Fulcrum (North Sea) Limited. IMS Manual. FUL-MN-001 Rev0

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1 Fulcrum (North Sea) Limited IMS Manual FUL-MN-001 Rev0 26 th January 2015

2 Revision Control Rev. Date Reason for Issue Originated Checked Approved 0 26/01/2015 For Comment MF KC KC Revision Notes: First issue. Revisions are indicated by a vertical mark in the right hand margin. FUL-MN-001 Rev0 Page 2 of 20

3 Table of Contents 1 INTRODUCTION 4 2 SCOPE 6 3 IMS OVERVIEW 6 4 LEGAL AND OTHER REQUIREMENTS 8 5 MANAGEMENT REVIEW 8 6 ROLES & RESPONSIBILITIES Roles Responsibilities Senior Management Team Consultants (duties) Team Members Office Manager (duties) First Aid Appointed Person Fire Arrangements Nominated Person Managing Director Technical Director Office Manager Consultants 12 7 EMERGENCY PREPAREDNESS & RESPONSE 13 8 INCIDENT INVESTIGATION 13 9 QUALITY, HEALTH, SAFETY & ENVIRONMENTAL OBJECTIVES COMMUNICATION PARTICIPATION & CONSULTATION IMS POLICY SUPPORTING PROCESSES - OVERVIEW SUPPORTING PROCESSES - SALES SUPPORTING PROCESSES - OUTSOURCED SUPPORTING DOCUMENTATION PLANNING - RISK ASSESSMENT 19 FUL-MN-001 Rev0 Page 3 of 20

4 1 Introduction Fulcrum (North Sea) Limited was formed in 2014 to provide an efficient high quality consultancy service. Our role is to deliver Functional Safety solutions to ensure compliance and continued safe operation for the North Sea Oil & Gas Industry. Based in Westhill, Aberdeen, the business has developed well and is expanding successfully. The company supports the North Sea Oil & Gas Industry in all aspects of the Functional Safety Lifecycle. The company operates an Integrated Management System (IMS). The IMS consists of a number of documents, each relating to different aspects of the system. The IMS Structure is shown in Figure 1. This IMS Manual, including the QHSE Policy, forms Fulcrum (North Sea) Limited s first level of IMS documentation. The manual should be read in conjunction with Fulcrum s processes, procedures and work instructions. At present, Fulcrum considers its Integrated Management System to be exempt from the following areas of the ISO 9001:2008 standard: 7.3 Design and development Identification & Traceability 7.6 Control of Measuring & Monitoring Equipment At present, Fulcrum s scope of services does not have any components / criteria which would require compliance with the above areas of the standard. All company activities are undertaken paying due cognisance to our neighbours, subcontractors, members of the public and other stakeholders who may be affected by our actions. FUL-MN-001 Rev0 Page 4 of 20

5 Figure 1 IMS Structure FUL-MN-001 Rev0 Page 5 of 20

6 2 Scope The Integrated Management System comprises of the following scope: Provision of Functional Safety solutions to ensure compliance and continued safe operation for the North Sea Oil & Gas Industry. 3 IMS Overview The Fulcrum (North Sea) Ltd Quality, Health, Safety and Environmental Policy Statement is included in Section 11 and is also available as document FUL-PY-001. The Policy and Manual are available electronically to ensure accessibility to all personnel. A signed hard copy is on display. The Integrated Management System applies to all personnel employed by Fulcrum on a permanent or contract / temporary basis. It also applies to all visitors, sub-contractors and suppliers involved in Fulcrum operations and processes both onsite and offsite or within jurisdiction of the premises or sites under the control of Fulcrum. All personnel will be made aware of the Manual, Policy and Integrated Management System on induction. This document will be reviewed as a minimum annually or, more often, at the discretion of the Directors or when there is a significant change that may impact the activities and / or Management System of Fulcrum. The Fulcrum approach to Continual Improvement with regards to QHSE is demonstrated in Figure 2. The IMS applies to all activities of the Company, and has been developed in accordance with ISO 9001, ISO and OHSAS A list of IMS documentation is available in the Document Register FUL-RG-001. Documentation is structured in 2 levels: Level 1 : IMS Documents These detail the corporate quality, health and safety and environmental policies and procedures of the Company. Level 2 : Operating Procedures These documents describe the procedures for activities associated with the delivery of services to clients. FUL-MN-001 Rev0 Page 6 of 20

