ehs review chemical industires

ANDERSON ENGINEERING CO., INC. (AECI)

OCCUPATIONAL SAFETY AND HEALTH PROGRAM

AECI DEFINED PRACTICES (ADP)

Project HSSE Review (PHSSER) ADP

Prepared by:

977 West 2100 South Salt Lake City, Utah 84119

April 2010

Revised Date

April 27, 2010

Anderson Engineering Co., Inc. i April 2010


Table of Contents

1.0 PURPOSE ................................................................................................... 1 2.0 SCOPE ........................................................................................................ 1 3.0 ROLES AND RESPONSIBILITIES ............................................................. 2

3.1 AECI Management (AM) ........................................................................................... 2 3.2 AECI Project Manager (PM) ...................................................................................... 2 3.3 AECI Project Engineer (PE) ...................................................................................... 3 3.4 AECI Health and Safety Compliance Officer (HSCO) ............................................. 5 3.5 AECI Field Representative (FR) ............................................................................... 5 3.6 AECI Workforce ........................................................................................................ 6

4.0 DESCRIPTION AND REQUIREMENTS ..................................................... 6 4.1 PHSSER Applicability ............................................................................................... 6 4.2 PHSSERs and Other Process .................................................................................. 6

4.2.1 Project Management Framework ........................................................................ 6 4.2.2 Hazard Identification Site Technical Practice ...................................................... 7

4.3 PHSSER Terms of Reference ................................................................................... 7 4.3.1 Required Reviews ............................................................................................... 8

4.4 PHSSER Stage Reports ...........................................................................................10 4.5 PHSSER Findings ....................................................................................................10 4.6 HSSE Stage Review Records ..................................................................................12

5.0 SUPPORTING DOCUMENTS .................................................................. 12 6.0 REFERENCES .......................................................................................... 12 7.0 RECORDS ................................................................................................ 12 8.0 COMPETENCE REQUIREMENTS ........................................................... 13


Anderson Engineering Co., Inc. 1 April 2010


1.0 PURPOSE The purpose of this practice is to describe the requirements and methodology for conducting Project Health, Safety, Security and Environment Reviews (PHSSERs). PHSSERs consist of review(s) of project documentation conducted by independent specialist(s). The review(s) are designed to verify Health, Safety, Security and Environment (HSSE) concerns, to address these concerns and to improve the quality of the project execution. The purpose of a PHSSER includes: • Avoiding changes or delays due to different interpretations of safety philosophy,

specifications or standards across project interfaces (project team, operating personnel, and contractors).

• Providing independent verification that appropriate management systems and accountabilities are in place to deliver technical integrity including consideration of: o Safety philosophy. o Standards. o Design procedures. o Quality Assurance/Quality Control (QA/QC). o Change Management. o Expertise and competency of designers.

• Identifying and appropriately managing the identified HSSE sensitivities. The PHSSER team provides a constructive independent review and is not responsible for the work of the project team. 2.0 SCOPE This practice has been prepared for the AECI workforce and applies to work carried out by and on behalf of AECI at AECI project sites. It is the responsibility of those carrying out AECI work to understand and comply with legal and regulatory requirements and ADPs. Contractors who provide services to AECI are required to meet the requirements in this ADP. Contractors may use their own policies and procedures to meet the requirements in this ADP if, prior to commencing work, they obtain written approval from AECI to do so. Such approval shall be granted when the Contractor provides AECI with documentation or other information demonstrating that the Contractor’s own policies and procedures meet or exceed the requirements in this ADP. If any requirements or recommendations in this ADP would conflict with applicable legal and regulatory requirements, it is necessary to comply with the legal and regulatory requirements. If this ADP creates a higher obligation, it shall be followed, as long as full compliance with applicable legal and regulatory requirements is achieved. Consideration shall also be given by the AECI workforce to the requirements of specific job sites. This ADP may be superseded by equivalent or more stringent site, job requirements through an agreed and documented Management of Change (MoC) process. If this ADP



creates a higher obligation, it shall be followed, as long as conformance with the site- or job-specific requirements is achieved.

3.0 ROLES AND RESPONSIBILITIES

3.1 AECI Management (AM) In the scope of this ADP, AM shall: • Have accountability for implementation of this practice within operations. • Have the authority to appoint a PHSSER authority to function as the subject matter

expert and technical authority on matters associated with the implementation and compliance of this practice. The PHSSER authority may be appointed at a project, region or functional level.

