Sept 09
Petroleum Development Oman L.L.C
Guidance Notes for Completion of
Contractor HSELetter of Assurance
Introduction
Contractors’ Chief Executive Officer (CEO) shall submit a HSE Letter of Assurance (LOA) every year by end of February to Petroleum Develolpment Oman (Company) in accordance with the guidelines stated herein. The LOA is a confirmation from the CEO, with or without qualifications, that the current implementation status and integrity of Contractor’s HSE management system meets the Contract requirements. Each Contractor is required to submit one LOA only to cover all contracts with Company that are operational on 1 January of that year.
The statements shall bein bold type and where necessary are followed by explanatory guidance in italics. Contractors’ CEOs should consider this guidance in deciding whether or not a statement can be made without qualification. In making their appraisal of whether or not a statement can be made without qualification, Contractors’ CEOs should consider how an auditor would rate compliance with the statement concerned. Statements should be qualified if a significant audit finding would be expected. An audit trail should exist to confirm the basis on which all statements have been made.Brevity is encouraged in both qualifications and any commentaries.
Contractors shall submit a completed HSE LOA (on attached template) and addressed to the following :
To:Naaman Al Naamani
MSEM, HSE&SD Manager, Petroleum Development Oman
P.O. Box 81, Post Code 100,Muscat, Sultanate of Oman
CC: Suleiman Tobi
OSD, Oil Director – South
CC:Hamad Al Khalfeen
MSE/1, Head Safety
CC:Contract Holder
Companyreserves the right to verify/ audit statements. False statements may expose Contractor to penalties as stipulated in the Contract.
TABLE OF CONTENTS
- Hazard and Effects Management Process3
- Life Saving Rules3
- Road Safety3
- HSE Incident Management4
- Staff5
- Performance Reporting and Execution6
- Sub-Contractors6
- Asset Integrity - Process Safety Management6
- Health6
- Environment7
- Other Issues8
1Hazard and Effects Management Process
1.1Heath, Safety & Environment (HSE) Hazards & Effects Management Assessments have been performed and documented for each contract.
Refer to:
PR 1171 “Contractor HSE management Part II – mandatory for Contracts and Contract Holders.”, 2.6.6 Hazards and Effects Management process.
1.2Toolbox talk addresses the potential hazards to be encountered in the execution of the activity’s scope of work and is being applied effectively.
Refer to:
PR1172 Permit to Work Procedures, 6.10 Briefing the Work Party – the Toolbox Talk
1.3Contract specific HSE Management Plans have been developed for each contract and annual plans cascaded from these. The annual plans describe the specific actions, programs and procedures that are being implemented to manage the Hazards associated with Contract execution.
Refer to:
C9 HSE Specifications, 1.0 HSE Management System and HSE Management Plan
PR 1171 “Contractor HSE management Part II – mandatory for Contracts and Contract Holders.”
2Life Saving Rules
2.1Contract Managersresponsible for respectivecontracts have met with their Contract Holders and agreed a plan for ensuring sustained communication of the “Life-Saving rules” to the workforce.
Refer to:
PDO’s12 Life-Saving Rules documentation for contractors.
2.2A robust ‘HSE Consequence Management System’ has been established and is being effectively implemented and enforced.
Refer to:
PDO’s HSE Campaign - Consequence management.
3Road Safety
3.1Updated requirements in the latest revision of SP2000 Rev 3.0 have been identified and an implementation plan has been prepared and issued to Company.
Refer to:
SP 2000 Road Safety Standard, andC-9 HSE and; Fax transmission dated 20th August 2009 “Notification of Alterations to Document C-9 HSE Specification”.
3.2Confirm that the journey management processes are complied with, assured and corrective actions taken, recorded.
Refer to:
SP 2000 Road Transport Specification, Appendxi 3
3.3Confirm that the requirements of the commuting policy are being implemented, that assurance is in place and remedial actions acted upon and recorded.
Refer to:
SP 2000 Road Transport Specification, and; Fax transmission dated 7th Jan, 2008 “Notification of Alterations to Document C-9 HSE Specification”.
