHS 05)
5. Electrical safety. (LHS 06)
6. High voltage safety. (LHS 07)
7. Hot work& (LHS 08)
8. Fire prevention and fire protection. (LHS 09)
9. Lifting. (LHS10)
10.Fall control and fall prevention. ( LHS 11)
11.Heat stress. ( LHS 12)
12.Incident reporting and investigations. ( LHS 13)
13. Personal protective equipment PPE ( LHS 14)
14.Emergency response plan ( LHS 15)
15.EHS site inspection ( LHS 16)
16.EHS audit ( LHS 17)
7.9 Customer property

All applicable customer properties including personal information are filed and saved in a
secure system to avoid any damage or loss and the system is periodically checked.
7.10 Control of service provision
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For each type of service provided by Lufkin, relevant procedures, methods, instructions are
available, prescribing tests or controls, statistical control requirements.
Functional managers (operation manager and supervisor) shall ensure that :

 Competent person are to be delegated for the job, which could directly / indirectly
affect the HSEQ performance. All possible measures are to be taken to ensure that
the proper operation of any specified activity is performed. All possible measures
are to be taken to ensure that the proper operation of any specified activity is
performed as per IMS procedures.
 Adequate information about HSEQ requirements are provided to the concerned
employees/ suppliers to deliver Lufkin services as planned.
 The process is controlled through careful checks for monitoring at the subsequent
stages. Monitoring is performed at those critical stages of the process that could
affect the quality of Lufkin services.
7.11 Validation of processes for service provision

Special processes ( pumping installation, services, maintenance, punching,…etc) are
Included.
Whenever the resulting output cannot be verified by subsequent monitoring prior to the
service realization, such processes will be validated by any of the below means:
 Establishing and adapting the qualification& competence criteria for those
performing special processes such as automation engineers.
 Standardization of work methods, procedures and adapting the same while
performing special processes.
 Wherever special processes are performed by the contractors of any outsourced
parties, they shall follow Lufkin guidelines of standardization of work methods and
procedures.
7.12 Preservation of products

 Lufkin has a process to ensure that material and documents critical to the service are
Handled, stored, packaged, preserved and delivered to prevent damage or
deterioration.
 Storage areas shall be designated and controlled for all materials and equipment.
These areas shall ensure protection against any damage or deterioration to stored
items.
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 All materials, chemicals and hazardous materials / chemicals/ equipment being stored
within Lufkin shall be recorded, adequately stored, segregated and protected to
achieve adequate preservation.
7.13 Control of monitoring and measuring equipments

 Any monitoring, measuring equipment used to demonstrate the conformance of
servicing, HSEQ performance measurement shall be controlled.
 All external calibration facilities” if required shall be assessed for suitability.
Internal calibration shall be performed by qualified personnel. Any external
calibration facilities or internal calibration facilities shall be traceable to national,
international or manufacturing standards.
 The procedures shall define accuracy, frequency, standard, equipment type,
environment and acceptance criteria.
 Results of calibration/ verification shall be recorded and maintained. Each
equipment shall show its status of latest calibration. Any defective equipment shall
be withdrawn for repair or disposal.
7.14 Emergency preparedness and response

Lufkin has established a procedure for ensuring that the emergency response plans in
place to respond at any time to potential incidents, emergency and hazardous situation
involved in its operations for preventing and mitigating the environmental impacts as
Well as the consequences of health & safety risks that may be associated with them.
 The objectives of emergency preparedness are to ensure effective response to
emergency situation by specific planning and training.
 The emergency response procedures detail the company’s activities for both types of
emergency situation: environmental and safety & health such as major incidents, fire,
etc.
 The staff concerned has the obligation to comply with Lufkin safety rules when they
perform works on company’s site.
 In order to ensure that Lufkin personnel are fully prepared to take appropriate response
actions for all the identified emergency situations, the response actions will be
prepared at periodic intervals, where appropriate.
 Emergency response and exercises are conducted at regular intervals to ensure
applicability of the emergency response procedures and readiness of all Lufkin
personnel. The drill shall be conducted in Lufkin office and free zone twice a year.
Drill and exercise reports are documented and recorded.
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 Lufkin management shall review, where necessary its emergency preparedness and
response procedures, in particular after the occurrence of emergency situations. The
management will also periodically test such procedures where applicable.
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8.0 Division 8
Measurement, analysis and improvement
8.1 General
It is policy of the company to monitor, analyze and improve the performance