• Appoint AECI Project staff that has the required level of competence. • Provide resources necessary to implement and operate under the AECI Health,

Safety and Environmental (HSE) program, and confirm that all processes are in place to provide sufficient resources to carry out the intended scope of work in a safe, responsible and reliable way.

• Verify that the monitoring and auditing of conformance with ADPs is followed. • Verify that the appropriate lessons learned are captured and shared with the AECI

workforce. • Have ultimate accountability for the overall process, performance and content of the

HSE Program and associated practices and procedures. • Be accountable for authorizing and approving changes to the associated practices

and procedures, as well as for approving the categories of permits available under this practice.

• Employ the knowledge of experts within AECI and outside AECI, as required. • Have the skills to make decisions in areas of ambiguity and conflict while maintaining

conformance to AECI requirements. • Be responsible and accountable for the decision at the end of each stage of each

Project. • Authorize all work activities within their designated areas of responsibility, through

the review and approval, modification or rejection of Workplans for those activities. 3.2 AECI Project Manager (PM)

In the scope of this ADP, PM shall: • Be responsible for the application of this ADP for applicable projects. • Be accountable for appointing a qualified PHSSER leader (shall be a PE). • Determine how to best apply the PHSSER process to benefit the project outcomes

and account for unique circumstances of the project. • Delegate responsibilities for coordination of PHSSER. • Not lead or be a member of the PHSSER team reviewing his or her own projects. • Ensure implementation of the HSE program, including the provisions of this ADP. • Prepare Health and Safety Plan (HASP), Scoping Document, and prequalification

documents. • Identify the scope, performance standards, and objectives for each Project. • Inform relevant members of the AECI Workforce of the Project scope, performance

standards, and objectives, along with the consequences of failing to work within



these limits. Where work is to be done by a Contractor, this requirement may be satisfied by providing this information to the Contractor, and requiring the Contractor to provide it to relevant members of the Contractor workforce, including subcontractors.

• Have knowledge of and participate, where necessary, in the development and verification of permits

• Verify that all work activities for each Project are consistent with AECI’s HSE Program, ADPs, and any associated practices and permit requirements. This shall include responsibility to: o Verify that all work is appropriately planned and scheduled. o Verify that AECI’s permit system is implemented to control potential hazards at

project sites. o Verify that the appropriate permits are issued, closed and filed per respective

ADP record keeping. o Verify that all appropriate control measures have been or will be put in place prior

to commencement of activity so that the work can be carried out safely. o Verify that the Risk Assessment has been completed and implemented. o Verify that applicable Project scope, performance standards, and objectives are

met. o Verify that any legally required permits are in place and that any work undertaken

under those permits is consistent with and confined to the original scope of work. o Apply defined consequences for failure to meet the above requirements, where

the verification process identifies a failure to conform. o Contribute to the Lessons Learned, where appropriate, to support improvement

in the work process or in hazard assessment. • Function as a liaison between all PEs and other persons performing work at the site. • Coordinate any issues that could result in a change in work scope with the AM. • Identify and verify all Simultaneous Operations (SIMOPS), including all other

potential interaction with other permits being issued. • Determine if conflicts exist between permits, and after consultation with all affected

parties, shall decide the order of work to be performed. • Shall conduct the initial HASP and HSE program review in the field with all AECI

workforce. • Reports situations requiring medical attention to Health and Safety Compliance

Officer (HSCO). 3.3 AECI Project Engineer (PE)

In the scope of this ADP, PE shall: • Formulate a topic list to act as the framework of review before the team is convened.

The listing should take into account: o PHSSER terms of reference. o Nature and circumstances of the project. o Stage objectives identified in the terms of reference based on applicable

Appendix A Appraise/Select, Appendix B – Execute Preconstruction and Appendix C – Pre-Start-up Commissioning.

• Define in the terms of reference based on applicable Appendices A - C. • Assess the importance of the information to the integrity of the PHSSER and decide

whether to issue a recommendation to develop the information or postpone the



PHSSER until the information is provided if key information is not available from the project team.