7 CONTINUAL% IMPROVEMENT MANAGEMENT%REVIEW CONTINUAL IMPROVEMENT 1 NO#INJURY 1 NO#ILL#HEALTH LEGAL%AND%OTHER REQUIREMENTS PLANNING%AND%RISK% MANAGEMENT PERFORMANCE%MONITORING,%AUDIT% &%EVALUATION%OF%COMPLIANCE Progress Reports 1 NO#NEGATIVE# IMPACT#TO# ENVIRONMENT 1 DEMONSTRATE# COMPLIANCE# 1 ENSURE# QUALITY# 1 CUSTOMER# SATISFACTION# Legislation Client Specs INPUT OPERATIONAL%CONTROLS SERVICE OUTPUT Figure 2 QHSE Continual Improvement FUL-MN-001 Rev0 Page 7 of 20

8 4 Legal and Other Requirements Fulcrum shall demonstrate compliance to legislative and other requirements deemed significant to the business and its associated activities. Fulcrum will do this by initial identification of applicable legislation and other factors such as Client requirements and then, through its assurance activities, demonstrate that the methods for compliance are being evaluated. Registers have been created identifying Health & Safety and Environmental Legislation applicable to the company (FUL-RG-003 Legal Register and FUL-RG-005 Aspects & Impacts Register). These will be reviewed as a minimum on a 6 monthly basis or as required by change in legislation or business activities. Evaluation of compliance shall be monitored by way of internal audits (minimum annually), office inspections, feedback through meetings and feedback from personnel. Where it is found that Fulcrum is not compliant with legal or other requirements, an internal NCR shall be raised and the necessary corrective action identified, planned, undertaken and recorded. The Office Manager will monitor the HSE and SEPA websites on a regular basis, to identify legislation updates which may affect Fulcrum s ability to demonstrate compliance or may have significant impact on its business activities. Legislative updates will be discussed at monthly Team Meetings which include all personnel. 5 Management Review Management Review Meetings shall be held as a minimum annually. Additional Management Review Meetings will be arranged as deemed necessary by the Directors. An Agenda and any pertinent information will be issued to relevant personnel at least 3 days prior to the meeting taking place. The Management Team shall attend the Management Review Meeting. Actions resulting from Management Review Meetings will be recorded on the Master Action List. Actions arising from Operations and Team Meetings will be followed up at the next relevant scheduled meeting. FUL-MN-001 Rev0 Page 8 of 20

9 6 Roles & Responsibilities 6.1 Roles All personnel are given the authority to perform their allocated responsibilities. The following provides a summary of the principal responsibilities of each job role, and these are clarified in greater detail within the Service Agreements. All personnel share the role and responsibility of identifying non-compliances or possible improvements, and recording these instances such that corrective action can be taken, both to rectify the immediate situation and to prevent recurrence. The Managing Director continually reviews the company's resources to ensure that adequate personnel, competence and experience are available to meet customer requirements. 6.2 Responsibilities The Directors have overall responsibility for establishing and implementing quality, occupational health, safety and environmental practices and in particular; Ensure that adequate resources are available to implement this policy (human, specialised skills, financial, technological) Ensure performance is regularly reviewed Monitoring the effectiveness of the policy Reviewing the policy annually The Directors advocate & support the development of a culture that is supportive of quality, occupational health, safety and the environment, which is an essential key to achieving a high level of quality and reducing hazards & risks within the workplace Senior Management Team The Senior Management Team is primarily responsible for QHSE within their designated work area and in particular; Establish safe systems of work within their relevant work area Delegation of specific QHSE responsibilities and monitoring effectiveness in carrying out these responsibilities Provide adequately maintained equipment Creation / review of and compliance with risk assessments and ensuring actions requiring attention are closed out Enforcing of quality requirements Reporting and participating in accident / incident reporting and investigation FUL-MN-001 Rev0 Page 9 of 20

10 Ensure that all members of staff, contractors and temporary workers under their control receive information covering all matters affecting QHSE and emergency procedures within their department on their first day of work. Ensure all new members of staff or anyone else under their control receive full training from a competent operator, on any item of equipment Leading by example on matters of QHSE Consultants (duties) Consultants are responsible for the effective management of QHSE within their own area or function. In particular this includes but is not limited to; Ensuring that safe systems of work are implemented Ensuring that staff are adequately trained for the tasks they perform Monitoring premises and work equipment, reporting faults where necessary Identifying and reporting problems and issues Identifying training needs Reporting on accidents and incidents Participating in the risk assessment programme Leading by example on matters of QHSE Team Members Team members have a duty to co-operate with Consultants and Management on QHSE matters in particular this includes but is not limited to; To work in a manner so as not to put their own or other persons health and safety at risk or that has a negative impact on the environment Employees are to take reasonable care of their OH&S and report all QHSE concerns to an appropriate person To use personal protective equipment provided (as relevant) Keep their work area tidy Employees must not interfere with anything provided to safeguard their health and safety or to protect the environment. Employees must report any dangerous situation to a Director or the Office Manager To assist the Company fulfilling its QHSE duties the following roles have been appointed: Office Manager (duties) The Office Manager is the designated management representative and is responsible for maintaining and updating the IMS. The Office Manager acts as the primary source of advice within the company and to assist overall to ensure continued compliance with legal and other requirements. These responsibilities specifically include but are not limited to; FUL-MN-001 Rev0 Page 10 of 20

11 Coordinating the Company s quality standards Coordinating the Company s risk assessment programme as required Administering the accident and incident reporting, recording and investigation process and submitting reports as required by enforcing authorities Coordination of inspection programmes Facilitating training requirements and providing or sourcing required training Sourcing additional specialist assistance when necessary e.g. for liaising with the Health and Safety Executive, Company s insurers and other external bodies and identifying implications of changes in legislation First Aid Appointed Person Although the landlord has overall responsibility for First Aid within the building and has trained First Aiders on site, Fulcrum has nominated First Aid Appointed Persons for their office. These are individuals who have been identified by Fulcrum to assess emergency situations and provide assistance to personnel should they become injured or ill at work. The First Aid Appointed Person will assess the situation and arrange suitable assistance from others to deal appropriately with it. In particular responsibilities include but are not limited to; Ensuring all first aid boxes are well stocked with the correct supplies on a regular basis Assessing emergency situations without putting self in danger and making area safe Send for help without delay Recording or reporting incidents involving injuries or illness which they have attended Liaising with the landlord s representative The First Aid Appointed Person is the Office Manager Fire Arrangements Nominated Person Although the landlord has overall responsibility for Fire Arrangements within the building and has trained Fire Marshalls on site, Fulcrum has nominated responsible personnel to deal with Fire Arrangements for their office. These are individuals who have been identified by Fulcrum to assist in emergency evacuations of the office. The company considers responsible individuals will assess the situation and arrange suitable assistance from others to deal appropriately with it. In particular responsibilities include but are not limited to; Spotting and reporting hazards Taking appropriate action in the event of fire Liaising with the landlord to ensure regular testing of fire alarms FUL-MN-001 Rev0 Page 11 of 20

12 Playing a leading part in fire drills and either recording the outcomes for Fulcrumspecific drills or liaising with the landlord s representative to receive a copy of the outcomes of building drills Ensuring safe evacuation of Fulcrum personnel in the event of a fire The Fire Arrangements Nominated Person is the Office Manager. In addition to the above assignment of responsibilities, the following roles and responsibilities are assigned to the management team Managing Director Refer to Service Agreement document FUL-SA Technical Director Refer to Service Agreement document FUL-SA Office Manager Refer to Service Agreement document FUL-SA Consultants Consultancy Services Project Management FUL-MN-001 Rev0 Page 12 of 20

