North Africa, Middle East & Southern Asia HEALTH SAFETY & ENVIRONMENT POLICY MANUAL

Transcription

1 North Africa, Middle East & Southern Asia HEALTH SAFETY & ENVIRONMENT POLICY MANUAL

2 G4S North Africa, Middle East & Southern Asia HSE POLICY STATEMENT All operating companies in the region are committed to providing our employees with a safe and healthy working environment where in they are able to deliver the desired quality of service to our customers. We will ensure that through our above efforts of spreading an HSE culture (compliant with local legislation), risks to our employees, our customers and our environment will be continually minimized. Adherence to the HSE policy is not only an essential priority of the top management but also of every employee within each operating company in the region The importance and usefulness of abiding to our HSE working standards will be explained to every staff where feasible after which it will be will be strictly implemented by the top management of each operating company. Necessary resources required to realign processes to these standards will be adequately deployed by the top management in each operating company. The management of each operating company in the region will regularly monitor and periodically measure compliance to the HSE targets. Purpose 2

3 Health and Safety at work can be defined as the requirement to establish and maintain a safe and healthy working environment so as to ensure the optimum physical and mental health of employees in relation to the foreseeable demands of work. Group 4 Securicor requires its operating companies to take due and proper regard of any risks to health, safety or welfare to which their employees or visitors are exposed. All operating companies must ensure that they meet or exceed all applicable legislative arrangements and also meet the common basic standards for health, safety and welfare at work as defined by Group Policy, additional details of which can be accessed through the G4S Group intranet. In all its business operations in the North Africa, Middle East & Southern Asia region, G4S will observe the following principles: At a very minimum meet local legislative health, safety and environment requirements; Conduct business as a responsible corporate citizen; Provide its employees with healthy and safe conditions of work; Give proper regard to health, safety and the environmental issues; and Manage HSE matters as it does any other critical business activity. Responsibility The designated accountable officer for reporting on health and safety matters at the NAMESA Regional level is the NAMESA Regional President, assisted by the NAMESA Regional Human Resources Director. Responsibility is devolved and delegated through the operating companies in the region to the Head of each operating company. Each Group 4 Securicor operating company will appoint a senior executive with responsibility for HSE matters within that company. In addition to their existing responsibilities, it is the responsibility of that senior executive to: Ensure that adequate standards of health and safety are being achieved within their company Advise and inform the company board on health and safety matters on a minimum six monthly basis. Ensure that sufficient resources are available for health and safety in proportion to other business needs. Scope This Pollicy Manual is applicable to all operating companies in the NAMESA region. Minimum Standards In G4S NAMESA, the health and safety of employees and visitors whilst at work is of paramount importance and operating companies in the region will use their best endeavours to make workplaces as safe as possible. It is recommended that the following arrangements will be made in each operating company: 3

4 Accountable Officer As detailed above a senior manager must be appointed to report on health and safety matters within the operating company and is the custodian of the company s HSE Policy. Policy Statement All operating companies in the region must have a policy/statement of intent prepared and displayed. This must also be accessible to all employees upon request. Organisation Where feasible a competent specialist, appropriately qualified and able to develop the local company health and safety policies and procedures, must be appointed. Effective arrangements must be established for communication and consultation with employees on matters of health, safety and environment. Management / employee training must be undertaken to ensure that all personnel are equipped to fulfil their respective health and safety responsibilities as follows: All managers are expected to: 1: Understand the legal requirements relevant to their areas of responsibility. 2: Ensure that their team implements the company health and safety policies and procedures and receive appropriate training. 3: Ensure that appropriate resources are allocated to health and safety matters 4: Consider the health and safety implications of any changes to equipment, working practices or procedures and to continuously seek to improve standards. All employees are expected to: 1: Become familiar with and observe health and safety policies and procedures. 2: Follow instructions and take care of their own health and safety and that of their fellow workers. 3: Report to their line manager all hazards, accidents and near-accidents at work. 4: Not misuse or interfere with any safety equipment or put themselves or others in a situation that could cause injury to themselves or others. 5: Inform any visitor or contractor under their control of emergency procedures and relevant hazards. Implementation and Monitoring Risk assessment processes must be developed and the required control measures as identified in the assessments must be implemented by all operating companies in the region. A process for checking compliance with the policies and procedures must be put in place. Accident and incidents must be investigated to determine the root cause and action must be taken to prevent re-occurrence. 4

