health, safety & environmental management system (hse ms ...... · hse risks resulting from...

HSE MS Documentation

Doc No: HSE-HH1-OP-01 Rev A1 May 2014

Uncontrolled Copy when Printed

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Horse Hill Development Ltd

(HHDL)

Health, Safety & Environmental Management System

(HSE MS) Framework Document

Doc No.: HSE-HH1-OP-01

Revision Record:

Date Rev Revision Description Author Checked By Approved By

25/04/2014 D01 Draft for Review JD FD -

29/05/2014 A1 For Issue JD FD SB

HSE MS Framework Document



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Table of Contents

Abbreviations ........................................................................................................................................... 3

1 Introduction ...................................................................................................................................... 4

1.1 Purpose .................................................................................................................................... 4

1.2 Scope ....................................................................................................................................... 4

1.3 Future Development ................................................................................................................. 4

2 Management System Structure ......................................................................................................... 5

3 HSE MS Process ................................................................................................................................. 6

3.1 Overview .................................................................................................................................. 6

3.2 Policy ....................................................................................................................................... 6

3.3 Plan .......................................................................................................................................... 7

3.4 Do ............................................................................................................................................ 7

3.5 Check ....................................................................................................................................... 7

3.6 Act ........................................................................................................................................... 7

4 Roles and Responsibilities ................................................................................................................. 8

5 Performance Standards and Expectations .......................................................................................... 9

5.1 Plan .......................................................................................................................................... 9

5.2 Do .......................................................................................................................................... 14

5.3 Check ..................................................................................................................................... 20

5.4 Act ......................................................................................................................................... 23

Appendix A: HSE Policy ........................................................................................................................... 24

Appendix B: HHDL Organogram .............................................................................................................. 25

Appendix C: HSE Risk Matrix ................................................................................................................... 26

Appendix D: Accident Reporting & Investigation Forms ........................................................................... 28

Appendix E: Document Numbering System ............................................................................................. 32

Appendix F: HHDL HSE Training Matrix .................................................................................................... 33

Appendix G: Supporting Documentation ................................................................................................. 34




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Abbreviations

ALARP As Low As Reasonably Practicable

CEO Chief Executive Officer

CMP Crisis Management Plan

HHDL Horse Hill Developments Ltd

HSE Health, Safety and Environment

HSE MS Health, Safety and Environmental Management System

KPI Key Performance Indicators

LTI Lost Time Incidents

PDCA Plan, Do, Check, Act




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1 Introduction

1.1 Purpose

Horse Hill Developments Limited (hereafter referred to as ‘HHDL’) has developed a Health, Safety and Environmental Management System (HSE MS) to provide a framework for systematically managing all aspects of its operations to ensure the safety and protection of people and the environment and compliance with the HHDL HSE Policy.

The structure and content of the HSE MS has been designed to enable critical activities to be identified and managed so that risks to the health and safety of personnel and to the environment are reduced to a level deemed to be as low as reasonably practicable (ALARP). In addition, the system has been developed to be reflective of industry best practices and complies with the logic of national and international standards: OHSAS 18001, HSG[65] (Safety) and ISO 14001 (Environment).

This Framework Document forms part of the HSE MS and provides a high level overview of the arrangements in place to manage Health, Safety and the Environment (HSE) through the HSE MS.

1.2 Scope

The HSE MS applies to all of HHDL’s activities. These relate specifically to onshore hydrocarbon exploration and production in the United Kingdom. The company resources projects largely through the engagement and effective management of, or alliance with, competent contractors and/or partners. Consequently, this HSE MS particularly focuses on:

Clear assignment of responsibilities;

Sound risk management and decision making;

Legal compliance throughout all operations;

A systematic approach to the planning of HSE critical business activities;

Excellence in HSE operational performance;

Continual improvement.

1.3 Future Development

It is the responsibility of Senior Management to identify changes in operational activity that will require further development of the HSE MS. This would normally occur as part of the annual review process as defined within the HSE MS, but may be required outside of the review schedule.




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2 Management System Structure

The HSE MS and its supporting documentation provide the framework within which all activities are controlled. The documentation hierarchy is illustrated in the triangle depicted in Figure 2.1.

At the apex, the HSE Policy defines the HSE culture and commitment for the whole organisation. The implementation of this HSE Policy across the Company is driven by the HSE MS which consists of the following documentation:

HSE MS Framework Document (this document): provides an overview of the structure and content of the management system, summarises the HHDL management, staff and contractors roles and responsibilities to ensure its effective implementation and defines mandatory performance standards and expectations.

Supporting HSE Documentation: provide detailed information on how the mandatory performance standards and expectations are met and include:

o Further Guidance: These provide more detail on the general implementation of the standards and expectations. An example is the Head Office Crisis Management Plan (CMP) which defines how the head office responds to operational emergencies (note that a parallel site specific emergency plan will define field emergency responses);

o Project Specific Documents: These provide detail on how HSE will be managed for each

HHDL project throughout its lifecycle (e.g. Well HSE Plans, HSE Risk Assessments, Audit Plans,

etc.). Such documentation also includes HSE Records which document the effective

implementation of the HSE MS (e.g. annual HSE Management Reviews, training records,

etc.).

