petroleum hsec controls

Petroleum

Health, Safety, Environment and CommunityControlsValid until June 2014

Control Control Owner Reference #

Hazard & Risk Safety and Risk Manager Element #3

Community Community Manager Element # 6

Crisis & Emergency Management Asset Protection Manager Element #11

Security Asset Protection Manager Element #11

Health & Hygiene Occupational Health & Hygiene Manager Element #13

Aviation Principal Aviation Specialist Element #14

Marine Principal Marine Specialist Element #14

Fatal Risk Safety & Risk Manager Element #14

Road Going and Light Vehicles Safety & Risk Manager FRC 1

Mobile Equipment Safety & Risk Manager FRC 2

Explosives Safety & Risk Manager FRC 3

Hazardous Materials Safety & Risk Manager FRC 4

Isolation Safety & Risk Manager FRC 5

Equipment Safeguarding Safety & Risk Manager FRC 6

Working at Height Safety & Risk Manager FRC 7

Lifting Operations Safety & Risk Manager FRC 8

Dropped Objects Safety & Risk Manager FRC 9

Working with Pressure Safety & Risk Manager FRC 10

Presence of Hydrogen Sulphide (H2S) Safety & Risk Manager FRC 11

Confined Space Entry (CSE) Safety & Risk Manager FRC 12

Diving Safety & Risk Manager FRC 13

Ground Disturbance & Ground Control Safety & Risk Manager FRC 14

Application of Fatal Risk Controls Safety & Risk Manager All FRCs

Site Traffic Management Plan Safety & Risk Manager FRC 1 and 2

Environment Environmental Engineering Manager Element #15

HSEC Data Reporting Safety & Risk Manager Element #16

BHP Billiton Petroleum HSEC Controls Accountabilities Table

Revision Number Revision Date URL Comments

Contents

IntroductionPurpose 1Scope 1Application 1Responsibility 1References 1BHP Billiton Petroleum HSEC Portal 1

Hazard and Risk Management Controls Control 1 – Risk Assessment 5Control 2 – Risk Treatment 6Control 3 – Governance and Compliance 7

Community Controls Control 1 – Stakeholder Engagement 11Control 2 – Community Development 12Control 3 – Human Rights 13

Crisis and Emergency Management ControlsControl 1 – Risk Assessment 17Control 2 – Emergency Response Structure 17Control 3 – Plans 18Control 4 – Provision of Resources 18Control 5 – Training and Exercises 19Control 6 – Business Continuity 19Control 7 – Review 20

Security ControlsControl 1 – Accountabilities 23Control 2 – Risk Assessment 23Control 3 – Plans 24Control 4 – Use of Public and Private Security Resources 24Control 5 – Firearms and the Use of Force 25Control 6 – Security Training and Awareness 25Appendix A: Security and Emergency Management 26 Approvals Framework

Health and Hygiene ControlsControl 1 – Occupational Exposure 29Control 2 – Fit for Work 29Control 3 – Reporting and Management Review 30Applicability Supplement 31Associated Documentation 31

Aviation ControlsControl 1 – General Requirements 35

Marine Operations Controls Control 1 – Operations Management 39Control 2 – Contracting of Vessels 41Control 3 – Facility Safety Zones 42Control 4 – Personnel Transfer 43Control 5 – Transfer of Supplies 44Control 6 – Off-Take Tanker Operations 45

Fatal Risk Controls Control 1 – Road Going and Light Vehicles 49Control 2 – Mobile Equipment 50Control 3 – Explosives 51Control 4 – Hazardous Materials 52Control 5 – Isolation and Permit to Work 53Control 6 – Equipment Safeguarding 54Control 7 – Working at Height 55Control 8 – Lifting Operations 56Control 9 – Dropped Objects 57Control 10 – Working with Pressure 58Control 11 – Presence of Hydrogen Sulphide (H2S) 59Control 12 – Confined Space Entry (CSE) 60Control 13 – Diving 61Control 14 – Ground Disturbance and Ground Control 62Appendix B: Notes, Application and Inter-Relationship 63 of Fatal Risk Controls

Appendix C: Site Traffic Management Plan requirements 66Appendix D: Transitional Requirements for Existing 66 Light Vehicles

Environment Controls Control 1 – Land, Marine and Biodiversity Disturbances 69Control 2 – Noise Disturbances 70Control 3 – Hydrocarbon 71Control 4 – Water Sourcing, Use and Discharge 72Control 5 – Air Emissions 73Control 6 – Energy Use and Greenhouse Gas Emissions 74Control 7 – Waste 75Control 8 – Drilling Muds and Drilled Cuttings 76References 77

Data Reporting Controls Control 1 – General Requirements 81Control 2 – Reporting Requirements 82Control 3 – Significant Events 84

D Health, Safety, Environment and Community Management System Framework

Controls 1

Introduction

PurposeBHP Billiton Petroleum corporate mandatory HSEC requirements as described in the HSEC related Group Level Documents (GLDs) are met through implementation of the BHP Billiton Petroleum HSEC Management System Framework, associated BHP Billiton Petroleum HSEC Controls and related procedures.

ScopeThe BHP Billiton Petroleum HSEC Controls cover BHP Billiton Petroleum activities that affect or have the potential to materially affect, beneficially or adversely, the health, safety and security of people, the physical environment and protection of assets.

ApplicationThe BHP Billiton Petroleum HSEC Controls apply to the entire lifecycle of BHP Billiton Petroleum activities, processes and products. Contractors must comply with relevant aspects of the BHP Billiton Petroleum HSEC Controls. Partners and suppliers are encouraged to adopt the intent and nature of the performance requirements in this document. Where there is a conflict between legislation and BHP Billiton Petroleum requirements, the more stringent standard prevails while ensuring legal compliance requirements are met. A BHP Billiton Petroleum variance form must be completed and submitted to BHP Billiton Petroleum HSEC Systems Support where applicable requirements cannot be met and are assessed as a material gap. Where the gap is associated with a Group Level Document (GLD), the purpose of the variance form will be to ensure visibility of the issue at the appropriate level within BHP Billiton Petroleum. For BHP Billiton Petroleum specific requirements, the variance form will be reviewed and addressed by the relevant functional owner.

ResponsibilityUnless otherwise stated, managers responsible for BHP Billiton Petroleum activities are accountable for the implementation of the performance requirements outlined in this document. Personnel must comply with the letter and spirit of the performance requirements in the BHP Billiton Petroleum HSEC Controls including associated documentation.

References • The HSEC Controls document must be used in conjunction with

the associated BHP Billiton Petroleum HSEC Controls Compliance Workbook. Each workbook provides additional details associated with each requirement (responsibilities, approvals, endorsements, evidence of compliance, frequency of execution and supporting documentation.

• BHP Billiton Petroleum HSEC Glossary of Terms

• BHP Billiton Petroleum HSEC Management System Framework

BHP Billiton Petroleum HSEC PortalConsistent with the principles of continuous improvement, the BHP Billiton Petroleum HSEC Controls and other related documents will be periodically updated therefore: • The BHP Billiton Petroleum HSEC Portal must be used to access

the governing current version of this document.

• HSEC Control References in the electronic copy are italicized and hyperlinked as appropriate within the HSEC Portal.

BHP Billiton Petroleum Controls

Hazard and Risk Mangement

Controls 5

IntentIdentify and assess HSEC Hazards associated with BHP Billiton Petroleum activities and manage HSEC Material Risks

Performance Requirements 1.1 Identify sources of hazards, possible causes and impacts as

a result of the risk.1.2 Conduct Process Hazard Analysis (PHA) workshops across

all phases of the life cycle of a facility in accordance with the PHA Management procedure to identify HSEC Hazards.

1.3 Involve appropriate technical and functional representation in the Process Hazard Analysis (PHA) workshops.

1.4 Conduct Hazard and Operability (HAZOP) studies for all new developments in accordance with the BHP Billiton Petroleum HAZOP procedure.

1.5 Conduct a revalidation Process Hazard Analysis (PHA) for operating sites in accordance with the frequencies as defined in the PHA Management procedure.

1.6 Conduct a Risk Analysis to determine severity and likelihood for each hazard event identified utilizing the BHP Billiton Petroleum HSEC Risk Matrix.

1.7 Identify all HSEC Material Risks in accordance with BHP Billiton Petroleum criteria, established by the Risk Management Procedure.

1.8 Manage actions from Process Hazard Analysis (PHA) workshops to completion in accordance with PHA Management procedure.

1.9 Document HSEC Material Risks in a controlled Risk Register in accordance with the Risk Management procedure.

1.10 Communicate HSEC Material Risks to personnel involved in the activities.

1.11 Develop and make available Bowtie diagrams for all HSEC Material Risks identified in accordance with the Management of Critical Controls procedure.

1.12 Use Bowtie diagrams to describe credible causes, consequences and Controls and ensure they form part of the Safety Case.

1.13 Maintain Bowtie diagrams to ensure alignment with current HSEC Material Risk Register.

.

Risk Assessment

Hazard and Risk Control 1

6 Health, Safety, Environment and Community

IntentIdentify, establish and evaluate Critical Controls that are required to manage HSEC Material Risks and demonstrate to BHP Billiton Petroleum stakeholders that facilities have been selected, designed, constructed, commissioned and can be operated in a manner such that residual risk levels are ALARP


Risk Treatment

Performance Requirements2.1 Identify Critical Controls for Material HSEC Risk in

accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure.

2.2 Identify Critical Equipment, required to satisfy the objective of the Critical Controls, in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure.

2.3 Develop and maintain a Critical Equipment Register.2.4 Develop Performance Standards for each Critical Control

(Equipment and Non Equipment) in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure.

2.5 Manage Critical Controls that do not meet their Performance Standard via the BHP Billiton Petroleum Case to Operate Procedure.

2.6 Review Performance Standards as per the relevant procedure and update in accordance with the Management of Change Procedure.

2.7 Verify Critical Control effectiveness through Control Self Assessment in accordance with the Risk Management procedure.

2.8 Develop a Safety Case in accordance with the Development Phase and/or operations lifecycle that includes all HSEC Material Risks, Bowties, Critical Controls, Critical Equipment and Performance Standards and verification procedures to demonstrate how the facility manages risk.

2.9 Review and update Safety Case in accordance with the Safety Case procedure. It shall be reviewed at least every 5 years, per local regulatory requirement or when there are material changes that might change the facility/project risk profile whichever is sooner.

2.10 Develop a Safety Case for Drilling Operations for activities that extend beyond 180 days per year and /or for well campaigns that present high risk e.g., HPHT wells.

2.11 Develop a bridging document to address a combined Operations Safety Case and for the interaction of critical controls when 2 or more facilities interact in combined operations.

2.12 Involve appropriate technical and functional representation endorsed by the HSEC function to review the Safety Case.

Controls 7

IntentPerformance measurement and verification for BHP Billiton Petroleum activities and sites provides assurance that HSEC Hazard and Risk Management is effective.

Performance Requirements3.1 Provide assurance that risks are adequately managed by

subjecting the Operations Safety Case and Risk Register to an Annual HSEC Material Risk Review in accordance with the Risk Management procedure and BHP Billiton Petroleum HSEC Assurance procedure.

3.2 Develop and report on Process Safety Key Performance Indicators (KPIs) as part of the Project or Production Unit annual KPIs.

3.3 Review associated actual or potential significant events when evaluating Critical Control effectiveness.

3.4 Manage Bowtie and Critical Controls Health checks in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure.

3.5 Develop risk-based handover certification to ensure assurance activities are conducted and satisfied prior to start-up or continuation of operations after a major shutdown.

Governance and Compliance



Community


Development

Selection and Definition Phases

Financial Investment

Decision

Execution Phase Operations

Exploration and Identification Phase

Pre-Development/ HSEC Screening/ Risk Assessment

HSEC Screening/Risk

Assessment

Acquire Lease

Evaluate Risk

Stakeholder Identification

Stakeholder Engagement

and Documentation

Stakeholder Engagement Management Plan (if critical)

Complaints and Grievances

Mechanism

Human Rights Impact

Assessment Maplecroft

<6.25

Evaluate Material Risk

Identify Business

OpportunitySocial Baseline

StudySocial Impact

and Opportunities Assessment

Commence Field Work

Verify/Validate HRIA

Human Rights Impact

Assessment

Stakeholder Analysis

Verify/Validate HRIA

Implement Community

Development Programs

Evaluate Effectiveness

Go

HSEC Screening includes sociopolitical and human rights

Human Rights Management

Plan

Human Rights

TrainingYes

Yes

Implement Stakeholder Engagement Management

Plan

Evaluate Material Risk

Human Rights Management

Plan

Yes


Mechanism

Human Rights Training

Yes

Design Local

Procurement Plan

Implement Initial

Community Projects

Initial Community Perception

Survey

Decision to Proceed to Develop

Obtain Broad-based Community

Support

Implement Local

Procurement Plan

Evaluate Targets

Design Community

Development Management

Plan

Annual Review Stakeholder Engagement Management

Plan

Community Perception Survey 3-yr.


Mechanism

Three-year HRIA Review

Annual HRMP Review

Figure 1 Community Requirements by BHP Billiton Petroleum Project Lifecycle

Note: Dotted line indicates earlier timing of a requirement based on risk. Refer to Community Controls for details.

Controls 11

IntentA Stakeholder Engagement Management Plan must be implemented and maintained to support regular and ongoing dialogue with stakeholders who could have an impact on, or be impacted by BHP Billiton Petroleum activities.

Community Control 1

Stakeholder Engagement

Performance Requirements The timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1.1.1 Identify those stakeholders who have an interest in the

project or operations and who could influence the outcome of the project or operations. Refer to the Stakeholder Engagement Procedure.

1.2 Prepare a Stakeholder Analysis to understand and consider the concerns, interests and relationships of identified stakeholders. Refer to the Stakeholder Engagement Procedure.

1.3 Implement and document consultation activities specific to each stakeholder. Refer to the Stakeholder Engagement Procedure.

1.4 Prepare, implement and maintain a Stakeholder Engagement Management Plan. Refer to the Stakeholder Engagement Procedure.

1.5 Document all stakeholder engagement activities, responses to concerns and complaints, outcomes, agreements and commitments. Refer to the Stakeholder Engagement Procedure.

1.6 Review and update the Stakeholder Engagement Management Plan annually. Refer to the Stakeholder Engagement Procedure.

1.7 Conduct a community perception survey to identify priority areas for community development. Refer to the Stakeholder Engagement Procedure.

1.8 Evaluate progress against the objectives documented in the Stakeholder Engagement Management Plan every 3 years based on a community perception survey that includes indicators reflecting community concerns. Refer to the Stakeholder Engagement Procedure.


