Practice 000.653.1305

Date 01Feb2010

Page 1 of 13

Inspections/ASSESSMENTS and audits

PURPOSE

This practice defines the inspection, assessment, and audit requirements for projects and offices.

SCOPE

This practice includes the following major sections:

  • Planned Inspections/Assessments

Weekly Inspections/Assessments

Annual Site Self-Assessments

Management Site Tours

  • Planned Corporate Audits
  • Audit Criteria
  • Inspection/Assessment Schedule
  • Regulatory HSE Inspections Performed by Outside Agencies

APPLICATION

This practice applies to work activities and employees under the control of P2S and its contractors.

DEFINITIONS

Annual Site Self-Assessment – The site self-assessment is a comprehensive review of all applicable HSE Management System requirements. The site performs this self-assessment annually.

HSE Audit – HSEaudits are formal methods used by Business Unit and Corporate HSE Representatives to evaluate compliance with HSE practices on a project.

Inspections/Assessments – Inspections and assessments are formal methods conducted by project employees to evaluate compliance with field HSE practices on a project. The project develops the method most appropriate for the site, and performs the inspections/assessments weekly.

Maximum Impact List/Projects – The Maximum Impact List is a method for prioritizing the corporate audit schedule.

TABLE OF CONTENTS

PURPOSE......

SCOPE......

APPLICATION......

DEFINITIONS......

1.0PLANNED INSPECTIONS/ASSESSMENTS......

1.1Weekly Inspections/Assessments......

1.2Annual Site Self-Assessments......

1.3Management Site Tours......

2.0PLANNED CORPORATE AUDITS......

2.1Frequency......

2.2Notification......

2.3Entrance Meeting......

2.4Audit Activity......

2.5Audit Report Preparation......

2.6Closeout Meeting......

3.0AUDIT CRITERIA......

3.1HSE Engineering Discipline Audit Template......

3.2HSE Audit Protocol and Scorecard......

4.0INSPECTION/ASSESSMENT SCHEDULE......

5.0REGULATORY HSE INSPECTIONS PERFORMED BY OUTSIDE AGENCIES......

5.1Commencement of Inspection......

5.2Opening Conference......

5.3Walk-Around Phase of Inspection......

A.General......

B.Conduct......

C.Records......

D.Information Requested by Regulatory Compliance Officers......

E.Test......

F.Photographs......

G.Employee Interview......

5.4Closing Conference......

5.5The Citation......

A.General......

B.Posting of Citation......

5.6After Inspection......

A.Abatement......

B.Report......

6.0REFERENCES......

7.0ATTACHMENTS......

1.0PLANNED INSPECTIONS/ASSESSMENTS

1.1Weekly Inspections/Assessments

  • Each site will develop a weekly inspection/assessment schedule (Form 000.653.F0190, Site HSE Inspection Schedule, or similar). The schedule designates individuals performing the inspection/assessment and the area/process to be assessed.
  • The project team, including the foreman, general foreman, superintendent, Construction Manager, Project/Site Manager, and appropriate field support staff, are expected to participate in weekly inspections/assessments.
  • All supervisors and managers will perform a weekly inspection/assessment.
  • The HSE Representative will maintain the inspection/assessment schedule and track participation.
  • The HSE Representative, along with the Project/Site Manager, tracks the status of corrective actions and develops an action-tracking log.
  • Where practical, a minimum of 2people should participate in the inspection. Craft employees should be included in the inspection walk-through.
  • Inspectors will use a standard format for the inspection/assessment (refer to Forms 000.653.F0150, Hazard Inspection Checklist, and 000.653.F0172, HSE Weekly Self-Assessment Program).
  • Inspectors will sign the completed form and forward it to the Project/Site Manager within 24hours of completing an inspection.
  • Sections of the inspection form, which are not relevant to a particular inspection/assessment or site/area, should be marked as “Not applicable” by the inspector(s).
  • The Project HSE Representative will monitor the progress of completing corrective actions.
  • The project keeps a copy of inspection/assessment schedules and completed reports in the formal project filing system.
  • Results of inspections/assessments are made available to employees via the scheduled Toolbox Meetings together with results of remedial actions taken.

