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EMAS

EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

Title

Procedure No.

Rev.

Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

Health, Safety, Environmental and Quality Management System Manual


MAN-EOCP-CORP-HSEQ-501

Revision List

0 A2 A1
Revision

15 Mar 2007 13 Feb 2007 28 Dec 2006


Date

Issue for Implementation Issue After Comments Issue For Review


Reason for Issue

ZG ZG ZG
Prepared by

FI FI FI
Checked by

KKL KKL KKL


Approved by HSEQ Approved by

- Printed copies are uncontrolled. For current controlled copies, please contact EOCP HSEQ Dept.-

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EMAS
EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

Title

Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

Table of Contents
1. 1.1 1.2 1.3 1.4 2. 3. 3.1 3.2 3.3 3.4 3.5 3.6 4. 4.1 4.2 4.3 4.4 5. 5.1 5.2 5.3 6. 6.1 6.2 6.3 7. 7.1 7.2 7.3 7.4 7.5 7.6 7.7 7.8 8 8.1 8.2 9 9.1 9.2 INTRODUCTION ............................................................................................................................ 5 Overview........................................................................................................................................................................... 5 Purpose ............................................................................................................................................................................ 5 Scope ............................................................................................................................................................................... 6 References ....................................................................................................................................................................... 6 LEADERSHIP AND COMMITMENT .............................................................................................. 7 POLICY AND STRATEGIC OBJECTIVES .................................................................................... 7 HSEQ Policy ..................................................................................................................................................................... 7 Business Objective ........................................................................................................................................................... 9 HSEQ Strategic Objective ................................................................................................................................................ 9 Key Performance Indicators (KPI) .................................................................................................................................... 9 Legal Requirements ......................................................................................................................................................... 9 Clients HSEQ Requirements ........................................................................................................................................... 9 ORGANIZATION, RESPONSIBILITIES AND RESOURCES ...................................................... 10 Organisation and Responsibilities .................................................................................................................................. 10 Resources, Training and Competence ........................................................................................................................... 10 Communication............................................................................................................................................................... 11 Customer Communication .............................................................................................................................................. 11 HAZARDS AND EFFECTS MANAGEMENT ............................................................................... 12 Hazards and Effects Identification .................................................................................................................................. 12 Risk Assessment ............................................................................................................................................................ 12 Control and Recover....................................................................................................................................................... 13 PLANNING AND PROCEDURES ................................................................................................ 15 HSEQ and Emergency Planning .................................................................................................................................... 15 Document Control........................................................................................................................................................... 16 Operation Control Procedures ........................................................................................................................................ 21 IMPLEMENTATION AND MONITORING .................................................................................... 26 Responsibility and Ownership ........................................................................................................................................ 26 Performance Indicators and Measurement .................................................................................................................... 27 Monitoring Program ........................................................................................................................................................ 27 Data Accuracy and Calibration ....................................................................................................................................... 27 Records .......................................................................................................................................................................... 27 Incident Investigation and Reporting .............................................................................................................................. 28 Corrective and Preventive Action ................................................................................................................................... 28 Non-Conformance .......................................................................................................................................................... 29 AUDIT ........................................................................................................................................... 30 Audit Plan, Process and Hierarchy ................................................................................................................................ 30 Audit Team and Frequency ............................................................................................................................................ 32 REVIEW ........................................................................................................................................ 33 Scope of Review............................................................................................................................................................. 33 Responsibility for Review ............................................................................................................................................... 33

ATTACHMENTS ................................................................................................................................... 34

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

Definitions and Abbreviations


Accident ALARP ASV CAR CMT Corrective Action Undesired event giving rise to death, ill health, injury, damage or other loss. As Low As Reasonably Practicable Accommodation Service Vessel Corrective and Preventive Action Request Crisis Management Team Any activity undertaken to address an incident or non compliance and if possible, prevent its recurrence. A pre-established plan to mitigate an unusual situation which has the potential for harm, which incorporates the best use of local as well as remote facilities and resources. Year-on-year enhancement of overall health, safety and environmental performance, not necessarily in all areas of activity, resulting from continuous efforts to improve. A direct or indirect adverse impingement of the activities, products or services of the company upon the environment. Non-fulfillment of a requirement or specification related to an intended or specified use. The severity of the consequences of an event attributed to any hazards, normally expressed in terms of consequences to people, environment, asset and reputation. Emergency Coordinator Emas Offshore Construction and Production Pte. Ltd. Emergency Response Plan Emergency Response Team Floating, Production, Storage and Offloading The potential to cause harm, including ill health or injury, damage to property, plant, products or the environment; production losses or increased liabilities. Hazard Identification Hazards and Operability Study Hazard and Effects Management Process Health, Safety, Environment and Quality

Contingency Plan

Continuous Improvement

Damage to Environment Defect

Effect

EC EOCP ERP ERT FPSO Hazard

HAZID HAZOP HEMP HSEQ

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EMAS
EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

HSEQ Audit

Independent, systematic and documented process of objectively obtaining and evaluating verifiable evidence to determine that HSEQ-MS is effectively implemented. Physical on-Project verification that work is performed and equipment is maintained in accordance with existing HSEQ standards and procedures. Periodic review of HSEQ performance and effectiveness of HSEQ-MS by means of documented performance data. HSEQ review is conducted at multiple organization levels in varying level of detail. International Labour Organization Event that gave rise to an accident or had the potential to lead to an accident. International Safety Management Job Safety Analysis Key Performance Indicator A documented system of physical barriers and notices that prevents the accidental or inadvertent operation of equipment whilst it is being maintained or inspected. Loss Time Incident An incident or potential incident which resulted in no actual harm to people, the environment, facilities or business. Non-government Organization Failure to meet the HSEQ-MS requirements. Non-conformance may be identified by monitoring activities, adverse trends in performance indicators, non-completion of HSEQ plans, non-compliance to legal and other requirements, failure to meet targets, incident investigations and audits. Occupational Health and Safety Assessment Series Permanent Disability Personal Protective Equipment Project Quality Plan Permit-to-Work Simultaneous Operations Safety Management Manual Emas Offshore Vessels Tool Box Meeting

HSEQ Inspection

HSEQ Management Review ILO Incident ISM JSA KPI Lock-out Tag-out

LTI Near Miss

NGO Non-conformance

OHSAS PD PPE PQP PTW SIMOPS SMM TBM

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EMAS
EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

Title

Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

1.
1.1

INTRODUCTION
Overview

The management of EOCP profess to unequivocal commitment in providing a safe work place, respect for the environment and the highest standards of operational professionalism. The EOCP HSEQ manual describes the process for managing EOCPs Health, Safety, Environment and Quality Management System (HSEQ-MS) at the corporate level and within any project or operational units. The HSEQ-MS is an integrated management tool that describes the EOCP organization, responsibilities, processes, practices, procedures and resources for implementing the companys HSEQ policies. The model used to represent EOCP HSEQ-MS is based on the ISO 9001/ OSHAS 18001 principles as shown in Figure 1.1 below. Figure 1.1: EOCP HSEQ-MS Model

1.2

Purpose

EOCP HSEQ-MS defines the Companys HSEQ Policy, Guiding Principles, Strategic Objectives, organization and the arrangements which are necessary to manage the identified health, safety, environmental and quality risks associated with EOCP businesses. The purpose of this HSEQ-MS is to ensure that: HSEQ risks have been systematically identified; Measures are in place to control these risks, mitigate consequences should the needs arise and at the same time providing continual improvement in HSEQ MS;

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

Title

Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

It provides a set of HSEQ expectations and requirements for all levels within the organisation with a view to ensuring consistent reporting and control over operational risks; Companys Policies, Procedures and Best Practices are communicated; and Training, auditing and improvement processes are in place to achieve these objectives.