13 7 Emergency Preparedness & Response Fulcrum has an Emergency Response Procedure FUL-PR-007 established and developed to deal with accident, incidents and emergency situations that may occur. This will work in alignment with the landlord s requirements. This plan will be subject to testing and reviewing on a regular basis. Records of tests and their outcomes shall be recorded. 8 Incident Investigation Fulcrum believes that incident investigation is an important process within any company to prevent recurrence and for raising OHSE awareness. Fulcrum have implemented and maintain suitable processes, FUL-PR-010 Accident / Incident Reporting, Recording and Investigation Procedure and FUL-TEMP-004 Accident & Incident Reporting & Investigation Form, to report, record and investigate accidents and incidents, including near misses, to determine the root cause and any contributory factors. Appropriate preventative measures shall be implemented to prevent a recurrence. Frequent analysis of accidents, incidents and near misses shall be developed to identify any trends and appropriate action taken. This analysis shall be carried out on a regular basis and discussed at various forums including Operations Meetings and Management Review Meetings. 9 Quality, Health, Safety & Environmental Objectives Fulcrum establishes and implements QHSE objectives, FUL-RG-006, that are appropriate in relation to corporate, operational and functional activities within the Company. The process of establishing, implementing and reviewing objectives shall be done through the Management Review process. Targets are reviewed on a monthly basis. 10 Communication Participation & Consultation Fulcrum will utilise a variety of methods for communicating with personnel affected by its work activities and operations. Internally, these include weekly Operations Meetings, monthly Team Meetings and regular Management Review Meetings all of which are documented. All personnel attend Team Meetings and are actively encouraged to participate in discussion. FUL-MN-001 Rev0 Page 13 of 20

14 At the beginning of a Team Meeting, either a member of staff or a sub-contractor gives a 5 minute talk on a QHSE topic they feel is relevant to Fulcrum operations. External communications are considered on a case by case basis and are the responsibility of the Directors. Options for external communications include utilising the website, direct communications with neighbours, stakeholders and other interested parties. Communication with any regulatory authorities will be the responsibility of the Directors and, if necessary, with the assistance of a competent QHSE third party. Fulcrum operations are considered Low risk with regard to environmental aspects. A copy of the QHSE Policy will be available on the website. 11 IMS Policy Fulcrum exists to further and improve application of Functional Safety concepts within the North Sea Oil & Gas Industry. Our primary goal is to provide high quality consultancy services and documentation that brings value to customers and allows the continued safe operation of client assets within the North Sea Oil & Gas Industry. We also wish to demonstrate that the company operates considering the health and safety of all personnel and our impact on the environment. Our objectives are stated in document FUL-RG-006 and these are reviewed as a minimum on an annual basis at the management review. The achievement of these objectives is managed throughout each year, with targets assessed monthly. We are committed to achieving and maintaining high standards of Quality, Health, Safety and Environmental (QHSE) practices internally through robust Management Systems, working processes and workforce engagement. We will consistently provide services that meet or exceed the requirements and expectations of our customers. We will actively pursue ever-improving quality through policies and procedures that enable each consultant to do their job right the first time and every time. This level of quality is achieved through adoption of a system of policies and procedures that reflect the competence of the Company to existing customers, potential customers, and independent auditing authorities. We aspire to continually improve QHSE performance by ensuring that the company identifies, eliminates or mitigates hazards; providing a safe and healthy workplace for all personnel that has no negative impact on the environment. FUL-MN-001 Rev0 Page 14 of 20

15 We will actively pursue continuous improvement in our policies and procedures to provide an increasingly competent and efficient service. We will also support our consultants so that they can develop their experience and qualifications in the field of Functional Safety. We acknowledge the requirement to demonstrate commitment to this policy by ensuring that a proactive QHSE culture is in place and by ensuring quality, protecting all personnel and the environment affected by Fulcrum activities and undertakings. We understand the expectations and requirements outlined in legislation and whilst overall accountability remains with the Directors, responsibility for the implementation of this policy and the management of QHSE on a day to day basis is delegated to personnel within the company. We will ensure that Fulcrum; Has processes and procedures in place that control QHSE and business risks arising from its undertakings and work activities to prevent injury or ill health to personnel and to have no negative impact on the environment Regularly consults with employees on matters affecting QHSE Provides and maintains safe plant and equipment Provides suitable and sufficient information, instruction, training and supervision for personnel to be competent to fulfill their tasks Complies with applicable legal requirements and any other requirements to which it subscribes Recognises the responsibility to manage the environmental impacts of products and services and has assessed its activities and identified significant environmental aspects and impacts Continually improves environmental performance through minimising the use of raw materials and energy wherever possible and thereby minimising impact upon the environment Further information with regards to responsibilities and arrangements for QHSE are detailed in specific procedures and processes (Integrated Management System). Further information with regards to responsibilities and arrangements for QHSE are detailed in specific procedures and processes (Integrated Management System). Signed: On hard copy Print: Stanley Kay Date: On hard copy Position: Technical Director Signed: On hard copy Print: Keith Cameron Date: On hard copy Position: Managing Director FUL-MN-001 Rev0 Page 15 of 20