Note that not every standard currently has supporting guidance or project specific documents. Such information is only provided where additional information is considered appropriate to facilitate HSE MS implementation.

Bridging Documents: At the base of the triangle, these documents link HHDL’s management system with its various contractors’ HSE MS, Operating Standards, Procedures, Guidelines and Work Instructions, etc.

The system is goal-oriented and allows sufficient flexibility for individual projects to achieve these goals in a manner which best suits the Company business.

Figure 2.1: HSE Management System Structure




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3 HSE MS Process

3.1 Overview

The HSE MS process provides the mechanism to deliver exemplary HSE performance throughout the business lifecycle from acquisition of new licences and acreage through to development and production and on to decommissioning and divestiture. It is structured around the ‘plan, do, check, act’ (PDCA) process, with a feedback loop to facilitate continual improvement in performance.

These steps are supported by:

A set of Performance Standards which define the mandatory actions required to meet the HSE MS requirements;

A set of Expectations listing the actions required to satisfy each Performance Standard.

Where relevant, HHDL may develop HSE Procedures to support these Performance Standards and Expectations.

This process is illustrated in Figure 3.1 and described further below. The Performance Standards and Expectations are detailed in Section 5 while Roles and Responsibilities for their implementation are described in Section 4.

The HSE MS is supported by further documentation as listed in Appendix G.

Figure 3.1: HSE MS Process

3.2 Policy

The HSE MS is driven by the HSE Policy, which sets out the Company’s expectations and commitments to HSE performance. The HSE Policy (a copy of which is provided in Appendix A) provides a framework for establishing performance goals, from which annual t argets are developed.

It is made available to the public and those working for and on behalf of HHDL as necessary. The implementation of the policy is achieved through application of the HSE MS.




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The HSE Policy is signed and dated by the Executive Director of HHDL. It is regularly reviewed and, if necessary, modified (as a minimum, on an annual basis) and revisited following any material changes in the company. In addition, requests for changes to the Policy statement can be made through the Executive Director, CEO by any member of staff and changes may be implemented following the formal Senior Management Review.

3.3 Plan

Within the planning stage the organisation and responsibilities for the management of H SE are defined and documented.

Potential HSE hazards and risks associated with planned activities are identified and appropriate control measures established and implemented. Any changes implemented are also subject to this risk review process.

As a minimum, processes are established to ensure that all national and international legislation are identified and complied with.

HSE objectives and targets are set by Senior Management and cascaded throughout the organisation to meet HSE Policy requirements

Effective response plans to foreseeable emergencies are developed and maintained and staff trained appropriately.

3.4 Do

During this stage, facilities are designed, constructed, operated, maintained and decommissioned in a manner which mitigates HSE risks and ensures compliance with HSE and legal requirements.

Personnel are selected who have the appropriate qualifications, experience and skills to meet their responsibilities.

Competent contractors are selected and managed to undertake specialist tasks in a manner which ensures that HSE expectations are met.

HSE risks resulting from design, operational, organisational, procedural or legislative changes are identified, assessed authorised and managed to limit the severity of any consequences.

“Controlled” HSE documents are identified and their production, review, ap proval, distribution, maintenance, storage and destruction managed.

HSE policy, plans, arrangements and performance will be effectively communicated both internally and externally.

3.5 Check

Routine monitoring, inspections, reviews and audits are conducted to ensure the effective functioning and continued suitability of the HSE MS.

All incidents, accidents and near misses are reported, investigated or reviewed and documented. The findings from investigations or reviews are used to prevent / minimise recurrence and improve performance.

Non-conformities are identified and, where appropriate, corrective and / or preventative actions are raised, tracked to completion and reviewed for effectiveness.

3.6 Act

Performance is reviewed periodically by Senior Management to verify conformance with the HSE MS and to evaluate the continued effectiveness of the HSE MS. When necessary, improvements are made to the HSE MS.




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4 Roles and Responsibilities

The Executive Director has ultimate responsibility for the implementation of the HSE Policy. This responsibility is delegated as follows:

Chief Executive Officer (CEO): Responsible for establishing the organisation, processes and resources to implement the HSE MS and driving continuous improvement. Provides the leadership to ensure that HHDL operations are fully compliant with the HSE Policy;

Senior Managers (e.g. Exploration, Drilling, Finance Managers): Responsible for implementing the HSE MS within their own functions / groups. This includes some or all of the following:

o Requiring staff and contractors to comply with the HHDL HSE MS;

o Providing HSE leadership;

o Monitoring, evaluating and reporting on their function/group’s HSE performance;

o Promoting best practice and continuous improvement;

o Investigating incidents and applying lessons learned;

o Developing and maintaining HSE competencies.

