jx nippon layang fpso

92
PROVISION FOR OF EPCIC AND LEASING FOR LAYANG FPSO FACILITIES Document No. A Revision HEALTH, SAFETY & ENVIRONMENTAL PLAN REV. NO. : A PSP-XXX-HSE-01 PAGE 1 OF 94 PROVISION FOR EPCIC AND LEASING FOR LAYANG FPSO FACILITIES FOR JX NIPPON OIL & GAS EXPLORATION (MALAYSIA) LIMITED TENDER NO.: PJT-13-C-019 HEALTH, SAFETY AND ENVIRONMENTAL PLAN A 20/10 NY For Client Review MAMY MSS REV. DATE BY DESCRIPTION Checked Approved Approved THHE Fabricators Sdn Bhd JX NIPPON OIL

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Page 1: JX Nippon Layang FPSO

PROVISION FOR OF EPCIC

AND LEASING FOR LAYANG

FPSO FACILITIES

Document No. A Revision HEALTH, SAFETY & ENVIRONMENTAL

PLAN

REV. NO. : A

PSP-XXX-HSE-01 PAGE 1 OF 94

PROVISION FOR EPCIC

AND

LEASING FOR LAYANG FPSO FACILITIES

FOR

JX NIPPON OIL & GAS EXPLORATION (MALAYSIA) LIMITED

TENDER NO.: PJT-13-C-019

HEALTH, SAFETY AND ENVIRONMENTAL PLAN

A 20/10 NY For Client Review MAMY MSS

REV. DATE BY DESCRIPTION

Checked Approved Approved

THHE Fabricators Sdn Bhd JX NIPPON OIL

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Document No. A Revision HEALTH, SAFETY & ENVIRONMENTAL

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REV. NO. : A

PSP-XXX-HSE-01 PAGE 2 OF 94

REVISION LIST

Section Rev. Date Description of Amendments

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TABLE OF CONTENTS

SECTION DESCRIPTION PAGE

1.0 OVERVIEW 6

2.0 INTRODUCTION 7

3.0 PURPOSE 7

4.0 SCOPE 8

5.0 REFERENCES 8

6.0 DEFINITIONS/ ABBREVIATIONS 10

7.0 PROCEDURES 11

7.1 LEADERSHIP AND COMMITMENT 11

7.1.1 Management Leadership and Commitment 12

7.1.2 Workers Commitment and Involvement 13

7.2 POLICY AND STRATEGIC OBJECTIVES 13

7.2.1 General 13

7.2.2 HSE Policy 14

7.2.3 Stop Work Policy 14

7.2.4 Drug and Alcohol Policy 15

7.2.5 Yard No Smoking Policy 15

7.2.6 HSE objectives / Targets 16

7.2.7 HSE Performance Target 17

7.3 ORGANIZATION, RESPONSIBILITIES, RESOURCES,

STANDARD AND DOCUMENTATION 20

7.3.1 General 20

7.3.2 Legal Requirement and Regulations 21

7.3.3 Training and Competency 22

7.3.4 Contractor Management 25

7.3.5 Communication Process 38

7.4 HAZARD, RISK AND ASPECT IMPACT MANAGEMENT 32

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PROCESS

7.4.1 General 32

7.4.2 HIRARC and Aspect, Impact 35

7.4.3 Job Hazard Analysis 38

7.4.4 U see U Act Program 38

7.4.5 Daily HSE Surveillance 38

7.5 PLANNING AND PROCEDURES 39

7.5.1 General 39

7.5.2 Standards and Specification 39

7.5.3 Technical Integrity 40

7.5.4 Management of Change 41

7.5.5

HSE Procedure, Guideline and Project Specific

Procedure 42

7.5.6 Emergency Response and Preparedness 43

7.5.7 Documentation and Control 46

7.6 IMPLEMENTATION AND MONITORING 47

7.6.1 General 47

7.6.2 Safe Work Practices 48

7.6.3 Inspection and Monitoring 57

7.6.4 Occupational Health and Hygiene Management 59

7.6.5 Environmental Management 64

7.6.6 Promotional and Incentive Scheme 66

7.6.7 Incident Reporting and Investigation 67

7.6.8 Security Management 70

7.7 HSE AUDIT 70

7.7.1 General 70

7.7.2 Audit Plan 71

7.8 HSE OPERATIONAL REVIEW 73

7.8.1 General 73

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ATTACHMENT

ATTACHMENT I: POLICIES

A. Health, Safety and Environment Policy

B. Drugs and Alcohol Policy

C. Stop Work Policy

D. Yard No Smoking Policy

ATTACHMENT II: Sample of Fabrication Hazard Register

ATTACHMENT III: Sample of HUC Risk Register

ATTACHMENT IV: Sample of HSE Plan and Programme

ATTACHMENT V: Roles and Responsibility

ATTACHMENT VI: Hospital Tuanku Ampuan Rahimah, Klang Direction

ATTACHMENT VII: Pantai Klang Specialist Medical Centre Direction

ATTACHMENT VIII: PPE for Offshore Personal

ATTACHMENT IX: Incident Notification Flowchart

ATTACHMENT XI: Incident Notification Matrix

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1.0 OVERVIEW

JX Nippon Oil & Gas Exploration (Malaysia) Limited (NIPPON) currently operates the Helang

gas field which is located 184 km North Northeast (NNE) of Bintulu, and approximately 85 km

Northwest (NW) of Miri, offshore of Sarawak in 90 meters of water in SK-10 PSC. It was

developed as part of the MLNG-Tiga system.

The Layang field lies 7 km to the east of the existing Helang Integrated Platform (HIP). Layang

field shall be developed by unmanned wellhead platform connected with a Subsea Pipeline to

a Floating, Production, Storage and Offloading (FPSO) vessel.

Layang and some of HIP well fluids shall be processed at FPSO, after the separation Layang produced liquids shall be stored in FPSO and later on to be offloaded and exported to onshore by using regular shuttle tanker service. The produced gas shall be sent to existing HIP and exported to B11 through existing 24” Subsea Pipeline.

LAYANG FIELDS

JX Nippon Oil & Gas Exploration (Malaysia) Limited (NIPPON) currently operates the Helang

gas field located offshore Malaysia, approximately 85km northwest of Miri. As part of the Area

Development Plan (ADP), NIPPON is progressing plans to develop the Layang field, which is

approximately 7km east of the Helang platform.

The Layang field lies offshore Sarawak in Block SK10 as shown in Figure 1.1, which NIPPON

acquired in 1987. The natural gas produced from this block, along with that from neighbouring

Block SK8 is exported via the Bintulu onshore plant.

Layang field shall be developed by unmanned wellhead platform connected with a pipeline to

FPSO. Layang well fluids shall be processed at FPSO and the produced gas shall be sent to

existing HIP and exported to B11 while produced liquids shall be stored in FPSO and later on

to be offloaded to downstream refineries via tanker.

Processed gas is off-loaded from the FPSO through a 10” x 2.5km Flexible Pipeline to the HIP

and tied into the HIP gas Export Pipeline with no further processing and exported to the B11

Complex through 24” Subsea Pipeline. Processed condensate/crude is stored in FPSO and

off-loaded to downstream refineries via tanker.

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Figure 1.1: Schematic of Layang Field Locality

Figure 2.1: Flow Scheme for Layang Field Development

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2.0 INTRODUCTION

2.1 This Project Health, Safety and Environmental Plan sets out THHEFSB‟s

requirements for HSE. The Plan contains provisions to ensure that the HSE Policy

requirements are fully implemented.

2.2 THHEFSB‟s HSE Policy will be published, both in English and Bahasa Melayu and

will be brought to the attention of all employees and subcontractors.

2.3 THHEFSB acknowledges that for Health, Safety and Environment to be managed

effectively, all employees must be aware of the standards demanded and be

encouraged to achieve those standards. All management and staff in a supervisory

position will be required to lead by example and conduct their behaviour in a manner

befitting their position.

2.4 Any person found to be disregarding the requirements of this plan will be subject to

disciplinary action which may result in their dismissal from the Project.

2.5 THHEFSB recognizes the fact that it is good business to achieve the highest possible

standards in health and safety in all of its operations. All accidents, irrespective of the

severity, involve costs. These accidental costs if uncontrolled can substantially affect

the final cost and subsequently the profitability of the whole undertaking.

3.0 PURPOSE

This Project specific HSE Plan is specifically prepared for providing a general description and

requirement of the HSE matters to be adopted throughout fabrication period of Project. All

procedures and references made herewith shall be applied where applicable to achieve the

highest standard of Health, Safety and Environmental.

The objective of the Project Safety Management Plan is to provide guidance to achieve the

project safety goal of zero incidents. The intent of “Zero Incident” thinking is to eliminate all on-

the-job accidents by changing the behaviour and thinking (mindset) of Management,

Supervisors, and Employees so they will live every day by the Project‟s Safety Tenets:

i. Says do it safely or not at all

ii. Always stop unsafe conditions and behaviours

iii. Always follow safe WORK practices

iv. Always operate equipment within design and environmental

v. Limits and with safety devices armed

vi. Doing it safely is always more important than schedule or cost

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vii. Management actions will always proactively support the safety tenets

Leadership and accountability at all levels of the Project Management Team, as well as

Contractor Management will be required to foster a “Zero Incident” mentality. Visible

Management Engagement will also be critical to the success of the project safety goals and

objectives.

4.0 SCOPE

THHE scope of work for the JX Nippon Project is Onshore Pre-fabrication and Offshore

Modification Works for JX Nippon‟s Facilities. The Project Specific HSE Plan is sets out for

THHEFSB‟s HSE requirement. This procedure is applicable to all work areas for „Project‟.

This procedure is applicable to THHEFSB and subcontractor employees, vendor, suppliers as

well as visitors as a guideline to execute „Project‟ in a safe manner from beginning to end of

Project.

5.0 REFERENCE

5.1 ISO 9001:2008 Quality Management Systems

5.2 ISO 14001:2004 Environmental Management Systems – Requirements

5.3 OHSAS 18001:2007 Occupational Health and Safety Management Systems –

Requirements

5.4 Exhibit I Scope of Work,

ITB No. PJT-13-C-019

5.5 Exhibit I, Scope of Work

13.0 Health, Safety And Environment

ITB No. PJT-13-C-019

5.6 PTS 60.1501.06 Guideline on Health Assessment for Fitness to Work

5.7 PTS 60.1501.02 Substance Misuse

5.8 PTS 60.1510 Management of Fatigue In The Workplace

5.9 PTS 60.1501.09 Pandemic Preparedness and Response Guideline

5.10 PTS 60.1501.08 Food Safety Guideline

5.11 PTS 60.2201 Management of Change

5.12 PTS 60.0305 Contractor HSE Management

5.13 PTS 60.1400.01 Health Risk Assessment

5.14 PTS 60.3310 Environmentally Hazardous Substances Management Guideline

5.15 PTS 60.3005 Waste Management Guideline

5.16 PTS 60.2206 Design Integrity

5.17 PTS 60.1502 Chemical Management Programme

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5.18 PTS 60.1504 Hearing Conservation Programme

5.19 PTS 60.1502.02 Asbestos Guidelines

5.20 PTS 60.2004 Hazard Identification (HAZID)

5.21 PTS 60.0101 HSE Management Systems

5.22 PTS.1110-001 PPMS Project HSE Management Plan Guideline

5.23 PTS 60.1400.01 Health Risk Assessment

5.24 PTS 60.1501.03 Health Surveillance

5.25 PTS 60.1506 Drinking Water

5.26 PTS 60.2001 Permit To Work System

5.27 PTS 60.2105 Entry Into Confined Space

5.28 PTS 60.2104 Working at Height

5.29 PTS 60.2106 Scaffolding Safety

5.30 PTS 60.2103 Lifting

5.31 PTS 60.2114 Personal Protective Equipment Guide

5.32 PTS 60.0501 Incident Classification, Reposting and Investigation

5.33 IMS-HSE-01-01 Aspect/Impact, Hazard Identification and Risk Management

5.34 IMS-HSE-02-01 Legal Register Procedure

5.35 IMS-HSE-03-01 Communication, Participation & Consultation

5.36 IMS-HSE-04-01 HSE Operational Procedure

5.37 IMS-HSE-05-01 Emergency Response and Preparedness

5.38 IMS-HSE-06-01 HSE Monitoring & Measurement

5.39 IMS-HSE-07-01 HSE Evaluation Of Compliance

5.40 IMS-HSE-09-01 Incident Notification, Investigation And Reporting

5.41 IMS-HSE-10-04 Hazardous Substances

5.42 IMS-HSE-12-04 Confined Space

5.43 IMS-HSE-13-04 HSE Performance, Statistics and Analysis

5.44 IMS-HSE-15-04 Inspection And Colour Coding Of Tools And Equipments

5.45 IMS-HSE-16-04 Waste Management

5.46 IMS-HSE-17-03 Lifting Management Procedure

5.47 IMS-HSE-18-04 Health Programme Procedure

5.48 IMS-HSE-19-06 Permit To Work

5.49 IMS-HSE-20-04 Personal Protective Equipment

5.50 IMS-HSE-21-04 HSE Requirements For Contractors

5.51 IMS-HSE-22-03 Hot Work Procedure

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6.0 DEFINITION / ABBREVIATION

7.0 PROCEDURE

7.1 LEADERSHIP AND COMMITMENT

This element addresses the management and THHEFSB commitment to sustain a

culture that ensures the success of the HSE MANAGEMENT SYSTEM. These

requirements apply to all Management personnel who provide the leadership,

commitment and guidance for the successful implementation of HSE MANAGEMENT

SYSTEM.

Management shall provide a visible and strong leadership and commitment to the HSE

MANAGEMENT SYSTEM.