16 12 Supporting Processes - Overview BUSINESS PLANNING Business Planning & Development Budget Control Management Reporting RESOURCE MANAGEMENT BUSINESS IMPROVEMENT Recruitment Training Information Technology CORE PROCESSES COMMUNICATION Customer Complaints Internal Audit Management Review Internal Problems - Correction & Improvement ADMINISTRATION Document Control Records Management Legal & Regulatory Requirements FUL-MN-001 Rev0 Page 16 of 20

17 13 Supporting Processes - Sales UNSOLICITED/ POTENTIAL ENQUIRIES OUTSTANDING QUOTES PLANNED SALES VISITS COMPLETED WORK CUSTOMER COMPLAINTS CUSTOMER COMMUNICATION LIAISING WITH PROJECTS/OPS SALES FORECASTING PLANNED SALES VISITS OPPORTUNITY TO QUOTE PLANNED/FOLLOW-UP SALES VISITS CUSTOMER FEEDBACK REPEAT/INCREASED WORK SUCCESSFUL/ UNSUCCESSFUL QUOTES FUL-MN-001 Rev0 Page 17 of 20

18 14 Supporting Processes - Outsourced Fulcrum outsources the following: Item Service Vendor Method of Control 1 Third Party Verification DNV 2 QHSE Services QuEnSH Specialists Limited 3 Insurance Caunce O Hara Written Information/Formal Contract Written Information/Formal Contract s/Acceptance of T&Cs 4 Company Accounts Grampian Accounting Ad-Hoc 5 Legal Services Mackinnons Ad-Hoc 6 Office Facilities BlueSky Business Space Limited Contract 15 Supporting Documentation 15.1 Document Preparation FUL-PR Control of Documentation, Data and Records FUL-PR Project Lifecycle FUL-PR Control of Non Conforming Service; Corrective and Preventive Action FUL-PR Training and Competency FUL-PR Audit FUL-PR Purchasing FUL-PR-009 FUL-MN-001 Rev0 Page 18 of 20

19 16 Planning - Risk Assessment As per FUL-PR-011 Risk Management Procedure and FUL-PR-012 Aspects and Impacts Procedure, Fulcrum shall identify and assess the OHS&E hazards and associated risks in connection with its activities, undertakings and any significant change in conditions or process and shall ensure results of these assessments are considered when determining controls. Suitable and sufficient control measures will be implemented to reduce any risk / impact of harm or loss to an acceptable and safe level in the widest term. The company shall document and keep the results of identification of hazards, risk assessments and determined controls up-to-date. The following matrix shall be used for Risk Management. Hazard Severity Likelihood of occurrence Injury Potential Environmental Impact Potential Theoretically possible / No previous occurrences in Fulcrum Harm may occur though unlikely / Records of occurrence within Fulcrum previously Harm may occur / Fulcrum records indicate a frequency of once year Harm is likely / Fulcrum records indicate a frequency of quarterly / 6-monthly Certain / near certain that harm will occur / Fulcrum records indicate a frequency of more than once a quarter No foreseeable injury Slight leak /spill / contamination - minimal effect contained locally Personal injuries / illness involving first aid treatment Minor leak /spill / contamination - no lasting effects Medical treatment beyond first aid recordable Minor leak / spill / contamination - public concern Major Injury (as per RIDDOR definition) Single Fatality Localised leak /spill / contamination / regulatory non-conformance / considerable public concern Multiple fatalities Massive leak / spill / contamination - major public concern. Major clean up required LOW (1) LOW (2) LOW (3) MEDIUM (4) MEDIUM (5) LOW (2) LOW (4) MEDIUM (6) MEDIUM (8) MEDIUM (10) LOW (3) MEDIUM (6) MEDIUM (9) MEDIUM (12) HIGH (15) MEDIUM (4) MEDIUM (8) MEDIUM (12) HIGH (16) HIGH (20) MEDIUM (5) MEDIUM (10) HIGH (15) HIGH (20) HIGH (25) FUL-MN-001 Rev0 Page 19 of 20

20 FUNCTIONAL SAFETY SPECIALISTS FULCRUM NORTH SEA LIMITED +44 (0) Westpoint House Prospect Road, WesthillUK, AB32 6FJ R-001 Rev 0 Page 20 of 20