HSE Manager: Reporting to CEO, the HSE Manager is responsible and accountable for:

Maintaining, updating and controlling the HSE MS documentation;

Acting as the main point of contact with regard to all ( internal and external) HSE issues;

Providing relevant HSE support, guidance and training to all staff;

Proposing annual HSE targets for Senior Managers, for subsequent review and approval by the Executive Director;

Monitoring performance against these annual targets;

Has the freedom to report directly to the Executive Director in the event that any HSE related issues are not being appropriately addressed.

Staff & Contractors: Responsible for working in a safe and environmentally responsible manner, fully implementing the relevant requirements of the HSE MS and reporting any HSE concerns or issues.

An organogram showing the current HHDL organisation, including functional reporting lines, is provided in Appendix B.




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5 Performance Standards and Expectations

5.1 Plan

1. HSE Leadership

Performance Standard

HSE standards, expectations and responsibilities shall be clearly defined, communicated and visibly demonstrated by leaders, managers and supervisors.

Expectations 1.1 HSE is a line management responsibility with the ultimate responsibility lying with the Executive Director.

1.2 Management commitment to high HSE standards shall be documented within the HSE Policy. The Policy shall be:

Signed and dated by the Executive Director of HHDL;

Communicated to all staff, contractors and stakeholders;

Reviewed periodically and, where appropriate, updated and re-issued.

1.3 Management shall be active and visible in promoting a common understanding of HHDL’s expectations and HSE culture. Senior Management shall be responsible for:

Promoting the Company’s HSE Policy and goals;

Monitoring HSE performance of staff and contractors;

Reviewing HSE performance annually and introducing improvements where required.

1.4 Management shall ensure that the budgeting process allows for sufficient resources (financial and manpower) to meet the Company’s HSE requirements and to implement, maintain and drive the continuous improvement of the HSE MS.

Further Guidance

HSE Policy (Appendix A)

Project Specific Documents

-




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2. Risk Management


All occupational health and safety hazards, major accident hazards and environmental aspects associated with HHDL’s activities (throughout all phases of the lifecycle) shall be identified, their risks assessed and prioritized, and steps taken to eliminate the risk or manage to As Low As Reasonably Practicable (ALARP) levels.

Expectations 2.1 Hazards and risks associated with the full lifecycle of operational activities, facilities, plant and/or equipment, with the potential to adversely impact operational and HSE performance, security or result in loss of business opportunities, shall be identified, evaluated and controlled to an acceptable level (e.g. ALARP, best available technology).

2.2 HSE risks shall be controlled in order of preference: elimination, treatment, and procedural controls.

2.3 A Risk Register shall be maintained to document HSE risks and associated controls and a process established to monitor effectiveness of controls and performance.

2.4 Environmental aspects and impacts shall be identified and documented within an Environmental Aspects Register. Monitoring programmes shall be established and management programmes developed to improve environmental performance.

2.5 Significant HSE risks shall be communicated to the workforce (including contractors) and, where appropriate, local communities and other stakeholders.

2.6 The results of hazard and risk assessments shall be considered in the preparation and review of emergency response plans.

2.7 Risk associated with management of change (e.g. changes in the organisation, HSE MS or operational activities) shall be assessed prior to introducing the changes.

Further Guidance

Risk Matrix (Appendix C)


HSE Risk Assessment (HSE-HH1-OP-06)

HSE Risk Register (HSE-HH1-REC-01)

Environmental Aspects Register (HSE-HH1-OP-07)




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3. Legal & Other Requirements


As a minimum, all applicable UK legal requirements and other requirements to which HHDL subscribes to (e.g. industry best practise) shall be identified and complied with.

Expectations 3.1 Applicable laws, regulations, standards and recognised codes of practice which should be complied with shall be identified, along with how these requirements apply to HHDL HSE risks and environmental aspects.

3.2 A Compliance Matrix shall be developed and maintained. This should list all HSE regulatory and legal requirements and, for each one, identify:

Who is responsible for obtaining / maintaining it;

Which external body is responsible for issuing permits and consents;

What needs to be done to ensure compliance;

Likely timescale to obtain permits and consents;

Lifetime of permit etc.

3.3 All necessary permits and consents shall be in place before any operational activity commences.

3.4 All conditions attached to the permits shall be met and all reporting requirements satisfied.

Further Guidance

-


Horse Hill 1 HSE Plan (HSE-HH1-OP-04)

Horse Hill 1 Compliance Matrix (HSE-HH1-OP-08)




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4. Objectives, Targets & Plans


Senior Management shall set HSE objectives and targets at relevant functions and levels within the organisation to achieve the requirements of the HSE Policy.

Expectations 4.1 Specific measurable HSE objectives and targets, consistent with the HSE Policy, legislation, HSE risks and business requirements shall be developed, documented and integrated into business objectives. Objectives and targets shall be reviewed and progress regularly monitored by managers involved with their implementation.