The HSEQ-MS Manual is a corporate level document intended for use by managers to assure them that all foreseeable risks will be effectively managed throughout the organization. Managers are responsible for the provision of necessary business controls to ensure currency of the HSEQ-MS and its effectiveness in the management of those risks. The HSEQ-MS manual will be reviewed annually and updated accordingly. A review of this Manual will also be triggered by any major incidents or due to any significant deficiencies found in the HSEQ-MS arising from audits or reviews of other parts of the system or Company (e.g. review of HSE Cases or ISO/ISM/Client audits). This manual is a live document and the EOCP Corporate HSEQ Department shall be its custodian.

1.3

Scope

The scope of this document covers the activities of EOCP Leadership Team, the Corporate Office and Project/Operational Site staff providing advice and guidance to all business operations on the management of their activities under their operational control. EOCP is primarily servicing the offshore oil and gas industry (pipe-laying/heavy lift/accommodation barges, FPSOs, shipbuilding) and its business operations, encompasses the following: Engineering and Procurement services; Construction; Project Management; Hook-up and Commissioning; Offshore support services including Installation; and Operations and Maintenance. In line with EOCP HSEQ policy, implementing and complying with the HSEQ-MS is the direct responsibility of everyone in the Company within their own individual sphere of operations including contractors engaged by EOCP.

1.4

References

The main reference documents used in the development of this HSEQ-MS are as listed below: E and P Forum, Guidelines for the Development and Application of Health, Safety and Environmental Management Systems, Report No. 6.36/210; American Petroleum Institute, Model Environmental, Health and Safety (EHS) Management System, API Publication 9100A; International Labour Organization, Guidelines on Occupational Safety and Health Management Systems, ILO-OSH 2001; Quality Management System, ISO 9001:2000. Environmental Management System, ISO 14001:2004; and Safety Management Manual, Emas Offshore and Marine Services International Safety Management (ISM) Code, 1993; The consistency between EOCP HSEQ-MS with ISO and ISM Standards is demonstrated in Attachment A.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

2.

LEADERSHIP AND COMMITMENT

EOCP Senior Management provides strong and visible leadership to promote a culture in which all employees share a commitment to HSEQ. They do this through setting a personal example, demonstrating commitment to implementing the HSEQ-MS, communicating HSEQ expectations with employees, discussing and reviewing progress against specific HSEQ goals including set Key Performance Indicators (KPI) targets and demonstrating personal participation in HSEQ activities. The Senior Management is proactive in target setting. They do this through developing and discussing improvement targets, ensuring staff have HSEQ goals in their appraisals, participating in the review of HSEQ indicators, providing immediate and visible involvement in incidents and in setting Targets. EOCP seeks to create and sustain a Company culture in which all employees share a commitment to HSEQ. Both EOCP employees and contractors are involved in creating and maintaining this supportive culture. The Senior Managements demonstrate an informed involvement in HSEQ issues. They do this through reviewing the progress in the development and content of the HSEQ Management System, making resources available to meet set goals and undertaking relevant training. In addition, they are fully aware of the high priority areas for improving EOCP HSEQ Management System and are personally involved in improvements arising from formal management reviews of the HSEQ Management System.

3.
3.1

POLICY AND STRATEGIC OBJECTIVES


HSEQ Policy

It is important that EOCP HSEQ Policy is initiated, developed, actively supported and endorsed by management at the highest level and made available in readily understood form to interested parties. Senior Management of EOCP defines and documents its HSEQ Policy and Strategic Objectives and ensures that they: Are consistent with those of the Companys external stakeholders; Are relevant to the Companys activities, products and services; Are consistent with and are of equal importance to EOCP other business policies and Strategic Objectives; Are publicly available; Commit the Company to meet or exceed all relevant regulatory and legislative requirements; Commit the Company to reduce the risks and hazards to health, safety and the environment to levels, which are As Low As Reasonably Practicable (ALARP); and Provide a framework to continuous efforts to improve HSEQ performance.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Procedure No.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Health, Safety, Environmental and Quality Management System Manual

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3.2

Business Objective

EOCP establishes Annual Business Objectives which includes Quality, Health, Safety and Environment Objectives for all its business units. EOCP is committed to meeting these expectations in all its business activities. These are further enhanced by HSEQ Strategic Objective.

3.3

HSEQ Strategic Objective

EOCP HSEQ Strategic Objectives are captured in the annual Corporate HSEQ Plan and reappraised in Project HSEQ Plans with actual performance and changing expectations of the variety of stakeholders. The HSE and QA Department is responsible to advise Managing Director and the EOCP Management Team on the appropriate strategic objectives required to improve HSEQ based on prevailing HSEQ performance data, HSEQ-MS reviews, audit findings and safety studies.

3.4

Key Performance Indicators (KPI)

Various measurements are used in EOCP projects to monitor, understand, predict and improve performance outcomes to meet our Business Objectives. Performance is demonstrated by achieving the KPI. Please refer to Section 7.2.1 Performance Indicators and Measurements.

3.5

Legal Requirements

In conducting its business as a good and responsible corporate citizen, EOCP complies with the principles embedded in the local legislations and international conventions. EOCP HSEQ-MS describes the processes for identifying the legal HSEQ requirements that are applicable to EOCP activities, products and services and for incorporating these legal requirements into EOCP HSEQ policies, strategic objectives and the HSEQ-MS generally. EOCP maintains procedures to determine and record legislative requirements and codes applicable to its operations, products and services to ensure compliance with such requirements. Legal and Other Requirements Identification Procedure (BP-EOCP-CORP-HSE-506)

3.6

Clients HSEQ Requirements

Client representatives assigned to EOCP are consulted in order to ensure that their HSEQ expectations and EOCP HSEQ-MS requirements are complimentary, consistent and workable throughout the operation/project phases. EOCP initiates, on a proactive basis, a bridging session in order to address any interface between EOCP and Clients HSEQ requirement. The agreed interface solutions are in place before any fieldwork is initiated.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Procedure No.

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

4.
4.1

ORGANIZATION, RESPONSIBILITIES AND RESOURCES


Organisation and Responsibilities

The EOCP business unit interface with support services is described below in Figure 4.1: Figure 4.1: EOCP Unit Business Interface

C U S T O M E R

EOCP PROJECT MANAGEMENT

BUSINESS EXECUTION
Business Development & Acquisition Engineering & Procurement Construction & Construction Management Installation Hook up Commissioning Operations & Maintenance

C U S T O M E R

SUPPORT SERVICES QUALITY HEALTH, SAFETY & ENVIRONMENT HUMAN RESOURCE PROJECT CONTROL ACCOUNTING DOCUMENT CONTROL

COMMUNICATIONS

INFORMATION TECHNOLOGY

The EOCP business unit is supported by common support services. These services include Accounting, Project Controls, HSE, Quality, Information Technology , Communications, and Human Resource provides support to both the Sales and Business Execution Processes. The EOCP Organization Chart is illustrated in Attachment B. Specific HSEQ roles and responsibilities of the EOCP Senior Management and other company personnel including contractors are detailed in Attachment C.

