Engineering Procedure

SAEP-66 8 May 2019

Occupational Health Hazard Assessment (OHHA)
Document Responsibility: Health Protection Standards Committee

Contents
1 Purpose and Scope .......................................... 2
2 Applicable Documents ...................................... 2
3 Objectives ......................................................... 4
4 Instructions........................................................ 4
5 Responsibilities ................................................. 8
Revision Summary................................................... 9

Previous Issue: 10 June 2018 Next Planned Update: 17 December 2020

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Contact: Arfaj, Ayman M. (arfaam0i) on phone +966-13-8800797
©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

1 Purpose and Scope

The purpose of Occupational Health Hazard Assessment (OHHA) Program is to ensure

that proactive, periodic site evaluations by the Environmental Protection Department
(EPD) take place at company proponent organizations in order to gauge compliance
against applicable government regulations and company workplace health protection
requirements.

2 Applicable Documents

Unless stated otherwise, the documents listed below shall be of the latest issue (including
revisions, addenda, and supplements) and are considered a part of this procedure:

2.1 Saudi Aramco Documents

Saudi Aramco Policy Statements

Policy INT-5 Saudi Aramco Environmental Protection Policy
Policy INT-4 Saudi Aramco Loss Prevention Policy

Saudi Aramco General Instructions

GI-0150.000 Industrial Hygiene and Occupational Health
Aspects of Environmental Protection Policy
GI-0150.001 Asbestos Hazard Management
GI-0150.100 Hazardous Materials Communication (HAZCOM)
Program
GI-0002.714 Environmental Protection Policy Implementation
GI-0002.717 Procedures & Guidelines for Handling
Polychlorinated Biphenyls
GI-0402.01 Operational Chemical Cleaning of Boilers
GI-1780.01.1 Atmosphere Supplying Respirators

Saudi Aramco Engineering Standards

SAES-A-105 Noise Control
SAES-B-069 Emergency Eyewashes and Showers
SAES-K-001 Heating, Ventilating and Air Conditioning (HVAC)
SAES-K-002 Air Conditioning Systems for Essential Operating
Facilities

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©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

SAES-K-100 Saudi Aramco Mechanical (HVAC) Code

SAES-P-123 Lighting

2.2 Government Requirements

2.2.1 Kingdom of Saudi Arabia, Labor and Workmen’s Law, Articles 128-130

2.2.2 SASO - Industrial Safety & Health Regulations in the Kingdom of Saudi
Arabia
SAS 315 Occupational Health & Environmental Control
SAS 316 Hazardous Materials, Gases
SAS 317 Hazardous Materials, Flammable and Combustible
Liquids
SAS 318 Hazardous Materials, Explosive Dusts, Explosive
and Blasting Agents
SAS 319 Hazardous Materials, Carcinogens
SAS 320 Hazardous Materials, Toxic and Hazardous
Substances
SAS 321 Hazardous Materials, Spray Finishing, and Dip
Tanks Using Flammable and Combustible
Materials
SAS 322 & 332 Personal Protective Equipment
SAS 335 Illumination
SAS 336 Welding, Cutting & Brazing

2.3 Additional Requirements

The American Conference of Governmental Industrial Hygienists (ACGIH):
Threshold Limit Values for Chemical Substances and Physical Agents and
Biological Exposure Indices
American National Standards Institute (ANSI): Performance Standards
The American Society of Heating, Refrigerating and Air Conditioning
Engineers (ASHRAE): Ventilation Standards
The Occupational Safety & Health Administration (OSHA): General Industry
and Construction Standards (29 CFR-1910/1926) & Sampling and
Analytical Methods
National Institute for Occupational Safety and Health (NIOSH) - Manual of
Analytical Methods
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©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

3 Objectives

The objective of conducting OHHAs is to protect the health of employees from

potential health-hazards found in the work environment. OHHA assessments provide
company management with assurance that appropriate control measures are in place and
that occupational health risks are mitigated. OHHA is designed to assist in the overall
management of occupational health in line with Policy INT-5, Environmental
Protection Policy, and GI-0150.000, “Industrial Hygiene and Occupational Health
Aspects of Environmental Protection Policy.”

4 Instructions

4.1 Planning Activities

4.1.1 Proponent Organization Selection and Scheduling

EPD selects facilities to be assessed during the following year based on

the level of risk, the previous assessment and the need to baseline a new
facility. The OHHA assessment cycle of specific facilities shall not
exceed five years.