4.2 HSE objectives are the overall goals and performance requirements, they should be seen as long term aims and are likely to remain unchanged over a period of years. An example of an objective could be no lost time incidents (LTI).

4.3 HSE targets should be specific and measurable. They will usually be set annually and represent the necessary steps to achieve the HSE Objectives. For example, if the objective is no LTIs then an annual target could be reduction of LTIs by 10%.

4.4 Project Specific HSE Management Plans shall be implemented by each project/operational site in order to achieve the set objectives and targets. These plans shall include actions required to achieve the objectives and targets, timeframes, responsibilities and allocation of resources and shall ensure that:

Operation and maintenance activities shall be undertaken by competent and trained personnel, capable of carrying out the required tasks and activities safely.

Procedures shall identify HSE critical items, performance standards, safe operating envelopes and risk management tasks and activities;

Contractual and bridging agreements are developed to provide assurances for contractor operated facilities.

Further Guidance

-






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5. Emergency Planning


Procedures and resources are in place to effectively respond to crisis and emergency situations so as to preserve the health and safety of people, protect the environment and preserve property and Providence’s capability and reputation.

Expectations 5.1 An Emergency Management Plan shall be established at a corporate level to deal with high level response to an emergency.

5.2 Emergency response plans and supporting contingency plans (e.g. Pollution Incident Plans, Bridging Documents, etc.) shall be established to address potential emergency situations, to designate roles and responsibilities and to identify the interface requirements with stakeholders (e.g. community, media, relatives, partners, insurers, shareholders or regulators). Points of contact and telephone numbers shall be included in the plans. Response equipment, facilities and personnel shall be identified in the plans and appropriate mobilization procedures agreed.

5.3 The plans shall be communicated to staff and contractors (where relevant).

5.4 Personnel shall be adequately trained to both understand the regulatory requirements and apply the necessary controls and preventative measures as described in the plans. This includes the ability to manage interface with media, authorities and other external agencies. Periodic refresher training shall also be conducted.

5.5 Emergency equipment (e.g. communications, operational specific equipment, spill control equipment, etc.) shall be available in sufficient quantities and shall be maintained in good working order.

5.6 Emergency plans shall be maintained through annual reviews and regular drills and exercises to validate controls and preventative measure, including liaison with and involvement of external support.

5.7 Lessons from emergency response drills, exercise and incidents shall be documented, communicated and significant findings used to improve the plans.

Further Guidance

HHDL Crisis Management Plan (HSE-HH1-OP-02)


Horse Hill 1 Management System Bridging Document (HSE-HH1-OP-03)




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5.2 Do

6. Resources, Competence &Training


An organisation shall be defined, responsibilities clearly identified and resources provided, which are adequate for implementing the requirements of the HSE Policy. Personnel are selected for job functions based on their competency to fulfil the associated roles and responsibilities. HSE training is provided to maintain their skills and competencies, with their competencies regularly assessed.

Expectations 6.1 Employees and contractors shall be selected on the basis that they have the HSE qualification, experience and/or training to perform the tasks that they have been assigned and meet HHDL’s HSE standards.

6.2 HSE accountabilities shall be identified, defined, documented, kept up-to-date, understood and applied.

6.3 Inductions that address relevant HSE objectives, hazards, risks and controls shall be conducted for employees, contractors and visitors, as appropriate.

6.4 HSE competencies required for company positions shall be identified, documented and periodically reviewed. Where appropriate, additional training shall be provided for employees to ensure compliance with these competency requirements (e.g. emergency response training).

Further Guidance

HHDL HSE Training Matrix (Appendix F)


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7. Communications


The company HSE policy, objectives, annual plans and targets, roles and responsibilities shall be effectively communicated internally to all staff and externally to all contractors and relevant stakeholders.

Expectations 7.1 HSE awareness shall be actively and visibly communicated and encouraged throughout the organisation. In this regard provision shall be made for open reporting and whistle blowing will not be penalised.

7.2 Management shall maintain internal communications (formal and informal) on HSE expectations by:

Induction programmes for new hires/contractors;

Routine written/verbal/electronic means;

Periodic management meetings and site inductions;

Safety meetings;

Pre-spud/tour meetings;

Toolbox/tailgate talks.

7.3 Minutes of meetings shall be documented and maintained, as appropriate.

7.4 External communications with contractors and stakeholders (e.g., regulatory authorities, industry organisations, interest groups) shall be effectively managed and documented.

Further Guidance

-


-




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8. Contractor Management


The contracting of services and the purchase, hire or lease of equipment and materials shall be carried out in a manner which ensures that HSE expectations are met

Expectations 8.1 Contractors shall be selected on the basis that they are competent to perform the tasks for which they have been contracted, either as a result of previous performance or through an appropriate selection process which may include an HSE audit prior to contact award.