Community Control 2

Community Development

IntentA Community Development Management Plan must be implemented, maintained and reviewed to assist BHP Billiton Petroleum to contribute to the livelihoods of people in host communities and enhance BHP Billiton Petroleum’s license to operate.

Performance Requirements The timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1.2.1 Complete a social baseline study and social impact and

opportunity assessment, and select key quality-of-life indicators. Refer to the Community Development Procedure.

2.2 Develop a community development budget, and design, implement, maintain, and annually review a Community Development Management Plan, according to the Community Development Procedure.

2.3 Identify, implement, and document the initial community development projects that are linked to focus areas, according to the Community Development Procedure.

2.4 Identify, implement, and document Community Development Projects linked to the quality-of-life indicators, according to the Community Development Procedure.

2.5 Evaluate the effectiveness of the Community Development Management Plan every three years, according to the Community Development Procedure.

2.6 Design and implement a local procurement plan with targets. Refer to the Community Development Procedure.

2.7 Complete and authorize the Community Development Project or Donation Anti-Corruption Template for all community development projects, donations, and sponsorships. Refer to the Community Development Project or Donation Anti-Corruption Procedure and the Community Development Project or Donation Anti-Corruption Template.

2.8 Complete and authorize the BHP Billiton Petroleum Community Development Project Quality Assessment Framework Template for community development projects with a total value over US$1 million.

2.9 Implement and provide access to the Employee Matched Giving program to all employees, in accordance with protocols defined by Group HSEC.

Controls 13

Community Control 3

Human Rights

IntentActivities must be undertaken so that people’s human rights are respected and BHP Billiton Petroleum’s human rights commitments are met.

Performance RequirementsThe timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1.3.1 Prepare, verify, validate and annually review a Human

Rights Impact Assessment. Refer to Human Rights Management Procedure.

3.2 Prepare a Human Rights Management Plan if the Human Rights Impact Assessment identifies a material risk issue. Refer to the Human Rights Management Procedure.

3.3 Where a Human Rights Management Plan is required, train employees and contractors to facilitate compliance with BHP Billiton Petroleum’s human rights commitments. Refer to the Human Rights Management Procedure.

3.4 Obtain and document broad based community support prior to seeking Execution approval, and document any opposition to the project. Refer to the Human Rights Management Procedure, and the Stakeholder Engagement Procedure.

3.5 Investigate and resolve promptly all breaches to the United Nations Declaration of Human Rights. Refer to the Human Rights Management Procedure.

3.6 Implement a resettlement program (voluntary or involuntary) for BHP Billiton Petroleum activities that require physical or economic displacement, consistent with the requirements of the IFC Performance Standard 5: Land Acquisition and Involuntary Resettlement, excluding the requirements to obtain Free Prior Informed Consent. Refer to the Human Rights Management Procedure.

3.7 Develop and implement a complaints and grievances mechanism commensurate with the country risk rating, and document through the BHP Billiton Incident Reporting System. Refer to the Human Rights Management Procedure and the Claims Management Procedure.


Crisis and Emergency

Management

Controls 17

Crisis and Emergency Management Control 1

Risk Assessment

IntentIdentify potential incidents that threaten the safety of people, environment, property and reputation.

Performance Requirements1.1 Identify credible emergency scenarios based on evaluation

of material risks and most likely hazards associated with BHP Billiton Petroleum activity.

1.2 Engage a cross-functional team inclusive of stakeholders to define:• Mitigation activities designed to reduce the impact(s)

arising from each identified emergency response scenario.

• Preparedness activities associated with organizing and mobilizing essential emergency response resources.

• Response strategies and actions to be followed during the emergency.

• Recovery strategies and actions required post-emergency for the re-establishment of normal state.


Emergency Response Structure

IntentEnsure that an adequate organization is established, that roles and responsibilities are identified, then communicated and understood.

Performance Requirements2.1 Put in place an emergency response organization in

alignment with BHP Billiton Petroleum CEM procedure as follows: • Establish a tiered response structure (FRT/IMT/EMT) to

direct, control, coordinate and escalate response and recovery activities.

• Authorize competent personnel to respond to and manage emergencies as follows:

- Confirm the nature and extent of an incident;

- Trigger and activate an appropriate emergency response at each tier level, commensurate with severity of the emergency;

- Have plans, processes and procedures for the activation, operation, coordination and communication of the incident response;

- Have resources available to support the plans, processes and procedures to manage an incident; and

- Communicate with stakeholders.

• Put in place adequate redundancy of personnel such that successful emergency response is likely, even if key individuals are not able to perform their assigned roles.



Plans

IntentEnsure that plans identify routine and contingency actions for managing risks and incidents.

Performance Requirements3.1 Develop Emergency Response plans that are scaled

according to the BHP Billiton Petroleum activities, associated hazards, material risks and applicable regulatory requirements. At a minimum plans must include:• Critical information that is organized and prioritized for

quick access.

• Procedures for incident detection, notification, incident severity thresholds at which each response level is mobilized.

• Procedures to communicate and coordinate with all persons involved in responding to or potentially affected by the emergency.

• Clear roles and responsibilities of all responders.

• Identification of response organizations and descriptions of command and control structures.

• Identification, description and methods of notifying and mobilizing predetermined resources, required personnel, equipment, and services.

• A communications plan to engage stakeholders including coordination with Group Public Affairs, for incidents with a maximum foreseeable loss.

3.2 Review Emergency Response plans annually, as well as under the following circumstances:• Change in nature of activity and associated risks.

• Change in availability or provision of response resources, services or equipment.

• Inclusion of lessons identified through training exercises or real events.

• Change in regulatory or Company requirements.


Provision of Resources

IntentIdentify, allocate and maintain necessary resources.

Performance Requirements4.1 Put in place resource management arrangements to enable

timely and unimpeded access to identified resources which prevent, mitigate, prepare for, respond to, or recover from identified emergency scenarios; resource management must include the following tasks: • Establishing processes for describing, inventorying,

requesting, and tracking resources.

• Activating, dispatching and deactivating these processes prior to and during an emergency.

• Contingency planning for shortfalls of resources

• Establishing alarm and warning systems to inform all affected personnel an emergency condition exists and what actions to take.

• Ensuring access to qualified medical resources.

4.2 Conduct an assessment to identify resource capability shortfalls, constraints and the steps necessary to overcome any shortfalls and constraints.

4.3 Establish formalized 3rd party contracts and agreements with defined performance standards/criteria for the provision of resources, services or equipment in support of emergency response activities.

4.4 Define Mutual aid arrangements inclusive of each participant’s commitment, as well as other agreed responsibilities.

4.5 Establish and implement Inspection, testing and maintenance procedures for emergency response equipment.

Controls 19


Training and Exercises

IntentIndividuals are skilled in their knowledge and application of plans and that processes and resources are acceptable.

Performance Requirements5.1 Train individuals assigned emergency response duties in

their roles and responsibilities prior to commencement of duties or actively participating in an actual response.

5.2 Identify frequency and scope of training through training needs analysis and comply with relevant regulatory requirements.

5.3 Maintain training records and certification.

5.4 Develop exercises using realistic scenarios. Events should be based on the relevant material risks.

5.5 Design exercises to test and evaluate individual essential elements, interrelated elements, or the entire plan(s), procedures, and capabilities.

5.6 Conduct post exercise and event reviews to assess the achievement of the aims and objectives and provide a written report that includes outcomes and required actions.


Business Continuity

IntentA plan is established which defines the steps necessary to ensure the continuation of or re-establishment of business activities following an emergency event.

Performance Requirements6.1 Develop business continuity plans aligned with the

BHP Billiton Petroleum Business Continuity procedure, that are scaled according to the BHP Billiton Petroleum activities, associated hazards, material risks and applicable critical activities.

6.2 Identify critical activities whose loss as the result of a disruption beyond the emergency response phase that would have the greatest impact in the shortest time and which need to be recovered most rapidly.

6.3 Identify measures that:

• Reduce the likelihood of a disruption.

• Shorten the period of disruption.

• Limit the impact of a disruption on key products and services.

6.4 Develop business continuity strategies and plan(s) which set out prioritized objectives in terms of:

• Critical activities to be recovered.

• Timescales in which they are to be recovered.

• Resources including external needed for implementing the recovery.

• Recovery levels needed for each critical activity.

• The situation in which the plan can be utilized.



Review

IntentEnsure plans are current, people are trained and resources are allocated in a consistent manner.

Performance Requirements7.1 Review Emergency Response arrangements including

response plans annually as part of the local HSEC assurance review and update plan(s) and procedures as deemed necessary.


Security

Controls 23

Security Control 1

Accountabilities

Intent Personnel with security management responsibilities or duties are suitably experienced, or trained, to perform the function.

Performance Requirements1.1 Appoint a Security Focal Point (SFP) and register the

appointment in a security plan.1.2 Execute the SFP responsibilities as defined in the Site

Security & Asset Protection Performance procedure.

1.3 Attain the required SFP training and competence as defined in the Site Security & Asset Protection Performance procedure.

Security Control 2

Risk Assessment

IntentSecurity risks are identified and mitigations or controls for vulnerabilities are evaluated.

Performance Requirements2.1 Conduct an initial Security risk assessment2.2 Utilize the Security Threat Management procedure to

evaluate security-specific threats2.3 Document security risk assessments and associated

mitigations.2.4 Record material risks in the appropriate risk register.

2.5 Update or review the initial Security risk assessment: annually, prior to commencement of any new activity or significant or material change to routine activities, or upon a change in threat or threat level.

2.6 Brief the relevant Divisional President on all material risks.2.7 Assess risks from Explosive Remnants of War where

appropriate and in accordance with the Threat Management Plan procedure.


Security Control 3

Plans

IntentDetailed responsibilities, operating procedures and controls to reduce and mitigate identified vulnerabilities or risks are captured within an approved security plan.

Performance Requirements3.1 Develop a Security Plan in accordance with Site Security &

Asset Protection Performance procedure.3.2 Review Security Plans as part of the Security Risk

Assessment process and update accordingly.

3.3 Label Security Plans and contingencies as “CONFIDENTIAL” and share on a need-to-know basis as approved in accordance with Appendix A.

3.4 Make available for review Security Operating Procedures to all company personnel assigned to the activity.

Security Control 4

Use of Public and Private Security Resources

IntentResources engaged to protect Company personnel and properties are effective and operate within a framework that upholds respect for individual rights. Public or Private Security forces shall comply with Voluntary Principles of Security and Human Rights.

Performance Requirements4.1 Review licensing and authority of Private and Public

Security Resources to be engaged.4.2 Private security resources comply with all relevant Company

policies and applicable laws including, without limitation: • The US Foreign and Corrupt Practices Act (FCPA) and all

other relevant anti-corruption laws.

• The Voluntary Principles on Security and Human Rights (VPSHR).

• Written agreement to the International Code of Conduct for Private Security providers.

4.3 Encourage Public Security resources to comply with all relevant Company policies and applicable laws including, without limitation: • The US Foreign and Corrupt Practices Act (FCPA) and all

other relevant anti-corruption laws.

• The Voluntary Principles on Security and Human Rights (VPSHR).

4.4 Receive approval from the Chief Executive BHP Billiton Petroleum prior to engaging any public or private security resource that may not adhere to the VPSHR.

4.5 The appointed SFP is to ensure compliance to all VPSHR GLD requirements by following the Site Security & Asset Protection Performance procedure.

Controls 25

Security Control 5

Firearms and the Use of Force

IntentThe use of firearms, weapons and the use of force by any security force shall be considered only when all other mitigation options have been exhausted and there remains an intolerable risk of harm or loss of human life due to an adversarial threat.

Performance Requirements5.1 Gain approval for the carriage, storage, or use of firearms

on BHP Billiton Petroleum business by the Chief Executive BHP Billiton Petroleum. This includes use for both the protection of human life and stewardship requirements such as injured livestock management. This control does not apply to the use of flare guns for emergency purposes.

5.2 Deploy armed security guards only when warranted by a security risk assessment and approved by the Chief Executive BHP Billiton Petroleum.

5.3 Comply with the International Association of Oil & Gas Producers Firearms and Use of Force principles as well as comply with, or meet the intent of, the Voluntary Principles on Security & Human Rights as it relates to the management of firearms, ammunition, and the rules of engagement for firearms use.

5.4 Brief any responding armed law enforcement or emergency response officials, legally acting within their appropriate jurisdiction and official capacity, of associated hazards of discharging firearms relative to the BHP Billiton Petroleum activity.

Security Control 6

Security Training and Awareness

IntentAll personnel are appropriately aware of security risks and individual responsibilities are understood and individuals with security responsibilities are competent to perform specific security duties.

Performance Requirements6.1 Include a description of security risks and procedures

during HSEC inductions or orientations and specifically address: any unique or local security risks; an overview of security controls in place; individual responsibilities for preservation of security and incident reporting.

6.2 Implement a process to support all personnel working at marine facilities or vessels to receive specific maritime security awareness training in alignment with ISPS Code.

6.3 Train personnel with security duties to perform their duties as documented in security plans, standard operating procedures and emergency response plans.


Appendix A

Security and Emergency Management Approvals Framework1

Coun

try/

PU/P

roje

ct

Secu

rity

Mgr

Coun

try/

PU/P

roje

ct

HSE

Mgr

Ass

et P

rote

ctio

n

Div

isio

nal H

SE M

gr

Coun

try/

PU/P

roje

ct

Mgr

VP

HSE

Lega

l

Hea

d of

Gp

HSE

C

Div

isio

n Pr

esid

ent

CSG

Pre

side

nt

Selection and appointment of Security employees or contractors.

As required by BHP Billiton Petroleum HR Approvals Framework.

Selection and appointment of security consultants or service providers, including training.

2

Engagement of any security provider not compliant with the Voluntary Principles on Security and Human Rights.

Design or modification of physical and technical site security controls.

PU, Project or Country level security procedures and plans.

PU, Project or Country level journey management procedures.

Safe travel plans for travel in high, or extreme, risk areas without established Production Units or Project Controls.

3

Security risk assessments, when conducted by an external agency, consultants and non-Asset Protection personnel.

Deployment of firearms in support of BHP Billiton Petroleum operations.

Recommend

Endorse

Inform

Approve

1 These approvals are intended in addition to normal approvals required by the BHP Billiton Petroleum Approvals Framework.2 Legal endorsement may be required for contracting of specific security services.3 CSG President approval required for travel to destinations rated as Extreme risk.


Health and Hygiene

Controls 29

Health and Hygiene Control 1

Occupational Exposure

IntentTo identify potential or actual health & hygiene exposures and implement measures to eliminate or minimize the risk of adverse health effects.