AELB - Atomic Energy Licensing Board

BOSET - Basic Offshore Safety and Emergency Training

CIDB - Construction Industrial Development Board

CSR - Company Site Representative

DOE - Department of Environment

DOSH - Department of Occupational, Safety & Health

ERPP - Emergency Response and Preparedness Plan

ERT - Emergency Response Team

HIRARC - Hazard Identification, Risk Assessment and Risk Control

HSE - Health, Safety, Environmental & Security

HSE-MS - HSE Management System

JHA - Job Hazard Analysis

Medevac - Medical Evacuation

MER - Medical Emergency Response

NIOSH - National Institute of Occupational Safety & Health

NOSCP National Oil Spill Contingency Plan

MOCA - Malaysian Offshore Contractor Association

PCSB - Petronas Carigali Sdn Bhd

PPE - Personal Protective Equipment

PTW - Permit To Work

THHEB - TH Heavy Engineering Berhad

THHEFSB - THHE Fabricators Sdn. Bhd.

UCUA - U See U Act Report Card

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Management shall provide sufficient resources and support for the compliance and

adherence of the HSE Policy and strategic objective requirements.

The leadership and commitment which is to be facilitated through the creation of a

company culture that supports the HSE MANAGEMENT SYSTEM, based on:

Belief in the company‟s intention to improve and maintain its HSE

performance at a required level for effective HSE MANAGEMENT SYSTEM

implementation.

Motivation to improve personal HSE performance based on positive

recognition, desirable attitudes and acceptance of individual

responsibility.

Participation of staff at all levels by encouraging their involvement and

incorporating their input in HSE MANAGEMENT SYSTEM development, and

continually seeking and supporting their suggestions for improvement.

Commitment of staff of all levels is essential to have a successful, effective

consistent implementation and maintenance of the HSE MANAGEMENT

SYSTEM.

Management shall also assure that adequate commitment is given for the effective

implementation of all program elements in the HSE MANAGEMENT SYSTEM, which

involve contractors and Client‟s representatives.

THHEFSB Management demonstrates their commitment towards HSE by:

Allocating adequate resources needed to HSE matters

Meeting agenda from Board downwards shall discuss highly on HSE matters,

including HSE performance data

Being actively involved in HSE activities and reviews, at both local and remote

sites

Imparting the importance of HSE considerations in business decisions

Identifying performance for achieved objectives

Participating in incident investigations, HSE plans, internal and external

initiatives and audits

Setting a personal example in day-to-day work

Conducting HSE audits or inspections personally

Attending HSE meetings/conferences outside the company

Developing an open approach to external liaison with authorities and the

general public

Spending time in the field

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7.1.1 Management Leadership and Commitment

THHEFSB management i.e. Managers, Engineers, Superintendents,

Supervisors and Technicians shall exhibit their leadership and commitment to

the HSE requirements.

In meeting this Project HSE Plan intent, management shall provide a visible and

strong leadership and commitment to HSE, which shall be instilled throughout

the organization based on:

Demonstration of leadership by nurturing a working culture of HSE

consciousness.

Participation of staff from all level in seeking their views and involvement in

the implementation of HSE programs.

Motivation to improve staff HSE awareness level and performance based on

positive attitude and acceptance of their respective roles and

responsibilities.

Commitment of all levels in meeting the agenda of the Project HSE Plan.

Setting personal examples in day-to-day activities.

Allocating the required resources to HSE matters.

Promoting HSE matters in meeting agendas and publication.

Communicating importance of HSE considerations in business decisions.

Encouraging suggestions for improvement of HSE performance.

Rewarding HSE performance when objectives are met or exceeded.

7.1.2 Workers Commitment and Involvement

To achieve a high standard for Health, Safety and Environment, workers

involvement and commitment is paramount. THHEFSB management will

provide necessary resources i.e. Personal Protective Equipments (PPE),

Trainings, HSE Briefings, Safety Incentives, and other programs that could

enhance workers among safety, health and environment awareness.

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7.2 POLICY AND STRATEGIC OBJECTIVES

7.2.1 General

As one of the leading company contributing to the oil and gas industries,

THHEFSB is very much aware of the potential risks, either inherent or caused

by which are prone to affect the Health, Safety and Environment (HSE).

THHEFSB has taken a laudable step in providing an Integrated Management

Systems Policy based on the ISO 9001, OHSAS 18001 and ISO 14001. It is the

intention of THHEFSB intends to envisage excellence in executing its activities,

products and services that meets customers‟, contractual, legal obligation,

Health, Safety and Environment requirements.

In addition to the IMS Policy, THHEFSB has in place the HSE Policy, Stop

Work Policy, Drugs & Alcohol Policy and the Yard No Smoking Policy for its

subsidiaries, in ensuring a healthy and safe work environment within THHEFSB

activities and workplace.

These policies are supported with Strategic Objectives that address and

elaborate the main essence of the respective policies outlined. The Strategic

Objectives also provide the appropriate measures to be taken in order to

accomplish the policies.

These policies are owned by the THHEB MD & CEO. The Designated General

Manager is the main custodian who is responsible for reviewing and

subsequent updates.

Being a dynamic company, changes within the company are anticipated from

time to time. These changes may bring about the requirement for regular review

of these policies. THHEFSB expects that the policies be regularly reviewed at

least on a yearly basis with emphasis on its intent, scope and adequacy.

7.2.2 HSE Policy

HSE Policy provides a means of communicating management objectives and

requirements in managing aspects of Health, Safety and the Environment which

may affect personnel to the environment as a result of the company business

activities.

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The intention of the Policy is to establish company commitment to health, safety

and environmental issues surrounding its activities. The policy was proposed

and then adopted by company functional management team and shall be

referenced as a basis for the formulation of various department plans and

objectives.

It is the company management intention to reduce the HSE risks to a

reasonably practicable and the company pledges to improve HSE performance

on a continual basis.

7.2.3 Stop Work Policy

Notwithstanding the Company‟s commitment to the safety and welfare of its

employees, it remains the responsibility of each individual to conduct

themselves with due respect to his or her health and safety as well as the well-

being of the environment.

Company employees need to understand that they have a duty and

responsibility to stop work that is being attempted in an unsafe manner, and

advise the respective personnel immediately where and why this has been

done. This obligation is reflected in the stop work policy.

7.2.4 Drugs and Alcohol Policy

Company is committed to the promotion of health and well being of its

personnel and contractor. As such company has a policy that explicitly

addresses the use of illegal drugs, misuse of medications and inappropriate use

of alcohol within its business activities. These substances may pose serious

affects to the personnel safety, health, job performance and subsequently might

affect the environment.

The policy applies to all personnel including Company, Clients, vendors and

contractors. Company expects full adherence to the policy and encourages that

contractor has a similar arrangement in meeting the intent of this policy. All

workers onsite need to comply with D&A policy and demonstrate commitment

by conducting D&A random screening at worksite. Test for Cause shall be done

for the following post incident and suspected under the influence of D&A.

Deviation and violation to this policy will be subjected to severe consequences,

either stern disciplinary action or deployment from company activities.

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7.2.5 Yard No Smoking Policy

The Objective of this Smoking Policy is to help maintain a safe and health

working environment in the Fabrication Yard and reflecting our support to the

government‟s call for the “Say No to Smoking” campaign.

(Refer to Attachment I: Policies)

7.2.6 HSE objectives / Targets

Objective Strategy KPI Target

To achieve

specific HSE

standard for

JX NIPPON

Project

Supervisory

personnel shall

engage closely in

HSE matters

Number of HSE

meeting

At least 30 weekly HSE

meeting conducted

(estimated 12 months Project

duration)

Number of HSE

walkabout

at least 30 weekly HSE

walkabout conducted

(estimated 12 months Project

duration)

To progress

towards

becoming a

self-regulating

body

Identify and

manage hazards

related to activities

executed

Number of Hazard

removed

100% close-out of hazards

prior to commencing activity.

To develop

HSE culture

through

implementing

proactive HSE

requirements

Engaging fit-to-work

employees

Number of random

Drug & Alcohol testing

conducted

At least 10% of average

manpower undergo test.

To ensure

information is

fully utilized in

improving

system of work

Communication of

site hazards.

Worksite

intervening to stop

unsafe acts/

conditions

Number of unsafe acts

and unsafe conditions

reports

90% of significant UCUA

reports to be closed-out

within 3 days.

To obtain

compliance of

Subcontractors

Compliance to

Project HSE

requirements

Number of

Subcontractor

inspection and audit

Weekly inspection and

monthly audit

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Regulatory

Authorities

Reporting

Establishment of

regulatory reporting

database.

Within timeframes and

provision of information

required as outlined.

Training

requirements

for all

personnel.

Establishment of

Weekly Training

Report

Number of training

conducted vs. training

matrix

100% completion of training

requirements for all

personnel as per training

matrix

HSE activities

matrix.

Establishment of

Weekly HSE Report

Number of actual

program vs. plan

100% completion of HSE

activity training requirements

for all personnel as per

training matrix

7.2.7 HSE Performance Target

Table 1: Lagging Indicator

DESCRIPTION TARGET

Safety Performance

Lost Time Injuries (LTI) 0

Fatality 0

Permanent Total/ Partial Disability (PTD/PPD) 0

Lost Workday Case (LWC) 0

Non Lost Time Injuries 0

Restricted Work Case (RWC) 0

Medical Treatment Case (MTC) 0

Lost Time Injury 0

First Aid Injury 0

Non-Injurious Incident 0

Fire/ Explosion 0

Property / Equipment Damage 0

Near Misses

Lost Time Injury Frequency (LTIF) 0

Total Recordable Cases (TRC) 0

Total Recordable Cases Frequency (TRCF) <1.30 (Aspiration of Project 0)

Environmental Performance

Spillage of Environmentally Hazardous

Substance into the sea 0

Environmental Incident 0

Health Performance

Occupational illness Case 0

Total Recordable occupational Illness TROI 0

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Table 2: Leading Indicator

DESCRIPTION TARGET

Senior Management Walkabout Monthly

Senior Management HSE Meeting Quarterly

Monthly Mass Toolbox Monthly

Emergency Response Exercise

Tier 1

Quarterly

Project HSE Committee Meeting Weekly

HSE Statistics and Activities Report Weekly

HSE Mandatory Training

HSE Induction

CIDB Green Card/ NOSP

BOSET

100% attended except for BOSET for

offshore personal

U See U Act (UCUA) 1 UCUA for every 500 man-hours

Note: If the estimated PROJECT man-hours throughout the duration of the Project are 500,000

man-hours. The UCUA submission should be approximately 1000 throughout the duration of

the Project.

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Table 3: Report Submission

DESCRIPTION TO WHOM WHEN

HSE Report JX Nippon 5th Day of Each Month

Incident Notification Report JX Nippon within forty-eight (48) hours

Status update of incident

investigation findings and

remedial action taken

JX Nippon Monthly

Summary report of all incident

statistics, manpower loading

and man-hours work record

JX Nippon Weekly and Monthly

Record of HSE incentives

adopted and results achieved

JX Nippon Monthly

Record of non-conformance

and status of corrective actions

JX Nippon Monthly

Report on compliance audit

of HSE Execution Plan and

WORK SITE HSE procedures

JX Nippon Monthly

Minutes of WORK SITE HSE

Committee meeting

JX Nippon Monthly

The HSE Performance target shall be delivered by THHEFSB to senior personal,

supervisor, shop floor and subcontractor through effective communication, consultation

and participation. HSE Plan Kick-Off Briefing shall be the place in delivering the project

HSE path and performance target. In addition to that, other mode of conveying the

message are through mass toolbox talk, daily toolbox talk, HSE Committee Meeting, HSE

Engagement with subcontractor and by displaying at notice boards.

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7.3 ORGANIZATION, RESPONSIBILITIES, RESOURCES, STANDARDS AND

DOCUMENTATION

7.3.1 General

The Company‟s structure illustrates the overall responsibility of THHEFSB

organization and line managers for the implementation of the HSE

OPERATIONAL CONTROL within their area of authority.

THHEFSB is fully aware that a HSE committee is essential in promoting the

awareness of HSE issues throughout the company organization, apart from

complying with the OSHA Act 1994 requirements. It also encourages proactive

communication pertaining to HSE among the personnel.

The Company‟s organization must also be sensitive and aligned with any

changes to be made either to facilities equipment, documentation, methods and

work scope.

Communication within the organization is necessary in ensuring that hazard

information is clearly defined and disseminated. A good communication

process also helps in establishing HSE interest and involvement by the

company‟s personnel.

Adherence to approved codes and standards and formulating the drug and

alcohol policy are other measures taken by THHEFSB in maintaining a

proactive HSE culture within its organization.

Please refer to Attachment V for Roles and Responsibilities

7.3.2 Legal Requirements and Regulations

THHEFSB shall comply with all applicable HSE regulations and safe operating

standards and shall take all necessary safety precautions related to or arising

out of the performance of the contract in order to protect the work, the personnel

and property of COMPANY, the THHEFSB and related parties.

Legal and other related requirements shall be referring to the THHEFSB legal

register. Please refer to IMS-03-XX Legal and other requirement procedure. The

THHEFSB shall meet or exceed the requirements of the following codes and

standards:

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a) COMPANY Health, Security, Safety and Environmental requirements.

b) Merchant Shipping Ordinance 1952

c) Merchant Shipping (Amendment & Extension) Act 2007 (Act A1316)

d) Factories and Machinery Act (FMA) 1967 (Act 139), Regulations and Rules

e) Occupational Safety and Health Act (OSHA) 1994 (Act 514), Regulations

and Rules

f) Environmental Quality Act (EQA) 1974 (Act 127), Regulations and

Rules

g) Malaysian Standard Code of Practices & Guidelines for Safety and

Health of Work

h) Atomic Energy Licensing Act 1984 (Act 304)

i) Atomic Energy Licensing (Basic Safety Radiation Protection) Regulations

2010

j) Petroleum (Safety Measures) Act 1984 (Act 302)

k) Fire Services Act 1988 (Act 314)

l) Dangerous Drugs Act 1952 (Act 234)

m) Petroleum (Safety Measures) (Transportation of Petroleum by

Pipelines) Regulations 1985; and any other such requirement

n) The Radiation Protection (Licensing) Regulations 1986

o) The Radiation Protection (Basic Safety Standards) Regulations 1987

p) International Ship and Port Facility Security (ISPS) Code

q) Code of Practice for Safe Working in a Confined Space 2001

r) Malaysian Standard MS 426 (1976) Code of Practice for General

Principles for Safe Working in Industry

s) Malaysian Standard MS 949: Code of Practice for Safety in Welding and

Cutting

t) Exclusive Economic Zone Act 1984 (Act 311)

u) International Ship and Port Facility Security (ISPS) Code

v) Safety of Life at Sea (SOLAS) Convention 1974

w) International Convention for the Prevention of Pollution from ShSIS, 1973

as modified by the Protocol of 1973 (MARPOL 73/78), Edition 2006

x) IMO Standard on Life Saving Appliances, Edition 2010

y) International Marine Contractors Association (IMCA)

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7.3.3 Training and Competency

7.3.3.1 General

Effective job performance depends on good selection, training and

development of personnel.