5 Accident Reporting Minimum Standards Each operating company in the region must implement a local system of accident reporting which complies with the legislative environment in which it operates. However, any death resulting from, or which may have resulted from, an accident or incident at work is to be immediately notified to the NAMESA Regional HR Director through the Major Incident Reporting Procedure, with an initial brief indication of the circumstances and action taken. Key Elements of HSE Culture Successful implementation of the HSE Policy Manual across the region requires that the senior management be fully committed to HSE and demonstrate a visible leadership role in this regard. A strong HSE culture will be promoted if the employees across the region truly believe that senior managers are committed to sound HSE performance. This belief will be developed and enhanced by visible leadership starting at the senior management level and extending throughout the region. Informed involvement by managers is demonstrated by them personally overseeing the implementation of the principles of the HSE Manual and allocating the necessary resources to meet performance targets. All operating companies in the region are encouraged to promote a strong HSE culture which can be demonstrated by: A workplace where HSE is a core value. A company-wide belief in the desire to improve HSE performance. Everyone being motivated to improve HSE performance. Everyone accepting their individual responsibility and accountability for HSE. Active participation at all levels in applying the HSE Management System. All persons feeling empowered to stop work that is unsafe, unhealthy or could damage the environment. Visibility 5

6 Senior Managers are encouraged to provide strong and visible commitment to sound HSE culture, encouraging those under their direction to do the same. They should do this by providing a positive personal example for others to follow. They can do this by: Putting HSE matters as a priority on the agenda of meetings. Actively participating in reviewing performance against HSE plans and targets. Regularly and consistently communicating their expectations for HSE performance throughout the Company. Leading or personally delegating incident investigations. Recognizing HSE performance improvement. Actively communicating HSE requirements to Contractors. Setting an example by personally complying with mandatory HSE requirements. Undertaking visits to locations of potential high risk. Proactive Target Setting All G4S NAMESA operating company heads are encouraged to set proactive targets to continually improve HSE performance. HSE performance should be measured against result targets (e.g. number of Lost Time Injuries) and activity targets (e.g. the number of HSE visits or audits undertaken against plan). Operating company heads may wish to utilize the following in proactive target setting: Develop and include in the annual HSE Plan results and activity HSE performance indicators and targets. Include result and activity HSE targets in staff appraisals that are aligned with those in the HSE Plan. Informed Involvement Senior Mangers may support informed involvement by: Being fully aware of the high-priority areas for improvement identified in their HSE Plan. Reviewing progress in the implementation of the requirements of the HSE Plan and understanding the shortfalls and remedial needs. Taking an active interest in HSE performance and understanding the status of planned targets. Participating in an annual HSE Management Review. Endorsing HSE Policies, Standards and Procedures and ensuring their use to the business processes over which they are responsible. Key Accountabilities All accountable officers in operating companies across the NAMESA region are expected to: Comply with local legislation. Provide Management leadership & commitment to achieve this Policy. Disseminate the HSE Policy through out the operating company. Protect the health & safety of employees, Contractors & other persons involved or affected by their business. 6

7 Systematically identify, evaluate and manage the risks to people and the environment to a level that is as low as reasonably practicable. Set challenging HSE objectives & targets. Monitor HSE performance as a means of ensuring continuous improvement. Select Contractors on the basis of their performance against this HSE Policy Statement. Ensure all employees work only when it is safe to do so, and empower them to stop any work when it is unsafe. Prevent pollution of the natural environment. Responsibility of Delegated Officers All persons who have been delegated HSE responsibilities by the OPCO Head have a moral, legal and employment duty and responsibility to work in a manner which will avoid risk to their own health and safety - or that of others, and which will minimize damage to the environment. This includes: Understanding the hazards of the workplace and HSE risks within their portfolio of responsibilities. Setting and following procedures and work instructions. Ensuring emergency response procedures are followed. Reporting all incidents, near misses and potential hazards. Stopping work or preventing work starting, where appropriate risk controls or recovery measures are not in place. Ensuring HSE responsibilities are outlined in all Job Description Forms. Ensuring HSE is covered under all employee induction programs. Ensuring all new employees, and employees changing jobs, are made fully aware of the hazards of their workplace, and the risk controls for which they hold responsibility. Responsibility of Employees All employees of operating companies in the NAMESA region must agree, as a term of their contract of employment, to comply with their individual duties in that they will: - Familiarize themselves with and conform to the HSE Policy and relevant procedures at all times. Take reasonable care of their own health and safety; Consider the safety of other persons who may be affected by their acts or omissions; Work in accordance with information and training provided; Refrain from intentionally or recklessly interfering with anything that has been provided for health and safety purposes; Immediately report any hazardous defects in plant and equipment, or shortcomings in existing safety arrangements to a responsible person; Not undertake any task for which authorization and/or training has not been given; Co-operate with their Employer so as to enable the Employer to carry out his health and safety duties towards them. Report all workplace injuries to the OPCO, by telephone to the Control Room. Never put themselves in a situation that could cause injury to themselves or others. 7