Performance Requirements1.1 Complete a Baseline Assessment to establish an

Occupational Health & Hygiene Exposure profile. 1.2 Communicate Baseline Assessment findings to the Senior

Manager; relevant Senior Manager direct reports; Central HSEC team.

1.3 Develop Occupational Health & Hygiene monitoring strategies associated with the Baseline Assessment.

1.4 Develop and implement Exposure Control Plan(s) to manage issues highlighted in the Baseline Assessment.

1.5 Communicate findings and proposed plans to affected personnel.

1.6 Provide targeted training to affected personnel.1.7 Report on progress against the Exposure Control Plan(s).1.8 Train persons with responsibilities for managing

Occupational Hygiene Exposures for role.


Fit for Work

IntentTo ensure all personnel are present fit-for-work upon employment and while performing duties assigned.

Performance Requirements2.1 Comply with fit for work requirements in accordance with

BHP Billiton Petroleum Health and Hygiene procedures.2.2 Undertake BHP Billiton Petroleum Medical assessments or

equivalent in accordance with BHP Billiton Petroleum Health and Hygiene procedures.

2.3 Implement a drug and alcohol testing program in accordance with the BHP Billiton Petroleum Drug and Alcohol Procedure.

2.4 Implement a fatigue management program in accordance with BHP Billiton Petroleum Fatigue Management Procedure.

2.5 Manage injury and illness cases in accordance with the BHP Billiton Petroleum Injury & Illness Case Management Procedure.

2.6 Identify resources to implement systems to manage all aspects of Fitness to Work.

2.7 Require Site Medical Professionals to be approved by the BHP Billiton Petroleum Health & Hygiene Manager.

2.8 Require third party medical support to be approved by the BHP Billiton Petroleum Health & Hygiene Manager.


Reporting and Management Review


IntentTo ensure compliance and quality assurance with Company requirements and regulatory agencies.

Performance Requirements3.1 Make available the results of Occupational Exposure

monitoring and surveillance to participating individuals.3.2 Conduct management reviews of all occupational health

and hygiene programs, incidents and opportunities for improvement.

Controls 31

Health and Hygiene Controls

Applicability Supplement

Associated Documentation• Medical Assessment Procedure

• Occupational Exposure Management Procedure (Occupational Hygiene)

• Injury/Illness Case Management

• Drug and Alcohol

• Ergonomics

• Fatigue Management

• Hearing Conservation

• Respiratory Protection

• Drug and Alcohol Procedure for Workers Regulated by the DOT

• Travel Medical Kit – Use and Contents

• First Aid and Medical Equipment

• Pre-requisites for Site Medical Professionals

• Medical Protocols for Site Medical Professionals

• Assessment for Determination of Occupational Health Support

• Bloodborne Pathogens Questionnaire

• Actions by Sites with a Site Medical Professional

• Actions by Sites without a Site Medical Professional

• Audiometric Testing Process with Work-Relatedness Determination Process

• Health & Hygiene Control Compliance Assessment Workbook

Occupational Health and Hygiene Aspect

Office Short Term Projects Long Term Projects Production

Baseline Assessment Applicable1 *Applicable *Applicable *Applicable

Exposure Profile Applicable2 N/A *Applicable *Applicable

Exposure Control Plan N/A *Applicable *Applicable

Health and Hygiene Exposure Reporting

N/A *Applicable

Health Surveillance Reporting

N/A *Applicable

Management Review *Applicable *Applicable *Applicable *Applicable

Office Short Term Projects Long Term Projects Production

Fitness for Work *Applicable *Applicable *Applicable *Applicable

Notes

*In accordance with procedure

Short Term Projects – A project with duration of less than or equal to 6 months. (includes Development & Exploration Projects)

Long Term Projects – A project with duration of greater than 6 months. (includes Development & Exploration Projects)

Production includes World Wide Drilling long term rigs1Qualitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure)2Quantitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure)


Aviation

Controls 35

Aviation Control 1

General Requirements

IntentTo manage aviation activities in order to identify, assess and eliminate or minimize aviation related risk.

Performance RequirementsImplement the following for BHP Billiton Petroleum activity:1.1 Use aircraft operators approved by Head of Group HSEC

and the BHP Billiton Petroleum Principal Aviation Specialist (no deviation allowed).

1.2 Conduct aircraft operations in accordance with the BHP Billiton Petroleum Aircraft Charter Requirements which includes compliance with the Flight Safety Foundation Basic Aviation Risk Standard (BARS).

1.3 Have in place a written agreement (contract) with the charter operator that includes the BHP Billiton Petroleum Aircraft Charter Requirements and the BARS.

1.4 Require aircraft with two turbine engines and operated by two qualified pilots for carrying of passengers.

1.5 Manage BHP Billiton Petroleum aviation activities in accordance with the BHP Billiton Petroleum Aviation Management Procedure.

1.6 Engage the BHP Billiton Petroleum Principal Aviation Specialist prior to the start of any new operation or if there are significant changes to existing operations.

1.7 Conduct Aviation Self Assessments annually.


Marine Operations

Controls 39

Marine Control 1

Operations Management

IntentMarine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks

Performance Requirements Documentation1.1 Implement documentation for the management of marine

operations commensurate with activities and associated risk. The documentation must cover: • Compliance with the requirements in this Control and

local marine operations regulations (e.g., MOM for USCG, Safety Case for NOPSA).

• Conformance to the Marine Operations Framework Process.

• Conformance to the requirements of the BHP Billiton Petroleum Marine Operations Documentation Procedure.

• Vessel specific types and operational work scope.

• Roles, responsibilities and training requirements for key marine operations personnel.

• Site and/or field data required to support the execution of the BHP Billiton Petroleum marine operations.

• Process for conducting risk assessments requirements outlined in the Marine Operations Control document.

• Emergency response plans.

• Identified critical controls and established performance standards.

• Processes for testing critical controls associated with emergency response procedures prior to commencement of activities and periodically thereafter against a schedule of drills.

• Suitable procedures for storm avoidance and/or emergency down-manning.

• Berthing and Terminal Handbook for off take operations (see Marine Operations Control 6.4).

Marine Operations Risk Assessment1.2 Evaluate marine operations HSEC risks in accordance with

the BHP Billiton Petroleum Hazard and Risk Management Controls for:• Use of a new build vessel or a vessel under construction

prior to engagement.

• Use of a vessel undergoing modification, or requiring modification or conversion prior to commencement of the modification works.

• Offshore and onshore personnel transfers.

• Changes to a routine marine operation.

• Changes to regulatory or other requirements.

• Changes to environmental and/or operational conditions.

1.3 Engage responsible managers and other relevant personnel to participate in Marine Operations risk assessments.

1.4 Obtain Principal Marine Specialist endorsement where Marine Operations risk assessments identify material risks.

Emergency Response Plans1.5 Implement an emergency response plan for management of

Marine Operations. The plan must take into account:• The roles and responsibilities of emergency response

personnel from BHP Billiton Petroleum and third party marine contractors such as vessels operators or off-take tanker operators.

• Documented lines of communications between BHP Billiton Petroleum and relevant marine third parties.

• Oil spill response plans based on nature of the product, likely dispersion and available response resources. Oil spill response plans must include coordination with BHP Billiton Petroleum Marketing for transport of petroleum products.

• Local emergency response capabilities.

• Methods for recovering people falling overboard and contingency plans for recovery of people at imminent significant risk during personnel offshore and onshore personnel transfer.

• Hazards associated with the surrounding environment.


Marine Control 1

Operations Management (continued)

IntentMarine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks.

1.6 Exercise the Emergency Response plan(s) annually and if practicable within 30 days of a new operations start. Tests and exercises should be designed to include:

• Worst case scenarios covering weather, hours of darkness and availability of response resources.

• Effectiveness of bridging documentation between the third party marine contractors, operators, other emergency response resources (e.g., oil spill resources) and BHP Billiton Petroleum.

Communication1.7 Communicate relevant Marine Operations documentation

including the outcomes of the risk assessment to stakeholders, including affected employees and contractors.

Review1.8 Update Marine Operations documentation including the

outcomes of the risk assessment to reflect temporary changes to any critical controls or when there are events such as brownfield projects, seismic campaigns and dive support vessel activities.

1.9 Review Marine Operations documentation including outcomes of the risk assessment annually. The review must involve personnel from affected functions and the Principal Marine Specialist. The review must consider as a minimum the following:

• Changes in operational scope

• Procedural changes

• Changes in regulatory requirement

Variances1.10 Obtain an approved BHP Billiton Petroleum HSEC Variance

Form in circumstances where the requirements of this Controls document cannot be met prior to commencing Marine Operations activity.

Variances to this procedure must be approved by:• Principal Marine Specialist

• Contract Line Manager

• Project Manager For Variance Requests where the Functional Specialist has

assessed the consequence as an actual or potential significant event, additional approval is required from:• Vice President HSEC

Controls 41

Marine Control 2

Contracting of Vessels

IntentMarine vessels and marine operations suppliers are audited and verified as qualified to meet the requirements of the Marine Operations Controls prior to use.

Performance Requirements Selection, Approval and Engagement of Marine

Operations Suppliers2.1 Obtain the endorsement from the Principal Marine

Specialist regarding the use of marine vessels and marine operations contractors to ensure the appropriate specification, terms and conditions and written agreements are applied as follows:• Tender process

• Contract award

• Changes to existing contracts 2.2 Include a copy of the Marine Operations Controls and the

BHP Billiton Petroleum Marine Audit Procedure in Tender documentation relating to marine operations contracts.

2.3 Obtain approval from the Principal Marine Specialist for the use of all contracted marine vessels prior to engagement.

2.4 Audit all marine vessels prior to contract award according to the requirements of the BHP Billiton Petroleum Marine Audit Procedure.

2.5 Complete all high level and HSEC critical audit findings, as defined in the BHP Billiton Petroleum Marine Audit Procedure, prior to contract execution (e.g., commencement of field activities or construction activities). Variation from this requirement must be endorsed by the Principal Marine Specialist or delegate.

2.6 Obtain endorsement from the Principal Marine Specialist for the closure of high level and HSEC critical marine audit findings.

2.7 Obtain endorsement from the Principal Marine Specialist for the proposed modifications to marine vessels; modifications to critical equipment must be approved by the Divisional President.

2.8 Exempt vessels that have been independently audited within the last 12 months from a BHP Billiton Petroleum audit subject to a review of the findings and status of the associated actions by the Principal Marine Specialist.

New Build Vessels and Vessel Modifications2.9 Subject new build dynamically positioned vessels and

existing vessels with modified1 DP systems to a Failure Mode and Effects Analysis (FMEA) together with appropriate proving trials; the scope of sea trials and the FMEA must be endorsed by the Principal Marine Specialist.

2.10 Subject new build vessels and vessels undergoing modifications to the propulsion, steering or hull dynamics to appropriate sea trials; the scope of sea trials and the FMEA must be endorsed by the Principal Marine Specialist.

Bridging Documentation2.11 Prepare bridging documentation in accordance with

Element 10 of the BHP Billiton Petroleum HSEC Management System Framework.

2.12 Address in the bridging documentation differences and interface processes between BHP Billiton Petroleum and the marine contractor, including:• Communication protocols that cover:

- Normal activities

- SIMOPS

- Incident reporting

• Roles and responsibilities.

• Coordination of emergency response plan.2.13 Communicate the bridging documentation to all affected

personnel.

Marine Operations 2.14 Comply with the Marine Operations Framework Process

when contracting vessels.

1A modification means any substantial changes that would require Classification Society approval.


Marine Control 3

Facility Safety Zones

IntentMarine safety zones are established and managed at BHP Billiton Petroleum and contracted third party facilities (including MODUs).

Performance RequirementsEstablishment of Safety Zones3.1 Establish and maintain a Facility Safety Zone for Offshore

facilities as follows: • A minimum distance of 500m or as required by

regulations.

• Define provisions for monitoring the safety zone.

• Define activities permitted within the safety zone.

• Define critical controls to manage activities in the safety zone including the Facility Safety Zone Check Sheet.

• Define controls for SIMOPs in the safety zone.

• Communicate information concerning the safety zone to relevant stakeholders, including affected employees, contractors and contractor vessels.

Marine Operations within Safety Zone 3.2 Complete Part A of the Facility Safety Zone Check Sheet and

obtain approval from the Facility OIM prior to entering the safety zone.

3.3 Complete Part B and Part C of the Facility Safety Zone Check Sheet and obtain approval from the Facility OIM prior to the following respective phases:• Commencement of work within the safety zone (Part B).

• Departure from the Facility Safety zone (Part C).3.4 Keep the Facility Safety Zone clear except for vessel

operations and activities approved by the Facility OIM. 3.5 Require vessels to keep clear or to depart the Facility Safety

Zone when unable to maintain position or are experiencing degradation of station keeping capability.

Third Party Facilities 3.6 Establish Facility Safety Zones for third party contracted

operations such as drill rigs, heavy lift vessels or flotels in accordance with this control and document relevant aspects in the associated bridging documentation.

Controls 43

Marine Control 4

Personnel Transfer

IntentPersonnel transfer risks are controlled to ensure the safe transfer of personnel.

Performance RequirementsOffshore Personnel Transfers4.1 Conduct a risk assessment prior to initial commencement of

offshore personnel transfer activities, to identify the most appropriate means of transfer and relevant controls. Personnel transfer methods include:• By helicopter

• Basket transfers

• Boat to Boat Transfer

• Davit to Davit Transfer

• Swing Rope

• Temporary bridges4.2 Consider helicopters as the preferred primary means of

personnel transfer to vessels and facilities with a certified helideck. All helicopter operations must meet the requirements of the Aviation Operations Controls.

4.3 Prohibit the use of collapsible personnel transfer baskets (e.g., Billy Pugh X-800 series nets or similar) must not be used.

4.4 Use only rigid personnel transfer baskets (e.g., Billy Pugh X-904 and Reflex Marine FROG) or offshore personnel transfers.

4.5 Conduct marine personnel transfers under a lift plan in accordance with the BHP Billiton Petroleum Lifting Equipment Control and Operations Procedure. Personnel basket transfers must also comply with the BHP Billiton Petroleum Personnel Transfer and Man-Riding Procedure.

4.6 Prohibit personnel basket transfers during the hours of darkness with the exception of emergency situations.

4.7 Assign a designated person to supervise the transfer operation at each of the landing zones.

4.8 Subject all lifting equipment utilized in basket transfer operations to a visual inspection by a competent person such as a certified rigger prior to use.