4.2

Resources, Training and Competence

Effective operation of EOCP HSEQ-MS requires sufficient allocation of human, physical and financial resources. Resource requirements are considered during the HSEQ planning and review processes. Resource allocations are considered when managing change and during assessment of controls as part of the Hazards and Effects Management Process (HEMP). Effective allocation of physical resources including facilities requires consideration of the HSEQ risks that arise in all EOCP activities, including the supply chain. Human resources include both EOCP staff and contractors. Effective HSEQ management relies on the competence of these people.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

EOCP maintains a procedure to ensure competence by identifying training needs and providing appropriate training for all staff and contractors. Training is provided through formal courses or through structured programs in the workplace (on the job training). The extent and nature of training ensures achievement of EOCP HSEQ policies and objectives. The training programs also meet or exceed standards set by legislations and clients. Appropriate records of training are maintained with subsequent refresher training scheduled on periodic basis. All EOCP contractors also are subjected to this requirement. Competency assessment process applies to initial recruitment and also to selection of personnel for new tasks. The competency of staff and contractors to perform their duties is regularly reviewed and evaluated, including appropriate consideration of training required to achieve desired competency level for changing tasks, processes and equipment. Any lapses of competency identified are addressed with appropriate formal or workplace training conducted by their respective supervision. HSE Training and Competence Evaluation Procedure (WP-EOCP-CORP-HSE-507)

4.3

Communication

HSEQ issues are communicated to employees, contractors, partners and other interested parties to make them aware of: Roles and responsibilities in achieving compliance with defined HSEQ policies and objectives; Hazards and risks related to their work activities focusing on identification, evaluation, control and recovery measures; Assessed and approved deviations from agreed and documented operating procedures; and Incidents and lessons learnt to avoid repetition in other locations or areas of the business. EOCP provides the following channels for effective communication : EOCP Website including HSEQ-MS Portal EOCP Induction for New Hires/Visitors HSEQ Steering Committee Department/Project/Contractor Safety Meetings Daily Tool Box Meetings Safety Alerts, Safety Posters and HSEQ Statistics Displays

Internal and External Communication Procedure (WP-EOCP-CORP-HSE-508)

4.4

Customer Communication

EOCP determines and implements effective arrangements for communicating with customers in relation to: Product information which includes whole range of services offered by EOCP; Enquiries, contracts or order handling, including amendments; and Customer feedback, including customer complaints.

Customer Satisfaction Procedure (PM-EOCP-CORP-QMS-504) Customer Feedback Procedure (PM-EOCP-CORP-QMS-539)

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5.

HAZARDS AND EFFECTS MANAGEMENT

The identification, assessment and management of hazards are a vital element of a successful HSEQMS. The Hazard and Effects Management Process (HEMP) is the tool used for this. The HEMP should first be applied to high level corporate activities and then to all HSEQ critical company activities at the lower, more detailed level, through the respective project assessments and safety case studies. The HSEQ-MS provides a structured, documented management system that seeks to ensure that all foreseeable hazards have been identified, risks assessed and the necessary control/recovery mechanisms and procedures have been clearly defined. The HEMP of identify-assess-control-recover provides the basis for the identification of deficiencies from which a prioritized Remedial Action Plan for correction or improvement can be developed. All HSEQ risks that arise out of and in the course of EOCP activities, including contractor activities are reduced to a level that is as low as reasonably practicable (ALARP). EOCP Management Team provides the required support and resources, to enable the implementation of the required risk management activities. Hazard and Effect Management Procedure (PM-EOCP-CORP-HSE-509)

5.1

Hazards and Effects Identification

EOCP maintains procedures to identify systematically and record the hazards and effects which may arise from its activities. The hazard identification includes consideration during: Planning, design, procurement, construction, hook-up, installation and commissioning; Routine and non-routine operating conditions including shut-down, maintenance and start-up; Incident and potential emergency situations, including those arising from loss of containment, material failures, structural failures, natural disasters, sabotage, breaches of security and human errors; Decommissioning, abandonment, dismantling and disposal; and Potential hazards and effects associated with past activities. EOCP trains selected personnel from different sections of the organization on the specialized tools for hazard identification such as JSA, HAZIDs etc. The training is required since hazards and effects identification requires specialized technique and system, operational experience and technical knowledge. In hazards identification process, the type of hazards associated with either the activities or equipment and their effects shall be identified. The screening criteria shall also be established in order to define the acceptable and unacceptable level of risk. Job Safety Analysis Procedure (PM-EOCP-CORP-HSE-510)

5.2

Risk Assessment

Evaluation of the risk posed by the identified hazards requires consideration of both the severity of the consequences of a potential event and probability of its occurrence. EOCP maintains a procedure to evaluate risks and effects from identified hazards against screening criteria, taking account of probabilities of occurrence and severity of consequences to people, environment, facilities and business.

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EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ - 501 0

ALARP is the basis to be used when uncertainties arise from evaluation and agreed by all parties involved. Once the hazards and its effects have been identified and assessed, they shall be considered against an HSEQ risk screening criteria. Screening criteria are values or standards against which the identified hazards or effect can be judged such as occupational exposure limits, gas emission limits, wastewater discharge limits and engineering standards. In cases where the relevant HSEQ risk screening criteria is defined by local legislation or clients standards, such requirements shall be complied with. However, where EOCP HSEQ risk screening criteria is more stringent, the more stringent requirement shall be complied with. For a qualitative risk assessment, the assessed risk can be regarded as either: Low Risk - denoting risks low enough not to warrant further action or study; ALARP Area - denoting risks which fall within the ALARP area. These will be considered for cost effective mitigation; and High Risk - denoting risks that are so high that action to reduce them must be taken. Events within the High Risk and ALARP Area categories of risk will be considered for further study. The EOCP Risk Assessment Matrix shall be used for the qualitative overview of risk and screening criteria in risk assessment carried out throughout EOCP operations. Figure 5.1 illustrates the EOCP Risk Assessment Matrix. Hazard evaluations are recorded, together with the data sources and assumption used. These records which are used by operation personnel in developing procedures and issuing work instructions, documented in any of the following documents: Hazards and Effects Registers; and Critical Operating Procedures.

5.3

Control and Recover

Risk reduction measures are taken to evaluate and implement appropriate measures to reduce or eliminate risks. Risk reduction measures include those to prevent or control incidents and to mitigate effects. Mitigation measures include steps to prevent escalation of developing abnormal situations and to lessen adverse effects. Risk reduction measures also include recovery preparedness measures which address emergency procedures as well as restoration and compensation procedures. EOCP maintains procedures to: Identify prevention and mitigation measures for particular activities, products and services which pose potential HSEQ risks; Review activities to ensure that the measures proposed to reduce risks or enable relevant objectives are met; Implement, document and communicate to staff all interim and permanent risk reduction measures and monitor their effectiveness; Develop relevant measures such as plans for emergency response to recover from incidents and mitigate their effects; Identify hazards arising from risk prevision and mitigation and recovery measures; and Evaluate the tolerability of consequent risk and effects against the screening criteria.

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Health, Safety, Environmental and Quality Management System Manual

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Figure 5.1: EOCP Risk Assessment Matrix

Consequences Severity
People Assets/ Production loss Rare (1) Reputation Rarely or never heard of in E and P industry Environment

Frequency of Occurrence
Unlikely (2) Occurred several times in E and P industry Credible (5) Likely (8) Happen several times per year in EOCP Almost Certain (10) Happens several times per year on a particular location

Incident has occurred in EOCP

None (0)

No injury

No loss or damage No disruption to production. Loss/repair cost less than 10K USD Possible disruption to production. Loss/repair cost less than 100K USD Production shutdown. Loss/repair cost less than 1M USD Major production shutdown. Loss/repair cost less than 10M USD Loss of facility. Loss/repair cost more than 10M USD

No effect

No impact Local media interest

Insignificant (1)

Minor injury, First aid

Slight effect

LOW RISK

Minor (2)

Recordable case, MTC, LTI

Minor effect

Local TV, national papers

Moderate (3)

Multiple LTIs, one PD

Local effect

Considerable impact

ALARP AREA HIGH RISK

Major (4)

One fatality, multiple PDs

Major effect

National TV, international papers International TV, extended coverage

Critical (5)

More than one fatality

Massive effect

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6.
6.1

PLANNING AND PROCEDURES


HSEQ and Emergency Planning

The Corporate HSEQ Plan is constructed in coordination with the aspiration of the company business services and EOCP Management Team guided by: Specific clients standards on HSEQ; Regulatory requirements; International conventions; Local community and authority expectations; Company strategic objectives and targets; and Weaknesses identified from operation and service units, Departmental/Project Managers and corporate HSEQ-MS self-assessment questionnaire and annual HSEQ-MS reviews. The Corporate HSEQ Plan is reviewed at the HSEQ Steering Committee and approved by the MD. The Departmental/Project Managers cascade the corporate plan, with the assistance of their supervisors and use it as input to their respective HSEQ plans.