4.1.2 Assessment Team Selection

EPD determines the number of assessment team members based upon

the type and complexity of facilities. OHHA Teams will be led by
industrial hygienists who have the knowledge, expertise and experience
in the field of Industrial Hygiene (IH). Under no circumstances will
inexperienced IHs conduct OHHAs independently, interpret industrial
hygiene data, or recommend control methods.

Expertise from outside EPD may be called upon to provide the OHHA
team with additional experience, perspective, or specialized technical
knowledge that will enhance the effectiveness of the OHHA
(e.g., Environmental Coordinator (EC), Process Engineer, etc.).

4.2 Pre-Assessment Activities

4.2.1 Information Request

Approximately five (5) weeks prior to the scheduled OHHA date, the
OHHA Team Lead will contact the Proponent department’s EC to notify
them of the upcoming assessment, request assessment pre-work
information (e.g., chemical inventory, process flows, etc.) and to discuss
best available dates for the initial visit and the onsite assessment.

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©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

4.2.2 Formal Notification

The EPD OHHA Coordinator will generate a formal notification letter,

including the intended onsite assessment start dates, to the proponent
department.

4.2.3 Pre-Assessment Information and Team Preparation

At the guidance of the OHHA Team Lead, members shall prepare for the
OHHA by familiarizing themselves with the facility organization and
functions; gather and review existing historical information on the
specific location(s), population, chemical inventories, process flows,
agents of potential concern, and historical IH/OHHA assessments.

4.2.4 Security/Training Requirements

Once the dates of the OHHA are confirmed by the proponent

department, the OHHA Team Leader will request the proponent to
facilitate the logistics including the requirements to access their facilities
at the time of the assessment. This may include special training and/or
gate-passes (e.g., H2S Training, Helicopter Underwater Escape Training
(HUET), etc.) OHHA Team Members must ensure they meet any
training requirements or receive an approved exception prior to the
onsite assessment.

4.3 On-site Assessment Activities

4.3.1 Opening Meeting

A formal opening meeting shall be held before the onsite assessment

commences. The meeting is organized and chaired by the Proponent
Department’s facilitator and OHHA Team Leader at the Proponent’s
facilities. In attendance at the meeting is the OHHA Team, the
Proponent Manager (or assigned representative), appropriate facility
supervisory staff (as invited by the Proponent) and the EC(s).
The purpose of the meeting is to introduce the OHHA Team to the
facility management, provide an overview of the OHHA scope and
process, clarify any areas of uncertainty, discuss site details and logistics,
and set a time and location for the Closing Meeting.

4.3.2 Collecting and Verifying Information

During the site visit, the OHHA team members may request additional
information for review including the following: additional procedures,

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Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

additional process flow information, informal workplace tour (walk-

through), introductions, and interviews of supervision in affected areas.

4.3.3 Field Visit

The assessment team will assess the Proponent’s performance by

evaluating compliance with Company policies and procedures and any
other related standards deemed necessary. The duration of assessments
varies according to the size, nature and complexity of the organization.
OHHA field work duration is estimated during the planning activities as
described in Section 4.1.1.

Each OHHA is an independent assessment and shall be managed as such.

While the OHHA Team should endeavor to check on the status of any
“open” findings, the Team Lead shall ensure that major findings are not
duplicated from previous assessments.

Should an “over-exposure” event occur, it should be communicated and

investigated as soon as possible to determine the cause, and associated
control strategies (interim and/or long term). Recommendations should
be provided by the IH team to mitigate further exposures as necessary.
Commentary Note:

EPD has the right to add an OHHA finding to any proponent organization
outside of a scheduled OHHA event. This will be communicated to the
proponent organization in writing signed by the General Supervisor of
EPD/Workplace Environment Division (WED).

4.4 Closing Meeting

a) After completing the onsite survey and comprehensive data evaluation, the
team presents a summary of findings to the facility representative /
management. The feedback provides an overview of the field work,
assessment of documentation and professional assessment of current risks
and necessary controls.
b) Major findings are items that are in non-compliance with government
regulations and/or Saudi Aramco requirements. The findings should be
supported by reference to a specific section of the applicable standard or a
specific mandatory requirement.
c) Minor Findings are issues that should be brought to the attention of the
facility management (e.g., non-compliance issues). These are generally
findings that can be quickly resolved; the facility should seek to permanently
resolve these findings as soon as possible. They will be included in the final
report as minor findings, and will be tracked in EH&S system.
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©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

d) Exceptional Efforts and/or Best Practices will be highlighted by EPD in

recognition of the work done to promote and sustain occupational health
protection issues.