Offshore Temporary Bridge4.9 Inspect and certify “fit for purpose” all temporary bridges,

landing platforms and securing arrangements. 4.10 Clearly mark and keep free of obstructions access and

egress to temporary bridges.

Dockside4.11 Require use of a gangway or accommodation ladder for all

BHP Billiton Petroleum owned or contracted vessels alongside docks.

4.12 Install gangways and ladders in accordance with the manufacturer’s design and operating requirements.

4.13 Use an approved safety net as a supplement for gangways and accommodation ladders.

4.14 Provide safe means of access for personnel transfer between vessels rafted alongside each other.

4.15 Require the use of a designated person supervising transfer operations between vessels rafted alongside each other.

4.16 Conduct a risk assessment to determine the requirements for additional means of access/egress for vessels/facilities in shipyards. (e.g., two gangways).

Familiarization and Orientation4.17 Brief personnel undertaking offshore marine transfers prior

to commencing the initial transfer and then at ongoing intervals, the frequency of which is determined based on:• The assessed risk and nature of the transfer method.

• Applicable regulatory requirements.

• Helicopter transfers require safety briefing prior to each flight, as per the BHP Billiton Petroleum Aviation Operations Controls.

4.18 Include the following in the user briefing: • An overview of the transfer method type

• Hazards and risk management controls

• Emergency procedures

• Communication protocols (if required)


Marine Control 5

Transfer of Supplies

IntentSafe and environmentally responsible transfer of supplies (excluding petroleum products such as crude) to and from BHP Billiton Petroleum facilities and/or to and from contracted third party vessels.

Performance RequirementsCargo transferred by Crane5.1 Manage crane cargo transfers in accordance with the

BHP Billiton Petroleum Lifting Equipment Control and Operations Procedure.

Liquid Bulk Transfer5.2 Comply with the Marine Containment Audit Check Sheet

when vessels are engaged in bulk transfer activities.5.3 Manage bulk transfer activities under a permit-to-work.5.4 Implement a process to support using dedicated bulk

transfer hoses for the transfer of a single substance “type” only (e.g., diesel, potable water, brine). Bulk transfer hoses must not be used for the transfer of other materials.

5.5 Maintain direct line of sight during cargo transfer activities between the vessel’s master and the bulk hose(s).

5.6 Use bulk transfer hoses which have the capacity to remain afloat at all times. Where the inherent buoyancy of the hose is insufficient to support a particular product additional flotation devices must be provided.

5.7 Provide adequate illumination where bulk cargo transfers take place during hours of darkness. All hoses and the support vessel must be illuminated prior to, and throughout the transfer operation. Hoses should be fitted with retro-reflective material when illumination cannot be consistently maintained.

5.8 Use dry break couplings on hoses used for bulk transfer of petroleum, petroleum based products, and brines (for example Avery Hardoll or TODO couplings). Additionally, there must be a weak link breakaway coupling (for example a KLAW coupling) within the hose string.

5.9 Provide vessel Masters with a completed Dangerous Goods Declaration and MSDS (material safety data sheet) prior to commencement of loading or back-loading dangerous goods.

5.10 Conduct a risk assessment prior to back-loading contaminated supplies onto a vessel for transport onshore.

5.11 Obtain approval from the vessel master and the shore base manager prior to back-loading contaminated supplies onto a vessel for transport onshore.

Project Execution Plans5.12 Conduct a risk assessment as part of the Project Execution

Plan for project related transfers, (e.g., pipe bundles, sub sea lifts and heavy lifts).

Controls 45

Marine Control 6

Off-Take Tanker Operations

IntentTanker operations for petroleum products (including crude, condensate, LPG and LNG) to and/or from BHP Billiton Petroleum facilities are conducted using safe and environmentally responsible methods.

Performance Requirements Tanker Vetting & Inspection6.1 Implement a formal Off-take tanker vetting arrangement

using an approved marine tanker vetting company. 6.2 Audit the approved marine tanker vetting company on an

annual basis to ensure compliance with industry vetting standards.

6.3 Use tankers for the off-take of petroleum products which have undergone a formal vetting and inspection process in accordance with OCIMF and meet the BHP Billiton Petroleum Vetting and Operating Standards.

Facility/Tanker Operations6.4 Develop and maintain a Berthing and Terminal Handbook in

accordance with the Marine Operations Document Procedure for the management of tanker off-take activities.

6.5 Include the following in the Berthing and Terminal Handbook: • Terminal/location details

• Communications plan (including applicable VHF channels)

• A site specific lifting vessel questionnaire

• Relevant regulatory requirements

• Availability of bunkers, potable water and stores

• Any restrictions on crew transfers (except in case of emergency)

• Roles, responsibilities and training requirements for personnel associated with critical controls

• Operating limits/requirements at the facility/berth (e.g., max deadweight tonnage and displacement, vapor recovery, ballast)

• Environmental limitations

• Engine and steering gear tests required prior to the commencement of approach

• Pilotage and pilot boarding controls

• Insurance requirements (Protection & Indemnity)

• Mooring procedures including inspection requirements prior to mooring

• Pollution prevention and preparedness controls including coordinated emergency response plans

• Hose connection and disconnection, including emergency disconnect procedures

• Cargo operations

• Where the off-take tanker requires assistance by a vessel on static tow during the off-take, a procedure is required for the static tow

6.6 Communicate relevant aspects of the Berthing & Terminal Handbook to stakeholders including Joint Venture Partners, customers and vessel owner/operators.

6.7 Test critical controls associated with emergency response procedures prior to commencement of off-take activities and periodically thereafter against a schedule of drills.

Joint Interest Unit Operations6.8 Assess management of off-take arrangements and any

other Terminal Controls against requirements of the BHP Billiton Petroleum Marine Operations Off-Take Tanker Controls.

6.9 Engage BHP Billiton Petroleum Principal Marine Specialist where a material risk has been identified.


Fatal Risk

Controls 49

IntentSelect, equip, operate and maintain Road Going & Light Vehicles to protect personnel (including pedestrians) from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.

Performance Requirements PlantFor new acquisitions of Road Going and Light Vehicles1.1 Acquire new BHP Billiton owned or leased light vehicles

which have a 5 Star NCAP (USA- NHTSA or IIHS) safety rating. This includes the safety features referenced in Appendix B. See Appendix B for NCAP, NHTSA and IIHS details.

Existing Road Going and Light Vehicle fleet1.2 Implement a process to support all BHP Billiton owned or

leased light vehicles having a 5 Star NCAP or equivalent safety rating by 1st January 2016. In the intervening period, existing vehicles must have the safety features referenced in Appendix D.

Support Equipment1.3 Fit company owned or leased vehicles being used at site or

on direct company business with support equipment as defined by location specific risk assessment (this does not apply to personal vehicles used temporarily on business travel). See Appendix B for examples of support equipment.

PeopleCompetence Management1.4 Use and manage competent drivers (employees and

contractors) as follows:• Operate vehicles with certified, licensed drivers.

• Comply with local regulatory certification requirements.

• Comply with company defined requirements inclusive of training on defensive driving.

• Implement a process for identifying and managing at-risk driving behaviours.

• Prohibit the use of mobile phones by drivers, including hands-free applications, unless the vehicle is stopped at a safe location.

ProceduresLight vehicle management process.1.5 Inspect and maintain vehicles as follows:

• Implement a formal inspection & preventative maintenance system in keeping with manufacturer guidance.

• Identify and manage high-risk road journeys.

• Implement emergency response arrangements to mitigate consequences of accidents or break down risk.

• Comply with BHP Billiton Petroleum Management of Change (MoC) Process with regard to vehicle modifications (company owned & leased vehicles only).

• Prohibit installation of aftermarket equipment to 5 Star NCAP vehicles (other than special purpose light vehicles such as ambulances) except where necessary to meet the requirements of visibility and communications equipment.

1.6 Comply with Traffic Management Plan requirement for a minimum safe distance to be maintained between light vehicles and mobile equipment when light vehicles are used within a facility.

Notes: See Appendix B for supplementary information regarding Road Going and Light Vehicles.

Road Going and Light Vehicles

Fatal Risk Control 1


IntentSelect, equip, operate and maintain Mobile Equipment to protect the workforce and the public (including pedestrians) from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Mobile Equipment

Performance Requirements Plant

Safety Features2.1 Select mobile equipment appropriate for the function and

cargo to be carried or task to be performed. This includes the safety features referenced in Appendix B.

Support Equipment2.2 Fit mobile equipment with support equipment as defined by

risk assessment. See Appendix B for examples of support equipment.

Access and Egress2.3 Provide safe access and egress, including:

• Emergency egress, from mobile equipment.

• Safe systems of work for operation and maintenance of components where there is a potential to fall two or more meters, or where a fall could result in a significant incident.

Equipment Management Risk Mitigation2.4 Manage equipment operation and maintenance to:

• Prevent uncontrolled movement of vehicles and mobile equipment during operation and repairs.

• Mitigate risks from towing and recovering mobile equipment, loading and unloading of cargo to prevent dropped objects, spillage or un-planned movement of loads.

PeopleCompetence Management2.5 Use and manage competent people:

• Operate mobile equipment using certified, competent drivers. This includes local regulatory and company defined requirements.

• Identify and manage at-risk driving behaviours.

• Prohibit the use of mobile phones by drivers, including hands-free applications, unless the vehicle is stopped at a safe location.

ProceduresMobile Equipment Management Process2.6 Implement a defined process for management of mobile

equipment which includes the following:• A documented formal inspection & preventative

maintenance system for mobile equipment and registered heavy vehicles; inclusive of checks required prior to operation and appropriate action to be taken if defects are identified.

• Define requirements for the isolation of mobile equipment in line with the BHP Billiton Petroleum Fatal Risk Control - Isolation and Permit to Work.

• Require compliance with BHP Billiton Petroleum Management of Change (MoC) Process with regard to vehicle modifications (company owned & leased vehicles only).

2.7 Develop a process for management of traffic which includes: • Use of an authorized traffic management plan (see

Appendix C).

• A process to identify and manage high-risk road journeys.

• Emergency response arrangements to mitigate consequences of accidents or break down risk.

Controls 51

IntentThe transport, storage and usage of explosives and initiating components must only be performed by trained, competent and authorised employees and contractors in strictly managed and controlled environments for the security of explosive materials and protection of personnel.

Performance RequirementsPlantExplosives Register3.1 Define and document in a register the approved types

of explosives to be used for supporting BHP Billiton Petroleum activities.

PeopleCompetence Management3.2 Engage third party specialists in the management and use

of explosives who are suitably qualified as per manufacturers, regulatory and BHP Billiton Petroleum requirements.

3.3 Educate impacted personnel about access control to support effective management of blasting activity.

ProceduresExplosives Management Process3.4 Develop and implement an Explosives Management

Procedure which includes the following:• Defined processes for management of all stages of

operations involving the use, transportation, storage, handling and disposal of explosives.

• Defined training and competency requirements for transport, storage, handling and usage of explosives and initiating components.

• Process for control access to areas of blasting activity, including clearance zones for potentially affected areas.

• Process for mitigating the risks of equipment operating in the vicinity of loaded holes or explosives remnants.

• Process for management of simultaneous operations ‘use of explosives’ is involved.

• Emergency Response arrangements when explosives are involved.

• Process for managing the risk of misfires and the destruction of old explosives.

• Process for identifying and managing the risks of blasting in hot or reactive ground. See BHP Billiton Glossary of Terms.

3.5 Supplementary Requirements• Comply with all applicable local laws and regulations

controlling use of explosives.

• Comply with manufacturers, regulatory and BHP Billiton Petroleum requirements as it relates to the packing of explosives, inclusive of secondary boxes.

• Comply with manufacturers, regulatory and BHP Billiton Petroleum requirements as it relates to support documentation for explosives.

Notes: See Appendix B for supplementary information regarding Explosives.

Explosives



IntentProcess, store, handle, produce, transport, recycle and dispose of hazardous materials to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Hazardous Materials

Performance RequirementsPlantHazardous Material Risk Mitigation4.1 Implement the following arrangements:

• Locate vessels, containers, bulk stores and process areas containing hazardous materials within areas of adequate design and size to safely contain spills and allow for effective response to spills.

• Identify vessels, containers or pipes containing hazardous materials by appropriate signage or labels and, where relevant, clearly indicate the direction of flow.

• Equipment associated with hazardous materials must fail to a safe condition in the event of interruption to electric, hydraulic or pneumatic power supply.

• Segregate hazardous materials from incompatible materials.

• Install detectors/monitoring appropriate to the hazard where there is the potential for exposure to harmful levels of flammable or toxic materials.

• Identify and make available Emergency Response equipment associated with Hazardous Materials operations.

• Maintain copies of all relevant design input and output records including those from risk assessments throughout the life of the plant.

• Access control appropriate to the identified risk for the process, storage and handling areas of hazardous materials.

Management of Temporary Powered Equipment4.2 Implement the following arrangements for the use of

Temporary Powered Equipment:• Site Temporary Powered Equipment in an appropriate

zone that conforms with regulatory and BHP Billiton Petroleum requirements to minimize potential negative interaction with hazardous materials.

• Equip Temporary Powered Equipment with appropriate protective devices for use in those defined zones which include automatic shutdown devices, over-speed protection, spark arrestors, protected exhaust manifolds, non-flammable fuel lines, pneumatic starter motors.

PeopleCompetence Management4.3 Training, Access and Monitoring

• Provide personnel with information and training on the nature of the hazards to which they may be exposed and the means of assessing and controlling their exposure.

• Educate personnel about the importance of adhering to access control requirements.

• Assess and monitor health of personnel involved in hazardous materials management activities.

ProceduresHazardous Materials Management4.4 Conduct an initial risk assessment as follows:

• Conduct a ‘basis of design’ process hazard analysis (PHA) for new, modified or temporary processes which transports, produces, stores, uses or disposes of hazardous materials.

• Update “As-built” design drawings based on findings from PHA.

4.5 Manage Hazardous Materials as follows:• Complete a PHA and define required controls before any

new hazardous materials are first used.

• Maintain a site register of hazardous materials.

• Maintain Material Safety Data Sheets (MSDS) for hazardous materials and make them accessible for involved personnel.

• Implement an appropriate maintenance system to support the safe operation of equipment involved in processing hazardous materials.

• Make available, relevant procedures, associated documentation and records for the management of Hazardous Materials.

• Address identified risk from Hazardous Materials in the site Emergency Response Plan.

Controls 53

IntentPlan and manage phases of work, tasks, locations, machinery, vehicles and mobile equipment requiring a permit-to-work, or isolation of energy sources to safely perform work (including de-energisation of stored energy) to protect personnel from harm.