8.2 Contracts shall contain appropriate HSE provisions to provide assurance that the contractor will meet HHDL’s HSE expectations. In particular, HSE roles, responsibilities and performance criteria will be agreed and set out in Bridging Documents and HSE provisions shall be outlined in the contract kick-off meeting.

8.3 The HSE performance of contractors, and specifically their compliance with the obligations specified in contracts, shall be monitored and reported. For example:

The monitoring of contractors’ HSE performance relative to contractual obligations during the execution of the work;

Carrying out audits where deemed appropriate by the nature of the work;

Assuring contractors report / investigate all incidents and relevant near misses;

Assuring contractors close out agreed recommendations for remedial action in a timely manner;

Providing feedback to contractors and, where appropriate, identifying areas for improvement.

8.4 Timely feedback shall be provided by HHDL to contractors and, where appropriate, areas for improvement identified.

8.5 Where relevant, a contract close out report shall be compiled, including a commentary on HSE performance.

Further Guidance

-



HSE Contract Clauses (HSE-HH1-OP-09)




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9. Manage Design, Construction & Operational HSE Risks


Wells and facilities shall be designed, constructed, operated, maintained and decommissioned in a manner which mitigates risks and ensures compliance with HSE and regulatory requirements.

Expectations 9.1 Technical, environmental, health and safety requirements shall be considered for all survey activities and drilling operations and at each stage in the design, construction or modification of any facility / development.

9.2 Potential hazards shall be identified and HSE risks evaluated (including risks introduced by simultaneous/combined operations) using appropriate risk assessment tools. Risks shall be mitigated through the implementation of effective control measures.

9.3 Project management systems and procedures addressing technical integrity and HSE accountabilities shall be documented and well understood.

9.4 Processes shall be established and maintained for design review, validation and verification, and for the control of design inputs, design outputs and design changes.

9.5 Specifications for wells and facilities, including reference to design and engineering standards, and any local regulatory requirements shall be clearly referenced in relevant documents.

9.6 Safety & environmentally critical equipment, systems, procedures, and activities

shall be identified and documented and performance standards verified.

Further Guidance

-


-




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10. Change Management


HSE risks resulting from design, operational, organisational, procedural or legislative change shall be identified, assessed and managed to limit the severity of any consequences.

Expectations 10.1 Formal, documented procedures shall be established and maintained to effectively manage all HSE risks associated with temporary or permanent changes, including:

Plant, equipment or any other hardware;

Procedures and work instructions;

Process method and parameters, control software and operating conditions;

Materials;

Site or plant layout;

Organisations structure or responsibility and authority of personnel;

Acquisition or divestment of assets and properties;

Any additional change that has the potential to effect people or the environment.

10.2 Changes in legal and regulatory requirements, technical codes, and knowledge of HSE effects shall be tracked and appropriate changes implemented.

10.3 The implementation of changes shall include documentation, updating of drawings, training, assessment of the risk of the proposed change before it is implemented and communication of the changes to personnel who may be affected.

10.4 The original scope and duration of temporary changes shall not be exceeded without review and approval.

Further Guidance

-






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11. Documents & Record Management


‘Controlled’ documents shall be identified and their production, review, approval, distribution, maintenance, storage and destruction managed.

Expectations 11.1 Critical HSE procedures, documents, drawings, design data and other documentation shall be identified. A system shall be established to securely manage such documentation including responsibilities for maintaining the information.

11.2 Pertinent records (e.g. HSE reviews and reports, certification, testing) shall be retained as necessary. Obsolete documentation shall be identified and removed from circulation.

Further Guidance

Document Numbering System (Appendix E)


Register of Controlled Documents (Appendix G)




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5.3 Check

12. Incident Reporting & Investigation


All incidents, accidents and near misses shall be reported, investigated or reviewed and documented. The findings from investigations or reviews shall be used to prevent / minimise recurrence.

Expectations 12.1 Systems shall be established and maintained for the identification, reporting and investigation of all incidents.

12.2 Incident investigation should include the identification of root causes and preventive actions being identified and recorded.

12.3 Prioritized actions, aimed at preventing recurrence, shall be implemented, verified effective, and monitored through to completion.

12.4 Lessons learned shall be shared across the organisation and with other stakeholders, as appropriate.

12.5 Information gathered from incident investigation shall be analysed to identify and monitor trends and improve standards, systems and practices.

Further Guidance

Accident Report & Investigation Form (Appendix D)


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13. Monitor, Review & Audit


Routine monitoring, inspections, reviews and audits will be undertaken to assess and, where necessary, improve HSE performance and the suitability of the HSE MS

Expectations 13.1 An active HSE performance monitoring and measurement programme shall be established and maintained. This could include monitoring performance on an on-going basis against Key Performance Indicators (KPIs), such as:

Frequency of incidents;

Number of accidental releases to environment;

Number of non-compliances with permits;

Action items implemented/action items outstanding;

Training planned/training completed.