6.3.1

HSEQ Objectives and Targets

The Corporate HSEQ Plan drives the establishment of HSEQ Objectives and Targets at corporate level. At the lower level, Departmental/Project HSEQ Plan establishes HSEQ Objectives and Targets for each functional department/project. Each EOCP employee is required to establish personal HSEQ objectives and targets. HSE Objectives and Targets Establishment Procedure (WP-EOCP-CORP-HSE-513)

6.3.2

HSEQ Management Programs

The Corporate HSEQ Plan establishes company-wide performance indicators and annual targets. It also includes a list of action or management programs to be completed within set completion target dates and by respective action parties. These management programs are developed in the respective operation and service units to track progress against a target set to achieve continual improvement of the HSEQ performance of a given activity. HSE Management Programs Establishment Procedure (WP-EOCP-CORP-HSE-514)

6.3.3

Emergency Preparedness and Crisis Management

EOCP ensure emergency preparedness through identification of foreseeable emergency situations by HEMP and establishing Emergency Response Plan (ERP) which is periodically assessed for its effectiveness. EOCP emergency response tier is broken down into: Departmental/Project/Facility level emergency response managed by the On-scene Commander (OSC) with operationally ready Emergency Response Team (ERT); Regional level emergency response managed by the Emergency Coordinator (EC) through Emergency Command Centre (ECC); and Corporate level crisis management led by Managing Director. In general, emergency at operation/ project site must be handled directly by the operation and service unit management. EOCP Crisis Management Team (CMT) headed by the Managing Director will only be activated when the emergency condition escalates to a higher level requiring outside resources.

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The ERP is reviewed annually, led by the HSE Manager together with EC and OSC to identify weaknesses and propose improvements. The findings of the system review are presented to the HSEQ Steering Committee. The ERP is simulated throughout the year by a series of table top and live exercises followed by post mortems. Reports and reviews are recorded for documentation purpose. Emergency Response Preparedness Procedure (PM-EOCP-CORP-HSE-515)

6.2

Document Control

For all critical task and their supporting tasks, written procedure are developed and maintained at workplace. The procedures are simple, understandable and accessible to all staff to ensure its effectiveness. It is also important that the procedures include measures to control HSEQ risk and means for communicating the work instructions to the staff prior to job execution. EOCP maintains HSEQ records which are made available to all clients and suppliers as needed to demonstrate HSEQ compliance and the effectiveness of the operation of the Management System. The Departmental/Project Manager in liaison with the QA Manager will be responsible for coordinating the dissemination of any HSEQ records to clients and suppliers. HSEQ records must be legible and traceable to the product or activity they represent. HSEQ records retained on the projects are normally outlined in the HSEQ Plan, QA/QC Plan, Inspection and Test Plan, contracts and/or project plans. Measures are taken to prevent damage or deterioration to all records retained. Records are retained for a period of time in accordance with contract or statutory requirements, whichever is greater. EOCP maintains procedures for controlling HSEQ-MS documents to ensure that: They can be identified with the appropriate company, function or activity; They are periodically reviewed, revised as necessary and approved for adequacy by authorized personnel prior to issue; Current versions are available on the EOCP website and all printed copies are uncontrolled and may be found at those locations where they are needed; and When obsolete, they are promptly removed from all points of issue and points of use. Documentations are legible, dated (with dates of revision), readily identifiable, numbered (with a version number), maintained in an orderly manner and retained for a specified period. Policies and responsibilities are established for the modification of documents and their availability to employees, contractors, government agencies and the public. A complete hard copy set of signed and approved HSEQ-MS documentation are kept by the HSEQ department. The EOCP HSEQ documentation is structured into 5 levels as shown in Figure 6.1 and Table 6.1. Management System Documentation Numbering (BP-EOCP-CORP-QMS-502) Procedure Development, Issue and Change Control (PM-EOCP-CORP-QMS-541)

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Figure 6.1: EOCP HSEQ-MS Documentation Hierarchy

Note : The HSE-MS Documentation Hierarchy as illustrated above is deployed on projects and operations in varying stages and is adapted as applicable depending on the work scope.

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Table 6.1: EOCP HSEQ-MS Documentation Hierarchy


Level I Policy Statements of corporate HSEQ policy that apply to all employees.

HSEQ Policy

Level II

Business Practices e.g. HSEQ Manual Describe the policy, organisation, responsibilities and arrangements of the appropriate management system in line with the recognised standard e.g. ISO 9001:2000, ISO 14001:2004 or OHSAS 18001:1999
HSEQ-MS Manual

Level III

Work Processes Linkage Describe work process required which is designed to promote a common understanding among interfacing departments, group or discipline that contribute to a given process. It identifies who does what and functional responsibilities of the individual departments. Figure 6.2 and 6.3 illustrates HSE and Quality Linkage of Processes respectively.

C h e c k & R e v i e w D e s i g n

Level IV

Process Maps/Procedures Intent of this is to provide detail process to achieve goals. This is provided, for the ease of implementation, in the form of written narrative, Procedures or Process Maps or a combination of both.
ST

END

Level V

Work Methods and Instructions Details of how tasks within a process are performed. Normally deployed in a single discipline and relevant to a particular task.

Work Instructions

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Note : The below describes the key activities performed by the HSE Function and associated procedures that support its successful implementation .

HSE LINKAGE OF PROCESSES


Audit & Review

Management Review Doc No.: PM-EOCP-CORP-HSEQ-535 Internal & External Quality Audits Doc No.: PM-EOCP-CORP-HSEQ-533 HSE Site Inspection Procedure Doc No.: WP-EOCP-CORP-HSE-534

Leadership & Commitment

Policy & Strategic Objective

Organization, Responsibilities & Resources

Hazards & Effects Management

Planning & Procedures

Implementation & Monitoring

Legal & Other Requirements Identification Procedure, Doc No: BP-EOCP-CORP-HSE-506

HSE Training & Competence Evaluation Procedure Doc No: PM-EOCP-CORP-HSE-507 Internal & External Communication Procedure Doc No: WP-EOCP-CORP-HSE-508

Hazards & Effects Management Procedure Doc No: PM-EOCP-CORP-HSE-509 Job Safety Analysis Procedure Doc No: PM-EOCP-CORPHSE-510 Risk Control Procedure

HSE Objectives & Targets Establishment Procedure Doc No : WP-EOCP-CORP-HSE-513 HSE Management Programs Establishment Procedure Doc No: WP-EOCP-CORP-HSE-514 Emergency Response Preparedness Procedure Doc No: PM-EOCP-CORP-HSE-515 Emergency Equipment Management Procedure Doc No: WP-EOCP-CORP-HSE-516 Operational Control Procedures