Isolation and Permit to Work

Performance RequirementsPlantPurchasing and Design5.1 Purchase equipment which meet the requirements of this

control (this includes hired and contracted temporary equipment)

5.2 Identify any points of isolation.5.3 Provide personnel performing the work with unique,

secure, control of the points of isolation prior to commencing work.

PeopleUse and Manage Competent People5.4 Authorization, Training, Accountabilities

• Specify who can authorize the issue of a permit-to-work.

• Establish the training and competency requirements for permit issuers, permit holders and persons performing isolations inclusive of lock-out/tag-out.

• Define the responsibilities and accountabilities of the permit issuer, individual permit holders and persons performing isolations.

ProceduresIsolations and Permit to Work (PTW) Management5.5 Implement an Isolations and PTW procedure(s) which

include the following processes:• Identify and document all sources of stored energy

which could impact the planned activity.

• Identify and document the hazards.

• Identify, document and implement appropriate prevention and mitigation controls to manage the hazards associated with the planned activity.

• Identify and document isolation points.

• Safe management of identified isolations.

• Safe management of breaking of containment.

• Permit to Work management.

• Defined controls which apply to personnel accessing machinery that may start and stop automatically or by instruction from a remote location.

• Control and approval of software overrides, hard-wire bridging or interlock bypassing.

• Control of isolations and permits-to-work which span one or more shift handovers.

• Definition of how a competent person will prove safe isolation is achieved before commencing work.

• Determination and description of actions required if there is any doubt safe isolation was achieved.

• Management of permits-to-work and isolations for interacting with simultaneous activities.

• Work authorization by a responsible person.

• Verification that all personnel undertaking work requiring a permit understand the hazards being controlled by the permit, the permit conditions to be met, isolation standards to be achieved and the control of simultaneous operations (SIMOPS) activities.

• Authorization of changes which may affect the scope of the permit-to-work and/or the isolation standard(s) required, including a re-assessment of the hazards, potential impact on other operations, changes to planned tasks and the action to be taken by the permit-holder in response to an emergency.

• Verification that isolated equipment/plant is returned to a safe operating condition before equipment/plant is brought back into service.

Notes: See Appendix B for supplementary information regarding Isolation and Permit to Work.



IntentManage the interaction between personnel and moving parts of plant and equipment to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Equipment Safeguarding

Performance RequirementsPlantDesign, Modifications and Controls6.1 Design plant and equipment as follows:

• Eliminate the need for guarding where practicable in new, temporary or modified plant and equipment. All energy sources must be considered. Safeguarding must be in place where other potential mitigation measures do not adequately protect personnel.

• Design and construct plant and equipment safeguards to comply with applicable law, standards, codes of practice and relevant recognized industry practices and considering maintainability and operability.

• Install fail-to-safe switches or devices on all manually operated rotating plant, rotating equipment and power hand tools (e.g., saws, lathes, drill presses, etc.).

• Retain and control all documentation related to the risk-based process for the selection of safeguarding requirements.

PeopleSeparate People from Moving Parts6.2 Control and monitor access to plant and equipment where

safeguarding and interlock systems are assessed as insufficient to protect people.

ProcedureEquipment Safeguarding Management Process6.3 Implement the following via procedure:

• Do not modify or alter guarding except through the application of the BHP Billiton Petroleum Management of Change (MoC) process.

• Retain and control all documentation related to the risk-based process for the modification of safeguarding requirements.

• Use the BHP Billiton Petroleum Management of Change (MoC) process to ensure the integrity of safeguarding is addressed when change occurs.

• Conduct a Process Hazard Analysis (PHA) to identify where safeguarding and interlocks are required on plant and equipment.

• Implement a formal inspection and maintenance system to ensure the integrity of plant and equipment safeguarding.

• Remove guards for maintenance and repair only after plant and equipment has been isolated, and verified as isolated (proved isolated) in line with the BHP Billiton Petroleum Fatal Risk Control - Isolation and Permit to Work.

• Where the temporary removal of safeguards is necessary on operating plant and equipment, for the purposes of fault finding, testing and commissioning, a PHA must be conducted.

• Guards must be re-instated prior to plant and equipment being put back into operation.

Controls 55

IntentManage Work at height activities where there is a potential to fall two meters or more, where a fall could result in a significant incident, or where there is the danger of dropped objects from the work being performed.

Working at Height

Performance RequirementsPlantDesign and Controls7.1 Design new plant and equipment and plan tasks to

minimize the need to work at height where a fall could result in a significant incident, or where there is the danger of dropped objects from the work being performed.

7.2 Provide a secure working area of suitable design and strength where work at height is unavoidable. This working area must include:• Flooring securely fastened in place so it cannot be

accidentally dislodged.

• Mesh, railings or solid barriers to prevent a person falling.

• Toe-boards or similar means to prevent tools and materials falling off the edge of the platform.

7.3 Provide a fall arrest or fall restraint system if a fixed ladder is used and a work at height risk exists.

7.4 Require fall arrest and fall restraint systems to:• Have lanyards and snap-hooks with a secondary locking

mechanism.

• Be used in a manner which ensures the user is able to achieve 100% tie-off 100% of the time.

• Incorporate a shock absorber when using a fall arrest system.

7.5 Protect personnel from objects dropped or dislodged by personnel working at height by using barricades, warning signs and tool lanyards.

PeopleCompetence Management7.6 Engage third parties who are suitably qualified to execute

specialist Working at Height activity.7.7 Educate people about their required role to support

effective management of Work at Height activity.7.8 Personnel who work at height must have no Fit to Work at

Height restriction.

ProcedureWork at Height Management Process.7.9 Prohibit the use of portable ladders unless provision of a

secure working area is not reasonably practicable.7.10 Prohibit the use of portable ladders for tasks at heights

exceeding 9 meters.7.11 Require personnel to use a fall arrest or fall restraint system

where provision of a secure working area is not reasonably practicable. The system must incorporate a full body harness attached to anchor points and or safety lines designed to withstand the maximum dynamic load from all persons attached to the anchor point and/or safety line.

7.12 Require personnel working in Mobile Elevated Work Platforms (includes cherry pickers, scissor lifts and vehicle-mounted booms) or suspended work baskets to wear a fall restraint system attached to an anchor point in the basket, which is designed to withstand the maximum dynamic load from all persons attached.

7.13 Inspect work at height equipment prior to use and clearly show compliance with periodic inspection with marks or tags.

7.14 Prohibit personnel from working alone when using a fall arrest system.

7.15 Develop a plan for immediate response to a person suspended in a harness within a time to prevent suspension trauma.



IntentManage lifting operations to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Lifting Operations

Performance RequirementsPlantPositioning, Illumination and Protection8.1 Use lift equipment appropriate to the activity.

• Install and correctly position lifting equipment to eliminate the risk of the equipment or a load striking a person.

• Illuminate lifting operations appropriately.

• Provide cranes with electrical/mechanical overload protection and, except for automated cranes, calibrated load cells with a display clearly visible to the operator.

• Provide load moment indicators on cranes, other than electric overhead travelling cranes, portal cranes or automated stacker cranes.

PeopleTraining and Competence8.2 Plan and execute lifts safely.

• The level of planning will be appropriate to the complexity of the lift.

• Plan and execute lifts using trained, certified, competent and authorized personnel.

ProcedureLifting Operations Management Process8.3 Operate, maintain, inspect, test and certify cranes and

lifting equipment using approved standards, systems and procedures.• Define and manage the operational area to prevent the

risk of injury from the equipment or the load.

• Mark all lifting equipment to show the safe working load.

• Undertake defined periodic examination and testing of cranes and lifting equipment using a competent person.

• Mark lifting equipment clearly to confirm compliance with the periodic examination requirements.

• Implement a process to clearly identify and quarantine damaged or out-of-certification lifting equipment.

• Implement a process to identify and manage the risk of sling roll-out from the hook.

• Develop clear criteria for what constitutes a complex lift and require such lifts to have a lift plan.

• Implement a process to verify the ground is suitable for safe operation of cranes and, where they are fitted, deploy outriggers.

• Provide operating manuals and load charts in a language understandable to the crane operator.

• Certify cranes and any associated equipment used for lifting personnel.

Controls 57

IntentManage potential dropped objects to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.

Performance RequirementsPlantSecure Potential Dropped Objects9.1 Identify and manage potential dropped objects

• Assess permanently installed equipment suspended more than 2 meters above ground to determine the requirement for primary and secondary securing mechanisms in order to prevent dropped objects.

• Implement an in-built secondary securing device (e.g., nuts with split pin or securing wire) on the primary securing mechanism; where an external secondary securing mechanism is deemed unnecessary or impractical.

9.2 Comply with relevant approved design standards, manufacturers specifications and local regulations for the following:• permanent structures

• temporary structures

• plant and equipment

• portable elevated work platforms

• movable elevated work platforms

• suspended work baskets

• scaffold structures

PeopleCompetence Management9.3 Engage third party specialists who are suitably qualified to

identify potential dropped objects to conduct scheduled Dropped Object assessment inspections.

9.4 Educate personnel about the risks of potential dropped objects and their role in supporting the process.

ProcedureDropped Objects Management Process9.5 Implement a dropped object management system. The

system must include the following provisions: • A register of all structural objects that have the potential

to drop.

• Control strategies for managing these objects.

• Assessment of the impact of weather on these potential dropped objects or work associated with these objects.

• Associated maintenance arrangements inclusive of inspections.

• A process which manages temporary tools and equipment being taken aloft, inclusive of a return to a safe location at the end of work activity.

• A process to ensure contractor-owned and contractor-operated equipment, third-party equipment, and equipment hired or contracted directly for BHP Billiton Petroleum activity complies with this Fatal Risk Control before usage.

Notes: See Appendix B for supplementary information regarding Dropped Objects.

Dropped Objects



IntentManage pressurized equipment to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Working with Pressure

Performance RequirementsPlantDesign10.1 Design, construct, test, inspect, place into service and

maintain pressure equipment, regardless of pressure rating, in accordance with appropriate internationally recognized industry standards.

10.2 Design and install storage and racking systems with positive latching retaining bars that prevent pressurized bottles/containers from tilting out of the rack.

10.3 Mark with a unique identifier and verified maximum working pressure, all new and refurbished/repaired pressure vessels as defined by API codes.

10.4 Label pressure containing equipment to identify contents and pressure. This must include all buried pipelines/ flow-lines and associated rights-of-ways.

10.5 Provide a means of safe isolation for all instrument connections on pressure containing systems.

10.6 Use pipe-work in the following order of preference:1. Fixed pipe-work (temporary or permanent)

2. Flexible type steel piping (temporary or permanent)

3. Temporary pipes connected with swivel joints10.7 Provide permanent piping systems with properly

engineered and installed piping clamps and restraints; design must factor in vibration and thermal effects on the piping and restraints.

PeopleUse and Manage Competent People10.8 Use persons who are trained in: Job Risk Assessment,

Isolations and Permit to Work; Emergency Response; Lock Out/Tag Out; Safe pressure testing practices. These personnel must wear appropriate PPE during pressure testing.

ProcedureWorking with Pressure Management10.9 Implement a maintenance program which includes the

following:• Verification of ratings and currency of pressure testing

equipment prior to usage.

• Inclusion of pressure containing equipment in the planned maintenance system.

• Verification of performance standards and certifications where pressure equipment classed as “Critical”.

• Clamp or restrain flexible hoses and temporary piping to prevent whipping in the event of a connection failure.

10.10 Implement procedure(s) to cover the following:• Visual inspection for transit and other damage; thread

and sealing surfaces integrity; flanges and bolts being fit for purpose.

• Use a documented “handover procedure” to transfer responsibility to the testing authority. This procedure must include verification of torque requirements/ methodology and system isolation points/methods.

• Incorporation of an exclusion zone for pressure testing; pressure testing with gases must be approved; pressure testing with volatile/flammable fluids is not permitted; pressure testing must be conducted in accordance with a written procedure and supporting Job Risk Assessment.

Controls 59

IntentManage exposure to hydrogen sulphide (H2S) to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.

Performance RequirementsPlantDesign11.1 Design, construct, and maintain equipment that is required

for H2S service using materials suitable for H2S service (e.g., NACE Standard MR 0175-96, Standard Material Requirements: Sulphide Stress Cracking Resistant - Metallic Materials for Oilfield Equipment).

11.2 Label systems and piping that contain H2S. 11.3 Secure potential exposure points from public access

through the use of fences, locked gates and warning signs.11.4 Identify and make available Emergency Response

equipment associated with H2S operations.

PeopleUse and Manage Competent People11.5 Train persons involved in BHP Billiton Petroleum activity

with potential for exposure to H2S; visitors must receive adequate training to support safe operations for the duration of their stay.

11.6 Require persons involved in H2S Emergency response are clean shaven to minimize exposure to H2S while effecting their duties; additionally they must be subject to a face-fit testing for breathing air apparatus; Site Medical professionals supporting operations must receive training in the physiological effects of H2S toxicity and its treatment.

ProcedureH2S Management11.7 Assess the likelihood of encountering H2S each time a new

hydrocarbon source is introduced; an existing source is being worked upon or reservoir analysis indicates the requirement for such a review.

11.8 Define and implement an appropriate H2S Management System inclusive of controls and mitigations. This includes the use of fixed, portable, personal detection systems; breathing air and associated equipment for normal work activity; emergency escape; emergency rescue; emergency drills; muster points; use of aids such as wind socks; associated maintenance systems.

11.9 Assess the potential impact of H2S exposure to the public and implement relevant controls as part of the Emergency Response Plan.

Presence of Hydrogen Sulphide (H2S)



IntentManage entry into and work within confined spaces to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.


Confined Space Entry (CSE)

Performance RequirementsPlantConfined Spaces 12.1 Identify confined spaces and maintain a confined space

register. Use the register to inform all work planned on such confined spaces; the register must include permanent equipment and any permanent or temporary third-party service contractor equipment used in support of BHP Billiton Petroleum activity.

12.2 Label all known confined spaces to prevent inadvertent or unauthorized access to those spaces by personnel.

12.3 Assess equipment and spaces that undergo a modification (permanent or temporary) to determine whether the modification has created a confined space.

12.4 Identify and make available Emergency Response equipment associated with Confined Space Entry operations.

PeopleRoles and Responsibilities12.5 Define and document the roles and responsibilities for all

personnel working in and supervising work in confined spaces.

12.6 Use people who are trained, deemed competent and assessed as fit to work in confined spaces.

12.7 Require personnel who work in confined spaces to be appropriately trained in Permit to Work and Job Risk Assessment processes.