13.2 Compliance with applicable legal requirements shall be periodically evaluated.

13.3 Calibrated or verified monitoring and measuring equipment shall be used and maintained.

13.4 Monitoring results shall be documented and records retained.

13.5 Monitoring results shall be analysed, the results compared against agreed parameters and findings reported through line management.

13.6 An audit programme, covering both internal and independent audits (i.e. independent of the facility being audited), shall be developed and implemented. The scope and frequency of these audits shall be determined by historic HSE performance and risk to HHDL.

13.7 Audit deficiencies shall be identified and action taken to rectify them. Audit findings shall be documented and records maintained. Agreed actions shall be communicated, tracked to completion, and closed out;

13.8 Agreed improvements shall be integrated into the work planning and budget process, responsibility and schedule agreed and the plans executed in a timely manner.

Further Guidance

-







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14. Non-Conformity, Corrective & Preventative Action


Non-conformities shall be identified and investigated and all corrective and / or preventative actions documented, tracked to completion and reviewed for effectiveness.

Expectations 14.1 Non-conformities shall be identified and investigated to determine their cause(s) and to ensure appropriate corrective and / or preventative actions are implemented in order to avoid recurrence.

14.2 Appropriate corrective and / or preventative actions shall be agreed by the Responsible Manager and, where appropriate, reported to the regulatory authorities.

14.3 Agreed corrective and / or preventative actions shall be documented, responsibilities for implementation assigned, communicated, tracked to completion and closed out.

Further Guidance

-


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5.4 Act

15. Continual Improvement


Senior Management shall, as a minimum, conduct an annual review to verify conformance with the HSE MS and to evaluate its continued effectiveness.

Expectations 15.1 Senior Management (the Executive Director and CEO with the support of the HSE Manager) shall conduct an, at least annual, review to ensure the continued suitability, adequacy and effectiveness of the HSE MS. Such a review can be scheduled within the annual business review process and should assess opportunities for improvement and the need for changes to the HSE MS, including the HSE Policy and objectives and targets.

15.2 The review shall take account of HHDL’s strategic business objectives, short and long term operational plans, operational risks and potential legislative changes, as well as changes with any other requirements to which HHDL subscribes (e.g. changes in industry best practice).

15.3 The input to the review shall include:

Results of internal audits and evaluations of compliance with legal requirements and with any other requirements to which Providence subscribes (e.g. industry best practice);

Any communications from internal / external stakeholders, including recommendations for improvement;

HHDL’s HSE performance;

The extent to which previous objectives and targets have been met;

The status of corrective and preventative actions;

Follow up actions from previous management reviews.

15.4 The output from the review shall include any decisions and actions relating to changes to the HSE Policy, objectives, targets, and other elements of the HSE MS, consistent with the commitment to continuous improvement.

15.5 Records of the review shall be retained.

15.6 Improvements shall be integrated into the annual business plan(s) with responsibility and timing for execution stipulated and executed in a timely manner.

Further Guidance

-


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Appendix A: HSE Policy




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Appendix B: HHDL Organogram

HHDL Staff

Contractors




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Appendix C: HSE Risk Matrix

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Health Safety Environment Reputation Financial Multiplier 1 2 3 4 5

Major health

exposure for 10 or

more people on site or

in local community.

Irreversible health

effect.

Multiple Fatalities (or

permanent total

disabilities) to staff

and/or contractors

Major oil spil l , blow-

out or loss of integrity

with effects outside

site boundaries .

Major national news

event.

Widespread anger

within community.

National protest. Loss

of l icense to operate.

Cost of

response/clean-

up/production loss /

asset loss

>US$ 10million

5 5 10 15 20 25

Major health

exposure for up to 10

individuals.

Irreversible

Single Fatality or

permanent total

disability

Major loss of integrity

with effects outside

site boundaries.

Contained with

l imited environmental

License to operate

threatened.

Significant local

protest/.anger.

Interruption to

operations.

Cost of

response/clean-

up/production loss

/asset loss

US$ 10m to 1m

4 4 8 12 16 20

Exposure of up to 5

individuals. Serious

health effect but

reversible.

Serious Injury

(reversible) to one or

more individuals.

Medical treatment

required (LTI > 3

days)

Major loss of

integrity. Contained

within site boundaries

Significant

concern/anger in

local community .

Reputation of

company damaged

locally

Cost of

response/clean-


asset loss

US$ 1m to 0.1m

3 3 6 9 12 15

Exposure to minor

health risk for up to 5

individuals. No

lasting health effects.

Minor Injurt /

Medical Treatment to

one or more

individuals.

Localised loss of

integrity. Minor

contamination within

site boundaries.

Complaints from

local communities.

Effects reversible but

some social impact

Cost of

response/clean-


asset loss

US$ 100,000 to 10,000

2 2 4 6 8 10

Exposure to minor

health risk for one

individual. No lasting

health effect

First Aid Case.

Administered locally .

No external resources

required.