THHEFSB management recognises that proper performance of every

job task depends on good training and effective task instruction. Thus,

they are committed to provide all employees comprehensive

instruction in the jobs that they are expected to do, with update

training given at regular intervals.

In any event, it is the responsibility of each department to ensure its

staff receives the appropriate HSE training. Similarly, General and

Project Managers shall ensure that sub-contractor personnel

associated with their respective departmental activities receive the

required minimum training as appropriate.

Manager or Heads of Department shall be responsible to identify the

yearly training needs and plan of training for his/ her subordinate

through Training Needs Analysis distributed during the yearly

Performance Appraisal exercise.

Other methods of identifying the training needs of employees are from

the hazard identification, risk assessment and risk control result,

training matrix, HSE Critical Roles, legal and regulatory requirements

and clients‟ requirement.

7.3.3.2 Mandatory HSE Training

a) THHEFSB recognizes that the first few days on site are

potentially the most hazardous for any new employee. To ensure

that new employees are familiar with THHEFSB HSE

requirements, all the new employees shall attend an HSE

induction course, Construction Industrial Development Board

(CIDB) Green Card Training and Basic Offshore Safety and

Emergency Training (BOSET) for offshore personnel. This course

is applicable to all THHEFSB and subcontractors‟ employees as

well as client representatives.

b) HSE Induction Course for both onshore and offshore shall be

attended by all employees, conducted by qualified personnel who

have attended the required training program.

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Upon completion of the training, personnel are given a sticker to

indicate they have completed the HSE induction course. The

sticker shall be prominently displayed on the safety helmet at

workplace.

The topics discuss in the HSE Induction Course are;

HSE Policy, Drugs & Alcohol Policy, Stop Work Policy and No

Smoking Policy.

Legal and related requirements such as THHEFSB rules and

regulation including penalty system.

Overview of Work activities and general workplace HSE

awareness.

Typical hazards & risks, and impact of exposure.

Permit to Work System and JHA.

Emergency response and evacuation procedures.

Use of PPEs, safety equipment and tools

Handling of hazardous materials and waste management

Housekeeping, general hygiene and smoking policy

Occupational Health, Medical and first aid facilities

Environmental Protection

c) Subcontractor Project Manager shall maintain a register of

employees, which has attended and passed the HSE Mandatory

Training. THHEFSB QHSE Department has the right to audit this

register from time to time.

d) THHEFSB QHSE Department also has the right to prevent any

employees without above-mentioned identification from entering

and working in the THHE premises.

7.3.3.3 HSE Training

a) Regular HSE training will be implemented for the Project with

assistance from THHEFSB Project Manager and Subcontractor

Project Manager. They shall to ensure all employees attend the

required training throughout Project duration.

b) Subcontractor Project Manager shall be responsible to maintain

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and updated register of employees attending provided by

THHEFSB.

c) THHEFSB QHSE Department has the right to audit this register

from time to time.

(Refer to Attachment II: Sample of HSE Plan and Programme details)

7.3.3.4 Competency

THHEFSB management recognises that the key success for HSE

OPERATIONAL CONTROL implementation is the allocation of

sufficient and competent resources.

Where resources are contracted, the minimum level of competencies

required to carry out HSE activities shall be defined and allowances

made for any training necessary. THHEFSB encourages employee

involvement as it promotes teamwork in meeting company HSE goals.

Personnel undertaking the following jobs/tasks shall require

certificates or formal appointment to confirm their competency.

Gas Tester

Crane Operator

Scaffolder

Electrician specific to class of works (voltage, etc.)

Site Inspector specific to type of inspection

Radiographer

Welders for particular class of welding to code requirements

Emergency Response Team

THHEFSB will continuously ensure that regular review and

assessment on its employees‟ competency to perform their duties is

carried out. In addition, consideration of personal development and

training required in achieving competence for changing activities and

technologies shall also be accounted for.

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7.3.3.5 Training Records

Records of all training attained by each individual for THHEFSB are

kept under the custodianship of the HRA Department. The records

contained information on personal details, recruitment records,

medicals, vocational, training certificates and other personnel related

documents.

These records are filed in a manner to enable rapid access by the

QHSE Department to ascertained relevant personnel requirements

with regards to medicals, safety and training.

7.3.4 Contractor Management

THHEFSB requires that contractors have a mirror image HSE OPERATIONAL

CONTROL of their own, which shall be consistent with THHEFSB‟s standards

and expectations.

Procurement of all contractual services shall be controlled in accordance with

THHEFSB Procurement Management and all tender documents shall contain

standard HSE clauses specifying THHEFSB‟s HSE requirements.

The responsible manager within THHEFSB for the proposed contract shall

ensure that potential bidders are pre-qualified to meet THHEFSB‟s HSE

standards.

Prospective contractor shall have the ability to meet minimum HSE

performance criteria and requirements. The contractor shall complete a HSE

evaluation questionnaire that prompts the contractor to provide their HSE track

record, experience, qualification and ability to comply with HSE requirements.

The HSE Questionnaire shall be completed and submitted to the

Subcontracting department together with applicable documents.

THHEFSB shall evaluate and identify a shortlist of approved contractors who

meet the HSE criteria and only these will be considered for future contracts.

Potential contractor shall be assessed through the HSE Pre-qualification Audit

Process.

The responsible THHEFSB manager of the proposed contract shall ensure

that any specific HSE requirements are communicated to the contractors with

the tender documents. This may require the tenderer to provide:

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Details of working methods, demonstrating environmental protection and

safe work practices.

Skills/qualifications/competency/training of personnel.

Project organisation including HSE functions.

Responsibilities of individual personnel holding critical functions.

System to ensure effective management of interfaces between different

organisations including THHEFSB.

Selection of contractors, amongst other considerations, shall have specific

assessment of their HSE Policy, practices and performance, consistent with the

risk associated to the proposed services.

Contractor HSE Engagement shall be conducted timely to assist and mentoring

awarded contractor. HSE performances and reviews shall be managed and

implemented during the engagement and also during the weekly Project HSE

Committee Meeting which will be chair by Project Manager. It is THHEFSB

expectation for the contractor to have a mirror image of THHEFSB HSE

Management Plan.

Prior to the award of contract, a project HSE Plan kick-off briefing will be

conducted to brief on the HSE requirement for contractor to adhere. Relevant

work procedures and HSE Manuals shall be made available during the briefing.

THHEFSB is responsible for ensuring that all work is executed in accordance

with all statutory and safety regulations, codes of practice. At all times,

THHEFSB personnel, contractor and sub-contractor shall undertake the work in

as safe manner as practicable with due regards to the human health and the

environment.

7.3.4.1 THHEFSB Obligation

In order for an effective control of contractors can be realised, the

respective Project Manager shall:

Provide copy of all documents related to each contractor and

ensure that the contractual HSE obligations contained in these

documents are carried out by the contractor.

Ensure that all contractors are given the full orientation of the

Project scope before commencement of the work. The

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orientation shall at minimum include:

- Emergency procedures

- HSE rules and regulations

- Overview of THHEFSB HSE Procedure particularly

relating to Safe work practices, Permit to work system,

Personal Protective Equipment, THHEFSB Project

responsible personnel and THHEFSB HSE

OPERATIONAL CONTROL requirements

Arrange for the monitoring and inspection of contractor HSE

performance. For this purpose, substandard, non-compliance

or poor HSE performance of the contractors shall be compiled

and re-evaluated before being re-employed for other

THHEFSB Projects.

7.3.4.2 Personnel and Organization

Given the nature of the activities THHEFSB is involved in, it is crucial

that the contractor pay particular attention to the selection of

personnel for THHEFSB Projects.

Though THHEFSB does evaluate and select the contractor for each

of the contract, it does not however reduce the obligation of the

contractor to provide only qualified and experienced personnel for

THHEFSB Projects. For this purpose, only those personnel proposed

within the contract proposal and approved by THHEFSB can only be

employed for the Project.

In addition, the contractor shall also provide an effective organization

in ensuring that the Project can be managed within the stipulated

resources and schedule whilst maintaining a high HSE performance.

7.3.4.3 Systems and Equipment

All contractors‟ systems and equipment to be provided within the

Project shall meet all the codes, standards and THHEFSB

requirements. They are to be properly maintained and serviced to the

vendor specification and schedule and records shall be kept thereof.

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The systems and equipment shall be inspected prior to being

accepted to THHEFSB Projects. The applicable certificates from the

various authorities shall substantiate these passports. All these

documentation shall be handed over to THHEFSB prior to start work.

7.3.4.4 HSE Compliance Audit

Contractors are also subjected to THHEFSB audit in determining their

HSE Compliance to legal and other related requirement. There are

required to closed out findings during the audit in a given time period.

Failure to close might result in the consequence management.

7.3.4.5 Induction to HSE Expectations and Requirements

Project HSE Plan roll-out commencing after the award of contract to

the contractor. In the HSE Plan roll-out, HSE roles and

responsibilities, obligation, target, objective and strategy are being

discussed and explained to Contractors.

7.3.5 Communication Process

THHEFSB has taken the effort of establishing a communication system for

sharing of information on HSE matters and the involvement of management,

employees, contractors, Clients and the community to improve HSE

performance.

7.3.5.1 Project HSE Committee Meeting

THHEFSB firmly believes that to obtain commitment to HSE, all

personnel must be actively engaged in, and have a voice in, matters

relating to their safety, health and welfare. To accomplish this, the

HSE Committee is to be established at the various THHEFSB

business levels, to provide a framework within which the HSE Policy

can be developed and performance monitored. Project HSE

Committee Meeting is one of the medium whereby disseminate and

communication of policies are brought down from top management to

lower employees.

HSE committees play a role in assisting to impart HSE information

within the company.

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The committee members are responsible for communicating

information to employees at all stages of HSE studies while

maintaining confidential information.

a) The Project HSE committee meeting will be held once a week or

as agreed by the Project HSE Committee members.

b) The HSE committee meeting will be chaired by the Project

Manager or designate and the following, are required to attend:-

Client Representative if required.

THHEFSB Representative.

Subcontractor‟s Representative.

c) The agenda shall include a review of all matters related to HSE,

which have occurred during the previous week and measures

implemented to prevent any recurrence. The committee will also

review all HSE statistic and any matters requiring urgent action.

d) Copy of HSE Minute of meeting shall send to QHSE Department.

7.3.5.2 Project Management/ Sub-Contractor Meeting

a) Regular meeting will be arranged by the Project Management

Team with subcontractors currently undertaking work in the

Project. The agenda of any such meeting will include regulatory

compliance and site HSE matters.

7.3.5.3 HSE Briefing, Safety Stands Down, Toolbox Talk and Monthly

Mass Toolbox

a) Talks are held to permit meaningful communication throughout

the organization and to plan for continuous HSE improvement.

b) Discipline line management i.e. engineers, superintendent,

supervisor, technician or foreman will organize daily HSE briefing

and toolbox talk at the workplace. Topics selected shall be

relevant to the current activities.

c) HSE briefings shall be regularly delivered by all personnel.

These briefings will be delivered to focus on any new or current

operations, any recurrence or problem areas and any recent

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accidents and will actively encourage the passage of two way

information. General HSE briefings shall be carried out once a

week.

d) Safety Stands Down may also be delivered following any

problems, recurring accidents or any dangerous occurrence to

communicate THHEFSB‟s requirements or information.

e) The daily tool-box meeting which is held prior to commencement

of work is conducted by the respective line supervisor. This

meeting generally discusses outstanding works from previous

shift, Job Hazard Analysis and other HSE issues.

f) Toolbox talk will be conducted daily at the workplace by the

relevant line management prior to commencement of any activity.

The toolbox talk should discuss the method statement and JHA

for the task and any controls required for the PTW, including

interaction with other ongoing activities.

g) Monthly mass toolbox talk is held on the first Monday of each

month. It is a mode of communicating information from top to

bottom whereby management is given the opportunity to share

their thought on HSE.

7.3.5.4 Client Progress Meeting/ Sponsors Meeting

a) The meeting is held between project owner and THHEFSB to

discuss and communicate on the project progress.

b) HSE Statistics, activities, event and legal requirement are part of

the meeting agenda.

c) The meeting are held on a weekly basis or as arranged by Project

owner.

7.3.5.5 HSE Progress Meeting

a) THHEFSB shall hold HSE progress meetings at least twice per

month for construction supervisions and designated HSE

personnel to assess and deliberate the effectiveness of the

program and implement improvement as necessary.

b) The meeting to ensure effective cascading HSE requirements

and expectations from management to the working levels.

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7.3.5.6 HSE Notice Board and Safety Bulletin

a) HSE Notice Board

Publicity in HSE is an essential requirement for instilling HSE

awareness and emphasizing the importance of safe work

practices for the ultimate benefit of every employee.

Each site office shall produce and maintain a HSE Notice Board.

The board shall display any recently introduced site notices, HSE

bulletin and any other items pertaining to HSE. The board shall

be regularly updated by the site HSE personnel.