8 Inform any visitor / contractor under their control of emergency procedures and relevant hazards. Failure by any employee to comply with any aspect of the OPCO HSE Policy or procedures may result in disciplinary action. Serious breaches of the HSE Policy or procedures may be viewed as gross misconduct and may result in summary dismissal. HSE Committee It is recommended that each operating company in the region has an HSE Committee. This committee must be headed by the OPCO head and meet at least once every quarter and when an emergency arises. The purpose of this committee is to demonstrate HSE leadership, and to provide strategic planning and oversight. It also serves the purpose of providing direction through alignment and sharing of HSE lessons and best practice within the OPCO, its clients and contractors. Minutes of all HSE meetings must be recorded and documented. It is recommended that the HSE Committee take on the following responsibilities: Consider all aspects of HSE related to the business activities of the company. Disseminate learning points from internal and external notifications. Monitor training and compliance requirements (e.g. HSE training courses and audit/inspection reports. Initiate and facilitate incident investigation. Act as an Incident Review Committee. Track and ensure close out of HSE related actions. Ensure adequate provision of resources to ensure compliance with HSE requirements. Review and revise as necessary the HSE Policy annually. Produce the annual HSE Plan. HSE Advisor It is recommended that all operating companies in the NAMESA region co-opt an HSE Advisor to act in an advisory capacity to employees and contractors with regard to HSE matters. The appointment/delegation of an HSE Advisor will not dilute the OPCO Head and other managers obligations to HSE. The HSE Advisor will be trained appropriately to be able to provide professional HSE advice to all employees, line managers and contractors. The HSE Advisor will have direct access to all managers and will report directly to the OPCO Head on HSE matters. The OPCO Head may wish to delegate the following responsibilities to the nominated HSE Advisor: Providing HSE advice to line managers, employees and contractors. Assisting in the implementation of programs to meet the actions of the HSE Plan. Undertaking HSE audits of operations and contractors. Assisting contractors to understand gaps in their HSE plans. Undertaking Incident investigations. Reporting on HSE performance against work plan. 8

9 Staff Competence It is recommended that employees performing HSE-Critical tasks are competent on the basis of their knowledge, skills & attitude to carry out the tasks effectively. The processes for assuring the competence of employees performing HSE-Critical tasks must apply both to initial recruitment and transfers. The competence of persons performing HSE-Critical tasks must be periodically assessed, including consideration of personal and career development. The process for competence assurance shall include the following: Systematic analysis of job tasks. Assessment of individuals performance against defined criteria. Documented evidence of individual competence. Programs for periodic re-assessment. Suitable training. HSE Training Specific knowledge, skills or attitude gaps that are identified for any delegated employee through the application of the performance review process can be met through either formal training or structured learning & development in the workplace. Training may be coordinated by the HSE Committee or along functional lines to close competency deficiencies. Additional support may be requested through the NAMESA Regional HR Department. Use of Contractors and HSE In performing their business operating companies may procure the services of Contractors. The performance of these services may pose significant HSE risks. Operating companies must therefore rely on specific standards and procedures to define the minimum mandatory requirements for executing the contracted services. Minimum levels of performance are set so that Contractors manage HSE risks in a manner consistent with the HSE philosophy and objectives of G4S. Operating companies interface with its Contractors begins during tender evaluation and continues through mobilisation, execution of services, and demobilisation. By placing an emphasis on identifying HSE risks prior to the execution phase, through Contractors, operating companies are directed to manage these risks in a proactive way, rather than simply monitoring the performance of our Contractors following contract award. In the selection of contractors, operating companies will define the Company requirements and approach for managing contractors. This shall include: Specific assessment of the contractor s HSE Policy Statement, past performance and the adequacy of their Management System. Requirements for Contractors to identify hazards associated with the work and to apply controls used to manage HSE risks to the lowest acceptable level. HSE Requirements for the contract (e.g. HSE Standards & Procedures to be applied, & agreed HSE targets & performance criteria). 9