1.2Annual Site Self-Assessments

  • Each project will perform a comprehensive self-assessment on an annual basis. This assessment verifies compliance with the HSE Management System as well as applicable site-specific HSE requirements.
  • The site uses a team approach to perform the annual self-assessment. The team consists of, as a minimum, the HSE Representative, supervisor, and a craft employee.
  • The site uses the checklist in Form 000.653.F0951, HSE Site Self-Assessment, to perform the annual self-assessment.

Note:If a form/format is used other than Form 000.653.F0951, an equivalency approved by the Business Unit Lead – documented on Form 000.653.F0270, HSE Management System Compliance and Equivalency, - is required.

  • Results of the annual self-assessment are communicated to the management team.
  • The assessment is used as an integral part of the continuous improvement process.

1.3Management Site Tours

Management site tours are not intended to be another audit; these tours provide an opportunity for managers to walk the field, introduce themselves to the worker, and to be a visible example of P2S’s commitment to worker health and safety on and off the job.

When employees see and meet a manager walking the field and asking them personally for their opinions on how we can make their employment on a P2S project a safer place to work, it will ultimately leave a lasting impression on them that P2S truly cares about the safety and well-being of their employees. It will also encourage the managers to reinforce their behavior and to demonstrate their commitment and support for HSE-related efforts on the jobsite.

Managers are encouraged to:

  • Engage in dialogue about the project’s challenges and constraints and assist the project in being successful.
  • Give the workers a chance to discuss their unique schedule, cost, and design issues that may be affected, both positive and negative.
  • Discuss possible actions to maintain the positive status or continuously improve on these issues.

Managers will be encourage to visit active projects and to carry out a project tour when possible during normal site visits, documented on Form 000.653.F0327, Manager HSE Site Tour, (document findings, areas of concern, and thoughts for improvement). Tour frequencies may need to be on a case-by-case basis for projects that have a high-risk potential or poor performance.

Managers should distribute their completed 000.653.F0327 form to appropriate leaders. The project should provide periodic progress reports to the manager who conducted the tour.

2.0PLANNED CORPORATE AUDITS

Corporate HSE management will conduct audits, with invited participation from Site HSE Representatives and Project/Site Management.

2.1Frequency

The Business Unit HSE Lead, with agreement from the HSE Board, will compile an annual Maximum Impact List. The corporate audit goal is to audit 100percent of maximum impact projects annually. The total number of corporate audits also considers the size of each Business Unit. The schedule will have an equitable distribution.

Maximum impact criteria includes the following:

  • Projects not meeting corporate goals
  • Projects with significant work hours
  • Projects in high-risk industries
  • High-profile projects
  • Client-/project-requested audits

2.2Notification

The auditor contacts the Project/Site Manager to confirm the audit date, coordinate the entrance meeting, and arrange site access for the audit team. If document reviews are part of the audit, and if those documents can be provided before the audit, this notification will also request copies and/or electronic access to those documents.

2.3Entrance Meeting

The entrance meeting is the first formal activity of the audit and is conducted on day one. The purpose of the meeting is to introduce the auditors and to confirm the purpose, scope, and schedule for the audit.

2.4Audit Activity

Typical audit activities include a review of documentation, the team’s observation of activities in the field, and interviews with project employees. The HSE audit protocol is explained in Form 000.653.F0272, HSE Audit Protocol. Results of HSE audits are documented on Form 000.653.F0273, HSE Audit Scorecard. HSE audit scoring references are described in Form 000.653.F0274, HSE Audit Scoring Reference.

2.5Audit Report Preparation

At the completion of audit activities, the audit team(s) compiles notes to review with Project/Site Management in the closeout meeting. The team will prepare the official report after leaving the site, using Form 000.653.F0952, Sample HSE Audit Assessment Closeout Letter, as the distribution and cover document.

2.6Closeout Meeting

The closeout meeting is the last formal activity of the audit and is typically held on day two. Attendees include relevant project employees, the audit team, and those interviewed, as appropriate. The purpose of the meeting is to allow the audit team to present a synopsis of the audit findings.