HSE publicity is produced for the benefit of employees to improve

their knowledge and awareness and so improve their ability to

prevent accidents, safeguard health and protect the environment.

b) HSE Bulletin

HSE bulletins will be produced as required, giving the reader

details of any recent accidents or changed work practices

introduced following any accident. Safety bulletins should be

generated by the site HSE personnel.

7.4 HAZARD, RISK AND ASPECT, IMPACT MANAGEMENT PROCESS

7.4.1 General

THHEFSB has set a risk and impact management process throughout the

company‟s operation, to manage the risk and impact for each activity. The

process revolves around the identification of HSE hazard including the aspect

of the environment, evaluation of the HSE risks, determining the impact and

development of measures and procedures to minimize the risks. The purpose

of the risk and impact management is to ensure that risk and impact posed by

all potential hazards throughout its business operations are reduced to an

acceptable level or where it is practicable.

Though THHEFSB practices a systematic risk and impact management

program, it shall be noted that all potential hazards are to be managed early at

the design stage through a comprehensive and effective risk and impact

management systems as compared to having to resolve these issues at the

construction and installation stages.

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The fundamental of THHEFSB risk and impact management is to ensure that:

Hazard and aspect are identified, assessed and minimized or removed.

Residual hazard shall be eliminated during installation phase before

the operation of the facility.

The remaining acceptable risks will continue to be managed during

facility operation.

The essential principles of risk and impact management are as follows:

Ensure that all applicable statutory/regulatory requirements are

complied with.

Establish and document the health, safety and environmental plan for

the Project prior work start-up.

Identify the hazard and aspect, assess risk and the corresponding

effects and impact to the environment.

Ensure that employees of all stages recognize and familiar with the

hazards relating to their work by encouraging hazard communication.

Undertake health, safety and environmental inspection and monitoring

to ensure that selected hazard reduction measures are implemented.

Ensure that employees execute their respective responsibilities and

employ the necessary measures in order to manage the risk and

impact to the environment at the work place.

All Project activities shall be subjected to the hazard, risk and aspect, impact

management process.

7.4.2 Hazard Identification, Risk Assessment, Risk Control (HIRARC) and

Aspect/Impact

The identification and assessment of work site HSE hazard and aspect are the

first steps in the ultimate prevention and control of such risk and impact.

In addition to specific tools such as Job Hazard Analysis (JHA), Chemical

Health Risk Assessment (CHRA) and others, THHEFSB applies the Aspect/

Impact and Hazard Identification, Risk Assessment and Risk Control

(HIRARC) to manage and minimize any associated risk to an acceptable level

or where it is practicable.

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The Aspect/ Impact and HIRARC process is to be conducted for the following

situations but not limited to:

Routine and non-routine activities.

Introduction of new operational procedures.

Using new chemicals and materials in the plant.

Modification in yard processes and utilities.

Starting up equipment or systems.

Designing, constructing and commissioning of new or processes.

Risk and impact assessment shall be applied to a Project activity that falls

under statutory requirements or any other unusually hazardous activity that is

identified during hazard analysis.

It is the responsibility of the appointed Project Manager to ensure that risk

assessments are undertaken as prescribed by the statutory requirements or

contractual agreement.

Risk and Impact Assessment shall also be undertaken for unusually

hazardous activity where the consequence and its probability may impact the

employees, local environment and society.

Please refer to Attachment II: Sample of Fabrication Hazard Register and

Attachment III Sample of HUC Risk Register

Project heads or representative shall identify the risk and aspects relating to

their activities or processes and shall fill up the HIRARC, Aspect/ Impact

Form

Significance of the risk and aspects shall be evaluated by completing the

HIRARC, Aspect/ Impact Form using the assessment criteria. The impacts

are classified as High Risk („H‟), Medium („M‟) and Low Risk („L‟) through the

rating system base as per table of risk/ impact level.

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Table 4: Risk/ Impact Value

Severity (S)

Probability

(P) 1 2 3 4 5

5 5 10 15 20 25

4 4 8 12 16 20

3 3 6 9 12 15

2 2 4 6 8 10

1 1 2 3 4 5

Table 5 : Risk/ Impact Level

RISK DESCRIPTION ACTION

15-25 HIGH

A HIGH risk or impact requires immediate

action to control as detailed in the hierarchy

of control. Actions taken must be documented

on the assessement for monitoring purposes.

5-12 MEDIUM

A MEDIUM risk or impact requires a planned

approach to controlling the risk or impact

resulted from the hazard and environmental

aspect. Temporary measure shuld take place

if required. Actions taken must be

documented on the assessement for

monitoring purposes.

1-4 LOW

A risk or impact identified as LOW may be

considered as acceptable and further

reduction may not be necessary. However, if

the risk or impact can be resolved quickly and

efficiently, control measures should be

implemented and recorded.

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The Significant risk and impact level rating is obtained by multiplying the

scores allocated for the probability and severity as follows:

Risk/Impact Level = Probability x Severity.

e.g.

Probability = 2

Severity = 2

Risk/Impact

u

e

= 4, low but if it has a legal requirement,

meaning that the activities is considered

significant and control measure shall take

place.

Risk/ Impact Level which are rated 5 and above and/or made compulsory

under the Legal Requirement are considered to be significant.

Project heads or assigned shall determine the rating of probability and

severity as per below table.

Table 6: Probability of an Incident Occurrence.

Probability of An Incident Occurrence

Rating/

Consequence

Category

Probability Definition

5 Most Likely The most likely result of event being realized

4 Possible Has a good chance of occurring and is not unusual

3 Conceivable Might be occur at some time in future

2 Remote Has not been known to occur after many years

1 Inconceivable Is practically impossible and has never occurred

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Table 7: Severity of an Incident Occurrence.

Severity of An Incident Occurrence.

Rating/

Consequence

Category

Potential

Impact Definition

5 Massive Effect

Numerous fatalities, irrecoverable property damage and

productivity. Continual severe environmental damage or

severe nuisance over a large area. In terms of

commercial or recreational use or nature conservancy, a

major economic loss for the company.

Constant non-compliance of statutory or prescribed limits

4 Major Effect

Approximately one simple fatality, major property damage

if hazard is realized. Severe environmental damage. The

company is required to take extensive action measures to

restore the contaminated environment to its original state.

Extended non-compliance of statutory or prescribed limits.

3 Localised

Effect

Non-fatal injury, permanent disability. Limited loss of

discharge of known toxicity. Repeatedly exceeding

statutory or prescribed limits and beyond fence or

neighbourhood

2 Minor Effect

Disabling but not permanent injury. Contamination.

Damage sufficiently large to affect the environment. Single

non-compliance of statutory/prescribed criteria. Single

complaint. No permanent effect on the environment

1 Slight Injury

Minor abrasions, bruises, cuts, first aid type injury. Slight

financial consequences, restricted environmental risk

within the fence and system

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7.4.3 Job Hazard Analysis (JHA)

Job Hazard Analysis (JHA) is a systematic review of work practices with the

purpose of identifying hazards and developing recommendations for safe

working procedure. The main objectives of the JHA is to,

Study the job and develop the basic steps.

Identify the hazards on each major step of the job.

Identify the precautions need to be taken against each basic step.

Record and inform all participants of the job of the hazards and

precautions needed to be taken.

As part of the THHEFSB HSE Program, the JHA will be carried out before work

start-up and will be headed by the respective Supervisor or assigned personnel

depending on the works/areas to be analyzed.

THHEFSB has specified the following critical areas that require JHA:

Construction Works, which include rigging, welding, scaffolding, NDT,

heavy lifting or stated in the permit to work procedure.

7.4.4 U-See U-Act (UCUA) Program

The UCUA Program is a tool to manage unsafe acts and conditions at worksite.

Anyone who witnesses any unsafe act/unsafe condition shall utilize the Stop

Work Policy and stop the activity/person immediately. He/She shall

subsequently complete the UCUA card and submit to HSE personnel. HSE

Officer will administer and monitor the UCUA program and develop UCUA the

trend analysis to determine required corrective and prevention action (if, any).

7.4.5 Daily HSE Surveillance

Daily HSE surveillance is carried out by HSE Personnel, based on the area

assigned to him. He/She shall fill-up a „Daily HSE Surveillance‟ form and submit

the report to HSE Officer who will prepare a trending and present during Weekly

HSE meeting. HSE personnel shall stop any unsafe act/condition immediately

during the surveillance, utilizing the Stop Work Policy.

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7.5 PLANNING AND PROCEDURES

7.5.1 General

THHEFSB business mainly centred towards the fabrication, construction,

hook-up and commissioning. It is crucial that for each Project, the HSE

OPERATIONAL CONTROL requirement is planned and implemented through

a structured process.

It is recognised that the subcontractor work activities and actions may impact

THHEFSB operations and HSE performance. As such, it is essential that the

subcontractors perform its function consistent with THHEFSB HSE

OPERATIONAL CONTROL requirements.

This element further elaborates the mechanism on how THHEFSB plans,

manages and implements HSE OPERATIONAL CONTROL requirements in its

Project activities.

7.5.2 Standards and Specification

All work involving the construction & fabrication Projects shall follow

COMPANY HSE standards and contract specification requirement.

THHEFSB have detailed Project Specific Procedures (PSP) that will ensure

compliance to regulatory requirements, industry and IMS procedure standards

and appropriate practices in undertaking these activities.

Project Managers and HSE Personnel (Project specific) shall ensure that the

procedures for the Project are acceptable and meet all regulating codes and

standards relevant to any offshore and/or onshore facilities construction and

installation.

The responsibilities of the main contractor‟s managers and engineering

personnel shall be clearly defined and the control of technical documentation

and procurement will be detailed in procedures for;

Document control

Specifications

Preparation of requisitions

Procurement

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During design phase, the health, safety and environmental assessment will be

conducted as part of the audit requirement and will contribute to the final

design integrity of the facilities.

The codes and standards influence the way THHEFSB executes the policy

arrangements, and determines the minimum acceptable criteria for installation

during construction activities.

THHEFSB Project manager shall maintain an up-to-date register of the codes,

standards and all local, national and international health, safety and the

environment legislation applicable to Project. The respective department

managers shall maintain other legislation, standards, codes and guidelines

including matters relating to engineering and other relevant requirements.

In case of departures from agreed or approved internationally accepted

standards and procedures, authorization of the deviations must be obtained

via the Management of Change procedures.

7.5.3 Technical Integrity

THHEFSB shall ensure all activities for new Projects, existing installations and

modifications to existing facilities are procured, constructed, installed, tested,

inspected, monitored and maintained to acceptable standards and adequately

suitable for the specific purpose.

All Projects shall comply with IMS legal and related requirements, THHEFSB

standards and procedures.

Application of other codes and standards or deviation from the existing

THHEFSB standards shall be allowed upon reviewing and approval of the

respective management of each division or department, through the

Management of Change procedure.

THHEFSB‟s Project team shall be accountable to ensure that Quality

Assurance programe is applied and practice throughout the Project phases.

Projects shall be managed in accordance with specific quality programme for

Project

Any deviation from the programs shall be subject to Management of Change

control. The Quality Assurance programs shall be reviewed at regular

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intervals and any changes to the programs shall be authorised to the

Management of Change procedure.

In addition to the Quality Assurance programs, the contractor shall incorporate

the following, as an integral part of the Project development.

A practical and widely understood management of change

A transparent inspection philosophy and program

A program for cross-discipline/cross-facility inspections

A clearly defined responsibility for equipment/facilities custodianship

Appropriate documentation/computer systems shall be used for recording the

results and reports of all inspections and tests.

7.5.4 Management of Change

All Project teams shall implement Management of Change (MOC) and plan

changes and control hazards associated with it, either permanent or

temporary. The procedure shall encompass the vital requirements to manage

organisational and technical change, which shall be applicable to all Projects.

The MOC shall incorporate the following generic features:

• A documented system assuring the continued integrity of the

installation

• Description and technical justification for the proposed change

• Originator and initial approval authority

• Duration of change if temporary

• Authorisation requirements

• Risk and impact analysis required before the change is implemented

• Final authorisation prior to change implementation

• Tracking system so that all changes are easily referenced for future

review/audits.

Management of change procedures shall be established for HSE management

of new Projects or of modifications to existing facilities. These modifications

normally, create entirely different HSE concerns. The procedures shall define;

The proposed HSE objectives

Mechanisms for their achievement

Resource requirements to achieve these objectives

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Procedures for dealing with changes and modifications as Project

proceeds

Corrective measures to be employed, their implementation and how the

assessment for their adequacy should be measured.

A checklist shall be developed to ensure that any HSE impacts have been

identified and appropriate effects on the organisation and Projects are

thoroughly reviewed, analysed and recorded to ensure no dilution of existing

acceptable standards.

Any changes made shall be reviewed and amended prior to implementation by

the respective division/department Senior Management.

For organisation changes, the responsible line managers shall ensure that HSE

OPERATIONAL CONTROL responsibilities are reassigned and competent

persons are trained in line with their area of authority.

As part of management control, a thorough review of existing management

systems should be carried out to determine how the „change‟ can be

incorporated into THHEFSB‟s HSE OPERATIONAL CONTROL.

Any changes to HSE controlled documentation shall be authorised by the

Head of QHSE.

All documentation associated with construction changes shall be retained by

the respective department, which forms part of the handover documentation to

the Client.

All documentation for changes in others shall be kept by the respective

divisions/departments.

7.5.5 HSE Procedure, Guidelines and Project Specific Procedure

THHEFSB has formulated procedures, guidelines and Project Specific

Procedures (PSP) to serve as a guide and reference in ensuring that all

personnel adhere to safe practices in their activities throughout the Project

phase. The procedures, guidelines and Project Specific Procedures (PSP)

contents specify minimum HSE standards and requirements to be observed

during the course of THHEFSB‟s operations and give guidance on safe working

methods.

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All personnel and contractors are to observe the requirements in the HSE

Procedure prior to undertaking their respective work activities.