4.5 Post – Assessment Activities

4.5.1 Final Report

The OHHA Team lead is responsible for developing a written final report
after the field work and the analysis of the samples have been completed.

The EPD OHHA Coordinator will initiate EH&S notifications with all
findings which are detailed in the final report and initiate a work flow.
The workflow is approved by the EPD Manager (or assigned
representative) and is sent to the Proponent Manager.

The written final report and supportive information will be attached to

the EH&S notification by EPD OHHA Coordinator.
Note: A year-end annual report is submitted to corporate and executive
management by the Vice President, Engineering Services,
summarizing all of the OHHAs completed to date and the progress
made by proponents in resolving major findings as per the submitted
action plans.

4.5.2 Proponent Organization Action Plan

After receiving and reviewing the final report, the Proponent shall
complete an action plan for each finding through EH&S system. The
plan must include estimated dates for completion and be input into the
EH&S within four (4) weeks of receipt of the final report.

The proponent shall resolve major findings within the estimated dates of
completion (EDC), using appropriate Company resources as needed.

Proponents shall provide pertinent and verifiable documentation to

support closure of all findings. This information shall be attached to the
EH&S notification in support of closure. EPD verification of the
implementation of the corrective measures is required to close the
findings.

4.5.3 Assessment Follow-up

The proponent department shall update the status of findings every six
(6) months until the findings are resolved to the satisfaction of EPD.

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©Saudi Aramco 2019. All rights reserved.
Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

Proponent updates will be reviewed by the EPD OHHA Coordinator.

EPD authorizes the closure of major findings after verifying the
implementation of the corrective measures.

4.5.4 OHHA Records Retention Plan

Records of reports and supportive information shall be retained for a

minimum of twenty (20) years as required by the Industrial Safety &
Health Regulations of SASO. OHHA data and supportive information
shall be stored in the EH&S database.

5 Responsibilities

5.1 Environmental Protection Department (EPD)

 EPD is responsible for the administration, coordination, and execution of the
company OHHA program.
 An EPD OHHA Coordinator shall be appointed to manage the overall
program; including the tracking of formal findings and recommendations
through the EH&S database and the management of OHHA related
data/documents/records.
 EPD shall finalize facility selection for each OHHA to be conducted by the
end of the third quarter of the preceeding year. Provide formal notification
to the proponent manager of scheduled OHHAs at least one month prior to
initiating an onsite assessment.
 The OHHA Team lead shall submit the final OHHA report to the IHU
Supervisor or his designated representative.
 WED Division Head shall approve and release the OHHA report to the
Proponent manager.
 As requested, EPD will provide consultation to proponents on the
development of a corrective action plan to address OHHA findings.
 EPD shall track OHHA findings and verify the resolution of
recommendations.
 EPD shall submit an annual report to corporate management that
summarizes all OHHA work conducted to date and the progress made in
resolving major findings.

5.2 Proponent Organization

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Document Responsibility: Health Protection Standards Committee SAEP-66
Issue Date: 8 May 2019
Next Planned Update: 17 December 2020 Occupational Health Hazard Assessment (OHHA)

 The Proponent department shall provide an OHHA team member to act as a

facilitator with the qualifications and experience necessary to facilitate all
activities associated with the assessments.
 Prior to the assessment, the Proponent department shall provide any
information requested by the OHHA Team lead in sufficient time for the
team to evaluate the information and plan it’s visit.
 The Proponent department shall provide access and logistical support to the
OHHA Team to assess it’s facilities and associated job tasks, interview its
employees, and review pertinent documents.
 The Proponent department shall submit an action plan for the resolution of
findings within four (4) weeks of receipt of the final OHHA report.
Both major and minor findings shall be corrected as soon as possible.
 The Proponent department shall track the implementation or resolution of all
findings and recommendations and provide status reports to EPD every six
months until the findings are resolved.

Revision Summary
17 December 2017 New Saudi Aramco Engineering Procedure to ensure that proactive, periodic site
evaluations by the Environmental Protection Department (EPD) take place at company
proponent organizations in order to measure compliance performance against applicable
government regulations and company workplace health protection requirements.
10 June 2018 Editorial revision to change standards committee from Environmental to Health Protection.
8 May 2019 Editorial revision to comply content confirmation removal request.

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