ProcedureConfined Space Entry Management Process12.8 Conduct confined space entry only after other alternatives

have been evaluated and deemed unsuitable. 12.9 Identify and implement limits for exposure to dangerous

gases or other occupational exposures. 12.10 Conduct a documented risk assessment prior to actual entry

into a confined space. 12.11 Require a Permit to Work for Confined Space activity. 12.12 Isolate piping, equipment and spaces connected with or

adjacent to the confined space in accordance with Fatal Risk Control 5 – Isolation and Permit to Work.

12.13 Assess the atmosphere of any confined space prior to entry. Continue ongoing monitoring while work is being performed to ensure it remains safe. Minimum atmospheric monitoring includes: Oxygen content; Lower Explosive Limit; Toxicity of atmosphere.

12.14 Provide adequate ventilation to ensure a safe atmosphere at all times, from initial entry until the work is completed and the space is evacuated.

12.15 Do not introduce pure oxygen into an oxygen deficient space.

12.16 Do not use combustion engine driven or nitrogen driven mobile tools and equipment in confined spaces.

12.17 Locate gas cylinders used for the purposes of cutting or welding outside the confined space.

12.18 Isolate sources of gases when cutting or welding work is paused or stopped. Effective communication is required between those conducting the work and those controlling the gas shut-off outside the space.

Notes: See Appendix B for supplementary information regarding Confined Space Entry.

Controls 61

IntentManage diving activity to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.

Performance RequirementsPlantDiving Equipment and Support Vessels13.1 Use marine equipment and vessels to support diving

operations, including support vessels which comply with the specifications in the BHP Billiton Petroleum Marine Operations Controls.

13.2 Identify and make available Emergency Response equipment associated with Diving Operations.

13.3 Do not use “band-masks” or recreational SCUBA equipment; re-breather apparatus other than where used in rescue or emergency operations.

PeopleUse and Manage Competent People13.4 Use trained, certified, experienced and competent

personnel for diving operations including personnel inspecting and maintaining diving equipment.

13.5 Do not use uncertified or recreationally certified diving personnel.

ProcedureDiving Management Process13.6 Conduct diving operations only where the use of remotely

operated vessels (ROV) is not practicable.13.7 Implement BHP Billiton Petroleum Diving Operations

Procedure for all diving activities. 13.8 Conduct Diving Operations in accordance with a written

Dive Plan; plan must include specific emergency action plans aligned with the diving risk assessment.

13.9 Prohibit the following diving and subsea activities: • Diving operations of any type at working depth in excess

of 1,000 feet sea water (or 304 meters sea water).

• Diving in environments assessed by risk assessment as heavily contaminated.

Notes: See Appendix B for supplementary information regarding Diving.

Diving




Ground Disturbance and Ground Control

IntentManage work involving a man-made cut, cavity, trench or depression in the earth’s surface formed by earth removal to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities. This includes falls of ground at stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations.

Performance RequirementsPlantDesign and Use Appropriate Equipment14.1 Source and use equipment appropriate for Ground

Disturbance and Ground Control activity. 14.2 Source or define standards for the design and quality of

ground support materials.14.3 Identify and make available Emergency Response

equipment associated with Ground Disturbance or Ground Control rescue and recovery as deemed necessary.

PeopleUse and Manage Competent People14.4 Use personnel who are suitably experienced and have been

trained and certified to conduct Ground disturbance and Ground Control activity including personnel responsible for inspections and maintenance.

ProcedureGround Disturbance and Ground Control Management Process14.5 Develop and maintain an approved Ground Disturbance and

Ground Control procedure prepared by a competent person. The procedure must address the following requirements as applicable:• Mark excavations with a unique name or identification

number at sufficient intervals to accurately identify the location.

• Process for contacting relevant stakeholders prior to disturbing the ground.

• Process for identification and management of over-ground and under-ground hazards inclusive of buried pipelines, electrical cables, water lines.

• Methods for management of traffic.

• Methods to separate and protect personnel from unsecured ground inclusive of barriers, barricades, other access restrictions especially when powered equipment is in use or when Confined Space Entry permits are required.

• Methods to assess hazardous atmospheres based on risk.

• Methods for controlled disturbance of ground, inclusive of standards for the measuring, monitoring and analysis of ground condition data, classifying soil and aligning equipment selection, work methodology and emergency response protocols.

• Methods of securing disturbed ground inclusive of shoring, shielding, sloping and benching and assessment of excavation stability and the effectiveness of ground support (20 feet and deeper require engineered protective systems).

• Methods for management of stockpiles of disturbed ground.

• Methods for management of naturally occurring water in disturbed ground.

• A process for management of planned and unplanned changes to ground conditions inclusive of the impact of weather.

• Process for effective communications to affected personnel.

• Means for assuring the integrity of the installation of ground support materials, including frequency of examination and methods for repair.

• Identification and use of appropriate PPE.

• Emergency Response arrangements inclusive of rescue from cave-in.

14.6 Undertake an annual review of the Ground Disturbance and Ground Control procedure.

Notes: See Appendix B for supplementary information regarding Ground Disturbance and Ground Control.

Controls 63

Appendix B

Notes, Application and inter-relationship of Fatal Risk Controls

Control Application

1 Road Going and Light Vehicles This Control applies to BHP Billiton Petroleum owned, contracted (lease or hire) or operated road going and light vehicles used for work related activity. It also applies to all BHP Billiton Petroleum personnel using road going and light vehicles used for work related activities.

Road Going Vehicles includes all surface light vehicles, trucks and buses that are designed for public road use. Examples include pick-ups trucks, four wheel and all-wheel drive vehicles, rigid and articulated trucks (including associated trailers) and buses of all sizes.

Light Vehicles are a class of Road Going Vehicle which:• Have four or more wheels, seat a maximum of 12 adults (including the driver), • Are vehicles that, where registered, could be legally driven on a public roadway by a driver issued with

an approved driver’s license • Do not exceed 4.5 tonnes gross vehicle mass (GVM), which is the maximum loaded mass of the motor

vehicle as specified by: - the vehicle’s manufacturer; or - an approved and accredited automotive engineer, if the vehicle has been modified to the extent that

the manufacturer’s specification is no longer appropriate. • Light Vehicles may include the following categories of vehicles being used for work related activities:

- BHP Billiton owned or leased vehicles; - Hired rental vehicles - Contractor or supplier vehicles operating on company property; - Private vehicles used for work related activity.

The requirements of this Control do not apply in the following situations: • Vehicles being driven “on site” to the employee or visitor car park area, or for delivery drop off in

“non-hazardous” areas (e.g., warehouse deliveries).• Private vehicles being used on an occasional basis to undertake a low risk work related trip, such as

visits to Contractor offices etc, where approved by the Line Manager or equivalent. • Employees traveling between their fixed or temporary residence and their fixed or temporary work

place in either Company provided transport, public transport or personal transport.• Situations where the employee departs from a reasonably direct route of work related travel for

personal reasons, e.g., a side trip to visit a place of interest.

Support equipment includes:• Fire extinguisher• High-visibility vest• Signage appropriate for the location• First aid kit• Emergency roadside triangles or beacons• Survival or emergency equipment suitable for the operating environment• Signage appropriate for the location.• Two-way radio.• Method to move portable equipment while maintaining three points of contact.

Road Going & Light Vehicle Safety Equipment includes:• Air-bags for all occupants.• Anti-lock braking system (ABS).• 3-point inertia reel seat belt for all occupants.• Systems for control of cargo and segregation of cargo from occupants.• Roll-over protection based on 5 Star NCAP or equivalent rating and/or have installed an electronic stability control (ESC) system.

Off-road• Road which has no engineering design.• Natural tracks, river beds, gullies, naturally occurring land.

New Car Assessment Programmes (NCAP) New Car Assessment Programmes are active in the following countries or regions: Australia (ANCAP); Japan (JNCAP); S.E. Asia (ASEAN NCAP); Korea (KNCAP); Latin America (Latin NCAP); Europe (EuroNCAP); USA (NHTSA and IIHS). Until the NHTSA 5 star rating programme matures, and the available range of compliant vehicles increases, purchasers of USA-supplied vehicles can use IIHS ‘Good’ ratings as evidence of NCAP equivalency (for instance, ‘Good’ ratings in both frontal and side impact tests).

2 Mobile Equipment This Control applies to the use of all mobile equipment over and above those vehicles covered under Fatal Risk Control 1 – Road Going and Light Vehicles. Includes, but is not limited to, mobile elevating work platforms, self-propelled surface, tracked and rubber tyred equipment such as trucks, graders, tractors, excavators, drills, draglines and similar plant. It excludes relocatable plant such as crushers and stacking conveyors.

64 Health, Safety, Environment and Community Management System Framework

Appendix B

Control Application

2 Mobile Equipment (continued) Mobile Equipment safety features• Seat belt. • Fall-on and roll-over protection.• Adequate lighting for safe execution of tasks. • Reversing alarms, horn, effective windscreen wipers, guarding on moving parts.

Support equipment includes:• Fire extinguisher• High -visibility vest• Signage appropriate for the location• First aid kit• Emergency roadside triangles or beacons• Survival or emergency equipment suitable for the operating environment• Signage appropriate for the location.• Two-way radio.• Method to move portable equipment while maintaining three points of contact.

3 Explosives For WWD activity only - this Control must be used in conjunction with the World-Wide Drilling (WWD) Explosives Management Guidelines contained within the Drilling Safety Guidelines Document No WWD015.

DOT, OSHA, ATF or Local authorities requirements for shipping, handling and storing explosives must be complied with.

4 Hazardous Materials This Control applies to activities related to hazardous materials management. It includes management of hydrocarbon processing facilities and operations and includes hazards associated with the extraction, production, processing and transport of hydrocarbons and associated products. These controls must be used in conjunction with the process hazard analysis (PHA) as defined in the Hazard and Risk Management Controls. This Control does not cover handling of explosives (covered in Fatal Risk Control 3 – Explosives).

5 Isolation and Permit to Work This Control applies to the isolation of all sources of energy (electrical, mechanical, hydraulic, chemical, gravitational, pneumatic, kinetic, stored energy etc.). The requirements detailed in this Control must be used in conjunction with the BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure.

6 Equipment Safeguarding This Control applies to safeguarding of people from moving parts of plant, mobile machines, equipment and power tools, including moving equipment, high pressure equipment and applications, electrical, and other energy sources with the potential to move, and objects falling or projected from moving parts. This includes the integrity of such equipment.

7 Working At Height This Control applies wherever there is potential for any person to fall 2 meters or more, or to gain access to within 2 meters of an open edge from where there is the potential to fall 2 meters or more, including working from various forms of portable and moveable elevated work platforms, workbaskets, ladders, scaffolding, or where a risk assessment has identified high potential fall hazards when working at heights of less than 2 meters.

It also applies where a significant injury could result from a fall. (Note: if local applicable law requires more stringent controls, then those controls must be implemented.) This Control does not apply to rope rescue situations and abseiling that are regarded as specialist functions.

8 Lifting Operations This Control applies wherever lifting operations are undertaken. These controls must be used in conjunction with the BHP Billiton Petroleum Lifting Operations Procedure.

9 Dropped Objects This Control applies to all work conducted on BHP Billiton Petroleum sites and to facility equipment, third party equipment, and all equipment hired or contracted direct by BHP Billiton Petroleum. It includes:• Objects falling or dropped from plant/equipment or a rig/derrick.• Objects falling or dropped from crane booms, flare booms and other permanently or temporarily

installed structures and buildings.• Objects falling or dropped from elevated decks, platforms, scaffolding and any other workspace where

equipment is mounted or secured overhead.• Tools, equipment, and other objects falling or dropped while working from portable and moveable

elevated work platforms and while persons are working at heights using a work harness or working in cages.

Notes, Application and Inter-Relationship of Fatal Risk Controls continued

Controls 65

Appendix B

Control Application

9 Dropped Objects (continued) This Control should be used in conjunction with the requirements of Fatal Risk Control 7 – Working at Height and Fatal Risk Control 8 – Lifting Operations.

This Control excludes:• Loads falling from cranes during lifting procedures – these occurrences are covered under Lifting

Operations Controls.• Tubulars (drill strings, BHA’s, test strings, casing and tubing, etc.) suspended from or in the rotary table

that drop down the well – these occurrences are covered by Drilling procedures.

10 Working with Pressure This Control applies to all activities and operations where pressure-containing equipment is used. These controls must be used in conjunction with Fatal Risk Control 5 – Isolation, BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure.

11 Hydrogen Sulphide This Control applies to all BHP Billiton Petroleum activities where H2S may be encountered.

12 Confined Space Entry This Control applies to all BHP Billiton Petroleum activities involving confined space entry. These controls must be used in conjunction with Fatal Risk Control 5 – Isolation and the BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure.

The definition of a confined space must reflect local applicable law. The Australian Standard AS2865 defines confines space as, any space which:• Is at atmospheric pressure during occupancy;• Is not intended or designed primarily as a place of work;• May have restricted means for entry and exit; and may:

- Have an atmosphere which contains potentially harmful levels of contaminants; - Not have a safe oxygen level; or - Cause engulfment.

13 Diving This Control applies to all diving activities including:• Surface-supplied air diving.• Surface supplied mixed gas diving.• Saturation diving.• Remotely Operated Vessels (ROV) interventions during diving operations.

This Control does not apply to the use of non-diving related ROV’s or manned submersibles.

14. Ground Distrubance and Ground Control

This control applies to all BHP Billiton Petroleum activities involving ground disturbance. It requires the identification of situations which could create dangers to personnel due to movement of ground at stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations.

See OSHA 29 CFR 1926.650, .651, .652

OSHA defines an excavation as any man-made cut, cavity, trench, or depression in the earth’s surface as formed by earth removal.

A trench refers to a narrow excavation made below the surface of the ground in which the depth is greater than the width-and the width does not exceed 15 feet.

Trenching is common in utility work, where underground piping or cables are being installed or repaired.

If an excavation is more than 4 feet in depth or if there is a potential for engulfment, there must be a protective system in place while workers are present in the excavation.

Excavations more than 4 feet in depth must have a way to get in and out, usually a ladder, for every 25 feet of horizontal travel.

Shoring , whether the traditional timber shores or the modern hydraulic shores, brace against and hold up the walls of an excavation, preventing cave-ins. (never work outside of the shored area)

Shielding devices, commonly called trench boxes, shields, or coffins, are not designed to prevent a trench wall from collapsing, but rather serves as a “shield” to the workers within the structureshould a cave-in occur. With both shoring and shielding, the workers are only protected as long as they stay within the protective confines of the systems. (never work outside of the shored area)

Sloping refers to the cutting back of the trench walls at such an angle that there is little chance for collapse.