7.5.6 Emergency Response and Preparedness

In THHEFSB business, the greatest importance is to avoid damage and loss of

asset in consideration to life, health, environment and investment.

The Emergency Procedure covers the possible emergency situations

formulated as a guideline to all employees in order for them to response in an

organized manner without escalating further the situation or endangering any

human lives.

The procedure shall be devised according to the Project requirements to

provide personnel, contractor and also the Client with a comprehensive and

readily available source of information concerning the action to be taken during

emergency.

THHEFSB emergency procedure consists of two tier of communication channel

system as follows;

Site operation

THHEFSB headquarters.

7.5.6.1 Emergency Plan

The emergency plan, shall adequately features the following in the

documentation;-

Organisation, Roles and Responsibilities

Immediate emergency response and disaster control i.e.

- Emergency Alarm System

- Fire Fighting equipment

- Rescue Tools and Equipment

- First-aid equipment and personnel

Co-ordination of internal and external emergency response

teams

Procedures and systems on;

- Internal and external communication

- Maintenance of internal and external communication

- Evacuation, rescue, medical treatment

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- Mobilising company equipment, personnel and third party

resources

- Training for response teams

- Drills

The Project manager shall be the custodian of the Project emergency

procedure to ensure that it is kept up-to-date with emphasis on the

emergency communication system that may involve continual updating

throughout the Project development stages.

Types of emergency that require to be addressed in the emergency

procedure documentation shall include,

Fire and Explosion

Worksite injuries

Trap at height

Man overboard

Oil Spill onshore/ offshore

And others identified

First (1st) tier of response to any spill of oil or hazardous materials

originating from THHHEB related activities during the construction,

hook-up and commissioning phase shall be in accordance with the

response actions detailed in the specific project THHEFSB Emergency

Preparedness and Response Procedure.

The THHEFSB Project Manager will activate their Site ERT to take

charge of the situation and make careful assessment of the

environmental pollution/oil spill situation. Where necessary, the

THHEFSB Environmental Pollution/Oil Spill Response Team is to be

activated.

The NOSCP was formulated to control oil spill occurring within

Malaysian Waters, including the Exclusive Economic Zone (EEZ)

located within the straits of Malacca and South China Sea, as well as

Brunei Bay, Sabah and Sarawak Waters and the Sulawesi Sea.

Under the NOSCP plan, the Department of Environment is charged as

the coordinating agency and the focal point while the marine department

will act the implementing agency for Tier two (2) state responses and

Tier three (3) national responses.

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All emergencies shall be followed up with an incident investigation and

analysis. The emergency procedure shall be made available at the

Project site at QHSE Department.

Emergency Response plans shall be kept up-to-date particularly the

emergency communication system that may involve continual updating

throughout the development stages.

In an emergency case on platform or rig offshore, that requires the

injured person to be provided with further medical treatment by an

onshore medical facility, JX Nippon will use its best endeavours to

ensure that a MEDIVAC helicopter flight is available to transfer the injure

person from the platform or rig to nearby airport so that they can be

transported to suitable medical facility / hospital. All costs in this regard

shall be reimbursed to JX NIPPON by THHEFSB accordingly.

7.5.6.2Medical Emergency Response

The Medical Emergency Response (MER) Plan aims to minimise the

consequences of acute illness or injury occurring at THHEFSB, by

pursuing a tiered response.

This MER objective is to provide the framework for medical emergency

response within the THHEFSB area of operation, in accordance with

Emergency Response Procedure.

7.5.6.3 Exercise/Drills

In ensuring a smooth emergency response and management,

THHEFSB has put in place a program to ensure that drills are

conducted at the stipulated duration. Emergency exercise planned for

this project as per below table:

The main intention of this program is to maintain personnel readiness

and up-to-date knowledge in responding any possible emergencies

within THHEFSB operations.

Emergency Exercise Period

Emergency Response Exercise

Tier 1

Quarterly

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Following each drill exercise, an analysis should be carried out to

identify any shortcomings in the emergency plans that require

rectification.

Records of all training and drills shall be maintained by QHSE

Department.

The nominated person-in-charge of each Project shall ensure that a log

is kept of the actions taken during emergency as well as other significant

events as they occur.

A detail Emergency Response and Preparedness Plan designed and

developed specifically for this project.

7.5.7 Documentation and Control

The HSE OPERATIONAL CONTROL procedure provides requirements and

information primarily for management and supervisory staff.

The procedure applies to all THHEFSB construction activities. All employees

and contractors to THHEFSB are required to follow the requirements laid down

in this procedure.

The procedure has made use of existing documents for managing HSE. These

references have been assembled and reviewed for content and currency as a

first step to documenting the system.

The custodians for the HSE OPERATIONAL CONTROL procedure are

responsible for the periodical review and update of this procedure. This

procedure is controlled document and is distributed to authorised procedure

holder which is decided by the THHEFSB QHSE Department.

Copies of sections of this procedure are allowed. These copies are not

controlled and no updates will be issued.

THHEFSB shall maintain procedures for controlling HSE OPERATIONAL

CONTROL procedure to ensure that:

It can be identified within the appropriate company, division, function or

activity.

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It is continuously revised and updated as it is considered a living

document within THHEFSB.

Revisions may include changes to existing documents or incorporation of new

documents in the original procedure.

Procedure holders are responsible to acknowledge and understand the

contents in this procedure. Any errors or omission regarding to the procedure

should be addressed to the THHEFSB QHSE Department.

Upon receipt of the revisions, the procedure holder will immediately insert the

revision to the procedure as instructed, and remove the obsolete document.

Subsequently, the Revision History Sheet must be updated to ensure the

procedure is kept current.

7.6 IMPLEMENTATION AND MONITORING

7.6.1 General

THHEFSB management shall monitor procedures for the relevant aspects of

HSE implementation in accordance with THHEFSB‟s policy, strategic objectives

and performance criteria are in place to cover the entire Project activities.

Line functions shall, at appropriate interval, execute monitoring accordingly and

reports to the respective Project leader.

The monitoring program shall at minimum covers the following;

Regular monitoring of HSE related plans implementations

Regular inspection of Projects in terms of compliance to specific

performance criteria

Observation of key personnel for compliance with safe work

practices/instructions

Regular monitoring of environmental qualities; discharge,

emissions, etc.

Surveillance of personnel‟s Health and Medical aspects.

Monitoring of great depth and frequency shall be carried out for Projects that

exhibit higher number of potential hazards/risk. Active monitoring techniques

shall be adopted to avoid severity of incidents/accidents. Unsafe acts or

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conditions and fallible decisions can be reduced, if not prevented, by focusing

on active monitoring.

7.6.2 Safe Work Practices

THHEFSB has established the procedures for Safe Work Practices to ensure

the safe conduct of work activities. The general practices are as follows:

Permit-to-work system

Personal Protective Equipment

Safety passport

Equipment passport

Housekeeping

Work Environment

Chemical and Hazardous substances

Road Transport

THHEFSB ensures that these practices are properly developed and

implemented to produce effective tools in minimising or eliminating the

occurrence of workplace incidents.

Specific written procedures detailing a step-by-step instruction for a task e.g.

confined space work shall be prepared locally to ensure safety aspects of the

particular activities. Such procedures should not be a controlled document

although they shall go through an ownership and approval system prior to

implementation.

Safe Work Practices documents shall be controlled and authorised by Project

Manager.

7.6.2.1 Permit to Work

The Permit to Work (PTW) system is a tool designed to prevent

incident and all works are to be carried in accordance with safe working

practices stipulated to ensure that:

Safety of those undertaking the work.

Safety of others is not endangered by the work being done.

Overall safety and integrity of the facility is not put at risk.

The human health and environment are duly safe guarded.

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Generally, Company PTW system comprises the following,

Heavy lifting and/or use of multiple cranes

Work in Confined Space

Radiography work

Painting and Abrasive Blasting

Electrical Energize/Pressure testing

Hot work

Concurrent operations/activities

The success of the permit to work system depends on the care and

competence of those entrusted by line management to be responsible

for authorising the work, strict supervision and adherence to the

conditions specified.

A permit to work (PTW) system does not, by itself, guarantee a safe

job. This can ONLY be achieved by those preparing and those carrying

out the work.

A Permit to Work Coordinator to plan, organizes, monitor, review and

record all PTW documentation shall be dedicated by THHEFSB to

meet its Permit to Work System requirement.

7.6.2.2 Personal Protective Equipment

a) All personnel must be suitably equipped with personal

protective equipment (PPE) in compliance with the THHEFSB

requirements. It is the responsibility of every line management

to ensure that the individuals under his control are aware of the

dangers of their work, process and use the required protective

equipment.

b) It is imperative to wear suitable PPE to suit the work task and

the environment in which the work is being performed. It is

mandatory for personnel to wear the following minimum PPE

when on site.

Onshore (i.e. Yellow Zone Area)

Long sleeve coverall

Safety footwear

Safety Helmet with chin strap

Safety Glasses (clear/tinted)

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For Offshore PPE please refer to Attachment XI PPE for Offshore

Personal.

c) Contractors shall be responsible to provide, for their employees,

all the necessary PPE or any other safety equipment that may

be required to perform the work.

d) All visitors to the site must wear safety helmet and safety

footwear or any other suitable PPE applicable to the site

conditions. Only approved PPE meeting acceptable standards

shall be used.

e) PPE must be kept clean and serviceable and any defects or

loss reported instantly to the supervisor for immediate

rectification. PPE that is damaged shall be replaced and the

faulty PPE destroy beyond reuse.

f) Failure to use PPE by personnel or contractor will be subjected

to immediate disciplinary action.

g) Training in the correct use of PPE will be provided to all

personnel and contractors as part of their induction training.

h) Exposure to high noise levels can lead to noise induced

deafness, this disorder is permanent and irreversible. In areas

where noise levels exceed 85dB, hearing protection will be

made freely available. Where noise levels at or exceed 90dB

the wearing of hearing protection will be deemed as mandatory.

i) Where there are any high levels of dust, respiratory protection

(DOSH approved) must be freely available. For operations such

as shot blasting or paint spraying the wearing of the correct

grade of respiratory protection shall be considered as

mandatory. Any operation where the risk to respiratory system

is documented or recommended by the product supplier, this

too shall be considered as mandatory.

j) Hand protection shall be provided, where there is a risk posed

from any sharp or rough objects, chemicals, solvents, or any

operation or activity where the risk to hands is foreseeable,

documented, or where the wearing of proper gloves is

recommended. Barrier creams may also be considered

necessary, where there is a risk of dermatitis or in exceptional

cases skin cancer.

k) Where there is any risk of falling over 2 meters and where a

safe working platform cannot reasonably be provided, safety

harness will be used. Safety belts are not permitted.

l) Foot protection must be worn in Yellow Zone. Where personnel

required working in wet conditions waterproof foot protection will

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be provided. Footwear shall be supplied as personal issue and

shall not be worn by any second party, unless the correct

sterilizing facilities are locally available.

m) Wet weather protection shall be supplied as personal issue to

all personnel required working in any inclement weather or

where the process or operation requires.

n) Full cover body protection will be utilized in all blasting

operation.

o) PPE must always be considered as secondary protection only

and all other practical methods must be applied in preference.

Please refer to below table of Task Specific PPE Requirements.

Note: Other Personal Protective Equipment that is required, depending on the nature of the job to

be carried out and the likely hazards encountered in certain work environment.

7.6.2.3 Safety Passport

THHEFSB shall utilized Safety Passport requirements, among others.

The safety passport is a control-aid to check and ensure that

Company‟s employees and Contractor‟s engaged in all activities are

medically fit and has attended minimum HSE training. Eg. NOSP,

BOSET

Task Sa

fety

Helm

et

wit

h c

hin

str

ap

Cle

ar/

tin

ted

Sa

fety

Gla

ss

es

Lo

ng

sle

ev

e c

ov

era

ll

Sa

fety

sh

oe

s/

bo

ots

Cu

ttin

g G

og

gle

s

We

ldin

g S

hie

ld

Gri

nd

ing

Sh

ield

Glo

ve

s

Ea

r p

lug

/ m

uff

Re

sp

ira

tor

Fu

ll B

od

y H

arn

es

s w

ith

do

ub

le la

ny

ard

Welding / / / / / /

Fitting / / / / / /

Rigging / / / / /

Grinding / / / / / / /

Working

at

Height

/ / / / /

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7.6.2.4 Equipment Passport

An Equipment Passport System has been enforced by THHEFSB to

ensure the company and contractor owned/leased mobile equipment is

fit for purpose and maintained in a safe operating condition and

complies with legislative and Company requirements.

The equipment covered under the Passport System is listed as follows:

Mobile cranes;

Forklifts;

Air Compressors;

Welding machines;

Generator set;

Engine Driven pump;

Grit Blasting Equipment;

Hoists;

Any other equipment as decided by THHEFSB.

The system requires that above equipment be inspected using a

predetermined checklist. It is implemented on the equipment owner

and witnessed by a Competent Equipment Inspector from/or

representing the Client or THHEFSB. Spot checks by company

management may also be undertaken to ensure the system is being

maintained.

It is a requirement that all relevant company departments adhere to the

Equipment Passport System when employing appropriate mobile

equipment, directly or indirectly under their control.

7.6.2.5 Housekeeping guide

Good housekeeping contributes positively to incident prevention and

reduces the possibility of accidents to personnel and machinery and

reduces the risk of fire. It is the responsibility of all THHEFSB and

Contractor personnel to ensure that their working environment is

maintained to the highest possible standard.

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a) Worksites

All worksites including walkways shall be kept clean, tidy

and free from all scraps, litters and unwanted parts and

must be provided with adequate and sufficient signs and

lighting.

Work areas, passageways and stairways and all other

areas shall be kept free from debris and materials to

provide safe access in any emergency. Personnel leaving

the work site shall ensure that the area is clear from any

unwanted items.