of the products, processes and the Integrated Management System (IMS),
occupational Health and safety management system and also environmental
management system. This section describes how we define, plan, and
implement the monitoring, measurement, analysis and improvement
activities needed to assure product and IMS conformity and achieve
continual IMS improvement. These activities include assessment of customer
satisfaction, conduct of internal audits, process monitoring and
measurement, and product monitoring and measurement. Lufkin has established
several procedures to monitor and measure, in a regular basis several procedures their
HSEQ performance:
1. HSEQ performance
2. services delivered
3. process performance
4. customer satisfaction
5. Evaluation compliance with applicable HSEQ legal and other
requirements.
6. incidents ( including near misses)
7. key characteristics of identified operations that have significant HSE
impacts
8. occupational ill-Health
8.2 Monitoring and measurement of Customer satisfaction
Customers are the reason we exist and drive our quality policy “to meet or
exceed customer requirements.” The Sales Manager has overall
responsibility for identifying and reviewing customer requirements and for
monitoring and measuring customer satisfaction per procedures
contained Data collected by customer contact personnel during routine
communications provide our primary basis for assessing customer
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satisfaction. Sales personnel and Customer Service staff utilize

satisfaction survey to ascertain the customer’s overall perception of how
well we are meeting their requirements and to document any
recommendations for improvement. Customer complaints (whether
received in writing, verbally or electronically) are immediately forwarded to
appropriate Sales or Customer Service personnel for action. If these
personnel cannot resolve the issue to the customer’s satisfaction, then the
complaint is transferred to the Sales Manager for assignment to another
appropriate manager or function for resolution. Customer complaints are
documented and monitored through resolution through our continual
improvement system; Section 8.5. Customer survey data along with other
customer feedback (including written or verbal complaints and
information collected from is reviewed daily by Sales personnel and
Customer Service staff to initiate any improvement or
corrective/preventive actions needed. The Sales Manager periodically
reviews customer satisfaction survey data and other customer feedback
(including complaints), as well as progress towards achievement of
corporate level customer satisfaction improvement objectives and provides
related recommendations for review by Top Management
8.3 monitoring and measurements of processes

suitable techniques have been implemented at the relevant stages for
continuous measurements and monitoring of processes. The
management monitors and measures the IMS processes through the
collection of data related to customers, suppliers, internal audits and
evaluate continuous improvements and will discuss at defined
intervals in management review meetings.
8.4 evaluation of compliance with HSEQ legal and other requirements

with consistent with its commitment to compliance with HSEQ legal
and other requirements as stand in the company policy, Lufkin
evaluate the compliance with applicable legal and other requirements
periodically at one of the measurements of performance of the
management system. Records of the results of periodic evaluations
are kept to demonstrate their compliance.
8.5 control of non-conforming services and products
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The company ensures services do not conform to requirements are

controlled to prevent unintended use or delivery. The controls and
related responsibilities and authorities for dealing with non –
conforming services are defined and documented.
The non-conforming services or products are dealt by taking actions
to eliminate the detected non-conformity.
Records of non-conformity and any subsequent actions are
maintained. Any non- conforming services that have been corrected
are subjected to re- verification to ensure conformity to the
requirements.
Supporting document: OQR procedures for non-conforming,
corrective and preventive actions.
8.6 Monitoring and measuring of HSE aspects