Spoil piles shall be no closer than 2 ft from the edge of the excavation to the nearest point of the spoils.

Notes, Application and Inter-Relationship of Fatal Risk Controls continued

66 Health, Safety, Environment and Community Management System Framework

Traffic Management Plan Requirements

Appendix C

Develop and implement a Traffic Management Plan which establishes site road engineering and vehicle operating standards for surface and underground Operations. The Traffic Management Plan must establish criteria for: • Minimizing the risk for all site road users with site road

network, traffic flow, intersection design and vehicle selection.

• Keeping the number of light vehicles on site as low as practicable.

• Minimizing interactions between pedestrians and vehicles, and heavy and light vehicles, with physical separation provided wherever practicable, including safe parking area design and parking protocols.

• Coloring, marking and equipping vehicles and mobile equipment for adequate visibility and easy identification at a safe distance by other vehicles, mobile equipment and pedestrians.

• Building roads with adequate delineation and protection from roadside and overhead hazards.

• Managing road maintenance, including hazards arising from dust and over-watering.

• Selecting road traffic signs and road markings consistent with the standards set by the national or state authorities in the country of operation. Where such standards do not exist, or are not suitable, the site must select an appropriate standard from the European Union, North America, Australia, South Africa or Chile.

• Mitigating risks to personnel from the hazards of remote-controlled mobile equipment.

• Providing adequate visibility along company roads and at intersections.

• Implementing traffic safety procedures that at least include:

- right of way rules at site intersections.

- site overtaking and vehicle interaction protocols.

- site speed limits and how they will be enforced.

- the minimum safe distance to be maintained between site vehicles and mobile equipment.

- control of access to, and egress from, restricted areas, including a process for ensuring the number of light vehicles in a restricted area is kept to the absolute minimum needed for effective Operations.

- communication equipment requirements and communication protocols.

- work-related use of company-provided vehicles off site, including the identification and management of high-risk road journeys.

• Providing training and competency requirements for:

- road safety awareness including defensive driving techniques.

- permits to operate/drive including site drivers’ licences based on specific site rules, vehicle type, operating standards and risks.

- employees and contractors performing design and engineering of road networks, traffic flow and traffic engineering.

Transitional Requirements for Existing Light Vehicles

Appendix D

• Driver side air-bag.

• 3-point inertia reel seat belts (2-point inertia reel seat belts where 3-point seat belts are not available).

• Systems for control of cargo and segregation of cargo from occupants.

• Vehicle design to mitigate risks to occupants from toppling or rollover.


Environment

Controls 69

IntentLand and marine disturbances must be managed to minimize environmental impact.

Control FrameworkWhere land activities or marine use may impact the environment: • Assess the baseline biodiversity, land use, contaminated sites and environmental liability for areas potentially impacted. Identify

and map the owned, leased or managed land, freshwater and marine areas, designated protected areas and areas of high conservation value.

• Assess actual and potential impacts to biodiversity, land use, contaminated sites and environmental liability.

• Quantify the acceptable level of impact taking into account regulatory requirements and stakeholder expectations.

• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to biodiversity and land use.

• Implement a monitoring and review program to evaluate the effectiveness of control measures.

Performance RequirementsMandatory Controls1.1 Obtain approval (i.e., internal and/or regulatory approval)

to disturb land, freshwater, and marine areas that addresses regulatory requirements. This may be covered by the site closure plan, Environmental Management Plan, or regulatory submittal.

1.2 Design vessels, vehicles, plant or equipment that may cause ground or seabed disturbance to ensure minimal disturbance while meeting operational requirements and allowing safe operation.

1.3 Do not explore, drill, develop or extract within the boundaries of World Heritage listed properties.

1.4 Identify any local International Union for Conservation of Nature (IUCN) Red List Threatened Species and do not operate where the direct impact will result in their extinction in the wild.

1.5 Onshore, rehabilitate disturbed land as soon as practicable and consistent with the pre-disturbance land use or alternate land uses developed in consultation and/or agreement with stakeholders, regulators and land owners.

1.6 Offshore, conduct hydrodynamic modelling to predict the extent of impacts to offshore habitat for any physical disturbance that may impact shoreline, near shore areas or areas protected for the purposes of conservation. Conduct baseline benthic monitoring to predict the extent of impacts to habitat.

Land and Marine ManagementLand and Marine Disturbances

Enviroment Control 1

Risk-Based ControlsBased on the level of impact identified in a risk assessment process, the following must be implemented:1.7 Implement compensatory actions where actual or potential

residual impacts, after preventative and mitigating controls have been implemented, exceed the quantified acceptable level of impact to biodiversity, land use, watersheds and/or water resources.

1.8 Do not conduct exploration, drilling and/or development in the following instances:• Adjacent to World Heritage listed properties unless the

proposed activity is compatible with the outstanding universal values.

• Within the boundaries of the IUCN Protected Areas Categories I-IV, unless a Biodiversity Action Plan is implemented that delivers measurable benefits to biodiversity commensurate with the level of expected biodiversity impact and meets regulatory requirements and authorizations.

1.9 Onshore, obtain authorizations before the implementation of any material land conservation project.


IntentNoise must be managed to minimize impact to fauna and communities.

Control FrameworkWhere noise may impact fauna or the community: • Assess actual and potential impacts to fauna and communities.

• Quantify the acceptable level of noise impact taking into account regulatory requirements and stakeholder expectations.

• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to fauna and the community.


Performance RequirementsMandatory Controls2.1 Offshore, build sound power intensity of seismic shots

gradually (”soft-start”) following Joint Nature Conservation Committee (JNCC) guidelines (4) to allow marine mammals time to leave the area. In areas where cetaceans are not expected and in the absence of passive acoustic monitoring (PAM) systems, judgement must be used to ensure the area is free from cetaceans prior to the soft start.

2.2 Offshore, continually watch for marine mammals during the pre-shooting search and soft-start, and while airguns are firing, in regions with known (regulated, designated or otherwise indicated) marine mammal migratory pathways. Seismic source vessels must carry at least one competent Marine Mammal Observer (MMO) in accordance with JNCC guidelines (5).

2.3 Offshore, for seismic operations, where stricter guidelines do not apply: • Delay the soft-start if marine mammals are seen within

500 meters of the center of the array during the pre-shooting search. However, if marine mammals are detected within 500 meters of the center of the airgun array while the airguns are firing, either during the soft-start or while at full power, there is no requirement to stop firing the airguns (5).

Land and Marine ManagementNoise Disturbances

Environment Control 2

• Conduct the pre-shooting search and soft start procedure after shut down of the seismic source, or if all airguns have stopped and not restarted for at least 10 minutes.

• Begin seismic activities at least 500 meters from the platform where marine mammals are congregating around a drilling or production platform, or other structures.

Risk-Based ControlsBased on the level of impact identified in a risk assessment process, the following must be implemented:2.4 Onshore, conduct a baseline noise survey to determine

representative “background noise” and perform noise modelling to ensure acceptable environmental noise targets are met off-site.

2.5 Onshore, incorporate efforts to manage noise using good industry practices.

2.6 Offshore, consider the use of PAM for all offshore source vessels involved in seismic acquisition; particularly for use in areas where marine mammals are likely to inhabit the proposed survey location.

Controls 71


Hydrocarbon ManagementHydrocarbon

IntentLiquid hydrocarbon storage, pipelines and flowlines, must be managed to minimize the risk of land and water contamination.

Control FrameworkWhere hydrocarbon storage and pipelines may impact the environment: • Assess actual and potential impacts to biodiversity, water, air or community.


• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to biodiversity, water, air or community.


Performance RequirementsMandatory Controls3.1 Identify, map and manage liquid hydrocarbon storage and

pipelines. 3.2 Conduct and maintain a risk assessment for all existing

below-ground or subaqueous liquid hydrocarbon storage tanks (including vessels) and associated pipelines to determine the likelihood of containment failure and implement any required control measures.

Risk-Based ControlsBased on the level of impact identified in a risk assessment process, the following must be implemented:3.3 Implement a risk-based integrity management program for

BHP Billiton Petroleum facilities and pipelines.3.4 Construct new storage facilities and pipelines to comply

with local regulatory requirements and accepted petroleum industry standards.


IntentWater sourcing, use and discharge, including disposal, must be managed to minimize impact to water resources, biodiversity and communities.

Control FrameworkWhere water sourcing, use or discharge may impact the environment:

• Assess the baseline quantity and quality of water potentially impacted.

• Assess potential impacts on water quality and quantity.

• Quantify the acceptable level of impact to water taking into account regulatory requirements and stakeholder expectations.

• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to water (including quantity and quality criteria limits for water supply sources and discharges).

• Implement a monitoring and review program to verify the effectiveness of control measures.

Performance RequirementsMandatory Controls4.1 Maintain records of water sources, water use and

wastewater generation.

4.2 Where high quality water use exceeds or is anticipated to exceed 3,000 megaliters per annum for an Operation or project, or where water management is anticipated to be a material risk issue, the Operation or project must:

• Maintain a quantitative water balance model.

• Maintain a 5-year forecast for high quality water use.

• Establish targets and implement and maintain projects to reduce impacts to water resources in the regions where the Operation or project is located. These targets and projects must be included in the Asset 5-year plan.

• Maintain a high quality water use reduction cost curve that identifies potential projects to reduce all high quality water usage.

• Identify and assess water requirements, supply options and supply risks for the life of the Operation.

• Implement, monitor and review controls designed to deliver water supply requirements for the life of the Operation.

4.3 Evaluate chemicals used for water treatment to minimize potential environmental impacts.

4.4 Design, drill, complete, produce and abandon wells (oil, gas, water abstraction and water disposal), to meet local regulatory requirements and accepted industry standards for the protection of groundwater and surface water.

4.5 Offshore, do not exceed a 24-hour average oil and grease concentration of 30 mg/l for discharges of produced formation water (PFW) (6).

Water ManagementWater Sourcing, Use and Discharge


Risk-Based ControlsBased on the level of impact identified in a risk assessment process, the following must be implemented:4.6 Conduct an accounting of water use.4.7 Evaluate water recycling and reuse.4.8 Onshore, ensure surface casing strings are cemented back

to surface to provide adequate isolation of all freshwater zones penetrated. If cement is unable to be circulated back to surface, run diagnostic logs to evaluate top of cement and perform remedial cementing operations if necessary, to provide adequate isolation.

4.9 Onshore, conduct groundwater monitoring to detect potential impacts from losses of containment at permanent facilities.

4.10 Onshore, preferably store waste water in tanks rather than pits/ponds.

4.11 Onshore, design and construct pits/ponds in a manner to prevent leaching and unauthorized access.

4.12 Onshore, install leak detection systems on permanent wastewater storage pits or ponds.

4.13 Offshore, use inline oil-in-water analysers with shut-downs/auto-bypasses or manual sampling and testing for all PFW overboard discharges.

4.14 Offshore, manage ballast water in compliance with MARPOL 73/78 Annex I(7), International Maritime Organization (IMO) Ballast Water Management Convention(8) and BHP Billiton Petroleum Marine Operations Controls (9).

Controls 73


Air ManagementAir Emissions

IntentAir emissions (excluding greenhouse gases) must be managed to minimize impact to the atmosphere and subsequent impacts on water, land, biodiversity and communities.

Control FrameworkWhere air emissions may impact sensitive receptors: • Assess the baseline air quality at sensitive receptors and maintain an inventory of air emissions.

• Assess potential air quality impacts on sensitive receptors.

• Quantify the acceptable level of impact to sensitive receptor’s air quality, taking into account regulatory requirements and stakeholder expectations.

• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to sensitive receptor’s air quality (including air emissions criteria limits).


Performance RequirementsMandatory Controls5.1 Use natural gas as the preferred fuel at production facilities

where it is available.5.2 Use low-sulphur diesel (containing sulphur equal to or less

than 500 ppm) as the fuel source where it is available. 5.3 Assess suitability of SO2 controls, where low sulphur

diesel is unavailable, for continuously operated major emissions sources.

5.4 Utilize high-efficiency flare equipment on new facilities. 5.5 Measure (preferably) or estimate (using accepted industry

estimation methodology), record and report internally air emissions.

5.6 Avoid cold venting of natural gas where practicable. 5.7 Offshore, comply with emission guidelines for PM, SO2 and

NOx as indicated by International Finance Corporation, World Bank Group guidelines for air emissions and ambient air quality (10) for engines and turbines (permanent and temporary) owned or operated by BHP Billiton Petroleum.

5.8 Offshore, comply with the requirements of MARPOL 73/78 Annex VI (11) for emissions from combustion sources on controlled marine vessels.

Risk-Based ControlsBased on the level of impact identified in a risk assessment process, the following must be implemented:

5.9 Evaluate the use of the following designs for new facilities or at opportunistic retrofit:

• Clean/lean burn technology for use on BHP Billiton-owned equipment for control of NOx, CO and volatile organic compounds.

• Smokeless flare or high efficiency flare equipment.

• Vapour-recovery equipment for all planned or steady state venting sources.

• Low or no-bleed pneumatic devices to regulate pressure and control valves to minimize releases to a flare system.

• Electronic igniters as a means of lighting flares in lieu of permanent pilots.

• Flare gas recovery systems.

• Flash gas and vent gas for fuel or sale.

• Compressed air instead of natural gas for powering instruments and controllers.

• Bypass or closed-loop systems to eliminate excessive flaring associated with commissioning and start-up activities.


IntentEnergy use and greenhouse gas (GHG) emissions must be managed to reduce GHG emissions where emissions exceed or are anticipated to exceed 50,000 tonnes CO2-e (equivalent) per annum for an Operation or project.

Control FrameworkWhere emissions exceed 50,000 tonnes CO2-e per annum for an Operation or project: • Identify, evaluate and implement energy and GHG reduction projects based on current and forecasted energy use and GHG emissions.

• Develop a management plan and implement a monitoring and review program to verify the effectiveness of energy reduction and GHG reduction projects.

Performance RequirementsMandatory Controls6.1 Maintain a GHG emission 5 year forecast.

6.2 Where emissions exceed or are anticipated to exceed 1,000,000 tonnes CO2-e per annum for an Operation or project:

• Maintain an energy mass balance;

• Maintain a GHG reduction cost-curve that identifies potential projects to reduce all GHG emissions;

• Establish targets and implement and maintain projects to reduce greenhouse gas emissions consistent with the reduction quantums committed to from the GHG reduction cost curve. These targets and projects must be included in the 5-year plan.

6.3 Measure (preferably) or estimate (using accepted industry estimation methodology), record and report internally GHG emissions.