Temporary power lines installed are to be clearly marked

to prevent the storage of material beneath it and to control

the travel of mobile equipment under it. Electric power

cords to portable equipment shall not be located where it

can cut by closing doorways or windows.

b) Waste Containers

Domestic waste and schedule waste must be kept in

separate containers and properly labeled.

All waste must be disposed of in line with current

environmental practices and legislation.

Proper waste containers shall be made available in the

various work areas and used at all times to dispose of

waste materials from the worksite.

c) Storage

Storage areas shall be kept clean and materials neatly

stacked or placed. Areas designated to receive

construction materials shall be clean, tidy, level and

organized.

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7.6.2.6 Working Environment

a) Adequate and suitable workplace lighting must be provided and

maintained, either by natural or artificial means.

b) Recognizes the fact that smoking can be defined as unhealthy and

an unnecessary fire risk. Whereas there are no immediate plans to

ban smoking entirely from THHEFSB undertakings, it has been

necessary to restrict smoking on health and safety ground.

c) Smoking will be prohibited in all THHEFSB areas where:-

There are mandatory no smoking signs displayed.

Where there is a significant risk of fire.

At all refueling and storage points.

Where any flammable substances are be used or stored.

At any area where explosives are stored, transported or

used.

Where there is a risk of a volatile or explosive atmosphere.

In shared facilities where there is voiced opposition.

In any area where food is prepared, or consumed, unless a

defined area has been specifically set aside for that

purpose.

Yellow zone area except the designated smoking area.

d) Other factors including dust, noise, vibration, radioactivity, smoke,

fumes, temperature, humidity, working space, tidiness and

disturbance are all known to affect health, safety, temper, and

general well being. All of these factors should be considered when

planning any future operations to ensure the health and safety of

all personnel.

7.6.2.7 Chemical and Hazardous Substances

a) THHEFSB recognizes that many materials used in construction

contain dangerous, hazardous or harmful substances. Where any

such products are used, adequate control measures will be

develop and installed to prevent or reduce to an acceptable level,

any risk to health, safety and the environment.

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b) Any personnel involved with the transporting, storing or use of such

substances will be provided with all the necessary information,

instruction, training and supervision together with any necessary

protective equipment.

c) The store keeper will ensure that the substances received are

appropriately labeled in the MSDS, and stored as recommended

by the supplier or manufacturer.

d) In all instances where any hazardous substances or dangerous

materials are required, a safe substitute should be sought. Any

operation or process producing or requiring harmful hazardous

substances will require a method statement, procedure or work

instruction sheet. Wherever practical, the manufacturer product

data sheet must be included.

e) Where bottled gases are used on site, details of the arrangements

of the storage, handling and use shall be controlled by work

supervisor.

f) Where substances of a harmful, hazardous, or toxic nature are to

be used, copies of the material safety data sheets should be

supplied to the work supervisor for briefing and emergency

reference.

g) Current material safety data sheet should ideally be used as topics

for Tool Box Talks. The details of any known effects, the correct

action to take in an emergency, the PPE requirements and safe

use, should all be explained.

h) Where products are repackaged, sub divided or decanted, the

information originally displayed must be provided on the new

package or container. Where language difficulties exist, this

information will be transmitted verbally in Bahasa Melayu.

i) The disposal of toxic or hazardous materials will be strictly in

accordance with Legal requirement.

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7.6.2.8 Road Transport

a) All personnel shall abide to all speed limit and road transport

regulations.

b) Regular awareness campaign will be organized by the Project

team.

c) It is strictly prohibited using telephone while driving but with the

exception of using wireless device such as bluetooth device.

7.6.3 Inspection and Monitoring

7.6.3.1 Planned Inspections

Planned inspections are tools to identify potential hazards and aspect

which will enable the respective department/supervisor to rectify them

before incidents or losses happened. The inspections/audits are

undertaken to objectively ensure that:

Safe system of work is in-place.

Staff is motivated towards psychological and

physiological.

The activity „risk, effect and impact‟ are properly

managed.

Planned inspections will be conducted by supervisory personnel in

order to identify and rectify any substandard conditions. A checklist will

be used and on completion of the inspection. The planned inspection

shall cover all areas of activities within the site.

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A typical planned inspections schedule and frequency is as follows:

7.6.3.2 Monitoring

THHEFSB has established procedures for monitoring relevant aspects

of health, safety and environmental performance. Arrangements for

developing and maintaining records of the results have also been

carried out.

The following steps are taken for each relevant activity or area;

Identify and document the monitoring information to be

obtained, and specify the accuracy required of results

Specify and document monitoring procedures, locations and

frequencies of measurement

Establish, document and maintain measurement quality

control procedures

Establish and document procedures for data handling and

interpretation

Type Frequency Responsible Party

PPE/Hand Tools Daily Line Management

Gas Equipment Daily Fitters

Housekeeping Daily Line Management

Worksite Inspection Weekly Construction/Project

Manager, HSE Manager,

SHO and work site

supervisors

Scaffold Inspection Weekly Scaffolder

Project walk-about Weekly Project/HSE Committee

Fire Fighting Equipment Monthly HSE Personnel/ERT

Hoisting Machine Quarterly Rigging Supervisor

Pressurized Equipment Quarterly Facilities Supervisor

Lifting Equipment Color Code Quarterly Rigging Supervisor

Electrical Installation Bi-Annually Electrical Supervisor

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Establish and document actions to be taken when results

infringe the set performance standards

Assess and document the validity of affected data when

monitoring systems are found to be malfunctioning

Safeguard measurement systems from unauthorized

adjustments or damage

Monitoring covers the entire range of monitoring activities from those

carried out by individuals at the workplace (which may comprise a

simple visual check by a supervisor or skilled worker of the work being

carried out by a helper) through the more detailed checks carried out

by a assigned person in-charge/specialist on take-off to the

assessment of activity or task performance indicators.

Monitoring of great depth and frequency shall be carried out for

Projects that exhibit higher number of potential risk and impact.

Active monitoring techniques shall be adopted to avoid severity of

incidents/accidents. Unsafe acts or conditions and inaccurate decisions

can be reduced, if not prevented, by focusing on active monitoring.

7.6.4 Occupational Health and Hygiene Management

THHEFSB has adopted the occupational health and hygiene control practice as

part of the Project HSE management plan. The practice reflects THHEFSB

concern and commitment in maintaining the health and hygiene of personnel

during the Project phase.

The main objective of the occupational health and hygiene is the maintenance

of the physical, mental and social well-being of the workforce.

At minimum, the following programs are available to cater for personnel

occupational health and hygiene management:

a) Pre-employment Medical Examination

All new personnel, regardless permanent or those on contract must be

above 16 years of age and must have undergone a medical check-up and

urine test by THHEFSB panel doctors to be in perfect health to carry out his

job. Sub-contractors workers are also required to pass the pre-access

medical check-up.

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Designated employees namely crane and vehicle drivers, blasters, painters,

radiographers and respective supervisors are required to go for annual

medical check-up. Other employees in service are advised to go for medical

check-up every three year.

Offshore Personal shall undergo Offshore Medical Check-up by and

Approved Medical Examiners by PETRONAS.

b) Weekly Health & Hygiene Inspection

Weekly Health & Hygiene Inspection will be conducted once a week led by

Medical Assistant. This ensure canteen, toilets and other areas are clean

and hygienic.

c) Drugs and Alcohol Test

Drugs and alcohol are not permitted to be brought into the yard. Testing will

be carried out prior work engagement and at thereafter at random for all site

personnel.

Drugs – Non-Negative – Barred from Project

Alcohol – Non-Negative – Retaken after 3 days and if still barred from

Project.

d) Health and Hygiene Talks / Briefing

Health and hygiene promotions are conducted frequently to ensure that

personnel are continuously conscious of their health, hygiene and its

inherent health hazards within the Project. THHEFSB with assistance from

Ministry of Health Malaysia or other government authorities as well as third

party will conduct several health talks / briefing to all employees.

e) Noise Monitoring

HSE personnel will survey all work areas including offices and storage

facilities for noise hazards. Initial survey must be carried out to produce

noise map and identify high noise areas and activities such as blasting

operations, pre-commissioning activities, etc. Employees working in such

areas shall either be given ear plugs/muffs or the noise is treated/cordoned.

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Audiometric test shall be carried out as required by local regulations.

f) Hazardous Material Control

All materials brought into the yard are generally categorised into their

specific characteristics and usage. Hazardous materials are divided into

classes as per the United Nation Classification System that can be referred

through the Material Safety Data Sheet (MSDS).

These material will be identified through designated coding system with

handling, storing, transporting and disposing guidelines made available to

secure the safety and health of employees involve including preservation of

environment. Scheduled waste categorized under this procedure shall be

disposed accordingly.

Risk associated with the hazardous substances and chemical shall be

assess for their rating and to be included in the HIRARC.

g) Fit to Work Program

The “Fit-to- Work” program comprises, but not limited to the following:

Pre-employment medical examination.

Schedule Medical Examination

Drugs and Alcohol screening.

Random Drugs and Alcohol Test.

Subcontractor Project manager shall maintain a register of employees that

are “Fit-to-Work” based on the requirement.

THHEFSB QHSE Department has the right to prevent subcontractor without

above mentioned identification from entering and working in the yard.

h) Chemical Health Risk Assessment (CHRA)

Chemical Health Risk Assessment shall be conducted by an approved

DOSH CHRA assessor. The validity of the CHRA is within 5 years.

Recommendation made by the assessor must be treated as highly

important.

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i) Hygiene

Canteen operator shall strictly adhere to regulatory requirement in

addition to the THHEFSB Canteen Management procedure and

guideline.

Clean drinking water and toilets placed at strategic location throughout

THHEFSB Fabrication yard in meeting workers welfare and Factories

and Machinery - Safety, Health and Welfare Regulations 1970.

Domestic wastes shall be disposed regularly in accordance with the

local authority.

j) Radiography

It is the responsible of the Radiography Contractor to make sure the

safety and health of its radiation worker and public.

It is strictly for the Radiography Contractor to adhere to the Atomic

Energy Licensing Act 1984 and its regulations, especially on the Basic

Radiation Protection 2010.

Radiography contractor shall obtain a radiation certificate for

radiography work from AELB.

Extra precaution shall be taken to keep away all non- relevant

personnel from the area. The area shall be isolated by visible

barricades, signs and warning lights. The source shall be stored

according to approved procedure.

Radiography Contractor shall employ only qualified Radiography

Operators and Radiation Protection Officer (RPO) for the job.

Properly calibrated radiation survey meters shall be made available

and film badges shall be worn throughout the radiography activity by

the radiation workers.

k) Asbestos Management

THHEFSB at no means shall comply with Orders Occupational Safety

and Health (Prohibition on the Use of Substance) on the prohibition of

the use of Crocidolite at any time.

An arrangement shall be made by THHEFSB if the prescribed area

which asbestos dust in a concentration is exceeding the permissible

exposure limit, arising from an activity which requires handling/removal

of asbestos or asbestos containing materials at worksite.

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l) Fatigue Management

THHEFSB shall ensure that all works at its premises for JX NIPPON

Project are carried out during Normal Working Hours. THHEFSB shall

ensure that any work carried out outside the Normal Working Hours

shall be authorized by JX NIPPON.

THHEFSB shall ensure that all hazards associated with working after

Normal Working Hours including night shifts and weekend operations

are identified and mitigated.

7.6.4.1 Health Care Providers and Facilities

Project Manager shall consider a suitable health care providers and

facilities for the Emergency Response and Preparedness Plan (ERPP)

in THHEFSB workplace including onshore and offshore. Trained First

Aider will be available in each work team and on each shift. The QHSE

Department will keep an up to date list of trained First Aider. Details of

the Project Emergency Response and Preparedness will be specifying

in the Project Specific Procedure.

a) Emergency Health Care is to be provided for the project. It

includes the following:

i. Basic/ Advanced First Aider who applies first line treatment

following an injury or sudden illness. THHEFSB Designated

First Aider is a trained first aider with basic life support and

cardiopulmonary resuscitation (CPR).

ii. Medics and emergency medical personnel with specialized

training in emergency care who are usually employed in

field operations to manage medical emergencies. There are

medical assistant and nurse assigned for any medical

treatment in THHEFSB including onshore and offshore.

iii. THHEFSB Fabrication yard are equipped with site clinics

and three (3) units of ambulance.

iv. THHEFSB have identified two (2) hospitals to facilitate in

the case of medical evacuation. Refer to below list:

Tuanku Ampuan Rahimah Hospital, Klang

Pantai Medical Specialist Hospital, Klang

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v. THHEFSB shall make an arrangement for medical facilities

and resources for offshore work activities. This will include

the manpower; medical assistant/ nurse, medical equipment

and medication.

vi. Offshore medical emergency services such as helicopter

Service Company and marine vessel (fast crew boat and

standby vessel) are the mode of medavac. JX NIPPON may

provide the necessary emergency arrangements.

b) Primary, Secondary and Tertiary Health Care. Three levels of

health care are provided as follows:

i. Primary Health Care is a highly personalised form of

medical care provided by a medical officer working on site.

This primary health care includes: - Tier 1 Medical

Emergency Response (MER) care which provides medical

attention, first aid and basic life support (e.g. CPR).

ii. Tier 2 Medical Emergency Response (MER) cares where

MER professionals can arrive on site within one hour to

assess injury, administer advanced life support and initiate

medevac to Tier 3 MER hospital.

iii. Secondary and Tertiary Health Care is usually hospital

based and used when the capabilities of primary health

care are exceeded. This level of care includes: - Secondary

or Tier 3 MER medical care at the nearest approved Tier 3

hospital within 4 hours.

iv. Tertiary or Tier 4 MER specialist medical care at approved

Tier 4 hospitals which includes treatment of major trauma,

neurosurgery, severe burns, cardiac surgery, etc.

7.6.5 Environmental Management

THHEFSB is committed to pollution prevention and continuous improvement in

environmental performance, and shall comply with legislative requirements at

all times.