10 Requirement for Contractors to have a contract-specific HSE Plan. A requirement for Contractors to develop an appropriate program to monitor execution of the contract-specific HSE Plan. Sharing of relevant information that may impact on the HSE performance of the contract, or other G4S Contractors undertaking similar activities. Standards, Procedures and Work Instructions All operating companies shall comply with the requirements of its Standards, Procedures and Work Instructions. It is the responsibility of the OPCO Head (or their delegated officer) to develop and implement operational & activity control documents (i.e. Procedures and Work Instructions) that, at a minimum, reflect the expectations & requirements of local law and client specifications. These controlling documents must always be in place for HSE-Critical Tasks. To be effective, Policies, Standards, Procedures and Work Instructions must be simple, unambiguous, understandable and relevant. It is also important that Procedures and Work Instructions include measures aimed at improving HSE performance, in addition to controlling activities. Hazards and Effects Management The activities carried out by OPCOs, and those of any Contractors over which an OPCO has control or has a prevailing influence, have the potential to harm people and the environment, to cause damage to or loss of assets, to cause financial loss, and to adversely impact on reputation. To manage these risks, OPCOs must adopt a Hazard and Effects Management Process (HEMP), as a structured approach to identify the hazards and potential effects of these activities, and controlling the associated risks to a level that is As Low as Reasonably Practicable (ALARP). The core of HEMP involves the basic steps illustrated in the diagram below. It is recommended that OPCOs conduct the HEMP evaluation during a HEMP workshop initially to establish a generic Hazard Register for all activities and subsequently to refine the process for specific major projects and changes of activity. The following process is suggested as a model which OPCOs may wish to customize as per the nature of their business. HAZARDS & EFFECTS MANAGEMENT PROCESS 10

11 Key Terms ALARP Hazard (Aspect) Effect (Impact) Risk Consequence Controls Recovery Measures HSE Critical Tasks Incident As low as reasonably practicable. Risks are said to be reduced to a level of ALARP at a point where the time, effort, difficulty and cost of risk reduction measures have been assessed, with further reduction measures considered to be unreasonable in regard to the additional risk reduction. The potential to harm people or the environment, cause damage to or loss of assets, or adversely impact reputation. An adverse impact on people, the environment, reputation, or damage / loss of assets. Combination of the frequency of occurrence (likelihood) of an undesired event and the severity of the effect (consequence). An event that result from the release of a hazard. A protective measure put in place to prevent the release of a hazard, or to mitigate the consequence of such a release (i.e. recovery measures). Controls on consequences arising from the release of a hazard. Tasks that are undertaken to maintain controls for major hazards. The release, or near release, of a hazard which exceeds defined limits. These are unplanned events which have caused or could have caused injury, illness and/or damage and loss to assets, the environment or 3rd parties. Hazard Identification The first step of a HEMP evaluation is to systematically identify the potential health, safety and environmental hazards and effects of activities. Hazards and effects need to be identified as early as possible and tracked through the life cycle of each activity for normal, abnormal and emergency conditions. Simple identification analysis is performed using the knowledge and experience of the concerned personnel, and references to codes or standards. ACTION RESPONSIBLE For all assessments: Identify the HSE hazards arising during the entire lifecycle of an asset or Line Manager/HSE 11