Energy and Greenhouse Gas ManagementEnergy Use and Greenhouse Gas Emissions


6.4 Utilize waste heat recovery for new facilities or opportunistic retrofit if emissions are greater than 50,000 tonnes per year of CO2 equivalent (CO2-e).

6.5 Apply the BHP Billiton Carbon Pricing Protocol during project selection for applicable capital decisions (12).

6.6 Establish energy efficiency improvement goals and action plans to reduce emission levels. Goals should be on a normalized year-by-year basis and included in the management plan.

6.7 Assess energy efficiency during the selection of new or replacement equipment for fixed or permanent installations. Energy efficiency evaluations are case-specific for the selection of the required parameters to conduct a lifecycle analysis.

6.8 Avoid cold venting of natural gas where practicable.

Controls 75


Waste ManagementWaste

IntentWastes, excluding drilling muds and drilled cuttings, must be managed to minimize the environmental impacts resulting from the production, storage, handling, transport, recycling and disposal.

Control FrameworkWhere hazardous, non-hazardous and general wastes are generated: • Assess potential environmental impacts of wastes and determine if any wastes can be eliminated, reduced, recycled or reused in lieu

of disposal.


• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact (including the tracking of waste from source to disposal).


Performance RequirementsMandatory Controls7.1 Maintain records of waste type, source and quantities of

wastes, and the storage and disposal locations. 7.2 Manage, store, transport, and dispose or treat hazardous

materials and hazardous wastes in accordance with regulatory requirements or industry best practice. Where hazardous wastes are generated and there are no regulatory requirements, utilize the United Nations Environment Programme “Basel Convention on the Control of Transboundary Movements on Hazardous Wastes and Their Disposal” (13) as a guide.

7.3 Conduct audits or assessments at least every two years on waste management contractors to ensure their operating practices are appropriate and in compliance with regulations.

7.4 Evaluate chemicals, materials and products for environmental impacts to achieve waste minimization.

7.5 Onshore, dispose of hydrostatic test water according to regulations. Where regulations are not available, utilize best practices such as requirements of the International Finance Corporation (World Bank Group) (14).

7.6 Offshore, manage sewage and grey water in compliance with MARPOL 73/78 Annex IV (15), and MARPOL 73/78 Annex V (16), respectively, or other applicable permits prior to discharge. Utilize a marine sanitation unit where installed.


7.7 Conduct risk-based HSEC evaluation on waste management contractors prior to final contractual arrangements.


IntentThe use, storage and discharge of drilling muds and cuttings must be managed to minimize adverse environmental impacts.

Control FrameworkWhere drilling muds and drilled cuttings are generated: • Assess drilling muds and drill cuttings for recycling or reuse.

• Quantify the acceptable level of impact from discharges taking into account regulatory requirements and stakeholder expectations.

• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact.


Performance RequirementsMandatory Controls8.1 Assess the environmental impacts when selecting drilling

muds and completion fluids, including chemicals and additives.

8.2 Onshore, construct pits used for drilling and completion operations to prevent unauthorized access and to prevent leaching, leakage or unauthorized discharge of pit contents into the surrounding environment. Construct pits to ensure that overflow associated with rainfall will not occur.

8.3 Onshore, avoid use of oil or saltwater-based muds when drilling through groundwater and freshwater strata.

8.4 Offshore, do not discharge oil based mud (OBM) or OBM-contaminated cuttings into the environment (10).

8.5 Offshore, where a synthetic based mud (SBM) or OBM system is used, utilize separation equipment that is capable of ensuring the volume of SBM or OBM retained on drilled cuttings is no more than 10 percent by dry weight.

8.6 Offshore, conduct ecotoxicity testing (acute, sub-lethal and/or chronic) on fluids to be discharged. This may be a prior test conducted on a generic mud composition for the well, or it may be a test on the actual mud in use or discharged during the drilling operation.

Waste ManagementDrilling Muds and Drilled Cuttings



8.7 Evaluate use of low toxicity water based muds (WBM) for all drilling activities except for hole sections where SBM or OBM is justified for technical reasons.

8.8 Onshore, consider closed-loop drilling systems.

Controls 77

1. BHP Billiton. BHP Billiton Petroleum HSEC Management System Framework.

2. BHP Billiton. BHP Billiton Petroleum Health, Safety, Environment and Community (HSEC) Policy

3. BHP Billiton. Management Plan Preparation Document.

4. BHP Billiton. BHP Billiton Petroleum Investment Process Manual. (PM-PR-IM-01)

5. Joint Nature Conservation Committee (JNCC). 2010. ANNEX A- JNCC guidelines for minimising the risk of disturbance and injury to marine mammals from seismic surveys. August 2010 http://jncc.defra.gov.uk/pdf/JNCC_Guidelines_Seismic%20Guidelines_Aug%202010.pdf

6. Oslo and Paris Commission (OSPAR). 2006. OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic. OSPAR Recommendation 2001/1 adopted by OSPAR 2001 (OSPAR 01/18/1, Annex 5), Amended by OSPAR Recommendation 2006/4 (OSPAR 06/23/1, Annex). OSPAR Recommendation 2001/1 for the Management of Produced Water from Offshore Installations. http://www.ospar.org/v_measures/browse.asp?menu=00520417000000_000000_000000

7. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex I: Regulations for the Prevention of Pollution by Oil. London: IMO, consolidation edition, 2006.

8. International Maritime Organization Ballast Water Management Convention. 2009

9. BHP Billiton. BHP Billiton Petroleum Marine Operational Controls.

10. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Offshore Oil and Gas Development. World Bank Group, April 30, 2007. http://www1.ifc.org/wps/wcm/connect/bfc6f4004886590bb80afa6a6515bb18/offshoreoil.pdf?MOD=AJPERES&CACHEID=bfc6f4004886590bb80afa6a6515bb18

11. International Maritime Organization (IMO). 2009. International Convention for the Prevention of Pollution from Ships (MARPOL). Revised MARPOL Annex VI and NOx Technical Code 2008: Regulations for the Prevention of Air Pollution from Ships. London: IMO, 2009 Edition.

12. BHP Billiton. Carbon Price Protocol. Updated quarterly. Information pertaining to the protocol can be obtained from relevant BHP Billiton Petroleum Planning or Economics analysts.

13. United Nations Environment Programme. 1992. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. http://www.basel.int/Portals/4/Basel%20Convention/docs/text/con-e-rev.pdf.

14. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Onshore Oil and Gas Development. World Bank Group, April 30, 2007. http://www1.ifc.org/wps/wcm/connect/4504dd0048855253ab44fb6a6515bb18/Final%2B-%2BOnshore%2BOil%2Band%2BGas%2BDevelopment.pdf?MOD=AJPERES&id=1323153172270

15. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex IV: Regulations for the Prevention of Pollution by Sewage from Ships. London: IMO, consolidation edition, 2006.

16. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex V: Regulations for the Prevention of Pollution by Garbage from Ships. London: IMO, consolidation edition, 2006

Environment Controls

References


Data Reporting

Controls 81

Data Reporting Control 1

General Requirements

IntentBHP Billiton Petroleum Exploration, Development and Production groups must define applicable reporting obligations and submit data to Group HSEC to allow monitoring of HSEC performance in accordance with Table 1 (Scope) and Table 2 (Authorities).

Performance RequirementsImplement the following for Exploration, Development and Production controlled activity in accordance with the BHP Billiton Petroleum HSEC Data Reporting procedure:1.1 Determine data reporting entities (e.g., Douglas, CR Luigs,

Macedon, GGO Project X).1.2 Define and document reporting boundaries including

classification of activities as controlled or monitored.1.3 Determine HSEC data reporting obligations in the areas of

Safety, Occupational Health & Hygiene, Environment and Community.

1.4 Collect, review, verify, authorize and submit applicable HSEC data listed in Control 2 (Reporting Requirements).

1.5 Submit HSEC data to Group HSEC by 7th calendar day of the month; submit data adjustments by the 15th working day.

1.6 Comply with the following for each applicable data stream:• Document measurement methods for each data point

including calculations or estimations.

• Define how reconciliation or adjustment of data is managed.

• Identify data sources (e.g., invoice, meter).

• Define relevant calibration and maintenance processes and records (e.g., 1SAP records).

• Define how review, authorization and verification of data will occur.

• Define process for changing, correcting and authorizing changes to previously reported or recorded data.

• Define process for documenting data variations from one reporting period to another (+/- ≥20%).

• Maintain a documented audit trail to support submitted data.

• Follow data collection framework defined in Table 3..

Table 1 – Scope

EntityReporting Requirements

H&S Hyg Env Comm Fines

CSG1 (BHP Billiton Petroleum Level including Marketing) Y N Y Y Y

Asset (Production Units, Joint Interest Units) Y N Y Y Y

Operation (Minerva, LBA, BlackHawk, Atlantis) Y Y Y Y Y

Closed Operation (Development/Production) Y N Y4 Y Y

Project in Study Phase2 (Development) Y N Y Y Y

Project in Execution Phase (Devlopment/Production)2 Y N Y Y Y

Exploration Y N Y Y Y

Other Function or Group Function3

Includes WWD, Supply, IM, HSEC at CSG or Asset level as relevant

Y N Y Y Y

Notes

H&S - Health & Safety dataHyg - Hygiene dataEnv - Environmental dataComm - Community dataFines - Regulatory data

1 Activities undertaken by a Customer Sector Group that are not covered by an Operation.

2 Major capital project in any phase of the group investment process.

3 Data for Group Functions (GFs) must be reported through Facilities and Services, not individual GF.

4 Through Asset or direct.

Table 2 – Authorities

Endorse Approve Inform

Data parameters to meet internal and external reporting obligations

Head of HSEC (Asset) ü

Senior Manager (Operation) ü

HSEC data reported to Group HSEC

Senior Manager (Operation) or Project Director (if Project) or President CSG ü



Reporting Requirements

IntentBHP Billiton Petroleum groups collect, track and manage applicable HSEC data as defined in the HSEC Data Reporting procedure to meet internal and external reporting obligations. Data must be reported as per Table 3 (HSEC Data collection framework) using HSEC data interpretations found in the BHP Billiton Petroleum HSEC Glossary.

Performance Requirements2.1 Health (hygiene)

• Audiometric assessments

• Exposures to defined agents >OEL

• Exposures to noise greater than 85dB(A)2.2 Health (illnesses)

• New cases of cancers, tumors or neoplasms

• Poisoning and toxic effects

• Noise induced hearing loss

• Dermatitis or eczema

• Infectious and parasitic diseases

• Musculoskeletal occupational illness

• Silicosis

• Chronic Obstructive Pulmonary Disease, Asthma, Pneumoconiosis, other respiratory system and other diseases and disorders

2.3 Safety• Fatalities

• Lost time cases

• Restricted work cases

• Medical treatment cases

• Restricted work days per injury/illness

• Lost days per injury/illness

• Exposure hours

• Number and value of safety related fines2.4 Environment

• Number and value of environment related fines.

• Emissions – Greenhouse Gas (GHG), Ozone depleting substances, fluoride, Nitrogen Dioxide (NOx), Sulphur Oxide (SOx), and mercury.

• Energy use

• Water input and output

• Waste

• Land use

• Unplanned and planned liquid releases

• Biodiversity data2.5 Community

• Community perception survey(s)

• Cultural Awareness training

• Human Rights training

• Number of security personnel

• Community complaints – dust, noise, odor and other related

• Value of in-kind and direct contributions

• Value of community programs.

• Information applicable to indigenous peoples

• Significant disputes associated with land use and customary rights

• Information applicable to artisanal mining on or near owned land inclusive of risks and plans

• Information applicable to resettlement activities

• Details of stakeholder consultation

• Sustainability Report metrics by 7th calendar day of July2.6 Other BHP Billiton Petroleum HSEC Data Requirements

• Comply with other BHP Billiton Petroleum data reporting requirements as defined in the BHP Billiton Petroleum HSEC Controls (e.g., Process Safety, MOC).

Controls 83

Table 3 - HSEC Data Collection Framework

Discipline Framework HSEC Data Examples

Safety and Health Title 29 Code of Federal Regulations Part 1904 Occupational Safety and Health Administration (OSHA)

Injury and illness

Environment Global Reporting Initiative Reporting Framework (GRI) and GRI Mining and Metals Sector Supplement.

• Air pollutants (NOx, SOx) • Ozone depleting substances • Waste • Land

• Energy content, greenhouse emission factors and calculation methods (in order of preference):

1. Local regulatory frameworks, if applicable

2. 2006 IPCC Guidelines for National Greenhouse Gas Inventories

• Emission factors for calculating greenhouse gas emissions (electricity):

- Minerals Council of Australia Water Accounting Framework: See BHP Billiton Petroleum HSEC Glossary for data interpretations

• Energy • Greenhouse gas emissions

Minerals Council of Australia Water Accounting Framework. See BHP Billiton Petroleum HSEC Glossary for data interpretations

Water inputs, outputs and quality

Community Global Reporting Initiative Reporting Framework (GRI) and GRI Mining and Metals Sector Supplement

• Community complaints • Stakeholder consultation • Human rights issues and breaches



Significant Events

IntentBHP Billiton Petroleum Exploration, Development and Production groups actual and potential significant events must be reported, investigated and action taken to prevent recurrence in accordance with the BHP Billiton Petroleum Event Management procedure

Performance Requirements3.1 Implement the following for all BHP Billiton Petroleum

actual significant events associated with controlled activity:• Notify authorities in accordance with Table 4.

• Seek legal advice and apply legal professional privilege.

• Record the event within 48 hours of occurrence.

• Complete an event investigation appropriate to the severity within 28 calendar days of occurrence.

• Distribute a copy of the completed investigation report in accordance with Table 4.

3.2 Implement the following for all BHP Billiton Petroleum potential significant events associated with controlled activity:• Record the event within 48 hours of occurrence.

• Complete an event Investigation appropriate to the severity within 28 calendar days of occurrence.

3.3 Implement the following for all BHP Billiton Petroleum actual significant events and aviation-related potential significant events associated with monitored activities: • Notify authorities in accordance with Table 4

within 24 hours of the event being reported to BHP Billiton Petroleum.

Table 4 – Significant Event Notifications

Occurrence of an actual significant event (controlled activities)

Individual informing Individual informed

President CSG or Head of Group Function or Division President

• Head of Group HSEC • Vice President Media Relations • Head of Group Investor Relations • Vice President Corporate

Communications

Completed Investigation Report for actual significant events (controlled activities)



Head of Group HSEC

Occurrence of actual significant events and aviation-related potential significant events (monitored activities)



• Group Management Committee (GMC) Owner

• Head of Group HSEC

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