3.0AUDIT CRITERIA

Audits can be many and varied. However, the intent of all audits conducted on a project is to determine the project’s adherence to relevant company, site-specific, statutory, and legislative requirements/industry codes of practice and where applicable, the relevant manufacturer’s instructions and operating requirements.

Adherence to requirements outlined in relevant site-specific documentation (such as contracts and work statements) and industry codes of practice will be required as will compliance with the project and contractor HSE Management System.

Deviations from requirements will result in a deduction of points as seen fit by the audit team. All deductions will be discussed with the Project/Site Manager and relevant area supervisors. While the audit team may offer recommendations during the audit, corrective actions will be determined by the project, with concurrence from the audit lead.

3.1HSE Engineering Discipline Audit Template

The HSE Discipline (Engineering) Audit template, Form 000.653.F0950, is designed to be used at appropriate points of engineering phases of a project. Typically, these HSE engineering audits are performed at 30percent and 60percent of engineering phase scope. The exact frequency of a project’s audits should be determined by the Project HSE Representative in consultation with the Project/Site Manager and the Quality Manager, who serves as the lead auditor for HSE engineering audits. Instructions for preparing and conducting the audit are included at the beginning of the audit template. The audit should reflect the actual scope of project engineering as reflected in the contract, unless other disciplines are auditing that scope in their discipline audits.

3.2HSE Audit Protocol and Scorecard

The HSE Audit Protocol, HSE Audit Scorecard, and HSE Audit Scoring Reference are to be used to address HSE items in an office environment at a field site. A Corporate HSE Representative will use the HSE Audit Scorecard when performing corporate audits. The frequency of corporate audits was discussed in Section 2.1 above.

4.0INSPECTION/ASSESSMENT SCHEDULE

A planned inspection (Form 000.653.F0172, HSE Weekly Self-Assessment Program) will be conducted by the Site HSE Representative on a weekly basis.

Designated HSE Representatives will assist in scheduled weekly inspections of all defined areas.

The Project/Site Manager will promptly investigate all areas where low inspections scores have been noted, take the necessary corrective action, and address all safety-related infractions and recommendations.

The Regional HSE Lead will conduct audits as requested by the Business Unit HSE Lead.

5.0REGULATORY HSE INSPECTIONS PERFORMED BY OUTSIDE AGENCIES

Note:Check in-country regulations for possible variations in the protocol described below.

This practice outlines the responsibilities of the Project/Site Management team in effectively managing inspections performed by outside regulatory agencies.

The Project/Site Manager (or designee) and the Project/Site HSE Representative will be the primary participants and the primary points of contact for regulatory inspections. The Project/Site Manager will designate 2alternates (in the absence of the primaries) to participate in the regulatory inspection.

5.1Commencement of Inspection

As soon as an outside regulatory compliance officer (RCO) arrives at the project/site, the Project/Site Manager, the HSE Representative, and the client (where applicable) will be notified.

An employer has the right to know who is entering the premises. The highest-ranking management official available will determine, by validating credentials, whether this person is a bonafide RCO before he/she allows them to enter or inspect the premises. An employer will not abuse this right as a means of delaying the inspection entry. However, the inspector may be asked to wait a few minutes while the highest available management official of the employer (P2S or client) is notified.

In the event that another person or persons accompany the RCO, the employer may also examine their credentials to determine whether they are appropriate regulatory representatives.

In a situation where a person wishing to participate in the inspection is neither an RCO or a representative authorized by the employer, Project/Site Management will carefully question this person to determine his/her affiliation or capacity and why he/she is present for the HSE inspection.

For example, if this person brought by the RCO as an expert consultant is otherwise a disinterested party to the investigation, let him/her participate. However, if the value of the person’s presence is questionable, the Project/Site Management representative should politely ask the outside party to wait until Project/Site Management can be consulted. In any event, an RCO presenting the proper credentials should not be delayed in his/her entry to the premises.

Outside parties generally do not have the right to participate in an inspection without the employer’s consent. The best rule to follow is one of common sense.