3.4The condition of all vehicles used in contracts are in compliant with SP 2000 requirements and only in operartion when they are road worthy.
Refer to:
SP 2000 Road Transport Specification, Appendix II, 8 Roadworthiness Assurance Standards (RAS) Inspection Scheme
3.5All drivers working on PDO contracts have a valid PDO Defensive Driving Permit and do participate in drivers HSE gatherings such as driver’s forums
Refer to:
SP 2000 “Road Transport Specification, 2.1 Requirements for Drivers
3.6Confirm that the requirements of the SP2001 Load Specification are complied with, that assurance takes place and remedial actions acted upon and recorded.
Refer to:
SP 2001 “Load Safety and Restraining
4HSE Incident Management
4.1All High/medium HSE incidents including near misses are investigated appropriately and learning points are disseminated to both management and the workforce.
Refer to:
PR 1418 Incident Notification, Analysis, Reporting and Follow-Up Procedure.
Guidance to help ascertain compliance:
All HSE incidents (including relevant Security incidents) are reported to the Business and appropriately investigated, including the reporting of incidents with ‘Significant Impact’ (defined as incidents with actual consequences rated 4 or 5 on the March 2006 PDO HSE Risk Assessment Matrix (RAM)), in accordance with the December 2007 'Incident Classification, Investigation and Reporting' guide.
Action has been taken to implement incident review findings within agreed time frame.
To disseminate learnings a working internal-communications process must be put in place by the contractor, so that PDO is confident that critical information provided to a contract manager will reach the lowest levels of the contractor and subcontractor workforce – if applicable. Such a process must make provisions for the faithful translation of the information into the various languages spoken by the workforce and for the accessibility to equipment such as internet-enabled computers, video players, television screens, projectors, public-address systems, megaphones etc. at the worksite.
4.2The findings from incident investigations are regularly analysed and trended to determine the common causes of incidents in the contract and actions to prevent recurrence of these causes are being implemented.
Refer to:
PR 1418 Incident Notification, Analysis, Reporting and Follow-Up Procedure.
5Staff
5.1All personnel have completed the required HSE training as per the agreed training matrix in the contract.
Refer to:
C9 HSE Specifications, 3.0 HSE Training
5.2A behavioural based programme such as STOP or Company approved equivalent, is being fully implemented in accordance with requirements.
Refer to:
C9 HSE Specifications, 9.0 HSE Safety Training Observation Programme (STOP)
SP 1259 Safety Training Observation Programme (STOP)
5.3CompetenceAssessment and Assurance programs are in place and incorporated relevant HSE requirements.
Refer to:
PR 1171 Contractor HSE Management Part II – mandatory for Contracts and Contract holders, 2.6 & 2.7.
5.4HSE Critical positions,in contracts with PDO, including Key HSE Personnel have been identified, assessed against the relevant requirements and their competence has been verified, recorded and plans to address any competence gaps are in place.
Refer to:
PR 1171 Contractor HSE management Part II – mandatory for Contracts and Contract holders, 2.6 & 2.7.
Guidance to help ascertain compliance:
Individuals have been assessed against the relevant requirements, and their competence has been verified and recorded. Any competence gaps have been identified and managed taking into account the risk associated with the gap, the need to work without support and the competence of the whole team. The plan is agreed, documented and includes mitigation measures such as:
-Modification of the activity
-Reallocation of the activity to someone who is competent
-Closure of the gap through training
-Provision of supervision and support.
6Performance Reporting and Execution
6.1All high/medium potential HSE incidents (including near-misses), the Health and Safety Statics (monthly returns) are reported appropriately and submitted as required.
Refer to:
PR 1171 Contract HSE Management Part II – mandatory for Contracts and Contract Holders, Appendix 4
6.2Management has reviewed the findings and follow up from HSE Audits, incident investigations and implementation of action items. There is a company action tracking system and no action items remain outstanding for more than 6 months after the date of the review.