Minor loss of integrity

within site

boundaries. No

environmental

damage after clean-

up.

Some minor

complains from local

community, low

social impact t

Cost of

response/clean-


asset loss /

<US$ 10,000

1 1 2 3 4 5

HHDL - HSES Risk MatrixProbability

Consequence Definitions

Co

nse

qu

en

ce




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Risk Ranking Categories:

Risk Score

1 to 4

5 to 12

15 to 25

Risks require further consideration. They do not necessarily require the instigation

of additional risk reduction measures provided that it can be demonstrated that it is

not practicable to reduce risks further. This is the area in which ALARP (As Low as

Reasonably Practical) or BAT (Best Available Technique) considerations are

relevant, and these can involve cost benefit analysis. Such cost benefit analysis

considers whether the environmental benefit gained by implementing additional risk

reduction measures is worth the financial cost. Taking extreme and contrasting

examples, a site could spend a million euros on a mitigation measure that only

reduces the environmental risk by a very small amount; this would not be

considered as BAT. Conversely, if their cost was very much lower, and the

mitigation measure enabled environmental risks in this ‘intermediate’ zone to be

lowered significantly, it could be considered that the cost is worth paying. Often

this requires judgement on the part of the operator and the regulator.

Risk considered unacceptable and, except in extraordinary circumstancesand with

Management Team approval, activity cannot progress without action to reduce risks

Risk Ranking Categories

Risk acceptable without further risk reduction




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Appendix D: Accident Reporting & Investigation Forms

Form D1: Incident Reporting Form / Notification Report No:

Page 1

A. INCIDENT INFORMATION

Date occurred: Time occurred:

Date reported: Time reported:

Site where accident/incident occurred:

Location where accident/incident occurred:

Incident reported to:

Type of Incident: (see below)

Reported via contractor’s procedures?

(If NO notify relevant contractor).

Contractor reference number. .

FI: Fatal Incident

LTI: Lost Time Injuries. Injured persons are unable to work for the next shift.

RWI: Restricted Work Incident

MTC: Medical Treatment Case

FAC: First Aid Case

NII: Non Injurious Incidents.

NM: Near Miss

B. INCIDENT DESCRIPTION

HIPO: High Potential Incident.

II: Industrial Illness

ENVI: Environmental Incident

Report Number: Lifecycle Stage/Sequential Number & Year e.g. D/001/04

(Lifecycle Stage. D: Drilling; PC: Project Construction; P: Production; OB: Operations Base; A: Abandonment).

Immediate actions taken to contain incident/ prevent recurrence:

Note: Include type of incident (caught between, slip, trip etc.), equipment involved, operation at time of incident, the sequence of events prior to and during

incident, property/resources damaged or lost, the estimated cost of the incident (replacement, repair, clean-up), volume oil/chemicals spilt. Describe

permits in force/ transgressed.

C. PERSONS INJURED / AFFECTED / INVOLVED

Name:

Nationality: Birth Date:

olved

Affected

Injured

Address:

Telephone: Job Classification/ Title & Department: Social Security Number:

Experience in Occupation: Experience Offshore:

Employer’s name and address: For non-employees only.

Part of Body Affected: Nature of Illness/Injury

Site treatment:

Transferred to:

Transferred by:

Time and Date:

Contact:

Hospital Treatment:

Injury Prognosis:

Lost Time:

Effected Involved Injured




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Report No:

Page 2

D. WITNESS INFORMATION

Name and Employer:

Address and Telephone:

Name and Employer:


Name and Employer:


Name and Employer:


E. FORM COMPLETION

Completed By:

Date:

HSE Manager:

Date:

ATTACH:

INDIVIDUALS OWN STATEMENT OF INCIDENT (WHEN REPORTING INJURY OR ILLNESS);

WITNESS STATEMENTS;

PHOTOGRAPHS AND / OR SKETCHES

CONTRACTOR ACCIDENT REPORT;

FIRST REPORT OF INJURY OR LAW ENFORCEMENT REPORTS.

Send completed reports to HSE Manager within 24 hours

NOTE: Records or Reportable Incidents (RIDDOR) must be kept for 3 years




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Form D2: Incident Reporting Form / Investigation Report Number: Page 1 A. RISK POTENTIAL ANALYSIS (Note 1)

Indicate the most serious situation that COULD have happened e.g. Pipe-wrench COULD have struck any of the rig floor personnel on the head causing fatality.