8.7 incident investigation, non-conformance, corrective& preventive
actins
To implement IMS management principles, a system of ongoing
improvement must be incorporated. If a potential or actual non-conformity
(including incidents) with a quality or health, Safety & environment
system found, suitable corrective/ preventive action shall be taken as a
result of root cause analysis. Procedures have been established and
maintained to define responsibility and authority for the handling and
investigating of incidents, nonconformities / potential non-conformities
and taking actions to mitigate any impact hazards caused pertaining to
the IMS.
All non- conformities and incidents must be reported to MR and

functional manager. The cause of all non-conformances, potential non-
conformities, incident, near misses, system non-conformities and damage
to the environment are investigated and acted suitably.
The effectiveness of corrective and preventive actions must be verified by
MR and functional manager.
Various source soft information are analyzed to detect potential causes of
non-conformities. Appropriate corrective/ preventive actions need ed to
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eliminate the non-conformities or potential non-conformities are

determined and implemented.
It is ensured that corrective and preventive actions are taken and are
effective in dealing with the problem. Any changes arising from corrective
and preventive actions are implemented by revising our IMS documents.
The corrective and preventive actions taken are included as an agenda
item at management review meetings.
Lufkin should establish, implement and maintain procedures to monitor

and measure OH&S performance on a regular basis. This procedure and
guidance information has been developed to identify key performance
parameters for HSE performance across the whole Lufkin's sites. A
program for the inspection of hazardous conditions is an essential part of
any active monitoring program. It is one of the best tools available to find
problems and assess their risks before accidents and other losses occur.
According to Lufkin policy we shave two types of monitoring
Proactive monitoring which is checking the achievement of objectives and

the extent of compliance with pre-set standards. Reactive monitoring
which is investigating, analyzing and recording HSE Management System
failure including accident, incidents, ill-health and property damage
cases. Monitoring of HSE aspects associated to activities carried out by
Lufkin Middle east shall address, at a minimum, the topics here below
summarized.
A plan to monitor HSE aspects associated to activities carried out by Lufkin
activities, including Contractors and subcontractors activities, shall be
defined and implemented. Monitoring activities to be reported in the plan
shall be identified taking into consideration at a minimum:
 The results of environmental review and risk assessment (see guidelines

“Environmental Impacts in Normal Operating Conditions” and “HSE
Risk Assessment”);
 Legal and non-legal requirements;
 HSE provisions reported in permits, licenses or authorizations required
to operate;
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 Requirements reported in the HSE IMS operational guidelines.

 Management of NC, Incident investigation, corrective and preventive
actions.
 Management of NC, Accidents, CA and PA shall address, at a minimum,
the topics here below
Whoever detect a situation of potential NC, is witness to or involved in an
Accident shall notify the site supervisor, the foreman and operational
Manager. Operations manager shall do the following:
 Depending on the nature and magnitude of the NC/Accident/Near-
miss, evaluate if an immediate response to restore normal conditions is
necessary and, should this be the case, implement the required actions;
 Depending on the nature and magnitude of the NC/Accident/Near-
miss, evaluate the applicability of the Site emergency plan (see
guideline “Emergency response”) and, should this be the case, act in
compliance with the requirements therein reported;
 In case of an event causing injuries on personnel, ensure that medical
assistance is provided according to the requirements set in the
guidelines “First Aid”;
 Record the NC/accident via a standardized form and send it to HSE
manager depending on its nature and level of application of the
NC/Accident/Near-miss notification standardized form shall include, at
a minimum, the following specifications
Notification and reporting: the following data should be defined