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Consistent with the THHEFSB policy, line supervision shall be collectively

responsible for HSE issues, the responsibility for management of the

environmental issues associated with each of the Projects is assigned to the

Operations. Corporate QHSE Department will act as an advisor to

management on matters pertaining to environmental issues.

THHEFSB shall have in place an emergency response organisation and plan

for each worksite that is compatible with JX NIPPON‟s to afford protection,

early containment and a high degree of readiness. The response plan shall be

geared to:

• safety and welfare of personnel at the emergency site

• protection of the environment including the community

• containment of damage

• restoration of facilities

• return to normal operations

In the event of spill, immediate steps to assess the situation, eliminate the

sources and contain the pollutant must be undertaken. Removal and clean-up

methods in the plan shall be arrived in consultation with the appropriate local

authorities.

As a minimum, the following environmental regulations under the

Environmental Quality Act, 1974 shall be complied with;

Environmental Quality (Licensing) Regulations 1977

Environmental Quality (Clean Air) Regulations 1978

Environmental Quality (Sewage & Industrial Effluents) Regulations

1979

Environmental Quality (Prescribed Activities) (Environmental Impact

Assessment) Order 1987

Environmental Quality (Scheduled Wastes) Regulations 2005

Environmental Quality (Prescribed Premises) (Scheduled Wastes

Treatment & Disposal Facilities) Order 1989

Environmental Quality (Prescribed Premises) (Scheduled Wastes

Treatment & Disposal Facilities) Regulations 1989

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The followings are minimum measures taken by THHEFSB in the effort to

conserve the environment from business operations activities:

7.6.5.1 Housekeeping

Housekeeping activities within THHEFSB premises are made

available including:

a. Scheduled waste disposal through qualified vendors.

b. Housekeeping campaigns in cleaning and arranging

work places.

c. Housekeeping audits in identifying areas and items to be

rectified.

7.6.5.2 Suspended Particle and Effluent Discharge Monitoring

Work area must be evaluated and assessed against

excessive suspended particles and the quality of the effluent

discharge from hazardous activities such as blasting

operations. Third party registered with the Department of

Environment shall carry out the assessment. Work area must

be well protected or screened to minimize pollution.

7.6.5.3 Waste Management

THHEFSB management is committed to protect the

environment. To satisfy this objective THHEFSB ensure that

adequate control and proper management for waste from

Project activities are in place. This is to avoid from any

environmental incidents or non-conformances.

The following summarises THHEFSB strategies on waste

management:

a) The disposal of hazardous waste shall be reduced by

applying the 4Rs: Reduce, Reuse, Recycle and

Recover. Where practicable, the need to dispose of

hazardous waste will be eliminated by avoiding the use

of hazardous material.

b) Wastes that cannot be eliminated shall be stored until a

suitable treatment/disposal route becomes available.

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Storage shall be such as to prevent health or safety

hazards to personnel or threat to the environment.

c) All waste shall be accompanied by information on its

composition, hazards and instructions for what to do in

an emergency involving the waste.

7.6.6 Promotional and Incentive Scheme Program

With the intention to promote workplace safety and actively encourage the

improvement of the Project safety culture, THHEFSB has introduced a

promotional and incentive scheme program.

All THHEFSB and subcontractor employees are eligible to be considered for the

incentive scheme and Promotional/ Recognition programs.

Each Project shall have a man-hour target without lost time injury. Some form

of incentive will be given by the management if these targets are met. A QHSE

day will be held for each man-hour target achieved and activities such as the

followings will be organized:

Quizzes, slogans competition, sports, presentation of video on QHSE

awareness.

Promoting healthy lifestyle program.

Soft launching of HSE program.

Other forms of awards/incentive and promotional program will be given if there

are productive/constructive suggestion or for active participation in HSE

program such as U See U Act, Near Miss Reporting, Man-hours Incentive,

Poster or Slogan Competition, PPE Campaign, etc.

Effective recognition program such as give tokens to encourage positive safety

behaviour or give immediate recognition for raising positive safety behaviour will

also be introduced to encourage safe working culture.

7.6.7 Incident Reporting and Investigation

7.6.7.1 General

All accident, incident and dangerous occurrences will be reported using

the Incident Report Form and all completed forms forwarded to the

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QHSE Department.

Any accidents resulting in death, serious or multiple injuries shall be

reported to the CEO and the Company/Client Site Representative

(CSR) immediately by the fastest possible means. The Head of QHSE

will also be notified, who will in turn arrange for the necessary

notification and an investigation to be implemented.

7.6.7.2 Incident Investigation

a) All accident, incident and dangerous occurrences will be reported

using the THHEFSB Incident Report Form and all completed

forms forwarded to the QHSE Department and COMPANY, CSR.

b) Any accidents resulting in death, serious or multiple injuries shall

be reported to the Project Manager and the Company Site

Representative (CSR) immediately by the fastest possible

means. The HSE Head will also be notified, who will in turn

arrange for the necessary notification and an investigation to be

implemented.

c) If the incident caused of occupational poisonings or occupational

disease shall be report using Third schedule form by NADOPOD

Regulation DOSH. Within seven (7) days a report there of to the

nearest Department of Occupational Safety & Health office.

(Refer to the NADOOPOD Regulations, 2004)

d) It is essential that Near Misses and Incidents be reported at work

sites so that actions can be taken immediately, stop the work,

remove or clear the unsafe act or unsafe conditions. Investigation

shall be initiated, and lesson learned after the investigation and

root cause analysis applied, and reviewed with all workers, so as

prevention and or mitigation shall be taken to prevent the

recurrence of same incident.

e) When reporting any incident, accident or dangerous occurrence,

it is vital to give as much detail as known about the event. It is

important to include any information on the current status and

what steps have been taken to prevent any similar

reoccurrences.

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f) Project Manager shall ensure that any personnel whose duty it is

to report incidents, accidents, or dangerous occurrences, is first

fully briefed on Incident/Accident Reporting procedure.

g) The Project Manager shall ensure that all incidents, accidents

and Dangerous Occurrences, occurring in the Project, including

subcontractor are correctly reported.

h) It must be remembered, „that you cannot control what you cannot

see‟ and therefore the reporting of all incidents, accidents or

dangerous occurrences is critical towards the management of

safety and the prevention of accidents.

i) A copy of preliminary incident report shall be submitted to the

client within 24 hours of occurrence, and Complete Report will be

seventy-two hours.

j) It is the intention of THHEFSB‟s management that accident

investigations shall be undertaken to:-

Ascertain the cause of any incident, accident, or dangerous

occurrence.

Determine the sequence of events leading up to the

occurrence.

Confirm the effectiveness of the existing control measures.

Identify any areas where the introduction of suitable control

measures, would remove, or reduce residual risks to an

acceptable level.

Identify any breaches, or failures in the duties of any

individuals, or groups.

Identify any instances where further information, instruction,

training, or supervision would have prevented, or lessened

the extent of the incident.

k) The purpose of conducting an accident investigation shall be to:-

Recommend actions, or suitable measures, which if

implemented will effectively prevent, or reduce the

likelihood, of any similar recurrences.

Communicate sufficient preventative information resulting

from the investigation, to any other parties involved, or likely

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to be affected by similar activities.

l) All accident reports produced shall be delivered to the Project

Manager who will consider suitability of any recommendations or

action contained.

m) HSE Bulletin may be issued following accidents or accident

reports as a means of communicating details or requirements.

n) COMPANY Representative may be a member of the investigation

team for all accidents.

o) The Project Manager will lead the accident investigation;

however, QHSE Department may hold concurrence or separate

investigation in order to determine the real root cause and the

root cause of this incident/accident will be cascade to all workers

as a lesson learns.

Please refer to Attachment IX: Incident Notification Flowchart and

Attachment XI: Incident Notification Matrix.

7.6.8 Security Management

a) THHEFSB shall ensure compliance with JX NIPPON security

requirements.

b) Twenty-four (24) hours of CCTV monitoring are located throughout the

office building and fabrication area.

c) Auxiliary Police and Security personal are provided by THHEFSB at

access point and strategic location. In addition to that, twenty-four (24)

hours of monitoring and clocking at check point done by security

personal.

d) Vehicle permit and entry pass are required to enter THHEFSB

premises.

7.7 HSE AUDIT

7.7.1 General

THHEFSB requires that audits of HSE performance be conducted against

standards set as part of the HSE OPERATIONAL CONTROL of THHEFSB and

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its Contractors. The audit results are reviewed by THHEFSB management and

performance standards are revised in line with continuous improvement

objectives. Priority audits will be on areas of critical safety importance including

identified risk areas and where safety controls must be effective.

Safe and healthy operations require an ongoing dedication of continuous efforts

to improve. THHEFSB includes an arrangement for reviewing and measuring

how well operations are meeting the company‟s HSE Policy goals and strategic

objectives.

As a minimum, the arrangement will ensure that,

THHEFSB operations are reviewed and assessed at predetermined times.

Reviews and assessments are carried out by qualified and trained

personnel.

Observations and findings from reviews and assessment are discussed and

implemented.

Provision for THHEFSB to undergo continual review and evaluation is also in

place. This is to ensure that HSE issues remain as visible and relevant as

possible within the company‟s system/operations.

7.7.2 Audit Plan

THHEFSB audit arrangement comprises of the following characteristics;

Areas for auditing – These will include undertaking Projects, individual

Departments within the THHEFSB organization and Sub-Contractors.

Resources for audit – THHEFSB audit resources is segregated into

Internal (audit carried out by THHEFSB internal audit team), and

External (audit carried out using outside independent HSE resources

selected by THHEFSB or Client).

Audit Team – The team shall consist of lead auditor and/or auditor/s.

Auditors must be independent of the area being audited.

All departments and Projects are subjected to the HSE audit undertaken by

either an internal or external auditor. Subject to Client‟s requirements, a formal

HSE audit by an external auditor shall be undertaken for Projects.

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All areas are however subjected to a formal HSE audit. THHEFSB shall ensure

that such audit is carried out annually based on the Company HSE plan.

The audit will generally address the following at each specific aspects of the

area;

Documentation reviewing.

Interviewing of selected personnel.

Observations of work practices and site inspections.

Completion of audit protocol.

To obtain audit effectiveness, THHEFSB will ensure that audit personnel will be

given the support and authority to procure the necessary information, resources

and assistance needed.

The frequency of audit allocated to each area of activity shall reflect the status

and importance attributed to that activity. Proposed audit schedule shall be

prepared by the Corporate Head of QHSE and reviewed during the Corporate

HSE Committee meeting, which form part of the annual HSE plan.

As part of the management involvement strategy, THHEFSB senior

management personnel shall participate to lead the formal HSE audit team in

carrying out one audit per year. The Projects or specific areas to be audited

shall be determined in the annual HSE plan.

Generic HSE audit‟s requirements include;

Compliance with the HSE Management System manual

Implementation of the HSE Policy, strategic objectives and plans

Compliance with relevant legislative requirements

Critical risk areas from the Hazard Register

Work sites and activities

Identification of areas for improvement

Audit can also be triggered by:

A major incident

Recurring incidents

Non-compliance to performance standards.

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7.7.2.1 Internal and Independent Audit

The audit findings and recommendations shall be given due

consideration in order to initiate corrective actions for continual

improvement.

7.7.2.2 External Audit

External audit will be undertaken for Projects if the requirement

is stipulated in the contract documents. The scope of work for

the external HSE audit will varies according to each Client‟s

requirements.

The QHSE Department is responsible in coordinating the

external auditing for all Projects.

The audit team will be headed by the external resources. The

composition of an external HSE audit team may include

expertise external consultants.

A draft report for factual correctness/confirmation will be

prepared by the audit team leader to be submitted to the Project

managers prior to the preparation of the final report for

THHEFSB corporate HSE committee.

Project audit program will be drawn up by the QHSE

Department after consultation with the Project managers. Any

special/focused or area of concern shall be incorporated in the

HSE audit program as advised by the Corporate HSE

Committee.

All recommendations from external audits shall be monitored by

the QHSE Department until completed or resolved by the

respective Project managers for the area being audited.

7.7.2.2 Regulatory Audit

In maintaining the highest standard of HSE throughout the

project period, Project Management is stipulated for the

regulatory compliance audit. These are to aligned and access

the adequacy of the legal, regulatory, statutory, and contractual

requirement.

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7.8 HSE OPERATIONAL REVIEW

7.8.1 General

THHEFSB management shall review its business activities and performance

twice a year. The general topics of HSE concern in management review are;

Compliance to relevant legislative requirements

Lessons learned from past incidents

Audit implementation and program

Summary of audit and formal HSE reports

Audit recommendation/findings/non-compliance

Organizational and resource management

Key HSE performance indicators

All elements of HSE OPERATIONAL CONTROL, policy, strategic

objectives and plans.

The review shall be part of the agenda in THHE Management Review Meeting.

The review process shall be documented and its results recorded to facilitate

implementation and consequent changes.

The minutes of the review meetings are held by the Head of QHSE who

ensures that timely follow-up meetings are arranged to review progress. No

item is closed until the approved action plans for improvement has been

completed and found to be satisfactory. Minutes of the review meetings are

distributed to relevant THHEFSB managers and to contractors for dissemination

at their management meetings.

7.8.1.1 HSE Operational Control Element Review

The following outlines THHEFSB management review on its HSE

OPERATIONAL CONTROL elements.

Policy & Organisation

THHEFSB‟s policy, strategic objectives, organisation structure

and responsibilities of respective personnel are all subjected to

an annual review.

Follow-up on Management of Change shall be thoroughly

reviewed to ensure that the present procedure is adequate

enough in addressing any foreseen changes.

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Training objectives and course standards are identified at the

beginning of each training session and comments are sought

from participants on adequacy of the trainers and the course

content. The comments are reviewed and improvement put in

place for the next training session.

The annual audits result of THHEFSB training requirements and

records are reviewed to ensure that personnel competency are

maintained at its optimum level.