Number Of People Exposed

Potential Severity (Note 2)

X

Recurrence Likelihood (Note 3)

=

Level of Risk (Note 4)

Level Of Investigation (Note 5)

B. PRIMARY CAUSE OF THE ACCIDENT/INCIDENT (Note 6)

C. UNDERLYING CAUSE(S) OF THE ACCIDENT/INCIDENT (Note 6)

D. ROOT CAUSE(S) OF THE ACCIDENT/INCIDENT (Note 6)

E. ACTIONS TO PREVENT RECURRENCE Actions proposed as a result of the incident investigation (Note 7)

F. PROOF OF CLOSE-OUT ACTIONS Actions successfully implemented (Note 8)

Investigated By:

Sign

Date

HHDL Manager Sign Date

HSE Manager Sign Date

Send this completed form and the full investigation report to HHDL HSE Manager




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Incident Reporting Form / Investigation – Supporting Notes 1. Risk Potential Analysis:

The risk potential (i.e. “What COULD have happened?”) of all reported accidents and incidents is used to determine the level of investigation into the incident necessary. The normal definition of risk (“Risk = Hazard Severity x Likelihood of Recurrence”) is used to determine the risk potential (see Table 1 for definitions).

2. Potential Severity: This is the most severe possible outcome that COULD have occurred had not luck, speedy response etc intervened. It is recognised that, in many instances, the maximum possible outcome has already occurred and caused the incident (see Table 1 for definitions).

. 3. Recurrence Likelihood:

The potential for the incident to happen again if NOTHING is done to prevent it recurring (see Table 1 for definitions).

4. Level of Risk: Combine the above criteria and rank the level of risk as Low, Medium or High based on the criteria indicated in Table 1.

5. Level of Investigation: The risk potential of the incident is used to determine the level of investigation of the incide nt as indicated in Table 2.

6. Investigation: The Investigation Leader should select an investigation team appropriate to the circumstances. The investigation team should collect information, including:

Site layout and condition prior to the incident;

Procedures being followed;

Supervisory structure;

Eye witness accounts (attached as written statements). The causes of the incident should be analysed in terms of:

Primary Cause(s) – Circumstances that immediately precede the incident. Attributable to unsafe acts or conditions;

Underlying cause(s) – Reasons for the substandard practices or conditions. Possible result of personal factors (e.g. lack of knowledge) or job factors (e.g. inadequate equipment);

Root cause(s) – The controlling cause of the incident/near miss. Possible result of inadequate programmes, programme standards or inadequate compliance with standards.

The Investigation report should be submitted within one week of the investigation to the same individuals who received the Notification report and to those responsible for implementing corrective/preventative actions.

7. Corrective Actions: Appropriate corrective actions will be identified. Actions will be included in the HSE or Project Specific Action Register to ensure follow up, implementation and close out. The register is completed and monitored by the HSE Manager.

8. Proof of Close-Out Actions: (Actions that have been successfully implemented). Proof that the “Actions to Prevent Recurrence” have been completed will be required before the Investigation Team Leader will sign off all actions as complete. In circumstances where the “Actions” have not been completed by the completion date the HSE Manager will initially consult with the responsible person to establish the reasons why the actions have not been completed.




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Appendix E: Document Numbering System

HSE Documents are numbered as follows:

HSE-XXX-YYY-NNN

where:

XXX: denotes the particular well or operation addressed by the document. Current designations are:

o HH1 which refers to all work associated with the Horse Hill 1 well in addition to head office

“corporate” activity;

YYY: denotes the particular functional activity under consideration. Current designations are:

o AUD which refers to audit activity;

o OP which refers to HSE support activities associated with a particular well operation;

o PD which refers to EA permit related documentation;

o REC which refers to all HSE records / action tracking documents, etc.

NNN: denotes a sequential number for each type of document.

The HSE manager will maintain a register of all such controlled HSE documents. This is currently contained as Appendix G of this HSEMS Framework Document




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Appendix F: HHDL HSE Training Matrix

It is the responsibility of the CEO to ensure that the following HSE related training is provided .

Training Courses

Position2

Exe

cuti

ve D

ire

cto

r

CEO

HSE

Man

age

r

Dri

llin

g M

gr3

Oth

er

Man

age

rs

Eme

rge

ncy

Re

spo

nse

Team

man

age

rs

Staf

f

HSE Induction3 X X X X X X X

HSE MS Training3

X X X X X

Office Emergency Response4

X X

Onshore Emergency Response (site / rig specific) X X

HHDL Corporate Crisis Management X X X X X X

Well Control1 X

Notes: 1. HHDL requires relevant staff to manage their own time to acquire this training and keep it

current.

2. Some of these may be “outsourced” positions – if so HHDL (CEO) will assure themselves that

incumbent has these skills prior to placing contract

3. HSE manager will maintain records to monitor status of training / induction

4. HHDL is in serviced office, company with responsibility for office will develop and maintain

this “Office Response Plan”




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Appendix G: Supporting Documentation

The following documents support the HSE MS:

HHDL Crisis Management Plan (HSE-HH1-OP-02)



HSE Risk Assessment (HSE-HH1-OP-06)

Horse Hill 1 Environmental Aspects (HSE-HH1-OP-07)

Horse Hill 1 Compliance Matrix (HSE-HH1-OP-08)

Horse Hill 1 HSE Contract Clauses (HSE-HH1-OP-09)

Horse Hill 1 Risk Register (HSE-HH1-REC-01)