1. Date of the incident/NC
2. Report date
3. Detail of the accident
4. Name of the location
5. Contributing factors of the incident/NC
6. Detail of injury and classification criteria
7. Corrective measure
8. Preventive measure
Classification
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After having received the Notification form, HSE Manager shall proceed to
classify the NC/Accident/Near-miss according to the following criteria:
1. Accident shall be classified according to the consequences categories
listed in “HSE Risk Assessment”;
2. High potential Near-miss = Near-miss whose potential consequences, in
terms of magnitude and severity, would have been critical;
3. Minor Near-miss = Near-miss whose potential consequences, in terms
of magnitude and severity, would not have been critical.
4. Major NC, non-conformity with respect to applicable legislation or with
respect to the HSE requirements affecting negatively the HSE efficiency
and effectiveness.
5. Minor NC, non-conformity with respect to the HSE requirements not
affecting the HSE efficiency and effectiveness.
Investigation
Root causes of the NC/Accident/Near-miss shall be investigated in order to
identify the proper CA/PA. Investigation and CA/PA definition shall include
the following actions:
1. Creation of an investigation team that shall incorporate the technical
and management skills adequate to the nature of the
NC/Accident/Near-miss;
2. Review of the NC/Accident/Near-miss circumstances;
3. Control of equipment and procedures or other data;
4. Interviews with witnesses and concerned personnel .
Depending on the severity of the NC/Accident/Near-miss, potential needs to
take pictures to record to support CA/PA identification shall be evaluated.
8.3 Internal audit

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The Internal Audit Process ensures that requirements of the ISO 9001
Standard are being satisfied and that the quality system requirements are
being consistently and effectively followed and maintained. The management
representative is responsible for the effective deployment and management of
this process. An audit schedule is prepared on an annual basis. The
schedule identifies a series of planned audits that will ensure that all
processes and ISO requirements are audited at least once a year. The audit
schedule is modified, as needed, to take into account the status and
importance of the processes, as well as the results of previous audits.
The MR plans individual audits by assigning qualified and competent
auditors to each scheduled audit, ensuring that the selected auditors are
objective and impartial. Auditors will never audit their own work. Auditors
are deemed qualified by the Lead Auditor, who is based on completed
training and/or actual audit experience. Training records are maintained to
document the basis for qualification.
The audit plan specifies the assigned auditors, the audit criteria, the scope
and, if applicable, the methods to be used for the audit. All detected non-
conformities and observations are brought to the attention of the manager
responsible for the area being audited through a PCAR that is submitted to
the PCAR process for follow-up and timely corrective action. All audit non-
conformances must be investigated for root cause identification and the
subsequent implementation of corrective action. Observations shall also be
documented on a PCAR form and submitted for consideration by the
management for possible preventive action. Follow-up actions are reviewed
for all non-conformities, as required, to verify that corrective actions were
taken and that the actions were effective in addressing the non-conformance.
The Quality Coordinator confirms all non-conformities are corrected and
closes the PCAR.
The Lead Auditor is responsible for reporting the results of internal auditing
including verified actions during quarterly Management Review meetings.
.
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Internal audits are conducted in accordance with a published schedule that

identifies the audit scope and frequency. Each of our key QMS processes,
with a special emphasis on our ‘core’ customer oriented processes and our
unique product realization processes is reviewed to determine effectiveness.
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The schedule is updated on the basis of status and importance of the activity
to be audited and previous audit results.
The Quality /HSE Manager maintains all internal audit records, including
internal auditor training records, results of internal audits and related
follow-ups; periodically reviews internal audit results as well as progress
towards achievement of corporate level objectives aimed at improving overall
QMS effectiveness and provides related recommendations for review by Top
Management;
Supporting documents: QP03
: QP03/F01
: QP03 /F02
: QP03 / F03
8.5 Monitoring and measuring processes
We apply suitable methods for monitoring and measuring all QMS/ HSE
processes. QMS processes depicted in 4.1 are documented, measured,
controlled and evaluated to ensure they are effective (i.e. achieve desired
results) and to identify opportunities for improvement. At a minimum,
managers with overall responsibility for carrying out a QMS process,
analyzes process performance and takes appropriate improvement, corrective
or preventive action (Section 8.5). We conduct process oriented internal
audits (Section 8.2.2) to verify QMS process conformance and identify
opportunities for improvement.
Processes are monitored by process operators per applicable instructions

and procedures. Significant process events, such as tool change or machine
repair are recorded. Operations personnel follow documented reaction plans
when processes become unstable or no longer capable. As required, the
corrective action plan is reviewed with and approved by the customer
8.6 Analysis of data
ISO 9001:2008, OHSAS 18001and ISO 14001 requires the company to