Refer to:
PR 1171 Contract HSE Management Part II – mandatory for Contracts and Contract Holders, 2.6.9 & 2.6.10
7Sub-Contractors
7.1HSE pre-qualification assessment is applied to all sub-contractors, and as a minimum includes the criteria in PDO’s 10 point HSE checklist. A system for monitoring the HSE performance of subcontractors is in place and being implemented and progress against improvement actions is being tracked at an agreed frequency.
Refer to:
Sub-contractor 10 Point HSE Checklist and Sub-contractor tracking tool (attached).
7.2The Consequence management framework includes provisions for penalising Subcontractor that do not comply with PDOs HSE Specifications.
Refer to:
C9 HSE Specifications, 1.0 HSE Management System and HSE Management Plan and 8.0 HSE Non-Compliance Penalties
8Asset Integrity - Process Safety Managementor movable equipment
8.1Any asset under operational control meets the requirements of Asset Integrity necessary to commence or continue operations. All HSE critical equipments (cranes, trucks, pressure vessels etc) are identified and maintained in accordance to the requirements outlined in the preventative maintenance schedule, and including the manufacturer’s requirements.
Guidance to help ascertain compliance:
Asset Integrity is the ability of the asset to perform its required function effectively and efficiently whilst safeguarding life and the environment. The contractor must be able to demonstrate that for all the assets he uses in relation to the contract, the risk of a consequence category 5 or high risk event, as defined on the PDO RAM matrix, is as low as reasonable practicable.
8.2Ownership of all assets and equipment under operation has been determined and agreed. The roles and responsibilities for inspection and all types of maintenance are clearly known and being implemented.
Guidance to help ascertain compliance:
Assets belonging to PDO given for the use of a contractor need to be identified and listed. Roles as to who is responsible for which type of maintenance must be agreed and included in the respective schedules of maintenance.Similarly ownership of the maintenance of the equipment hired from subcontractors should be clearly defined, agreed and recoreded down.
9Health
9.1Provision of and accessibility to appropriate, well equipped medical clinics and mecical emergency response has been established and is in conformance with PDO requirements.
Refer to:
SP 1230 Medical examinations, treatment and facilities, 4. Clinics
9.2Medical emergency response has been established and meets with the requirements of Minimum Health Management Standards.
Refer to:
SP 1230 Medical examinations, treatment and facilities, 4. Clinics
9.3Medical examinations including Fitness to Work (FTW) are carried out in accordance with PDO medical examination standards, by ministry of health and PDO approved medical staff.
Refer to:
SP 1230 Medical examinations, treatment and facilities,7. Medical Examinations
9.4Catering contractors and sub-contractors are HACCP certified (or PDO recognised equivalent) in each food production operation.
Refer to:
SP 1232Public Health, 2.3.6. Codex HACCP Food Safety Management System
9.5Camp facilities for permanent and mobile camps meet PDO’s minimum requirements.
Refer to:
SP 1232 Public Health, 2.2. Camp facilities.
10Environment
10.1Movement of hazardous waste from site to disposal area has an auditable chain of custody and the waste generator can provide the necessary evidence that the waste was properly disposed.
Refer to:
SP 1009 Specification for Waste Management, 2.2Deliverables
10.2Wastes are segregated at source and kept segregated until collected for disposal.
Refer to:
SP 1009 Specification for Waste Management, 2.6 Performance Standards
10.3Chemical storage is performed in accordance to Company’s requirements.
Refer to:
SP 1194Specification for Chemical Management, 4.0 Storage of Chemicals
10.4Sewage treatment and Reverse Osmosis plants are licensed and operate within their respective license limitations.
Refer to:
SP1006 Specifications for Aqueous Effluents and Accidental Releases to Land and Water Section, 2.5 Performance Standards
11Other Issues
11.1There are no other materially significant HSE issues related to the organisation’s activities that have not been addressed by these HSE assurance statements.
Guidance to help assertain compliance::
‘Materially significant’ means issues that put at risk the meeting of the HSE objectives or targets of the organisation covered by these assurance statements, or which could give rise to risk of reputation damage, and which should be drawn to the attention of the Contract Holder & Contract Owner.
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