HSE Performance Measurement, Monitoring & Reporting Procedure Doc No: WP-EOCP-CORP-HSE-529 Corrective & Preventive Action Doc No: PM-EOCP-CORP-HSEQ-531 Incident Notification, Investigation & Reporting Doc No: PM-EOCP-CORP-HSE-532 HSE Documentations & Records Procedure Doc No: WP-EOCP-CORP-HSE-530

Occupational Health & Hygiene Management Procedure Doc No: WP-EOCP-CORP-HSE512

PPE Management Procedure Doc No: WP-EOCP-CORP-HSE511

Environmental Management Procedure Doc No:WP-EOCP-CORP-HSE-536

Contractor HSE Management Procedure Doc No: WP-EOCP-CORPHSE-528

Management of Facility Integrity Procedure Doc No: WP-EOCP-CORPHSE-536

Material Handling Procedure Doc No: WP-EOCPCORP-HSE-523

Permit-to-Work (PTW) Procedure Doc No: PM-EOCPCORP-HSE-526

Resources Conservation Procedure Doc No: WP-EOCPCORP-HSE-521

Waste Management Procedure Doc No: WP-EOCPCORP-HSE-518 Emission Control Procedure, Doc No: WP-EOCPCORP-HSE-520

Maintenance Management Procedure Doc No: WP-EOCP-CORPHSE-517

Management of Change Procedure Doc No: PM-EOCP-CORPHSE-525

Lifting Procedure Doc No: PM-EOCPCORP-HSE-537

Lock-out Tag-out (LOTO) Procedure Doc No: PM-EOCPCORP-HSE-527

Discharge Control Procedure Doc No: WP-EOCP-CORPHSE-519

Hazardous Material Management Procedure Doc No: WP-EOCP-CORPHSE-522

Figure 6.2: EOCP HSE Linkage of Processes


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Procedure No.

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Note : The below describes the key activities performed by the Quality Function and associated procedures that support its successful implementation .

Problem Resolution Guide Doc No: PM-EOCP-CORP-QMS-544

QUALITY LINKAGE OF PROCESSES


Problem Resolution

Planning & Re-sourcing

Management Systems & ISO Certification

Audit / Measurement / Evaluation / Prevention & Continuous Improvement

Check
Customer & Review Satisfaction

Design

Project Quality Planning Doc No.: PM-EOCP-CORP-QMS-540 Coordination of Quality Resources Doc No.: PM-EOCP-CORP-QMS-538

HSEQ Management System Manual Doc No.: MAN-EOCP-CORP-HSEQ-501

Management Review Doc No: PM-EOCP-CORP-HSEQ-535

Customer Feedback Doc No.: PM-EOCP-CORP-QMS-539 Customer Satisfaction Doc No.: PM-EOCP-CORP-QMS-504

Procedure Development, Issue & Change Control Doc No.: PM-EOCP-CORP-QMS-541 Management Review Doc No.: PM-EOCP-CORP-HSEQ-535

Corrective & Preventive Action Doc No.: PM-EOCP-CORP-HSEQ-531

Internal & External Quality Audits Doc No.: PM-EOCP-CORP-HSEQ-533

Lessons Learnt & Knowledge Capture Doc No.: PM-EOCP-CORP-QMS-505

Corrective & Preventive Action Doc No.: PM-EOCP-CORP-HSEQ-531 Internal & External Quality Audits Doc No.: PM-EOCP-CORP-HSEQ-533

Control of Non-Conforming Product Doc No.: PM-EOCP-CORP-QMS-543 Quality Assessment of Suppliers Doc No: PM-EOCP-CORP-QMS-542

HR Procedures

Process Owners Business Practice Doc No.: BP-EOCP-CORP-QMS-503

Figure 6.3: EOCP Quality Linkage of Processes


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6.3

Operation Control Procedures

Controls for critical tasks are documented in the safety cases and HEMP registers and Process Owners Business Practice. Operational control is essentially maintained through: Implementation of HSEQ manual and subsequent procedures in EOCP Business Processes; Periodic review of HSEQ manual and subsequent procedures; Periodic Training Needs Analysis and training; Audits; and Preventive, routine and emergency maintenance programmes. Departmental/Project/Operation Managers have accountability over day-to-day operation, performance and development of all facilities. This accountability includes controlling the associated HSEQ risks. EOCP personnel managing contractors are responsible for specifying appropriate procedures and work instructions for contractor activities and for ensuring their adherence. Work instructions are generally developed within departments. Therefore, it is the responsibility of individual Departmental/Project Managers (Process Owners) to implement and communicate these documents among their teams. Process Owners Business Practice (BP-EOCP-CORP-QMS-503)

6.3.4

Engineering

The Engineering Core Process describes how the company plans and control the design and development of the product in accordance to the requirements of the contract. It encompasses the following activities: Review Design Basis and Criteria Plan Design Work Produce/Monitor Design Control Design Change Check and Review Design Design Verification Design Validation Approve Design Deliver Design to Procurement and Construction The Engineering Core Process is verified through application of EOCPs Core Process Elements listed (but not limited to) below: Identify all design input and deliverables Establish schedule for deliverables Implement design QC Plan Management of change Resolve design queries Check document and conduct design review Validate internal / external design equipment Check output meets design basis Obtain client approval for changes Internal/external approval of design dossiers Procurement, construction and operations review and validation Establish equipment list and material take off The end results of the interrelated actions undertaken through-out the Engineering Core Process is the actual design to be constructed or fabricated by the company in accordance to the requirement of the contract. In some instances the Engineering process is the final deliverable.

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6.3.5

Procurement

The Procurement Core Process describes how the company plans, selects and obtain defect-free equipment, materials and services from its suppliers and subcontractors that satisfy its customers requirements. It encompasses the following activities: Planning Enquiry Evaluation Award Order coordination Release and Delivery The Procurement Core Process is verified through application of EOCPs Core Process Elements listed (but not limited to) below: Establish Procurement Plan including integrity assurance/performance measures Obtain client approval on supplier listing Establish export compliance and requirements Rationalise resource plan Establish criticality strategy, as required Package risk identification Establish evaluation criteria Review and conduct audits Check purchase order package for completeness prior to issue Package risk management Review final documentation Reconcile and close-out purchase orders The end results of the interrelated actions undertaken throughout the Procurement Process is the successful selection of the right supplier and/or subcontractor to provide the equipment, materials and services to the company to complete the deliverable as required by the contract. In some instances the Procurement process is the final deliverable.

6.3.6

Construction Management

The Construction Management Core Process describes how the company manages a construction project from start to close out. It encompasses the following activities: Project start-up Mobilisation / demobilisation Project planning Project execution Project close-out The Construction Management Core Process is verified through application of EOCP process elements listed (but not limited to) below: Establish construction management plan Prepare project quality control plan which is linked to subcontract QC management plan Prepare Inspection and Test Plan Include integrity assurance/performance measure Conduct gap analysis/pre-start audit (action plan) Review/audit/approve subcontractor work processes Monitor cost against budget and progress against schedule Ensure change control is managed, reviewed and approved. Review construction documents for completeness and ascertain punch list items Ensure customer property including intellectual property is protected and maintained
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Ensure mechanical completion close-out Close out all Projects technical queries, change orders, variation orders, audits and corrective action requests Prepare project close out report Compile lessons learned

The end result of the interrelated actions undertaken throughout the construction management core process is the successful management and completion of the project to the satisfaction of the customer. In some instances this process is the final deliverable.