gather data that show characteristics and trends about processes, products
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and opportunities for preventive action. In order to identify opportunities, the

company monitors trends in the following activities.
1. incident/accident records
2. Customer satisfaction
3. Customer complaints
4. Quality Concern reports
5. Supplier performance
Management Review uses this data to assess the effectiveness of IMS .Top
Management and other officers, managers and supervisors collect and
analyze data using appropriate statistical techniques to determine the
suitability and effectiveness of key IMS processes against the overall KPIs
applicable to their area(s) of responsibility and to identify opportunities for
improvement. At a minimum, data is analyzed to assess achievement of the
corporate level quality objectives.
8.7 Continual improvement

The company is committed to a policy of continuing improvements in its
methods and the services supplied to clients. An important element is to
analyze any problem that may occur with a view to long term prevention. The
continual improvement process begins with the establishment of our quality
policy and objectives for improvement, based on objectives contained in our
Business Plan and customer targets/goals. Customer satisfaction, internal
audit, process and product performance data, and the cost of poor quality
are then compared to progress against objectives to identify additional
opportunities for improvement;
The overall effectiveness of continual improvement program (including
corrective and preventive actions taken as well as the overall progress
towards achieving corporate level improvement objectives is assessed
through our management review process.
Essentially, such actions are effective if the problems corrected do not

reoccur, potential problems identified do not occur, and other improvement
actions accomplish the desired results or objectives. Inputs to the
management review process are used to establish new/changed
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improvement objectives and to initiate/prioritize additional improvement

actions; Section 5.6.
The Quality/HSE Manager has overall responsibility for establishing and
implementing an effective continual improvement system which includes
improvement actions, and corrective and preventive actions.
8.7.1 Corrective actions

The company operates procedures for handling internal problems, accidents
and nonconformities, and customer complaints. Concern reports detail the
action taken, and discussion take place to consider any long term
implications. The Quality/ HSE m Manager has overall responsibility for
managing our corrective action process defined in the manual, Evidence of
nonconforming product, customer dissatisfaction, incidents and accidents
which cause injury or loss or ineffective processes is used to drive our
corrective action system because a problem exists requiring immediate
correction and
possible additional action aimed at eliminating or reducing the likelihood of
its recurrence. Management with responsibility and authority for corrective
action are notified promptly of product or process non-conformities.
Investigating and eliminating the root cause of these failures is a critical part
of our continual improvement process.
Follow-ups are conducted (through the internal audit process; to ensure that
effective corrective action is taken appropriate to the impact of the problem
encountered. In addition, the Quality/ HSE Manager summarize and analyze
corrective action data to identify trends needed to assess overall effectiveness
of the corrective action system and to develop related recommendations for
improvement. The corrective action system is considered effective if specific
problems are corrected and data indicates that the same or similar problems
have not recurred. Results of this analysis and related recommendations are
presented to Top Management for review and action during management
reviews;
Supporting documents : QP 02200

: QP04F01
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8.7.2 Preventive actions

Preventive action is addressed in a number of ways:
1. The IMS procedures incorporate various checks to ensure that potential
problems are identified, recorded and resolved.
2. An important aspect of the internal audit process is the recording of
Observations to highlight potential problems and possible
improvements.
3. Where possible, applying Corrective Action solutions to other areas of the
business. The effectiveness of actions taken is monitored through the
analysis of subsequent performance. This is reviewed periodically and
considered at Management Meetings.
The Quality/HSE Manager has overall responsibility for managing preventive
action process and summarized below:
Data from internal audits, customer feedback, employee suggestions, and
other appropriate data is collected and analyzed to identify the actions
needed to eliminate the causes of potential problems and thereby prevent
their occurrence. Investigating and eliminating the root cause of potential
failures is a critical part of our continual improvement process. We review
and initiate preventive actions through our preventive action process. We
apply controls and follow-up to ensure that effective preventive action is
taken appropriate to the risk and impact of potential problems and losses. In
addition, the Quality/ HSE Manager summarizes and analyzes preventive
action data to identify trends needed to assess overall effectiveness of the
preventive action system and to develop related recommendations for
improvement.
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5.7 management review

5.7.1 General
All management team attends the management review meetings. The
management review is conducted by the general manager and management
representative. In Lufkin Management Reviews is being conducted on
monthly basis. This is to ensure continuing suitability and effectiveness of
IMS to meet Quality Policy & objectives. In IMS implementation phase the
Top Management conducts a management review meeting the first Sunday of
each month to ensure the continuing suitability, adequacy, and effectiveness
of our QMS/ EHS in accordance with procedures detailed in manual. The
primary outputs of management review meetings are management actions
taken to make changes or improvements to our QMS and the provision of
resources needed to implement these actions.
5.7.2 Management Review inputs

The management review meeting includes a review of IMS quality policy and
objectives, all applicable requirements of the QMS, related performance
trends and opportunities for improvement, follow-up actions from earlier
management reviews, and results of self-assessments, and strategic or
operational changes that could affect the QMS. At a minimum company level
improvement objectives documented in prior management reviews are
reviewed for status and continuing suitability. As a minimum, the following
items are discussed:
1. Results of internal and external audits and Follow up actions on

previous management review minutes
2. Incident reviews
3. Legal compliance
4. Customer feedback (compliments and complaint)
5. Quality control issues
6. Corrective and preventive actions
7. Follow-up actions from previous meetings
8. Changes that could affect the QMS
9. Recommendations for improvement.
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5.9 Management review outputs

Results of management review meetings are recorded and maintained by the
Quality Manager/ HSE and management representative. The output from the
management shall include any decisions and actions related to:
1. Improvement of the effectiveness of the IMS

2. Improvement of the product related to customer requirements.
3. Improvement for the effectiveness of QMS/HSE and its processes.
4. Improvements related to customers’ requirements.
5. Resources needed to carry out identified improvements.
Minutes of Management Review meetings shall be recorded and
circulated for improvement of QMS and corrective /preventive actions
6. Resource needs.
In addition to the above, many other forums exist for review of performance,
such as Board meetings, Centre wise Periodical Performance Review on
various relevant aspects including financial Performance, physical
performance to provide directions for improvements. Timely actions on
decisions taken shall be ensured and followed up at suitable levels.
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Lufkin Environmental Aspects and Impacts Register

An environmental aspect is any element of Lufkin’s activities, products or
services that can interact with the environment. A significant environmental
aspect is an environmental aspect that has or can have a significant
environmental impact. An environmental impact is defined as any change to
the environment, whether adverse or beneficial, wholly or partially resulting
from Lufkin’s activities, products or services. This section outlines Lufkin’s
procedure to identify environmental aspects and maintain a register of these
aspects. These procedures apply to all planned and ongoing Lufkin activities
in the Permits in which it operates.
Lufkin Environmental Assessment Impact
As part of the overall risk management approach to operations, Lufkin shall
establish a methodology for:
 Environmental Aspects and Impacts Register
 Environmental Objectives and Targets
 Environmental Objectives and Targets
 Pumping unit installation Environmental Objectives and Targets
 Environmental Plans
Environmental screening
An Environmental Screening is performed, basically, for activities whose
potential impacts are marginal. These impacts are site-specific, usually
reversible and in most cases mitigation measures can be designed in
advance. The Environmental Screening should be carried out in order to:
1. describe the environmental sensitivity of the area affected by the
project;
2. provide an analysis of the main case histories related to projects that
caused similar HSE issues and/or impacts;
3. Provide an analysis of the potential significant HSE hazards related to
the projects.
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Environment impact assessment

An Environmental Impact Assessment (EIA) report is a tool aimed at
identifying and assessing potential environmental impacts of a proposed
project on the relative area of influence, at evaluating alternatives and at
designing appropriate mitigation, monitoring and management measures.
An EIA report is carried out in order to
1. define specific legislative constraints: systematic examination of all
relevant applicable legislation and associated codes of practice, all
current and applicable standards and all contractual agreements;
2. identify key environmental sensitivities in terms of nature conservation
value or local interest, relevant to the area involved in the project
analyze the project’s environmental disturbance on the receiving
environment and the significance of the environmental effects, using
predefined acceptance criteria;
3. Indicate actions to avoid and/or reduce environmental impacts,
identifying mitigation measures and designing proper methods to
monitor environmental effects.
Waste management
Responsible and effective waste management seeks, in a structured manner,
to minimize the risk of HSE incidents and liabilities which may be caused by
waste. A very important process of waste management is the periodical and
systematic review of the principles to prevent, reduce, reuse and recover
waste material. Equally important is the structured assessment of potential
HSE hazards and effects.
Usually the risk of liability can be eliminated or substantially reduced if
waste is transferred to duly authorized, certified and regularly audited waste
transporters and disposal facilities in accordance with applicable legislation.
If elimination of waste is not possible, then method to minimize the amount
of waste generated are investigated. The reduced amount of waste is
dedicated for specialized responsible company for disposal. Lufkin has
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issued a contract with Specialist Company for waste disposal for disposing
the oil contaminated rags.
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LUFKIN MIDDLE EAST

Lufkin Middle East Integrated

Dave Kennedy, President Date

Anthony Beck, Vice President Date

REVISION AND APPROVAL RECORD

Revision Description Approved By Date

LUFKIN MIDDLE EAST FREE ZONE

Lufkin Middle East Free Zone Company is the

LUFKIN MIDDLE EAST FREE ZONE

It is Lufkin’s policy to provide the highest quality

LUFKIN MIDDLE EAST FREE ZONE

1. It is Lufkin’s policy to provide the highest quality

Dave M Kennedy Anthony (Tony) Beck

LUFKIN MIDDLE EAST FREE ZONE

Dave M Kennedy Anthony (Tony) Beck

LUFKIN MIDDLE EAST QHSE CULTURE

Lufkin Middle East HSE Culture:

QHSE, is a line management responsibility, requires visible

Dave M Kennedy Anthony (Tony) Beck

Lufkin Corporate Organisation Structure

John F. (Jay) Glick

Brian J. Gifford Alejandro Cestero C. D. “Bud” Hay

1.0 Knowledge about the company

Lufkin Industries Inc. is a pioneer company that designs, engineers,

Lufkin Middle East respects and applies all regulatory requirements

2.0 Integrated Quality/HSE Management systems

2.1 Scope and Purpose

The system requirements of this manual aimed at achieving customer

2.2 General requirements

Lufkin QHSE is that part of overall management system which establishes,

Lufkin Management identified the company’s ‘core’ business processes”

Lufkin Middle East developed ‘Management Oriented Processes’, or MOPs,

2.3 Permissible exclusion:

Sub-clause 7.3 of design and development

As Lufkin is establishing integrated QMS/EMS management system, SO, the company is

1. ISO 9001: 2008 Quality management system- requirements

2.5 Terms and definitions

Interested party person or group, inside or outside the workplace (3.23),

Risk, combination of the likelihood of an occurrence of a hazardous event or

combination) the creation, emission or discharge of any type of pollutant or

3. 0 Lufkin Integrated management system (IMS)

Lufkin Middle East Business plan

Taking the PDCA cycle as a reference led to the identification of the

5. Identification, dissemination and periodical updating of the legal and

By the application of the rule of PDCA on Lufkin IMS QHSE management

5.Sales department takes up bid for tender

 Availability of materials, work orders ( operations department, sales

All departments, including operations, sales, logistics, and finance

 Safety department shall provide procedures, equipment’s, and audit

Corrective & preventive actions

 The non- conformities in work process shall be identified and concerned

Lufkin Quality management system

Lufkin QMS Process Mapping

The major Processes are the following:

 Receiving shipments from local markets

4.0 IMS Documentation requirements

4.1 IMS Quality/HSE Manual

4.2 Control of documents