RCO(s) are typically authorized by agencies to perform the following:

  • Upon presentation and verification of credentials, enter any work area without delay, at any reasonable time, and without advance notice.
  • Inspect the place and conditions of employment, equipment, machinery, devices, and the processes or methods being used.
  • Check recordkeeping procedures and investigate incidents.
  • Take photographs and collect samples or evidence.
  • Confer privately with employees of their choice concerning conditions or procedures.
  • Review their findings with the designated management representatives.
  • Issue citations resulting from the inspection. Such notice will be submitted in writing following completion of the inspection.
  • Reenter the premises to determine that correction of violations has been made within the time established.

5.2Opening Conference

The Project/Site Manager and authorized project/site representatives must attend the opening conference. The Project/Site Manager (or designee) will be the sole spokesperson during the conference.

The type and scope of the inspection and existence of a warrant, if any, must be determined. If a complaint or warrant exists, the RCO will provide Project/Site Management with copies at the opening conference. In all cases, the appropriate Business Unit HSE Lead must be notified.

5.3Walk-Around Phase of Inspection

A.General

The Project/Site Manager (or designee) will be assigned spokesperson duties during the walk-around inspection, and another site representative will be assigned note-taking duties. The spokesperson will be the sole spokesperson during the walk-around phase of the inspection.

Care must be taken when responding to inquiries by the RCO. Listen carefully to the questions asked, so that your answer is accurate, complete, and directed to the question being asked. Judgmental statements on the spokesperson’s part are to be avoided.

P2S will maintain and make available information regarding all records as required by national, local, and in-country regulations.

Note:At no time will the RCO be allowed to walk around the project/site without a Project/Site Manager (or designee) as escort.

B.Conduct

Courteous treatment of the RCO is expected at all times. The following principles must be followed during the walk-around phase.

  • Do not agree that any alleged violation exists.
  • Do not point out any possible/potential problem areas.
  • Do not indicate that you have been or are aware of any alleged violations.
  • Do not argue with the RCO whether a violation or problem exists.
  • Do not volunteer any information or make any admissions.

C.Records

Agencies place emphasis on the good faith of the employer. P2S will post, and maintain in a conspicuous place, copies of the agency notices dealing with HSE.

D.Information Requested by Regulatory Compliance Officers

Typical questions/subjects investigated by RCOs include the following:

  • HSE Staff

How large is the HSE staff?

Are their duties full or part-time?

What other duties do they perform?

  • HSE Committee

Who is represented on the committee, if one exists?

How often does it meet?

  • HSE Training

Who conducts the training and how is it programmed?

Is it formal or on-the-job training?

  • Medical Programs

What professional healthcare providers are available?

Are they full-time, part-time or consultants?

Are trained first-aid personnel and first-aid equipment available?

Are preemployment and annual physical examinations required?

Is there a sight and hearing conservation program in force?

In hazardous occupations, are there periodic and follow-up physical examinations?

  • Personal Protective Equipment

What protective equipment is provided for foot, eye/face, respiratory, hand/skin, safety harness, hearing loss, and rescue?

  • Incident Investigation

Who conducts investigations?

Who makes the analysis and takes corrective action?

Who makes a follow-up inspection?

Who enforces HSE rules?

Are no-injury accidents investigated?

  • Incentive Rewards

Are incentive awards given for HSE and, if so, how are they awarded?

  • Publicity/Promotion

How is HSE publicized and promoted?

Are rules and requirements available and understood?

Are posters and bulletin boards used?

Are HSE meetings held with employees?

  • Project/Site Management Interest (on a day-to-day basis, not just during inspection)

Does Project/Site Management exhibit a good faith effort?

What is the injury/illness rate?

What are the costs of injuries or sickness?

Notes must be made of records reviewed by the RCO or furnished to the RCO, and any comments made by the RCO relating to the records.

E.Test

Every test made by the RCO during the inspection must be documented with the following information:

  • Purpose of the test
  • Time and date of the test - start/completion time
  • Test equipment used
  • Name and department of employee(s) participating in the test
  • Area in which the test was made
  • Location of testing equipment and distance from closest employee
  • Result of the test, if available, or results as discussed at closing conference

F.Photographs

Every photograph taken by the RCO must be documented, including: