20100324 3rd Edition Corporate SHE Management System Manual

PETROPLUS

CORPORATE SAFETY, HEALTH AND ENVIRONMENTAL (SHE)

MANAGEMENT SYSTEM MANUAL

THIRD EDITION

Copyright is a property right which all authors have in relation to the works which they create. It is a right to stop others

copying or exploiting in various ways authors' works without permission. Copyright in this publication is vested in

Petroplus Marketing A.G. Permission for anyone, including other subsidiaries within the Petroplus Group, to copy or

reproduce any part of it should first be obtained from the PETROPLUS Group.

Safety, Health and Environmental (SHE) Management System Manual

List of hard copies to be issued (registered)

Copy No. Location Role Current Holder

1 Zug Chief Operating Officer C Kuchta

2 Zug Refining General Manager P Senkbeil

3 Teesside Corporate SHE Manager C Platt

4 Teesside Corporate Safety Specialist D Pinder

5 Coryton Corporate Safety Specialist R Graham

6 BRC Corporate Environment Specialist S Cobben

7 BRC Corporate SHE Specialist L Van Berendonck

8 BRC Refinery Manager M Mazenauer

9 BRC Refinery Manager M Mazenauer

10 Coryton Refinery Manager J Barden

11 Coryton Refinery Manager J Barden

12 Cressier Refinery Manager G Vollin

13 Cressier Refinery Manager G Vollin

14 Ingolstadt Refinery Manager G Fischer

15 Ingolstadt Refinery Manager G Fischer

16 Petit Couronne Refinery Manager P Billant

17 Petit Couronne Refinery Manager P Billant

18 Reichstett Refinery Manager C Philipponeau

19 Reichstett Refinery Manager C Philipponeau

20 Teesside Terminal Manager P Grange

21 Teesside Terminal Manager P Grange

22 Zug Technical Manager L Pelsez

23 Zug Projects and Capital Program R Arthur

CONTENTS

PART 1: CORPORATE SHE MANAGEMENT SYSTEM

SECTION SUBJECT

1 INTRODUCTION2 SHE MANAGEMENT FRAMEWORK3 SHE PERFORMANCE OBJECTIVES4 MONITORING CONFORMANCE WITH CORPORATE SHE

MANAGEMENT SYSTEM STANDARDS

PART 2: STANDARDS

SECTION SUBJECT

1. RDSHE1: LEADERSHIP AND COMMITMENT2. RDSHE2: SHE PLANS, MANAGEMENT, RESOURCES AND LEGAL

COMPLIANCE3. RDSHE3: COMMUNICATION AND CONSULTATION4. RDSHE4: SHE TRAINING, AWARENESS AND COMPETENCY5. RDSHE5: OCCUPATIONAL HEALTH AND WELLBEING6. RDSHE6: SUBSTANCE HAZARDS7. RDSHE7: NEW PLANT, BUILDINGS, EQUIPMENT AND PROCESS DESIGN8. RDSHE8: MANAGEMENT OF CHANGE 9. RDSHE9: ASSURANCE10. RDSHE10: SYSTEMS OF WORK11. RDSHE11: PLANT OPERATION12. RDSHE12: MANAGEMENT OF CONTRACTORS AND SUPPLIERS13. RDSHE13: ENVIRONMENTAL IMPACT 14. RDSHE14: EMERGENCY PREPARDNESS15. RDSHE15: SHE RISK MANAGEMENT16. RDSHE16: INCIDENT INVESTIGATION AND FOLLOW UP17. RDSHE17: SHE PERFORMANCE REPORTING18. RDSHE18: MONITORING OF SHE PERFORMANCE

PART 3: GLOSSARY OF TERMS

FOREWORD TO THIRD EDITION

It is the organization’s view that effective SHE performance is the foundation upon which all other business priorities are based. An emphasis shall always be placed on the SHE issues associated with any activity which is to be undertaken. It shall be clear that operating costs, production requirements, product quality and other priorities shall not be allowed to compromise SHE performance.

The Third Edition of the manual supersedes the Second Edition.

This Third Edition has been issued following consultation and discussions across the organization. During the review process, the objective has been to ensure that this manual continues to build upon existing good practices and learning from previous experiences.

A number of key changes are highlighted below:

Updating has been undertaken to reflect the latest organisational changes (November 2009) together with the related modified reporting requirements.

In terms of SHE management system structures, the Corporate SHE Committee and the SHE Management Framework appear for the first time. The Letter of Assurance process has now been discontinued and has been removed from this manual.

The Petroplus triangle which shows how Operational excellence can only be based on the establishment of a firm foundation of SHE excellence is included in the Introduction.

In order to improve leadership and governance of SHE processes, there is now a requirement for each site to appoint a member of their management team to be responsible for each standard within this manual.