12 activity. Consider: Planning, mobilisation & set-up Routine conditions Abnormal conditions (e.g. weather extremes) Emergency situations For Safety Assessments: Consider: Land Transport (e.g. Driving) Working at heights Offices, Workshops and industrial facilities Slips, trips and falls Machinery with moving parts Working in extreme temperatures Electricity and electrical equipment For Environmental Assessments: Consider: Waste management Use of energy, materials and resources Environmental noise and vibration For Health Assessments: Consider: Noise and Vibration Dust, Asbestos other respiratory hazards in the field Chemicals Ergonomic factors Mental stress Advisor Line Manager/HSE Advisor Line Manager/HSE Advisor Line Manager/HSE Advisor Risk Assessment After all of the hazards associated with the activities have been identified, the next step in HEMP is to perform an assessment of the risk that is associated with each hazard, and to rank these risks as High, Medium and Low. The diagram below may be used as a template in this process. 12

13 Developing and Maintaining Controls Develop Controls Following assessment of risks, HEMP requires that controls be applied so as to reduce risks to ALARP. Controls must focus on risk elimination and reduction before recovery measures. ACTION Develop and implement control measures to reduce risks to a level deemed ALARP. In developing all control measures, consider: RESPONSIBLE Line Manager/HSE Advisor The Risk Assessment Matrix Preventative measures (which reduce likelihood) Mitigation measures (which reduce the effects) All stages of the activity. Controls should include preventative and mitigation measures involving active, passive and/or operational systems. Examples 13

14 of operational systems to be considered include: Competence assurance schemes & training Safety hardware (guards, speed limiter, set belts) 3 rd party inspection & certification program Monitoring programs Procedures & work instructions Management plans Emergency response plans Audit and inspection programs. Performance Criteria for Maintaining Controls Performance indicators must be set and measured against all HSE Critical Tasks for medium and high potential HSE risks. Data on performance of controls should be collected for HSE Critical Tasks such as: Competence assurance of persons in HSE Critical Positions Inspection and certification of equipment Routine maintenance of equipment Operation of a Journey Management system Maintaining HSE and Operational Specifications & Procedures Auditing & work-site inspections Evaluation of ALARP Risk ALARP? Once controls are developed, it is necessary to determine if each HSE risk is managed to ALARP. This cannot necessarily be expressed in absolute or quantitative terms. Therefore, the following statements provide a guide to determine whether a particular risk is being managed to ALARP: It is recommended that Line Mangers decides whether ALARP is achieved, on a case by case basis. For each particular risk, ALARP can only be demonstrated by comparing a number of risk control options. Demonstrating ALARP relies on the following practical steps: Identifying control options & assessing the cost and effort of implementing each. Identifying any applicable standards for controlling the particular risk. Assessing the level of risk that remains after each control is implemented. To reduce a risk to ALARP involves balancing the reduction in risk achieved by use of specific controls against the effort and cost of achieving this risk reduction. ALARP represents the point at 14

15 which the effort and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction achieved. A key concept in identifying the ALARP point is to ensure that all possible options for risk reduction have been identified. It is often the case that only the obvious or easy options are considered. It is important however to look at all options even if at first they appear difficult or costly. The figure below provides an example of an ALARP evaluation of 6 different options for reducing an HSE risk. Risk $$ & Effort Acceptable level of risk Control Options 6 Level of risk remaining after control option is applied Cost & effort of implementing each control option As a guide to deciding whether a risk has been managed to ALARP, the following statements can be made about the above example: Options 1 and 2 are not acceptable as they exceed the acceptable risk level. For only small increased cost & effort, the risk of Option 3 could be further significantly reduced to Option 4 so it is therefore not the ALARP option. Options 5 and 6 may not be ALARP as reduction in risk may not be justified by the further large costs & effort required for only minor reduction risk. In view of the above assessments, Option 4 can be considered the ALARP option. 15

16 Risk Reduction Measure Recovery Once the controls required to reduce the risk to ALARP have been identified, an additional examination of the hazard control measures should be made to identify the means by which recovery in the event of the release of a hazard (i.e. an incident occurs) if all of the controls fail. Control and recovery can include the same physical or procedural elements, but recovery measures are applied after things go wrong. Recovery measures are aimed at mitigating the consequences of the hazard being released and aid in reinstatement of the activity. Examples of typical recovery preparedness measures include: Physical equipment (e.g. roll-bars, seat belts, airbags) Action plans for emergency response (e.g. call-out duty roster) Curative measures (e.g. medical facilities, first aid training) Compensative measures (e.g. financial payments) Effective recovery requires: That all staff and Contractors are fully trained as to the recovery measures. Regular testing and review. In addition, recovery procedures should be regularly updated in light of root causes and lessons learned from incidents, and following analysis of drills and testing. Recording of Hazards and Effects All hazards and effects from activities undertaken by any OPCO in the region or under its control or influence must be compiled in the HSE Hazards & Effects Register. Contractors shall compile similar registers for the activities which they undertake or manage on behalf of G4S operating companies. Hazards & Effects Register It is mandatory that every OPCO in the region maintains a Hazards & Effects Register for all activities within its scope of work that pose medium or high HSE risks. The Register must align preventative controls & recovery measures against these risks to achieve the ALARP option. The 16

17 local HSE Management Committee should decide which of the activities are required to be included in the Register. The Register may include: A description of the activity & related hazards. Probable threats that could release the hazard (cause and incident). Possible consequences if control of the hazard is lost (an incident occurs). Assessment of the HSE risk before and after application of control & recovery measures. Tasks undertaken to provide or maintain controls or recovery measures (i.e. HSE-Critical Tasks). Positions responsible for HSE-Critical Tasks (i.e. HSE-Critical Positions). Indicators to be measured to assure that controls and recovery measures are in place and working effectively. Any change to equipment or activities that significantly changes the associated HSE risks and/or the management of HSE risks must include a revision to the Register. The Register must be reviewed at least every three years. HSE Plan It is mandatory for all operating companies in the NAMESA region to have a planning process that begins in Q4 with the review of the year s performance by the local HSE Management Committee. This review must cover performance with respect to the previous year s HSE targets. Results of the review exercise feed into the rest of the business planning cycle. Information used to develop the HSE Plan may include: Findings from audits and incident investigations. Information on organisational changes. Input from clients and contractors. Legal and other requirements relating to local operations. High and medium level HSE risks contained within the operating company s activities. Technological, financial and operational factors. The HSE Plan must be made available in draft form to all employees as well as contractors and clients on request. The HSE Plan must be revised following feedback from employees clients and contractors and issued as a final document. Requirements set by the operating company must be cascaded down through the organisation and into individual tasks and targets for employees and managed through the staff appraisal process. This will ensure that all employees are fully aware of, and aligned with the company s overall HSE objectives. HSE targets must be: Quantified and measurable wherever practicable. Realistic yet challenging. Have defined time scales. Clear and unambiguous. Communicated to all employees and contractors. Reviewed regularly to ensure their continuing relevance and suitability. A mechanism for delivering continuous improvement in HSE performance. 17

18 Facility and Equipment Integrity Facility & equipment integrity and management of HSE risk are inextricably linked. Operation, maintenance, and inspection of facilities and equipment, and the management of modifications to those facilities & equipment, can have a significant impact on the hazards experienced during their use. Ensuring facility & equipment integrity is a major control mechanism to manage many HSE risks. ACTION Develop and implement a formal process to maintain the integrity of facilities & equipment throughout their operation (maintenance, inspection). For example: RESPONSIBLE All Managers Equipment and asset registers. Inspection & maintenance procedures. Routine inspection & maintenance schedules. 3 rd Party Certification schedules. Crisis and Emergency Response Although every effort is made to ensure that incidents do not occur, the potential for incidents and emergency situations still exists. A system and resources must be in place to respond swiftly and effectively to any emergency situation. All operating companies are advised to have in place an Emergency Response Procedure to help deal with emergencies, which also provides a link to external emergency systems & services. ACTION Develop and maintain an Emergency Response Procedure (e.g. competent personnel, physical resources) in line potential crisis and emergency scenarios. Conduct drills and exercises to test the emergency response arrangements. RESPONSIBLE OPCO Head HSE Management Committee All Managers Implementation and Monitoring Continual examination by local management of the performance of the HSE Management System as well as actual performance against targets is necessary to gauge whether progress is being made towards the objectives and vision of the OPCO. Effective implementation involves: Setting performance targets and performance indicators. Monitoring to measure performance against targets. Keeping performance monitoring records. Addressing non-compliance & ensuring that corrective action is taken. Reacting to incidents to make sure that they are reported & investigated. 18