6.3.7

Construction

The Construction Core process describes how the company construct or fabricate the product according to the requirements of the contract. It encompasses the following activities: Receiving equipment/materials] Prepare materials Fabrication activities Mechanical completion Pre-commissioning/commissioning Verification and Validation Load-out The Construction core process is verified through application of EOCPs core process elements listed (but not limited to) below: Identification and ensure traceability of materials Ensure compatibility of materials Check and ensure qualification of personnel Establish inspection requirements Ensure control of welding consumables Ensure change control is managed, reviewed and approved Check testing requirements System completion checks Ensure correct load out equipment The end result of the interrelated actions undertaken throughout the construction process is the successful completion of the deliverable to the requirements of the contract. In some instances, this process is the final deliverable The construction procedures are defined at the project stage and identified in the project plans.

6.3.8

Installation

The installation core process describes the installation of the constructed or fabricated product as required by the contract. It encompasses the following activities: Selection of vessels/tugs/barges Mobilisation and demobilisation Field installation Tie-ins The installation core process is verified through application of EOCPs core process elements listed (but not limited to) below: Establish required size and capacity Ensure marine warranty surveyors approvals Monitor and ensure that certification of personnel are valid Ensure incident and accident free installation

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Monitor progress against schedule Minimise repairs and defects Establish non-destructive testing and other inspection requirements

The end result of the interrelated actions undertaken throughout the installation process is the successful installation of the constructed or fabricated product. In some instances this process is the final deliverable.

6.3.9

Hook-up and Commissioning

Hook-up and commissioning follows on from the close out of mechanical completion and involves precommissioning checklist conclusion and start-up. Completion is achieved when all agreed deliverables, records, testing have been delivered to and accepted by the client. Hook up and commissioning process are verified through the application of elements including but not limited to: Maintenance of job cards Maintenance of the commissioning management system Completion of the commissioning procedure check-lists

6.3.10 Operations and Maintenance


Operations and Maintenance of plants and installations are supported through the use of supplied operating manuals approved by the client. Adequately experienced personnel with the right skills and knowledge will be deployed to operate and maintain the facilities. Detailed performance standards will give the measurable values that the organisation requires to meet in order to achieve its goals. Strategies will be developed, planned, organised and implemented to meet the standards and the performance will be monitored, reviewed and developed to give continuous improvement or reinforcement to the process.

6.3.11 Marine
The marine core process describes how the company deals with operation and maintenance of marine vessels. It encompasses the following activities: Operation and Maintenance of Pipe Lay Barge; and Operation and Maintenance of Floating Production Storage and Offloading facility. The marine core process is verified through application of EOCPs core process elements listed (but not limited to) below: Instruct the fleet and shore based staff on policies and procedures in compliance to the International Safety Management (ISM) Code for Safety Operations of Ships and Pollution Prevention Ensure marine warranty surveyors approvals Monitor and ensure that certification of personnel are valid under international marine codes Minimise and if possible eliminate pollution to marine environment Monitor progress of projects and production activities against planned schedules Minimise repairs and defects of marine vessels

6.3.12 Facility Integrity


Facility integrity and management of HSEQ risk are closely linked. Maintaining facility integrity is a major control mechanism to manage many HSEQ risks i.e. loss of containment, structural failure, fire and explosion.

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EOCP maintains procedures to ensure that facilities or installations are suitable for the required purpose and comply with relevant legislative requirements, industrial codes and international standards throughout facilities life cycle i.e. design, procurement, construction, installation, operation and maintenance phase. Pre-procurement and pre-construction assessment of new facilities and equipment includes explicit assessment of appropriateness to meet HSEQ requirements and emphasizes design as the best preventive measure to reduce risk and adverse HSEQ effects. EOCP procedures and systems for ensuring facility integrity address structural integrity, process containment, ignition control and systems for protection, detection, shutdown, emergency response, evacuation and life saving.

6.3.13 Management of Change


EOCP requirement for planning and controlling changes within its operations either temporarily or permanently, in people, plant, processes and procedures, is addressed in relevant change procedures. The procedures are suitable to address the HSEQ issues involved, according to the nature of the changes and their potential consequences. The procedures also address: The changes and its implementation; Government/local authority approval and reporting; Responsibility for reviewing and approving the changes or its implementation; Measures to identify hazards and to assess and reduce risks; Hazards communication and training requirements; Implementation timeline; Verification and monitoring requirement; and Acceptance criteria and action to be taken if breached. Management of Change Procedure (PM-EOCP-CORP-HSE-525)

6.3.14 Permit-to-work System and LOTO


EOCP operations employ a Permit-to-Work System and LOTO program to ensure all work is carried out safely in a controlled manner and that everyone is aware of the hazards involved in their work and of the precautions to be taken to ensure safe work. Operational personnel are put through vigorous training and assessment to understand and implement arrangements set in the PTW/LOTO programs. Permit-To-Work Procedure (WP-EOCP-CORP-HSE-526) Lock-out Tag-out Procedure (WP-EOCP-CORP-HSE-527) Shipboard Operations, Section 7 Emas Offshore SMM

6.3.15 Contractors HSEQ Management


A considerable part of EOCP activities may depend on contractors to carry out a wide variety of works and the majority of these are carried out in and around workplaces of relatively high risk. Especially for large and longer-term contracts, there is a need for early identification of clear and common HSEQ objectives from the onset and it is imperative to include these in the contract. Contractors are required to develop HSEQ management system interface documents aligned to satisfy EOCP HSEQ policies, manual, procedures and work instructions. All contractors activities, products and services must meet the local and international legislations pertaining to HSEQ and EOCP HSEQ-MS requirements.
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All EOCP contractors are pre-qualified with a rating for HSEQ competency and performance. EOCP personnel in charge of contractors are responsible for assessing the possible risks of contracts before awarding and ensure that the contractors HSEQ plan is: assessed for fitness prior to contract award; reviewed for compliance and fitness prior to mobilization; monitored for compliance during the execution phase; and reviewed during contract close out.

6.3.16 Environment Management


EOCP Corporate Environment Management Plan (EMP) is designed to meet ISO14001 EMS standard and EOCP Senior Management provides unwavering commitment and support towards achieving the Target Zero goal of Zero Damage to Environment. The EMP identifies and plans on operations that are associated with or may have identified environmental impacts consistent with its HSEQ Policy, Objectives and Targets, in order to ensure that they are carried out under specified conditions, by: establishing, implementing and maintaining documented procedures to control situations where their absence could lead to deviation from the HSEQ Policy, Objectives and Targets; stipulating the operating criteria in the procedures; and establishing, implementing and maintaining procedures related to the identified environmental impacts of goods and services used by the organization and communicating applicable procedures and requirements to suppliers, including contractors. Environmental Management Procedure (WP-EOCP-CORP-HSE-536)

7.
7.1

IMPLEMENTATION AND MONITORING


Responsibility and Ownership

Full implementation of the HSEQ-MS means that people are doing what the Management System says they should be doing, at all levels of the organization. Successful implementation requires embedding HSEQ into the EOCP culture; with clear responsibilities and Departmental/Project ownership. Activities and tasks are conducted according to procedures and work instructions developed in accordance with HSEQ policies and set objectives and targets: At management level, activities will normally take the form of plans and actual implementation; and At departmental/project level, activities shall be in the form of executing activities and tasks assigned. Successful implementation of EOCP HSEQ-MS requires that it be viewed as part of the way EOCP do things. HSEQ management is an integral part of our business. Responsibility for conducting critical tasks is clearly communicated to the individuals involved. Each responsible person monitors and regularly reports the performance of the critical activities using set performance indicators. People identified as responsible for critical tasks must take ownership. To achieve this, it is essential for Project staff to be genuinely involved in developing the HSEQ-MS, HSEQ Plans and Operational Safety Cases.