Hazards, Risk & Aspect, Impact Management

The focus areas as identified by the HIRARC process shall be

subjected for audit and review before starting of each shift. This

is carried out by the work supervisor. The audit and review

recommendations are assessed and subsequent

implementation and follow-up is carried out to ensure that

hazards are controlled, if not prevented.

Safety reviews on THHEFSB overall activities are carried out

during the Corporate HSE Committee meeting.

Planning & Implementation

Review of THHEFSB Project implementation stages will be

undertaken on completion of the Project phase. Thereafter

construction and commissioning activities will be significantly

reduced until another major Project arises. Minor Projects will

be audit and reviewed under Management of Change

procedure.

THHEFSB in conjunction with contractor, are responsible for

ensuring ongoing safety. In this respect the General Manager

regularly reviews the requirement for new operating procedures

and ensures that an annual review of all procedures, according

to agreed performance standards, is completed on THHEFSB

procedures and those of relevant contractors.

Additionally, other related interfaces with contractor systems

and procedures will also be subjected to annual review

according to the THHEFSB Project HSE Management Plan.

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Incident Prevention & Emergency Management

Results of the statistical analysis of incidents within the

company over a period of time are presented at THHEFSB

review meetings on performance. The data and information are

used to:

- Monitor performance

- Review safety objectives

- Identify unforeseen risks

- Prevent a recurrence

Audit and management review on THHEFSB emergency management

practices, which include emergency training and procedures, is undertaken at

least annually to obtain the required performance

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Attachment IA: Health, Safety and Environmental Policy

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Attachment IB: Drugs and Alcohol Policy

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Attachment IC: Stop Work Policy

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Attachment ID: Yard No Smoking Policy

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Attachment II: Sample of Fabrication Hazard Register

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Attachment III: Sample of HUC Risk Register

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Attachment IV: Sample of HSE Plan and Programme

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Attachment V: Roles and Responsibility

Designation Roles and Responsibility

Senior

Managers

a) Has overall HSE responsibility to implement THHEHSE Policy, HSE-MS

and HSE procedures within the Department as well as to assure and

review effectiveness of HSEMS implementation within the Department

b) Review, endorse and implement THHEFSB HSE Plan in his Department.

c) Define and obtain adequate resources to execute HSE-MS and HSE

Plan

d) Demonstrate visible leadership and commitment to HSE by „Leading

Thru Example‟.

e) Shall strive to ensure that contractor have been selected on their ability

to comply with THHE HSE requirements and excellent safety record.

f) Ensure that all incidents are reported promptly and thoroughly investigate

high potential and significant incidents to determine the root cause and to

allow appropriate recommendation to be taken to prevent recurrence.

g) Foster active involvement of his staff and contractors in improving HSE

performance by encouraging a culture of belief, motivation, individual

responsibility, participation and commitment.

h) Is responsible for ensuring that key HSE studies, audits, incident

investigations etc are conducted and the resulting actions items are

closed out and areas of deficiencies improved.

i) Shall ensure the workplace is regularly reviewed and audited to allow an

evaluation of the site safety performance against HSE Policy Statement,

objectives and targets for the purpose of identifying opportunities for

improvement.

j) Shall ensure that their subordinates are provided with sufficient training,

instruction and supervision to allow them to carry out their duties in a

safe and effective manner.

Head of QHSE a) Assist the General Manager to implement and maintain THHEFSB HSE-

MS and THHEFSB HSE Plan to ensure its effective implementation and

compliance as well as compliance with legislative and JX NIPPON HSE

Requirements.

b) Formulate HSE procedures, regulatory requirements and monitor/audit to

verify compliance in THHEFSB (and project).

c) Provide appropriate safety equipments, training and advice related to

HSE issues to ensure safe working environment in THHEFSB (and

project).

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d) Advise all THHEFSB (and project) employees on matters pertaining to

the HSE Policies, HSE Procedures, and related laws and regulation in

the industry.

e) Arrange and coordinate other HSE program such as Tool Box Talk

(TBT), HSE walkabouts, audits etc within THHEFSB (and project).

f) Conduct quarterly inspection and surveillance, to ensure all activities

comply with all THHEFSB HSE Policy and Procedures in THHEFSB (and

project).

g) Participate as a member of investigation teams for high potential and

significant HSE incidents occurring in THHEFSB (and project).

h) Organize and coordinate HSE campaign, HSE communication, HSE day

event, emergency response drills/exercises in THHEFSB (and project).

i) Ensure that THHEFSB (and project) HSE staffs in the line are trained

and competent to carry out their assigned duties.

Project

Manager

a) Ensure that the HSE Plan is adequate for PROJECT needs and has been

approved and implemented throughout the PROJECT.

b) Ensure that adequate resources are provided for the PROJECT in

terms of personnel, home office support and any other identified

aspects of the PROJECT that may have impact the overall HSE

program.

c) Ensure that HSE documentation is comprehensively prepared and

delivered to COMPANY at appropriate time as specified by COMPANY.

HSE documentation shall include relevant information which is required to

allow the COMPANY to operate and maintain the workplace safely

during the operational phase.

d) Chair weekly Project HSE Committee meeting.

e) Monitor HSE performance of the PROJECT.

f) Participate in HSE management walkabout, audit and inspection

programs at WORK SITE.

g) Ensure that relevant personnel participate in HSE audit and inspection

program at WORK SITE.

Construction

Manager

a) Implement the Construction, Installation and Commissioning HSE Plan

and WORK SITE HSE procedures.

b) Ensure WORK SITE conditions are safe for the personnel and the risks

have been reduced to ALARP level.

c) Ensure that SUB-CONTRACTORS personnel are competent.

d) Develop detailed planning of WORK SITE activities to ensure proper

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coordination of interfaces in order to minimize and control potential

issues and hazards.

e) Ensure that all risks associated with the construction and pre-

commissioning works are identified and properly communicated to

relevant SUB-CONTRACTORS.

f) Obtain from SUB-CONTRACTORS their risk assessments, work

method statements and HSE plans and ensure that they are reviewed,

approved and all mitigation measures are in place prior to

commencement of the work.

g) Ensure that SUB-CONTRACTORS have been made aware

of their roles and responsibilities with regard to safe working

procedures and that both SUB-CONTRACTORS and their workers

comply with WORK SITE rules which have been set out in the

Construction,

h) Installation and Commissioning Plan and WORK SITE HSE procedures.

i) Ensure that all workers are properly informed and consulted on

HSE matters. Ensure that field staff is suitably competent and

understand their HSE responsibilities.

j) Participate in HSE audit and inspection programs at WORK SITE.

Managers and

Leads

a) Are responsible for implementing the HSE-MS in their area of

responsibilities.

b) Ensure that all tasks take full account of HSE requirements.

c) Implement effective two-way communication and coordinate HSE training

requirements for all relevant personnel.

d) Promote a company culture conducive to good HSE performance, in

which the HSE-MS can function effectively.

e) Take responsibility for assigned HSE/Risk action items and ensure timely

updates and proper close out.

f) Ensure HSE issues associated with their subordinates are adequately

addressed.

g) Ensure collaboration and integration of HSE activities that cross multiple

sub team boundaries.

h) Review and endorse or approve the Simultaneous Operations (SIMOPS)

activities and related procedures.

i) Ensure that HSE issues are addressed in contracts.

j) Ensure that HSE contractual requirements are fulfilled through

verification and audits.

k) Participate in and/or ensure performance of applicable Hazard / Risk

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assessments and reviews (e.g. HAZOPs, Operations readiness review,

start-up review etc).

l) Manage Contractor HSE management and performance e.g. review,

approve and monitor

m) Contractor HSE Plan including reporting and investigating HSE-related

incidents

Project

Engineer

a) Shall ensure that all THHEFSB operations are carried out in keeping

with the Health, Safety and Environment Policies.

b) Shall ensure that the Project HSE Plan is fully implemented.

c) Shall participate and take active role in Project HSE Committee.

d) Shall participate in the HSE Walkabout and attend the Project HSE

Meeting.

e) Shall participate in the emergency drill/ exercise.

f) Shall assist the Project Manager in formulating and reviewing the

Health, Safety and Environment Policies and shall bring to his notice

any significant deficiencies or omissions.

g) Shall deputies for the Project Manager in his absence.

HSE Officer/

Supervisor

a) Satisfactory implementation of Project HSE Plan.

b) Developing and implementing all aspects of HSE training.

c) Establishment, training and performance of site emergency response

team.

d) Preparation and implementation of evacuation procedures

e) Provision of advice and assistance to line management for

implementation of the HSE Plan.

f) Carry out all necessary HSE inspection and reporting as required for the

Project and Company.

g) Assisting Supervisors whenever required with accident/ incident

investigations.

h) Ensure that relevant information is given to other departments to prevent

any incidents from occurring relating to HSE errors.

i) Distribution of safety promotional material.

j) Check the adequacy of appropriate personal protective equipment.

k) Shall ensure that suitable parties conduct all HSE inspection and

reporting.

l) Assist line supervisors in giving tool box talks and monitor subcontractors

tool box talks.

m) Shall participate and take active role in Project HSE Meeting activities

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every week i.e. meeting and walkabout.

n) Ensure housekeeping for each work location is carried out every day

before commencing of work and end of the day.

o) Resolution of HSE issues in a manner that maintains industrial harmony.

p) Intervene when witnessing any unsafe act/unsafe condition and take

ownership of the situation.

Construction

Superintendent

a) Shall ensure that each control construction activities have an approved

procedures, method statement, guidelines etc. as per client

requirement.

b) Shall ensure that all plant on the Project is safe, adequately guarded

and suitably equipped with any necessary safety devices.

c) Shall ensure that a programme of regular maintenance and inspection is

established and ensure that the necessary maintenance or inspection is

carried out to that programme.

d) Shall ensure hired plant is safe and that, where appropriate, copies of

current test certificates, or licenses are available.

e) Shall ensure that any items of plant subject to special licensing shall be

licensed before commencing work.

f) Shall ensure that only experienced and competent operators are

employed for the Project.

g) Shall ensure that construction activities at the Project site are

adequately supervised.

h) Shall conduct regular workplace inspections covering all areas and

activities under his control.

i) Shall participate and take active role in Project HSE Committee

Meeting.

j) Shall participate in the Project HSE Walkabout and meeting every week.

k) Shall participate in the emergency drill/exercise.

Supervisors a) Organize the workplace so that all work, including servicing and

maintenance, is carried out to the required standard with the minimum

of risk to personnel, equipment and materials. Safe systems of work for

all workers, including those of subcontractors, must be established and

approved before work starts. Thereafter, the work must be strictly

monitored.

b) Know the requirements of Occupational Safety & Health Act, Factories

and Machinery Act, Environmental Quality Act, Client requirements and

other relevant legislation, carry out regular inspection of the

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workplace(s) to ensure that statutory provisions are being observed,

and that safe systems of work are being followed.

c) Participate in the Weekly HSE walkabout and Project HSE Committee

meeting.

d) Shall ensure that regular maintenance and inspection is established and

is carried out.

e) Ensure that all new employees/sub-contractors are well supervised and

given full HSE awareness before start work.

f) Present at Weekly General Safety Briefing every Monday prior to start

work.

g) Carry out Tool Box Talk for workers daily, prior to start work.

h) Plan and maintain a tidy workplace.

i) Check the adequacy and suitability of all Personal Protective

Equipment, hand tools and gas equipment daily.

j) Shall ensure hired equipment is safe and that, where appropriate,

copies of current test certificates, or licenses are available.

k) Shall ensure that all equipment on the Project is safe, adequately

guarded and suitably equipped with any necessary safety devices.

l) Ensure that a record of all inspections carried out should be kept.

Training and instruction should be arranged when necessary.

m) Ensure that proper care is taken of casualties and know where to obtain

medical help and ambulance service in the event of serious injuries.

n) Shall ensure that only experienced and competent operator employed

for the Project.

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Attachment VI: Hospital Tuanku Ampuan Rahimah, Klang Direction

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Attachment VII: Pantai Klang Specialist Medical Centre Direction

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Attachment VIII: PPE for Offshore Personal

1 Coverall Type:

Material:

One Piece

Nomex or equivalent with flame resistant properties.

2 Safety Boot Type:

Material:

Pull- On High Cut Safety Boot

DOSH-approved or meets ASTM F 2413 standard

3 Safety Glassess Type:

Material:

Clear Lenses

DOSH-approved or meets ANSI Z87.1 standard

4 Presciption Glassess Type:

Material:

Clear Lenses (single focal/ bifocal/ muti-focal)

5 Safety Helmet Type:

Material:

Hard Top Hard Hat

DOSH-approved or meet ANSI Z89.1 standard

6 Ear muff Type:

Material:

Hard Hat Mounted Ear Muff

DOSH-approved or meet ANSI S3.19 standard

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Attachment IX: Incident Notification Flowchart

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Attachment XI: Incident Notification Matrix

Incident

Severity Level

Inform

Immediate

Supervisor

Inform

Leads and

/or Project

Manager

Notify HSE

Dept.

Notify

(Senior)

Manager

Notify

General

Manager

Notify

Share-

holders

Minor

No Injury / / /

Property

Damage

RM < 10 K

/ / /

Near Misses / / /

Serious

First Aid Case / / / /

Medical

Treatment

Case

/ / / /

Oil Spill <

5bbls

/ / / /

Property

Damage

RM > 10 K to

100 K

/ / / /

Major

One Serious

Injury (LTI)

/ / / / /

Oil Spill > 5 to

100 bbls

/ / / / /

Property

Damage

RM > 100 K to

10 MM

/ / / / /

Catastrophic

More than 1

LTI or

Fatalities

/ / / / / /

Oil Spill

>100bbls

/ / / / / /

Property

Damage

RM > 10 MM

/ / / / / /

Action Party Witness /

Person

Involved

Supervisor Leads

and/or

Project

Manager

Leads

and/or

Project

Manager

(Senior)

Manager

General

Manager