19 Key Terms Pro-active Monitoring Reactive Monitoring Non-compliance Incident Near Miss Corrective Action Forward looking monitoring that provides information in the absence of any incident, ill-health or damage to the receiving environment. Evidence of deficient performance that provides information on incidents that have occurred and provides insights into the means of preventing similar incidents in the future. Planned or unplanned deviation from the requirements of the HSE Management System. An unforeseen occurrence that has actual or potential adverse impact on people, facilities or equipment, reputation or the environment. An incident that has resulted in no actual harm to people, the environment, facilities or equipment, or reputation. Any activity undertaken to address an incident or noncompliance, and if possible, prevent its occurrence. Performance Monitoring Effective implementation of the HSE Management System requires both reactive and pro-active monitoring. The indicators used include quantifiable, results-based indicators and activity-based indicators. Examples include: PRO-ACTIVE INDICATORS Persons assessed as competent. Audits & inspections undertaken. Routine maintenance undertaken. HSE audit findings closed out. Certifications maintained. Near Miss Reporting levels. REACTIVE INDICATORS Fatalities. Lost Time Incidents. Occupational Illnesses. Road Traffic Accidents. Wastes disposed to landfill Spillage quantities. Planning of HSE monitoring programs must: Identify the information to be obtained. Define the required accuracy of the results. Specify the monitoring methods and identify monitoring locations. Specify the frequency of measurement. Define roles and responsibilities. The monitoring program includes regular examination of progress towards achieving the targets set in the HSE Plan. Performance against indicators is tracked and regularly reported. 19

20 ACTION Establish and maintain programmes for monitoring: RESPONSIBLE HSE Management Committee Performance against HSE targets. Performance of HSE-Critical Tasks. Implementation of the HSE Plan. Impacts on Health and Safety. Impacts on the natural environment. Records Records must be kept to demonstrate effective implementation of the HSE Management System. It is recommended that all records are retained for a minimum period of 5 years. Records must be kept in good condition and in such a way that they are readily accessible on request to verify trend analysis or statistical summary data. Records must be legible. Non-Compliance and Corrective Action Non-compliance may be sudden and temporary, or it may persist for long periods. It may result from deficiencies or failures in the local HSE Management System itself, failures in vehicles or equipment, or from human error. Non-compliance must be reported directly by those in control of activities, or found through inspections and audits of activities. Investigations should fully establish the root causes, including failures in the HSE Management System. Investigations enable the planning of corrective action including measures for: Restoring compliance as quickly as possible. Preventing any recurrence. Evaluating and mitigating any resultant adverse HSE effects. Assessing the effectiveness of the above measures. Incident Reporting and Investigation Incidents and/or near misses must be given particular attention in all HSE Management Systems across the region. OPCOs must address all types of incidents in a similar fashion, but may group incidents into one of the following categories: Personal injury. Fatality. Environmental damage/impacts. Asset damage. Reputation damage. HSE Audits HSE Audits provide operating companies with a systematic and structured means to assess the adequacy and effectiveness of the controls described in the HSE Management System, and their degree of implementation. A hierarchical system of HSE audits shown in the following diagram is 20

21 recommended and operating companies may wish to utilize this template in designing their own audit system. Audit Objective Tier III HSE-MS Test the effectiveness and implementation of the HSE-MS Tier II Activities & Processes Assess how HSE risks are being identified & managed. Tier I Task Verification & Application Assess actions on the ground & Verify procedures being applied. Tier I Audits are designed to verify that work instructions & procedures designed to eliminate and control HSE risks are being communicated and followed in the workplace. These audits are carried out at a specific location or in relation to a specific activity. Examples include proper use of daily checks of vehicles, load securing, and speed checks. Tier II Audits are designed to verify that processes are adequate to identify and manage the HSE risks associated with an activity or area of work. Examples include Standards & Procedures are documented for high-risk activities such as driving and load safety, and the Journey Management Procedure is being routinely followed. Tier III Audits address the scope and effectiveness of the HSE Management System in meeting the requirements of the HSE Policy. These audits are not specific to activities or any one area of work. Key Terms Audit Inspection A structured, independent means of demonstrating that the framework of business controls is appropriate and effective. A scheduled, structured examination of a work site with a specific focus on physical conditions and working practices, in addition to normal supervisory duties. 21