There has been an increase in the focus on process safety which has been reflected in a number of modified standards.

A new standard on “SHE risk management” has been created to ensure that systems are in place to identify, assess and appropriately mitigate SHE risks.

There is a more detailed standard highlighting expectations with regards to monitoring SHE Performance across the organization which includes auditing processes.

A more detailed standard setting the expectations of investigation and follow-up of SHE incidents has been developed to ensure that root causes are more effectively identified and evaluated so as to prevent recurrent incidents.

A Glossary of SHE terms has been included for the first time.

THE PETROPLUS COMMITMENT TO SAFETY, HEALTH AND THE ENVIRONMENT

We recognise that an excellent SHE performance cannot be achieved without the involvement and contribution of every individual within the business. Only through each employee assuming responsibility to prevent, as far as reasonably practicable, harm to themselves, others and the environment will we be able to deliver the level of SHE performance which we desire.

At Petroplus we emphasize the integration of sustainable Safety, Health and Environment (SHE) working conditions into our daily operating practices. We do this within all levels of the company. These sustainable SHE working conditions lead to control and reduction of SHE risks for our employees, contractors, the community and our business and assets.

The Prevention of Injuries, Incidents, and Occupational Illnesses

We believe that all injuries, incidents, and occupational illnesses are preventable and that incident reporting and investigation are of fundamental importance in their prevention. Our working procedures and practices are focused on the prevention of any kind of incident and consequently, on the improvement of working conditions at every location.

The Prevention of Harm to the Environment

We believe that by operating our business in the most efficient way we can reduce the impact on the environment and the neighbors that surround our operating entities. Our aim is to work in harmony with our surroundings and to provide economic benefit to the local communities.

SHE Policy Compliance with Relevant Company Policies and the Law

We have set clear expectations within our Corporate SHE Management System Manual. All Petroplus companies are required to adhere to the corporate expectations and to comply with laws and regulations applicable in each working location.

Continuous Improvement and Commitment

SHE improvements form an integral part of the development of our business opportunities. To fulfil our SHE obligations and to meet the high standards set by the Company’s Executive Committee required in all areas of safety, health and environment there is a need for continuous improvement and commitment by everybody.

Auditing, Monitoring and Corrective Action

Petroplus are committed to setting objectives and targets, auditing, monitoring, sampling, conducting reviews and implementing corrective actions to ensure full compliance with the principles of the Corporate SHE Management System.

Personal Responsibility

Everyone who works with us and for us has a personal responsibility to prevent harm to themselves, others and the environment. We are individually and collectively committed to these principles and expect all who work in our business to behave in accordance with them.

Jean-Paul Vettier Chris Platt Chief Executive Officer Corporate SHE Manager

January 2010

PART 1: CORPORATE SHE MANAGEMENT SYSTEM

SECTION SUBJECT

1 INTRODUCTION2 SHE MANAGEMENT FRAMEWORK3 SHE PERFORMANCE OBJECTIVES4 MONITORING CONFORMANCE WITH CORPORATE SHE

MANAGEMENT SYSTEM STANDARDS

1.0 INTRODUCTION

1.1 PETROPLUS VISION

The Petroplus vision is that we should manage all of our operational activities in such a way that the SHE impact is “Zero Harm” Specifically, this means protecting the safety and health of those who work with us and for us and respecting the needs of the environment in which we operate.

This means that SHE performance forms the foundation of the continuity of our business.

To help Petroplus meet our commitments to SHE, we have developed: the Petroplus SHE Triangle which demonstrates our SHE principles, the SHE Management Framework, and the Corporate SHE Management System Manual.

1.2 SHE PRINCIPLES

We believe that our operations should have fundamentally safe well-designed plant, equipment and infrastructure, with robust risk-based SHE management systems operated by risk aware individuals.

OPERATIONAL EXCELLENCE

SAFETY

ENVIRONMENTAL COMPLIANCE

RELIABILITY

PROFITABILITY

1.3 APPLICATION

The Corporate SHE Management System Manual applies to all personnel and assets within Petroplus. It sets the Group’s SHE expectations which all Petroplus entities must comply with.

The Manual specifies a number of mandatory requirements to be incorporated in the SHE management systems of the Petroplus entities. These requirements are in addition to any local or national legal requirements and shall be delivered through local SHE procedures as necessary.

The principles of the Corporate SHE Management System Manual shall be used in any merger or acquisition process to assist in identification of potential SHE risks and liabilities associated with facilities and businesses prior to them becoming part of the Petroplus Group.

1.4 SCOPE

The Corporate SHE Management System Manual contains standards that cover the marketing and distribution through to refining and the entire lifecycle of operations from planning, operation, decommissioning and remediation.

1.5 MANAGEMENT REVIEW

Authorization

The Corporate SHE Management System Manual has been prepared by the Corporate SHE Department on behalf of Petroplus and has been authorized by the Chief Executive Officer and the Executive Committee.

Review and Revision of the Manual

The Corporate SHE Department is responsible for arranging the review and updating of this manual on a periodic basis to ensure that the document remains current and valid. This will be carried out in consultation with Petroplus stakeholders such as SHE professionals and line managers.

Document Control

This Corporate SHE Management System Manual is held on the SHE Portal of Sharepoint. Any copy printed from the system will be classified as an uncontrolled copy.

Enquiries and Correspondence

All enquiries and correspondence concerning interpretation of this manual should be addressed to the Corporate SHE Department.

2.0 THE SHE MANAGEMENT FRAMEWORK

The SHE Management Framework defines roles and responsibilities of the corporate and functional organizations to help Petroplus drive towards “Zero Harm”. The corporate organization defines and communicates requirements in relation to vision, principles and SHE Policy and standards for managing the safety, health and environmental risks associated with our business activities. The Petroplus entities implement and incorporate the corporate requirements into their business activities.

Corporate function will define and communicate SHE requirements, including Corporate SHE Policy and Corporate SHE Management System containing clear non-negotiable SHE standards.

This will require sufficient resourcing, communication and setting of corporate key performance indicators.

Petroplus Entities

Entities will implement the requirements of the Corporate SHE Management System.

This will require sufficient resourcing, communication and setting of business specific key performance indicators and operational safety plans.

Operating Locations

Procedures

Training

Behaviour of People

LEADERSHIPPetroplus SHE

vision and principles

Corporate SHE Policy,

Corporate SHE Management

system

LEADERSHIPPetroplus SHE

vision and principles

Corporate SHE Management system and local SHE

Management Systems

MONITORING

Corporate SHE Review program

Local Audit Management System

Third Party

MONITORING

Corporate SHE CommitteeCorporate SHE Review program

Third Party

Petroplus BoardExecutive Committee

Corporate SHE

2.2 LEADERSHIP

Senior managers and supervisors must lead by example and demonstrate behaviours that will drive continual improvement in SHE performance. Managers and supervisors must set high standards for SHE, actively engage with the workforce, and identify and correct unsafe behaviors or situations.

All unsafe practices and incidents will be investigated to understand what happened and why. All necessary steps will be taken to prevent a recurrence and learning shall be communicated to ensure that all Petroplus entities benefit from the outcomes of these investigations.

Managers and supervisors at all levels in the organization have a responsibility to abide by the principles as defined by the standards. They must be embraced and embedded into the organization and, as leaders, managers and supervisors must pursue the development of a safety culture which reflects our vision and principles.

We believe that everybody should understand their SHE responsibilities and clear accountabilities should be established.

2.3 SHE POLICY

The Petroplus Corporate SHE Policy defines the organization’s SHE strategy and corporate governance structure for managing SHE risks within the company.

2.4 SHE STANDARDS

A set of common mandatory standards have been developed that are incorporated into the Corporate SHE Management System Manual. Functional line managers at all levels have the responsibility of implementing and maintaining the standards.

The standards form the basis for the development, improvement and application of comprehensive, integrated SHE Management systems throughout all operations. The standards have been developed from pre-existing Petroplus standards and industry recognised good practice.

These standards principally identify duties to have systems to ensure safe and environmentally responsible management of activities, in certain specific areas of SHE risk. There must be both: i) systems in place and ii) effective compliance with those systems, in order to satisfy this requirement.

In a number of areas of SHE risk, these requirements are specified in detail as a result of:

a) A need for uniform practices across Petroplus.

b) A need to emphasise certain issues which might give rise to a long term corporate business risk.

c) An understanding that in certain areas, compliance with government regulations may not be sufficient to deliver the level of performance and liability limitation which the Company requires.

The SHE Standards are to be found in Part 2 of this manual.

2.5 LOCAL SHE MANAGEMENT SYSTEMS

The SHE standards are implemented via local SHE Management systems which define the arrangements in place for managing SHE risks. The SHE Management systems need to incorporate local legal requirements and also take into account good management practice.

3.0 SHE PERFORMANCE OBJECTIVES

Petroplus believes that by setting objectives it will drive continuous improvement in SHE performance across the organization. Specific Key Performance Indicators (KPIs) have been set for process safety, personal safety and the environment and targets have been established which are regularly monitored.

The KPIs set are both leading and lagging indicators to ensure that proactive as well as reactive monitoring of the organization’s performance is carried out.

The KPIs set by the Corporate SHE Department will be reviewed on a periodic basis to ensure that they remain current and valid.

4.0 MONITORING CONFORMANCE WITH CORPORATE SHE MANAGEMENT SYSTEM STANDARDS

The Petroplus Board of Directors and the Company’s Executive Committee seek assurance of compliance to the SHE standards contained within the Corporate SHE Management System and the process of continual improvement. As such the Corporate SHE Review process has been developed as a means of assuring that comprehensive risk-based management systems are in place at all facilities.

The Corporate Safety, Health and Environment Reviews are aimed to assist all Petroplus entities to proactively identify areas of improvement in their SHE management systems and to prevent injury, accidents, incidences of occupational related illnesses, process safety related incidents, loss of containment and to be environmentally responsible.

The SHE Review process is led and managed by Corporate SHE. The Company’s Internal Audit department will review the Corporate SHE Review policies and processes and provide assurance to the Audit Committee of Petroplus that the Corporate SHE Reviews are conducted in accordance with appropriate standards and methodologies.

The Corporate SHE Review process utilizes the knowledge, skill and experience of people across the Petroplus Group by involving them in the fieldwork of the SHE Review process. This acts as a catalyst for learning and sharing across the organization.

The Corporate SHE Review process involves a review of management system arrangements, the visible condition of hardware, the content of records and the knowledge and views of personnel.

The Corporate SHE Reviews are conducted using a ‘risk based’ approach so as to ensure that they are focused on the issues that are most important to the organization.

PART 2: STANDARDS

SECTION SUBJECT

1. RDSHE1: LEADERSHIP AND COMMITMENT2. RDSHE2: PLANNING, MANAGEMENT, RESOURCES AND LEGAL

COMPLIANCE3. RDSHE3: COMMUNICATION AND CONSULTATION4. RDSHE4: SHE TRAINING, AWARENESS AND COMPETENCY5. RDSHE5: OCCUPATIONAL HEALTH AND WELLBEING6. RDSHE6: SUBSTANCE HAZARDS7. RDSHE7: NEW PLANT, EQUIPMENT AND PROCESS DESIGN8. RDSHE8: MANAGEMENT OF CHANGE 9. RDSHE9: ASSURANCE10. RDSHE10: SYSTEMS OF WORK11. RDSHE11: PLANT OPERATION12. RDSHE12: MANAGEMENT OF CONTRACTORS AND SUPPLIERS13. RDSHE13: ENVIRONMENTAL IMPACT 14. RDSHE14: EMERGENCY PREPARNESS15. RDSHE15: SHE RISK MANAGEMENT16. RDSHE16: INCIDENT INVESTIGATION AND FOLLOW UP17. RDSHE17: SHE PERFORMANCE REPORTING18. RDSHE18: MONITORING OF SHE PERFORMANCE

RDSHE 1 – LEADERSHIP AND COMMITMENT

SUMMARY OF STANDARD

Site Managers and their Management Teams are ultimately accountable for the safety, health and the environmental of their site, have clear responsibility to set priorities for SHE and lead the commitment to ensure continual performance improvement in this area.

All activities on site should be managed safely and with respect for the environment through an effective SHE Management System.

1.1 RESPONSIBILITIES

Duty

Site Managers shall ensure that all members of management, supervisory level employees, and contractors understand the importance of their roles in delivering SHE on site.

Key aspects of these roles involve implementation and maintenance of an effective SHE management system. Managers at all levels will be expected to support and promote the site’s SHE management system to ensure that activities on site are managed safely and with respect for the environment.

Principles to be followed

All sites shall formally define and document the SHE accountabilities and responsibilities of all levels of management, of all supervisory level employees, and all contractors.

All activities on site are to comply with the Corporate SHE Management System. All sites shall have a management appointee to act as a sponsor for each standard within this document. For each standard, it will be the appointee’s role to ensure compliance with the Corporate SHE Management System and to bring non-compliances to the attention of the management team if they occur. Where incident root causes relate to learning in an appointee’s nominated standard, the appointee is to provide sponsorship for the any actions which are recommended.

Site Management shall integrate SHE expectations into business planning and decision making processes, ensuring that documented systems are in place to deliver expectations. Timely planning and communication is considered to be key to ensuring that SHE related activities are not compromised by cost, deadline or quality considerations.

Site Management shall define and consistently enforce site SHE rules.

Site Management shall adopt formal processes that recognise, reinforce and reward desired SHE outcomes.

1.2 MANAGEMENT AND SUPERVISORY BEHAVIOURS

Duty

All levels of management and supervisory level employees shall lead by example in terms of the behaviours they wish employees and contractors to follow.


Site Management, supervisory level employees, and contractor representatives shall proactively demonstrate their commitment to SHE compliance by participating in SHE performance programmes, such as audits and inspections. This shall include engaging with the workforce and contractors.

Managers, Supervisors, Employees and Contractors at all levels shall demonstrate the highest standards of SHE risk awareness and shall be held accountable for the impact of their actions in terms of SHE performance through the Petroplus Performance Management Process.