• Be accountable for: o Delivering of a quality PHSSER review. o Achieving the objectives outlined in the PHSSER terms of reference. o Working with the project team to understand the scope of the PHSSER and

relating that information to the PHSSER team. o Notifying the project manager of a potential non-compliance with legal

requirements or HSSE contractual commitments identified by the PHSSER team. • Ensure safe and healthful work conditions and practices are maintained at the

project site. • Directs and coordinates the HSE program for AECI employees. The PE may

delegate their responsibility to the Field Representative. • Supervise the Risk Assessment for any jobs classified as having a substantial risk

level or higher. • Oversees and assures the quality of the work. • Perform the tasks in the field which the PM assigns to him or her. • Perform oversight on all AECI subcontractors. • Complete all field documentation of work and provide to the PM copies of all

changes to project documents that occur in the field. • Be responsible for the issuance and closure of permits in his or her area of

competency • (e.g., hot work, confined space entry, ground disturbance, lifting and energy isolation

work permits). • Be on site for all applicable permit issuance and then as required by the specific

permit practice. • Review HASP with all members of the AECI workforce at the site location. • Responsible for coordinating any SIMOPS that occur on site. • Communicate with the PM about the issuance and closure of permits, and inform the

PM when each permit is ready for approval. • Verify and certify to the PM that:

o The permits contain all required controls. o The required permits are in place and that any word undertaken under those

permits is consistent with and confined to the original scope of work. o Work is progressing within permit requirements. o Each permit is revalidated and closed as defined in the respective permit ADP. o All members of the AECI workforce have been informed and demonstrated a

clear understanding of the scope of work, potential hazards, controls and mitigations for the work they will perform.

o The correct tools and equipment are available to the AECI workforce and the appropriate certifications and inspections are reviewed or made, as appropriate.

• Prepare Lessons Learned, where appropriate, to support corrective action or continuous improvement efforts and share these with the PM.

• Participate in the risk assessment for any planned activity. • Accept and sign any authorized permits for work activity that is being performed. • Verify the following information to the PM:

o that nonessential members of the AECI workforce are kept a safe distance from the work activity.

o adequate handovers take place at all shift and crew changes. o that the following have been clearly established, communicated and understood:



A process for the transfer of safety between work groups. Specific procedures and policies that will be followed (e.g., what permit

tracking system will be used). o Verify, by including it as a topic in the Task Safety Environmental Analysis

(TSEA) discussion, that all members of the AECI workforce involved in the task fully understand the scope of the work and associated hazards and controls. This shall include informing members of the AECI workforce of the scope of work and associated hazards and controls, and requiring members of the AECI workforce to demonstrate their understanding.

o Verify that all members of the AECI workforce involved in the permitted work activity sign TSEA and permit(s), acknowledging their understanding and agreement with the potential risk associated with completion of the task. In the event that there is more than one work team, there will be representation from each team during the TSEA.

o Identify Stop Work Procedures. o Verify that only work that is within the scope of the permit takes place. o Verify that the site is kept in a clean and safe condition both during and upon

completion of the job. • Observe all work activities covered by the applicable permit. If an individual deems

that he or she cannot safely manage more than one concurrent task, stop the appropriate portions of assigned work and request assistance from the PM.

• Confirm that all members of the AECI workforce working on the site have reviewed and signed the Daily Toolbox Meeting Record, any job risk assessment(s) and TSEA(s).

• Remain on the site until work activities have stopped, permits are closed and appropriate equipment has been secured for the shift.

• Confirm that the appropriate lessons learned from the job are captured, reported and shared with the PM. They should also be incorporated into future TSEAs for tasks that are the same or similar.

3.4 AECI Health and Safety Compliance Officer (HSCO) In the scope of this ADP, the HSCO shall: • Under the direction of AM, has the responsibility for developing and distributing

health and safety requirements to AECI Workforce at all levels of the company. • Train all new employees. • Responsible of maintaining records of training and ensure that refresher training,

where required, is timely. • Works with the PM and PE to ensure Health and Safety compliance at each job site. • Coordinate medical and health actions. • Reports situations requiring medical attention 3.5 AECI Field Representative (FR)

In the scope of this ADP, the FR shall: • Act as directed by the PE or PM.