22 Audit Frequency All business processes and activities should be periodically audited, with the frequency and depth of HSE auditing determined by: The level of HSE risk of the process or activity. How critical the process or activity is in relation to business objectives. The contribution, or potential contribution, of the process or activity concerned to overall HSE performance. Past HSE effects related to the activity and the results of previous audits. All business processes and activities should be audited within a 5 year audit cycle. ACTION Agree the scope of activities & processes relevant to the audit. Within this scope, assess the level of HSE risks. Risk may be associated either with the importance of a process as a business control in the management of risk (e.g. emergency response) or as the inherently high level of risk within a facility or activity. Select auditors & audit timing based on the level of HSE risk. Incorporate HSE audit program into the Corporate HSE Plan. Prepare and resource the HSE audit program based on the audit frequencies and selection decided above. RESPONSIBLE HSE Committee and OPCO Head OPCO Head Decide external support level (e.g. staff, expert advisors or consultants, Contractor representatives). Approve HSE Audit Plan. Appoint Audit Team Leaders. Monitor & Change HSE Audit Plan (if required). Ensure HSE Audit Plan meets the requirements of the client (where appropriate). HSE Committee Divisional Head Auditor Competency Personnel carrying out HSE audits must to qualified to carry out the audits impartially and effectively. Audit team members should be selected so that their skills and knowledge are appropriate to the audit type and scope. The audit team should have: A broad knowledge of HSE matters. Adequate independence from the activities being audited. Working experience in the area being audited. The necessary expertise and experience in auditing practices and disciplines. The support from senior managers to procure the necessary information. 22

23 Management HSE Review It is recommended that operating companies revisits the HSE Management System in a formal manner whereby the Senior Management reviews its continuing effectiveness and suitability in: Managing HSE risks. Reinforcing efforts to continually improve HSE performance. The purpose of the review is to identify the possible need for changes to the OPCO s policies, strategic objectives, HSE Plans and control documents in the light of changing circumstances and the commitment to strive for continual improvement. The review process is documented, with the results recorded to assist in implementing any recommended changes that become apparent. The review process is the final step in the HSE Management System, with the results feeding directly back into the cycle of setting strategic HSE objectives. Issues to be addressed as part of the review process include: Any recommendations which have been made in audit reports. Any recommendations made in investigating incidents. Extent of follow-up on audit and incident action items. The continuing scope & suitability of the HSE Policy Statement. The continuing suitability of HSE strategic objectives and consequent amendments to the Corporate HSE Plan and HSE documents. Performance against targets. Resources allocated to achieve strategic objectives performance targets. ACTION Appoint members to the review team. Agree on the terms of reference for the review. Draft the terms of reference for the review. Propose members of the review team. Collate relevant data and circulate the information to the review team. Information for the review should include: HSE performance against targets for the last 12 months. A status report on audits from the period of the review, any overdue items carried into the review period, and details of any high-risk findings. Progress in meeting the Corporate HSE Plan and Contract specific HSE Plans, highlighting any potential difficulties. Summaries of investigations completed in the review period, with details of any trends identified. Legal and other requirements that may have changed. Outstanding non-compliances. Status with respect to the Corporate and contract-specific HSE Plans objectives and targets. Suitability of the HSE Policy Statement based on changes during RESPONSIBLE OPCO Head HSE Committee 23

24 the year in stakeholder interests. Assess the overall effectiveness of the HSE Management System based on the terms of reference. Review Team Identify and recognise examples of any exemplary HSE performance, as well as shortfalls in performance. Assess the underlying reasons for any shortfalls identified and make recommendations on remedies. Endorse the findings and recommendations. Enter actions into the Action Tracking Database. Draft the annual HSE report. Review the annual HSE report. Endorse & sign the annual HSE report. HSE Committee OPCO Head Delegate OPCO Head Delegate HSE Committee OPCO Head Insurance It is the responsibility of all OPCO Heads in the region to take out suitable insurance to cover against liability for death, injury and/or disease suffered by any of its employees in the course of employment provided that it was caused by the negligence and/or breach of statutory duty on the part of the operating company. *** 24