Site Management shall be visible in the field and utilise their time to demonstrate SHE leadership and commitment.

1.3 THE PREPARATION OF A LOCAL SHE MANAGEMENT SYSTEM

Duty

Site Managers shall ensure that a SHE Management System is developed and reviewed on a periodic basis to foster continual improvement to be made.

The SHE Management System should be consistent with internationally recognised SHE management system standards such as OHSAS 18001 and ISO 14001.

Site Management shall allocate competent resources to maintain SHE Management Systems on site.


The SHE Management System should:

a) Contain a published SHE Policy Statement as a visible demonstration of leadership by the Site Manager.

b) Establish clear SHE goals and objectives to measure SHE performance on site.

c) All sites shall have clearly defined roles, responsibilities and accountabilities at all levels and functions on site to ensure effective implementation of the SHE Management System. These shall be defined, documented and communicated to all persons.

d) All sites shall have arrangements in place to manage the SHE risks associated with the operation of the site, for example, policies, procedures and operating instructions.

e) All sites shall ensure that proactive processes, such as SHE audit programmes are in place to ensure continual improvement in SHE performance.

f) All sites shall ensure that processes are in place to ensure the effective review of the SHE Management System on a periodic basis, to make sure that they remain relevant and appropriate to the nature and extent of the associated SHE risks.

RDSHE 2 – SHE PLANS, MANAGEMENT, RESOURCES AND LEGAL COMPLIANCE

SUMMARY OF STANDARD

In order to ensure continuous improvement of SHE performance targets and objectives are integrated into the overall business planning process and deployed throughout the organization, resources (e.g., human, technical and financial) shall be available and employed to assist management, employees and contractors to comply with the SHE policies, the law and to discharge their SHE policy responsibilities.

2.1 LEGAL REQUIREMENTS

Duty

Site Managers shall ensure that all applicable legal, regulatory and other SHE compliance requirements are identified, documented, maintained, accessible, communicated, understood and complied with.

2.2 SAFETY, HEALTH AND ENVIRONMENTAL IMPROVEMENT PLANS

Duty

Site Managers shall prepare and issue an annual SHE compliance improvement plan, which shall form part of a longer term SHE compliance improvement programme.


The SHE Improvement Plan should include:

a) The establishment of formal and measurable goals, priorities and numerical targets for the forthcoming year, using a risk-based approach (see Corporate SHE 003). These goals, priorities and targets should be communicated and understood by all appropriate personnel, including contractors.

b) A review of current SHE compliance performance and results of relevant audits and inspections.

c) Action plans for specific tasks to be undertaken to improve performance, ranked according to urgency together with accountabilities clearly defined.

The SHE Improvement Plan should be reviewed on an annual basis to ensure that goals, priorities, targets, and established timescales remain appropriate.

SHE Improvement Plans should be prepared in consultation with employees and their representatives.

2.3 SHE INPUT TO ANNUAL BUDGET REVIEW AND ASSET LIFE PLANS

Duty

Site Managers shall ensure that when assessing the SHE input into the annual budget review an adequate risk assessment is carried out to ensure the following:

a) Adequate manpower resources are identified.b) Adequate SHE information is supplied to justify cost implications.

The annual budget review for each site should make explicit reference to the summarised SHE Improvement Plan, identifying cost implications and priorities. In order to achieve this, Site Managers should have processes which effectively integrate asset life plans with SHE investment needs.

2.4 RESOURCES

Duty

All sites shall ensure that adequate resources (human, technical and financial) are made available and deployed to ensure that goals, priorities and numerical targets can reasonably be achieved.

2.5 INSURANCE LIABILITY MANAGEMENT

Duty

Site Managers shall manage their activities in order to ensure that insurance policies in respect of Property Damage (PD), Business Interruption (BI), Employers Liability (EL) and Public Liability (PL) can be obtained on as favourable terms as possible. This will require that action plans arising from brokers’ and insurers’ visits are actively managed in consultation with Petroplus’ Corporate Insurance Managers and those parties.

Principles to be followed:

a) An individual shall be identified at each site as responsible for co-ordination of insurance matters. A particular activity will be to ensure that the annual insurance coverage renewals processes are conducted efficiently, in collaboration with the Corporate Insurance Manager.

b) Following site visits by brokers and insurer’s representatives, a draft report will be issued to the site management team for consideration. The draft recommendations will be assessed and a process will then be managed to ensure that those recommendations in the final report are fully agreed.

c) Recommendations will then be carried out to the timescales agreed with the insurer.

RDSHE 3 – COMMUNICATION AND CONSULTATION

SUMMARY OF STANDARD

All sites shall proactively communicate, consult and involve all appropriate employees and contractors in matters of safety, health and the environment.

3.1 ROUTINE COMMUNICATION PROCESSES

Duty

Site Managers shall ensure that they have processes to ensure effective consultation and communication of SHE compliance matters with all employees and contractors on a continual basis.


All sites shall develop and implement formal processes to ensure effective consultation, participation and communication of matters relating to SHE compliance at all levels and functions within the operation.

The consultation and participation process shall be an interactive process allowing for two way dialogue. The process shall involve all appropriate personnel, contractors and suppliers and shall formally define and communicate to appropriate personnel the arrangements for employee safety representation.

All sites shall establish and maintain effective and appropriate forums for the regular consultation and communication of SHE matters. These shall involve all relevant personnel and shall be used as a mechanism to track, monitor and report on the effectiveness of current safety systems and performance. Key topics process shall include the sharing of lessons learned, good practices and improvement opportunities. The processes shall also include the sharing of information with other sites and the corporate organization.

The consultation, participation and communication processes shall be reviewed on a regular basis with all applicable personnel to evaluate their effectiveness and to ensure they remain relevant and appropriate.

RDSHE 4 – SHE TRAINING, AWARENESS & COMPETENCY

SUMMARY OF STANDARD

SHE Training needs shall be identified and training shall be carried out to ensure that plant is operated and work is conducted with proper regard for SHE compliance.

4.1 TRAINING OF PERSONNEL

Duty

Site Managers shall ensure that all organisational roles, positions and job functions have the required SHE competencies formally defined in terms of appropriate skills, qualification, training and experience.

Site Management shall ensure that their recruitment and selection policies specifically consider SHE training, awareness and competencies of all relevant personnel prior to employment.

Site Management shall be accountable for identifying training needs and developing and implementing a formal SHE training management system. The SHE training management system should include SHE awareness and competence programmes, which are applicable to all relevant levels and functions within the operation. This shall include regulatory SHE training requirements.

Site Management shall ensure general and specific training needs, including refresher training, shall be identified, prioritised and delivered to ensure adequate levels of competency before work activities are undertaken. Training records for employees, contractors and visitors shall be documented, accessible and maintained. The effectiveness of the training shall be monitored.

Site Management shall ensure that individual SHE training needs shall be managed through the Petroplus performance management process.

Site Management shall ensure training shall take into consideration all changes to the operations and personnel that may impact upon SHE. Specifically issues such as changing roles and returning from absence shall be addressed.

Site Management shall ensure that processes are in place to ensure the effective review of HER training management systems to ensure that they remain relevant and appropriate to the nature and extent of the associated SHE risks.

4.2 TRAINING OF SHE PERSONNEL

Site Managers shall ensure that personnel specifically employed to work within a SHE role hold a formal recognised SHE qualification and should participate in continual professional development within the field of SHE.

4.3 TRAINING OF CONTRACTORS

Duty

All sites shall have formal systems in place to ensure that all contractors and suppliers are competent to perform their activities safely when engaged by Petroplus or acting on behalf of Petroplus.

4.4 SHE INDUCTION TRAINING

Duty

All sites shall implement a formal induction programme for employees, contractors and visitors. The induction programmes shall be appropriate to the nature and extent of the hazards and risks associated with the site operations.

RDSHE 5 – OCCUPATIONAL HEALTH AND WELLBEING

SUMMARY OF STANDARD

Maintaining a healthy workforce is essential to operating our sites efficiently. To protect the health of employees and others who work on our sites systems, procedures and facilities shall be established, maintained and monitored to manage the occupational health risks on site.

There shall be systems in place for proactive health promotion on site to ensure the well being of employees.

5.1 THE PREVENTION OF OCCUPATIONAL ILL HEALTH

Duty

Site Managers shall ensure that the occupational health related risks on their sites are reduced to as low a level as is reasonably practicable.


There shall be a health risk profile in place that contains the following information:

Identification of the health hazards and causes of ill health related to work on site.

Identification of the functions that could potentially be exposed to the health hazards recognised.

An assessment of the likely exposure and impact of the health hazards during specific tasks or activities undertaken in the work environment and identification of all precautions necessary to minimise exposure.

Identification of the specific health surveillance required for the health hazards and causes of ill health related to work on site.

Identification of the training required for employees on the prevention of exposure to the health hazards and causes of ill health related to work on site.

At a minimum, the health risk profile should include specific controls to ensure that the following occupational health hazard categories are appropriately managed:

Biological (i.e. fatigue, including the effects of shift work, workplace stress etc.)

Chemical (i.e. benzene) Ergonomic (i.e. musculo-skeletal disorders, including those arising from

manual handling activities or use of display screen equipment) Physical (i.e. noise, vibration) Workplace environment (i.e. temperature)

For the management of asbestos, water systems with a risk of legionella and ionizing radiation see RDSHE 6 Substance Hazards.

5.2 PROVISION OF HEALTH SURVEILANCE

Duty

Site Managers shall ensure that there are systems in place to monitor the management of occupational exposure related health risks and the well being of employees during the course of their employment.


There shall be a health surveillance system in place that contains the following:

A health assessment of individuals at pre-placement. A defined schedule of specific health surveillance requirements in accordance

with the health hazards identified in the sites’ health risk profile. A program of proactive sampling of the main health hazards identified on site. A process to collate ill health statistics and the review of any relationship of ill

health to work.

5.3 THE PROMOTION OF HEALTH

Duty

Site Managers shall ensure that there are systems in place to promote the health and well being of employees on site.


Systems and facilities shall be established for:

Proactive routine health monitoring to monitor aspects of health during the course of employment.

Good standards for workplace and personal hygiene practices. Health education and health promotion activities. Provision of an independent employee assistance program.

5.4 THE TREATMENT OF ACCIDENTS AND ILLNESS OCCURRING AT WORK

Duty

Site Managers shall ensure that accidents and illnesses occurring at work receive timely treatment carried out by appropriately trained persons.


Systems and facilities shall be established for immediate first aid such as:

Provision of a suitable number of professionally trained first aid providers. Dedicated treatment rooms. Provision of safety showers. Eye wash bottles. Other emergency response equipment.

5.5 THE RESTORATION OF HEALTH

Duty

Site Managers shall ensure that active support is given to individuals to recover from ill-health as soon as possible.


Systems and facilities shall be established for:

Rehabilitating sick or injured workers. Ensuring that employees who are off work due to illness for extended periods

of time are referred for assessment by the occupational health function upon their return to work.

Facilitating medical referrals to physiotherapists and other specialized treatment.

5.6 PROFESSIONAL ASPECTS OF HEALTH CARE

Duty

Site Managers shall ensure that there is adequate provision of health care on site and that health care on site is managed responsibly and in accordance with this policy and legal requirements.


a) Resources

Each site shall assess its requirements for professional support from:

An Occupational Health Physician, Nurses or Advisors. First-aid providers to assist with the immediate treatment of accidents and

illness in the absence of an occupational health professional

At each site a suitably trained person should be appointed who will receive hazard data for all materials used on site and communicate same to site personnel as appropriate.

b) Medical Records

Medical records should be retained in accordance with local or national requirements, but should include, at a minimum, any first aid treatment given on site. Records should be retained for at least 30 years after the termination of employment.

c) Ethics - Disclosure of Medical Information

Site Managers shall have a documented statement describing the management of medical confidentiality. This will be in accordance with local regulatory requirements and practice and will address the rights and obligations of the employee, Petroplus, and medical staff.

5.7 DRUG AND ALCOHOL MANAGEMENT

Duty

Site Managers shall establish a procedure for the identification and management of drug and alcohol use problems in so far as any such use may affect an individual’s performance at work. The procedure will recognise both the personal rights of the individual and the obligations of Petroplus to provide a safe site.


The consumption of drugs or alcohol on site can pose a significant risk to the safe operation of plant and facilities and to sound and reliable judgment in employees, as well as causing serious health effects. It is entirely unacceptable for the consumption of non-prescription drugs and/or alcohol on site.

Management teams shall investigate any cases where a drug or alcohol use problem is suspected and to take measures to control its impact. However, there are likely to be clearly defined limits to the action that can be taken in each location.

Site Managers shall ensure that limits of activity at each location are understood by the management team. Full consultation with the workforce at each site supported by a clear policy will be required to provide management with maximum scope for action in response to incidents.

Drug and alcohol testing will be of greatest effectiveness in reducing the impact on the company’s interests, if it can be carried out:

Before employment with the company begins On a random basis during employment “With cause” for example following an incident or in those instances

where an employee or contractor may be reasonably believed to be under the influence of drugs or alcohol.

It should be noted that there may well be local regulatory limitations on some or all of these reasons for testing.

RDSHE 6 – SUBSTANCE HAZARDS

SUMMARY OF STANDARD

All hazardous substances and chemicals need to be appropriately managed on site. Formal systems need to be in place to ensure that all materials contained, used, produced on site or manufactured for sale are properly classified, labelled, handled, stored, transported, used and disposed of in accordance with local and national regulatory requirements.

6.1 INFRASTRUCTURE HAZARDS

There shall be specific management systems in place to ensure that the following infrastructure hazards are appropriately controlled on site:

Asbestos (see RDSHE 10.1) Water systems with a risk of legionella Ionizing radiation

6.2 USE OF HAZARDOUS SUBSTANCES

Duty

Site Managers shall ensure all workplace exposure limits for relevant materials and physical agents are adhered to, recorded and monitored in accordance with local and international regulatory requirements. There must be adequate communication of any exposure limits to all those who are potentially exposed to the hazardous substance.