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7.2

Performance Indicators and Measurement

EOCP establishes procedures to maintain appropriate records to demonstrate conformance to the HSEQ-MS, policies, objectives and targets, local legislations, international standards and clients specific requirements. EOCP regularly measures, records, tracks and reports HSEQ performance against objectives and targets set in the HSEQ plan and in maintaining control of critical activities. EOCP develops procedures for periodic review of performance against annual Corporate and Departmental/Project HSEQ Plans. EOCP HSEQ performance measures are generally of two types: Proactive systems, which monitor achievements of plans and the extent of compliance with legislations, standards and procedures; and Reactive systems, which monitor incidents and emissions. Proactive monitoring provides information in the absence of any incidents, health impairment, damage to the receiving environment or breach of laws. Proactive performance indicators are forward looking and predictive, aimed at raising the awareness of the possibility of incidents that might happen. Reactive monitoring provides information on incidents that have occurred and provides insights into means of preventing similar incidents in the future. Reactive performance indicators provide evidence of deficient HSEQ performance. HSE Performance Measurement, Monitoring and Reporting Procedure (WP-EOCP-CORP-HSE529)

7.3

Monitoring Program

A monitoring program is required to measure HSEQ performance and the implementation of the HSEQ-MS, against established targets. A monitoring program: Identifies the information to be obtained; Defines the required accuracy of the results; Specifies the monitoring methods and identify monitoring locations; Specifies the frequency of measurement; and Defines roles and responsibilities for monitoring. A monitoring program also regularly examines progress towards achieving set departmental/project level HSEQ Objectives and Targets.

7.4

Data Accuracy and Calibration

Sufficient quality control over measurement errors is important to ensure clear and accurate interpretation of monitoring results and to maintain consistency of measurement. Monitoring equipment is calibrated by competent personnel on regular basis. Procedures are established for collection, analysis and interpretation of monitoring data.

7.5

Records

EOCP establishes a system for records management in order to demonstrate the extent of compliance with legislative requirements, HSEQ policies and its requirements and to record the extent to which planned objectives and performance indicators which has been met.

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The retention times of records are captured, recorded and analyzed, such that evidence is available of the achieved compliance levels, to identify problem areas, to ensure the effectiveness of actual implementation and its traceability. HSE Documentations and Records Procedure (WP-EOCP-CORP-HSE-530)

7.6

Incident Investigation and Reporting

EOCP maintains procedures for incident investigation, notification and reporting for any incident occurred in the company. Any accident or near miss must be notified, analyzed, reported and followed up with corrective and preventive measures to prevent recurrence Incidents may affect people or the environment, or the assets and reputation of EOCP. The corresponding consequences of incidents are: Personal injury/occupational illness; Facility loss/damage; Environmental damage/impacts; and Business reputation affected. EOCP defines requirement relating to the investigation and reporting of incident including near misses that may arise and in the course of EOCP business activities. The purpose of incident investigation and reporting are to ensure that: All cause of incident are identified; Lesson learnt from incidents are identified and implemented, in view of preventing recurrence; All relevant parties within EOCP are promptly notified; and Any legal issues relating to the incident are duly considered. All incidents including near misses, that arise within EOCP activities are investigated and reported in accordance with EOCP corporate procedures and Client reporting standards as applicable.. All incidents are reported immediately to appropriate supervisors and responsible manager, who will then take the required actions including participating in incident investigation, reporting and implementation of corrective actions and preventive measures. For contractors, they need to notify all incidents to the respective EOCP contract in-charge and Project HSEQ personnel. The Project HSEQ personnel must notify the Client within 24 hours. Notification to the authority concerned will be managed by the EOCP HSEQ Manager or his designate in project organization. Lesson-learnt from incidents are disseminated as widely as possible during daily tool box meeting (TBM) and HSEQ Alerts; in particular where lesson-learnt from the incident has lateral applications to the EOCP businesses as well as activities conducted by the clients. The HSEQ alerts are distributed internally as well as to the clients office, business partners and other stakeholders. Any major incident such as fatality, lost time injury (LTI), major spillage, occupational illnesses and non compliance to legislative requirements shall be reported directly to EOCP Senior Management in accordance with the companys Emergency Response Plan. Incident Notification, Investigation and Reporting Procedure (WP-EOCP-CORP-HSE-532)

7.7

Corrective and Preventive Action

When non-conforming materials or non-compliant processes are detected, all associated and root causes will be investigated. A corrective action is selected in balance with associated risks. Corrective
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actions shall be documented and evaluated for effectiveness and, if necessary changes made to procedures and work practices to prevent recurrence. Preventive action is directed toward eliminating the causes of potential non-conformances. It shall be to a degree appropriate to the magnitude of problems encountered. Non-conformance/observations raised as a result of Management System reviews and audits will be reviewed by the management for preventive action, where applicable. EOCP defines the requirement in term of responsibility and authority for initiating investigation and corrective action in the event of non compliance with specified requirements relating to HSEQ-MS. Situation of non- compliance may be identified by the monitoring programs, through communications from employees, contractors, customers, government agencies or the public or from investigations of incidents. For any sign of non-compliance to HSEQ-MS, associated with procedures and legislative requirements, the responsible manager in association with HSEQ Corporate will initiate an investigation with an intention to establish the causes of non compliance and develop relevant mitigation measures. The party responsible must ensure the followings are executed in the event of any HSEQ non compliance: Notify relevant parties; Determine the root cause of non compliance; Initiate the necessary investigation; Provide corrective action with consultation of HSEQ committee; Ensure the preventive action are in place for long term measures; If necessary, revise procedures to incorporate actions to prevent recurrence; and Communicate the non compliance to all staff and contractors as a lesson learnt.

Progress in implementation of corrective and preventive action are monitored and presented at EOCP HSEQ Steering Committee Meeting. Corrective and Prevention Action (PM-EOCP-CORP-HSEQ-531)

7.8

Non-Conformance

Non-conformance may be sudden and temporary, or they may persist for long periods. They may result from deficiencies or failures in the HSEQ-MS itself, failures in plant or equipment or from human error. Quality Manager or his delegate will be responsible for the control of non-conforming materials and/or processes. This will include the identification, documentation, evaluation, segregation, disposition and preventing the use of non-conforming materials and/or processes. Quality Manager or his delegate will also be responsible for the notification of affected departments when non-conforming materials and/or processes are detected. Non-conformance is reported when there is a deviation from the agreed system, procedure or specified requirements that affect the safety, quality or continuity of the operation. Quality Department performs trend analysis as required and decided by the HSEQ Steering Committee during Management Review. Investigating non-conformance should fully establish the causes, including failures in the HSEQ-MS. Investigations enable the planning of corrective action including measures for: Restoring compliance as quickly as possible;
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Time scale to resolve; Identification of root causes; Appropriate corrective action for the immediate situation; Preventing any recurrence; Evaluating and mitigating any adverse HSEQ effects; Ensuring satisfactory interaction with other components of the management system; and Evaluation of the completeness and effectiveness of the solution and follow-up to ensure that the problem does not recurring.

Implementing corrective action will not be complete until the effectiveness of the above measures has been demonstrated. This includes making the appropriate changes to EOCP procedures and records. Control of Non-Conforming Product (PM-EOCP-CORP-QMS-543)

8
8.1

AUDIT
Audit Plan, Process and Hierarchy

EOCP believes that audits are essential for improvement and reaching the companys objectives. This is achieved by a combination of periodic assessment and/or audit of projects and business management and support activities. Internal audits are carried out with a minimum frequency of once a year and/or as required by the contract. External Audits are conducted as required on a project or bid normally on a vendor or a subcontractors facility. Auditing addresses the periodic assessment of system performance, its effectiveness and inherent suitability against the business requirement. EOCP defines the requirements in respect of internal HSEQ-MS auditing, to provide assurance to management that: HSEQ management within the EOCP conforms to HSEQ-MS; The planning and implementation of activities within the EOCP is consistent with achieving the intents of EOCP HSEQ policies, strategic objectives, targets and plans; and The level of understanding and implementation of the stipulated HSEQ requirements and the extent, to which they are adhered to in the Company, is appropriate and effective.

Audit Plan
EOCP maintains an audit plan, dealing with the following: Specific activities and areas to be audited. Audits will cover the operation of the HSEQ-MS and the extent of its integration into project activities and specifically address the elements of the HSEQ-MS; Frequency of auditing for specific activities/areas. Audits will be scheduled on the basis of the contribution or potential contribution of the activity concerned to HSEQ performance and the result of previous audits; and Responsibilities for auditing specific activities/areas.

Audit Process
EOCP maintain procedures for audits to be carried out, as a normal part of business control, in order to determine: Whether or not HSEQ-MS elements and activities conform to planned arrangements and are implemented effectively; The effective functioning of HSEQ-MS in fulfilling the companys HSEQ Policy, Objectives and performance criteria; Compliance with relevant local and international legislative requirements pertaining to HSEQ; and
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Identification of areas for improvement, leading to progressively better HSEQ management.

EOCP establishes the audit protocols that covered the following as a minimum; Allocation of resources to the auditing process; Methodologies for conducting and documenting the audits, which may involve the use of questionnaires, checklists, interviews, measurements and direct observations, depending on the nature of the function being audited. Procedures for reporting audit findings in a controlled manner to those responsible for the activity/area audited, who should take timely action on reported corrective actions and opportunities for improvement reporting should address: o conformity or non-conformity of the HSEQ-MS elements with specified requirements; o effectiveness of the implemented HSEQ-MS in enabling objectives and performance criteria to be met; o implementation and effectiveness of corrective actions from previous audits; and o conclusion and recommendations. System for auditing and tracking implementation status of audit recommendations; and Distribution and control of audit reports. The HSEQ audits are carried out internally by personnel from within the company but independent of the part being audited. However EOCP may also choose to engage external auditors where and when deemed necessary. The audit and review are carried out on quarterly basis and shall be initiated by the Operation Manager. The audit team are selected by the Operation Manager whom will ensure that audit team members possess broad knowledge on HSEQ matters and are experience in auditing practices and disciplines. The audit team gathers information by observation, through interviews and by checking documentations and hardware. The principal documents to be reviewed during the exercise include the following: HSEQ manual and procedures; Incident Reporting files; Permit-to-work and execution of critical activities; Medical log book; Inspection records; Equipment and machineries; Adherence to HSEQ policies and objectives; Adherence to procedures and work instructions; and HSEQ statistics and performance.

Audit Hierarchy
EOCP operates a multi-tiered system for HSEQ audit type comprising: Tier 1: Corporate HSEQ Audits led by HSEQ Specialists as appointed by the EOCP Senior Management. Audit findings are reported to the responsible managers of the audited departmental/project, copied to the MD and the HSEQ Steering Committees; Tier 2: Internal HSEQ Audits led and conducted by a departmental/project HSEQ audit team as appointed by departmental/project management. Audit findings are reported to Departmental/Project Managers. Procedures on how to conduct audits are provided by the HSEQ Manager; Tier 3: Contractors HSEQ Audits led and conducted by EOCP HSEQ Specialists as appointed by EOCP Senior Management. Audit findings are reported to Operations Director and contractors Senior Management. Procedures on how to conduct these audits are provided by the HSEQ Manager; and Tier 4: HSEQ Site Inspection conducted by Operation Manager, HSEQ Department and Discipline Supervisors.

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8.2

Audit Team and Frequency

Audit Team
People conducting HSEQ audits are appropriately trained to be able to carry out the task objectively, impartially and effectively. Audit team members are selected so that their skills and knowledge are appropriate to the audit type and scope. The audit team must have: A broad knowledge of HSEQ matters; Attended HSEQ Auditing training; Adequate independence from the activities being audited, to enable objectives and impartial judgment; Operational experience in the area being audited; The necessary expertise and experience in auditing practices and disciplines; Specialist HSEQ or other technical expertise or support, if necessary, from a wider range of specialists; and The support and authority from management to procure the necessary information. In order to maintain independence and objectivity, the Audit Team Leader and the majority of the audit team will not have a direct reporting line to the Principal Auditee.

Audit Frequency
All business processes are periodically audited, with the frequency and depth of HSEQ auditing being determined based on: The level of risk for the activity; How critical the process or activity is, in relation to EOCP business objectives; The contribution or potential contribution of the activity concerned to EOCP overall HSEQ performance; and The results of previous audits. All business processes activities and facilities must be audited within a year. Internal and External Quality Audits (PM-EOCP-CORP-HSEQ-533)

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EMAS
EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

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Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ 501 0

REVIEW

At periodic intervals the effectiveness of the Management System will be reviewed by the HSEQ Steering Committee which comprises of the EOCP HSE Manager, Quality Manager, Operations Director, and representatives from the various departments as required. As a minimum, management review meetings will be conducted once a year.

9.1

Scope of Review

The content of review includes the EOCP and its activities focusing on HSEQ-MS and critical activities. The scope of management review specifically, but not limited, addresses: To ensure Business Objectives are met; To assess the effectiveness of the HSEQ Management System; To review working practices within the company with a view to standardization and to identity all possible changes to improve working practices; To review the results of Management System reviews, audits, non-conformances, corrective and preventive actions and the effectiveness of these actions through trend analysis; To review customer feedback and complaints; To review all continuous improvement initiatives; Review of HSEQ policies for its applicability and continuing suitability due to emerging HSEQ concerns in specific areas e.g. potential regulatory developments, concerns of employees, contractors, customers, government agencies and the public market pressures which affects sensitivity of the environment; Possible need for changes to the HSEQ plans, objectives and targets, in the light of changing circumstances and the commitment to strive for continual improvement; Review performance against targets; Consequent amendments to the HSEQ-MS documentations; Implementation of any recommendation made in audit reports; Implementation of any recommendations made in investigating incidents; Extent of follow-up on audit and incident action items; and Resource allocation to achieve HSEQ objectives and for overall HSEQ-MS implementation and maintenance. The review process is documented and its result recorded, to facilitate implementation of consequent changes. Reviews are used to reinforce continual improvement of HSEQ-MS.

9.2

Responsibility for Review

Reviews are carried out by EOCP Senior Management consists of the following: Managing Director (MD) as Chairman of the review; Associate and Operations Directors; Financial Controller; Operation and Maintenance Manager; HSE or QA/QC Manager as Secretary of the review; and Functional/Departmental/Project Managers. The minutes of the review meetings are held by the HSE or QA/QC Manager whom ensures that timely follow-up meetings are arranged to review progress. No item is closed until the approved action plans for improvement has been completed and found to be satisfactory. Minutes of the review meetings are distributed to the relevant managers and to contractors for dissemination at their management meetings. Management Review (PM-EOCP-CORP-HSEQ-535)

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EMAS
EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD

Title

Procedure No.

Rev.

Health, Safety, Environmental and Quality Management System Manual

MAN EOCP CORP - HSEQ 501 0

ATTACHMENTS

ATTACHMENT A

Consistency between ISO and ISM Codes with EOCP HSEQ-MS Organisation Structure HSEQ Roles and Responsibilities List of Process Maps and Procedures HSEQ Records Master List Distribution List and Revision History

ATTACHMENT B ATTACHMENT C ATTACHMENT D ATTACHMENT E ATTACHMENT F

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