3.6 AECI Workforce

AECI workforce includes all AECI representatives whether they be AECI employees, AECI Contractors, or AECI Subcontractors. In the scope of this ADP, each member of the AECI workforce shall: • Comply with the all project ADPs and control documents. • Stop work if it appears potentially unsafe. • Attend training on the project safety and associated practices and procedures, as

appropriate. • Demonstrate an understanding and acceptance of their accountabilities or assigned

responsibilities. • Participate in or review risk assessments, when requested. • Conduct a site inspection prior to commencing work at the site, as appropriate. • Assist in the identification of deficiencies in the work process and help identify

possible improvements. • Actively monitor the site and its surroundings for changes that might affect the

performance of the task or affect the safety of those involved in the task. • Demonstrate understanding of the emergency response plan and his or her assigned

role in any emergency response activity. • Report all allegations or occurrences of unsafe work. • Participate in incident investigations, if requested.

4.0 DESCRIPTION AND REQUIREMENTS

4.1 PHSSER Applicability The PHSSER process is applicable where forecasted project spending exceeds five million United States dollars over a three-year period. It is also applicable when the AM determines that the project risk warrants further review. Independent resources required for the review increase with increasing scale and the complexity of the project. Table 1: Project Scale

Project Scale ($ million) Requirements Independent Resources

Less than 5 (<5) Discretionary Review Leader Greater than 5 (>5) and less

than 25 (<25) Peer Review Review Leader

Greater than 25 (>25) and less than 100 (<100) Team Review Review Leader and HSSE or

RET Representative Greater than 100 (>100) Per GP 48-01 Per GP 48-01

4.2 PHSSERs and Other Process

4.2.1 Project Management Framework The PHSSER process consists of as series of formal reviews scheduled either prior to Project Management Framework (PMF) stage gate approval or prior to



key project milestones such as field mobilization and system start-up. Figure 1 outlines the typical timing within the PMF process. PHSSER reviews should be planned within the PMF process as follows: • Prior to submittal of the Select stage recommendations to a governments

agency. • Prior to mobilization to the field for execution of the remedial corrective

measures. • Prior to start up of remediation systems. For remediation projects, such as

excavation or demolition where no engineered facilities will be started up or operated, the PHSSER review should occur in the design PMF stage prior to gate approval.

The full scope of PHSSER review topics, detailed in Appendices A – C and relevant to the project, shall be considered for review. The PHSSER verifies that all applicable topics have been addressed and completed. In addition, plans for items to be completed in future stages are subject to review in each PHSSER. The objectives, list of team activities and supplementary guidewords provided in Appendices A – C are the framework for the review process. The scale, circumstances and HSSE impact potential of projects vary greatly. The review strategy adopted for a particular project should acknowledge the nature of the development concerned. It is acceptable for review stages to be combined into fewer reviews if the nature of the project warrants and if the full scope of PHSSER issues are addressed. 4.2.2 Hazard Identification Site Technical Practice The PHSSER team does not repeat the work conducted by the project team to complete the appropriate Hazard Identification (HAZID) and/or Hazard Operability (HAZOP) studies. The work product from the HAZID/HAZOP should be reviewed by the team and the status of action items generated from the studies checked.

4.3 PHSSER Terms of Reference PHSSERs shall be performed in accordance with agreed terms of reference that define the scope of work, study objectives, time scale, and team members. Typical contents of terms of reference are shown in Appendix F– Typical PHSSER Terms of Reference. The project manager and PHSSER leader shall agree to and approve the terms of reference for the PHSSER. The terms of reference shall identify the agreed topics to be reviewed by the PHSSER team. Topics selected are based on consideration of objectives and topics identified in Appendices A - E and any other project-specific HSSE issues.



4.3.1 Required Reviews AECI shall conduct PHSSE reviews after the PMF Select stage, but prior to field mobilization and prior to start-up of remediation systems. The Select stage PHSSER is based on objectives and topics from Appendix A. Prior to field mobilization, the PHSSER shall be based on the objectives and topics from Appendix B, which includes a forward review of plans for construction. The PHSSER prior to start-up of remediation systems shall be based on Appendix C, which includes a forward review of plans for operation. Certain projects, such as demolition or “dig and haul” removal of contaminated soil, do not require the pre-start-up review. The project manager has the flexibility to conduct additional reviews to provide more timely and focused feedback on project performance. Figure 1: PHSSER Timing within the PMF Process indicates the recommended timing of PHSSERs.

Figure 1: Typical PHSSER Timing within the PMF Process



PHSSER Leader The project manager shall select a PHSSER leader who is: • Independent of the project and not directly associated with eventual operation

of the development. • Trained in the project HSSE review process. • An employee of AECI. • Capable of communicating critical findings to the appropriate level of

management. • A core competency of a PHSSER leader with the interpersonal skills to lead a

multidiscipline team to achieve objectives of the study. Before the team is convened, the PHSSER leader shall formulate a topic list to act as the framework of review. The list should take into account the: • PHSSER terms of reference. • Nature and circumstances of the project. • Stage objectives based on applicable Appendices A - C. PHSSER Team The PHSSER team membership shall be selected by the PHSSER leader in accordance with requirements of each review stage and the nature of the project. The team should be as small as possible but shall be consistent with the possession of the following expertise: • A good understanding of the project and its technology. • A sound appreciation of the host site and its existing activities. • Sufficient general expertise to conduct a credible and reliable HSSE review. The PHSSER team shall include members who are independent of the project to provide an objective and comprehensive review. Representatives of the project being reviewed may not be part of the PHSSER team, but their participation is expected since sharing of information during the review is critical for an effective process. Review members should typically include project management staff, an operations representative and HSSE specialist(s). The required review team is generally different for each stage of review. For example, the Pre-mobilization PHSSER requires construction safety expertise, whereas the pre-start up PHSSER requires commissioning, start up and operations expertise. Refer to Appendix D – Typical PHSSER Team Membership for additional information on typical PHSSER team composition. For projects in some locations, the PHSSER team may need to challenge the project to establish whether local laws and regulations are sufficient or whether international standards should be applied.



The PHSSER leader should consult with the appropriate specialists outside of the core PHSSER team if a specialist advice is needed and the experience of individuals on the review team is not sufficient to address a particular issue. The PHSSER team should also act as a coach in transferring lessons learnt and best practice. Suggestions to improve HSSE, integrity, risk management, engineering and project execution performance are encouraged. The PHSSER team shall be accountable for: • Providing specific background information on the project (i.e., sketches,

Material Safety Data Sheets [MSDS], potential hazards, flow and engineering diagrams, technical literature, etc.) prior to the review meeting.

• Making arrangements for a qualified representative to attend in his or her absence if he or she cannot attend a scheduled meeting.

• Providing sufficient lead time for the PHSSER leader to prepare, and for supporting the availability of adequate resources necessary for an effective review.

• The project team is accountable for tracking and close-out of all actions and recommendations in a timely manner. Closure times shall be agreed on at the review.

4.4 PHSSER Stage Reports Upon completion of each project HSSE review, findings and recommendations shall be formally recorded in a written report addressed to the project team (refer to Appendix E – Typical PHSSER Report Format). Each final PHSSER report shall be subject to approval by the PHSSER leader and sent to distribution in accordance with the terms of reference. The report should be prepared as a resource for the project team and the next stage review team. The PHSSER report shall document the scope of the review, project systems and plans that address topic list items to an acceptable level, conclusions of review, findings and recommendations of the review. The report should summarize the status of the project at the time of the review. PHSSER reports shall be considered final only after the PHSSER leader and the project manager have agreed upon final responses in the form of an action plan. AM should be consulted for final resolution if an action plan cannot be agreed upon between the PHSSER leader and the project manager. Stage reports shall be produced in time to allow recommendations to be addressed before the next review stage is initiated. 4.5 PHSSER Findings The PHSSER team shall prioritize PHSSER recommendations based on the targeted timing to complete the action items. The items should be classified as: • ‘A’ items: Items that shall be closed as soon as possible and latest before the end of

the current project stage.



• ‘B’ items: Items that shall be completed as part of project activities in the next project stage.

The project team shall develop a project response to each accepted PHSSER recommendation in the format of an action plan that describes actions to be taken, person(s) accountable for the action(s) and the required completion date. The project manager and the PHSSER leader shall agree on the action plan. AM shall endorse the agreed action plan and follow-up with the project team. AM shall be accountable for ensuring that the actions are completed by the required completion date and are fully documented. If an action plan cannot be agreed on between the PHSSER leader and the project manager, AM shall be consulted for final resolution. High priority actions shall be resolved before a project can proceed to the next stage of PMF or the next major project milestone in the Execute stage. AM shall engage the project manager and PHSSER leader to verify completion of high priority actions from the PHSSER review to ensure that the identified issues have been adequately addressed. Findings and conclusions of each project HSSE review shall be made available as input to AM so that the status of HSSE issues is taken into consideration in the decision if the project is ready to proceed to the next PMF stage. PHSSER recommendations subsequently rejected by the project should be subject to approval by the AM and the rationale for rejection should be documented. Projects shall document the completion of all agreed upon actions. Developing a plan for the action does not constitute completion of the action. Actions shall be reviewed in the Subsequent stage PHSSERs to confirm appropriateness of the resolution. Subsequent PHSSER teams should review previous PHSSER reports to: • Ensure continuity of the review process. • Be able to ascertain relevant developments since the last review. • Confirm that agreed upon actions have been adequately closed out. PHSSER leader should consult with the previous PHSSER leader to clarify that actions have achieved the intent of the previous PHSSER team. Prior to start-up, AM shall review PHSSER actions and confirm the closure of those actions required to be completed prior to start-up.



4.6 HSSE Stage Review Records Each project HSSE stage review should include, as a part of its review record, a list of documents examined by the PHSSER team, including: • Drawings. • Specifications. • Calculations. • Hazard and risk evaluations. • HSSE plans and procedures. The list should reference document numbers and where the documents can be found in project files or handover dossier.

5.0 SUPPORTING DOCUMENTS The documents in this section support the implementation of the requirements in this practice. • Appendix A – Appraise/Select • Appendix B – Execute Preconstruction • Appendix C – Pre-Start-Up Commissioning • Appendix D – Typical PHSSER Team Membership • Appendix E – Typical PHSSER Report Format • Appendix F – Typical PHSSER Terms of Reference

6.0 REFERENCES The document in this section is related to this practice and should be consulted to support the implementation of the practice requirements. • Training and Competence Assurance ADP • Scoping Document ADP • Driving Safety ADP • GDP 31-00-01, Assessment, prioritization and management of risks • GDP 44-00-01, Reporting HSSE and Operational Incidents • GDP 44-00-02, Incident Investigation • GP 48-01 • HSSE Management System, Policies, Standards and Practices • Integrity Management Standard

7.0 RECORDS Type of Record* Accountable Party Archive Location

PHSSER Reports H&S AM Server/File Cabinets

Recommendation and Action Tracking

Records H&S AA Server/File Cabinets

*H-Hardcopy (paper) S-Soft Copy (digital archives) H&S-Hardcopy and Softcopy



8.0 COMPETENCE REQUIREMENTS Refer to the Training and Competence Assurance ADP for general verification requirements. PHSSER Leader The PHSSER leader shall be: • Trained in the project HSSE review process • Capable of communicating critical findings to appropriate level of management A core competency of a PHSSER leader is to have the interpersonal skills to lead a multidiscipline team to achieve objectives of the study. PHSSER Team Members PHSSER team members shall have: • A good understanding of the project and its technology. • A sound appreciation of the host site and its existing activities. • Sufficient general expertise to conduct a credible and reliable HSSE review.

APPENDIX A

APPRAISE/SELECT

PHSSER Stage Activities - Appraise/Select

1


2


3


4


5


6


7


8

APPENDIX B

EXECUTE PRECONSTRUCTION

PHSSER Stage Activities – Execute - Preconstruction

1


2


3


4


5

APPENDIX C

PRE-START-UP COMMISSIONING

PHSSER Stage Activities – Pre-Start-up Commissioning

1


2


3


4


5

APPENDIX D

TYPICAL PHSSER TEAM MEMBERSHIP

Typical PHSSER Team Membership

APPENDIX E

TYPICAL PHSSER REPORT FORMAT

Typical PHSSER Report Format

APPENDIX F

TYPICAL PHSSER TERMS OF REFERENCE

Typical PHSSER Terms of Reference

ehs review chemical industires

Documents

high priority actions

reliable hsse review

sufficient general expertise

communicating critical findings

phsser stage activities

safety compliance officer

project hsse review

required completion date