Site Managers shall ensure that the hazards associated with the substances used on site are subject to the following:

An assessment of the potential exposure during application Mitigation by implementing control measures, such as identifying safe

systems of work and the use of personal protective equipment etc Risks are to be communicated to employees, contractors and customers as

appropriate Adequate training is to be provided to employees and contractors on the safe

use and handling of hazardous substances

6.3 SAFETY DATA SHEETS

Duty

Site Managers shall ensure appropriate information is maintained to enable all materials used on site or manufactured for sale, to be properly handled, stored, transported, used and disposed of in accordance with local and national regulatory requirements.


Sites shall have a system in place to manage Safety Data Sheet (SDS) obtained from suppliers of chemicals. The information contained in the SDS shall be made available to employees and contractors as appropriate. Activities on site will be carried out in compliance with the data sheet.

Sites shall have systems in place to ensure a SDS is compiled in accordance with Annex II of EU regulation 1907/2006/EC (REACH) for each petroleum product, additive and other imported chemicals that is being manufactured on the site or being imported to the site for delivery to customers.

6.3 REVIEW OF SUBSTANCE HAZARDS

Duty

Site Managers shall ensure that when a new material is introduced to the site or whenever the use of a material on site is changed or whenever a different material is substituted, the change is subjected to a formal management of change process. Any changes made should be communicated as appropriate. All materials that do not have workplace exposure limits assigned to them or do not require a SDS do not need to be subject to a formal management of change process.

Sites shall on a periodic basis review the materials used on site to identify if they are still required and whether they remain an acceptable option taking into account occupational health, safety and environmental considerations. Elimination/substitution of materials should be considered where the impact on occupational health, safety and the environment can be reduced.

6.4 CLASSIFICATION AND LABELLING

Duty

Site Managers shall ensure compliance with legislative requirements in respect of the classification, labelling, and documentation for distribution of products (For example EU regulation EC/1272/2008 on classification, labelling and packaging).

6.5 CHEMICALS REGULATION

Duty

Site Managers shall ensure implementation of obligations arising from new chemicals regulations.

Principles to be followed regarding EU regulation 907/2006/EC (REACH)

Under REACH legislation registration dossiers for substances which are produced or imported need to be produced. This will be required during the Pre-registration phase for substances and also when new materials are introduced to business activities.

Site Managers will provide adequate resource and information to ensure that registration dossiers are created and submitted in accordance with the requirements of REACH.

Site Managers shall ensure that site procedures are reviewed and updated in order to comply with all relevant obligations arising from REACH.

RDSHE 7 – NEW PLANT, BUILDINGS, EQUIPMENT, AND PROCESS DESIGN

SUMMARY OF STANDARD

There shall be formal systems for the management of projects and the design of all new facilities, plants, buildings, equipment and processes. Design and construction shall be in accordance with relevant engineering guidelines, local codes and regulations. Studies shall be carried out in order to eliminate or reduce risks to “as low as reasonably practicable (ALARP)”.

7.1 SHE ASPECTS OF PROJECTS

Duty

Site Managers shall ensure that SHE risks are fully considered and addressed at all stages in the management of projects.


A Project Manager shall be appointed who will be responsible and accountable for the implementation of a project from inception to completion of commissioning, including all SHE aspects.

A Commissioning Manager shall be appointed who will be responsible and accountable for the commissioning of a project including all SHE aspects.

An assessment of the SHE implications of a project shall be conducted, including:

a) A pre-sanction SHE assessment for inclusion with the expenditure proposal. In exceptional circumstances, this study may conclude that further SHE assessments are not required.

b) More detailed SHE studies as the detailed design progresses after sanction. These will need to be systematic and should include, but not be limited to:

Hazard and Operability (HAZOP) studies where changes to the process or its control are involved

Safety Integrity Level (SIL) assessments, in accordance with IEC 61511, where instrumented protection changes or additions are part of the project

Design review of the as built project

The depth and breadth of the relevant risk assessments and hazard studies will be determined by the nature of the project.

c) Appropriate pre-commissioning checks.

d) Commissioning procedures and checklists including formal acceptance of the project from the commissioning Manager by the operations team.

e) Appropriate post-commissioning checks to review whether the project has been implemented safely and with low environmental impact and also whether the project has had any unforeseen impacts on other activities such as operations or maintenance,

Any significant departure from the above five processes should be authorised by the Site Engineering Manager or equivalent.

It is a key principle that projects which interact with and/or entail modifications to existing plant should not compromise the SHE standards of the plant concerned.

Identified unacceptable risks have to be eliminated, or minimised, wherever this is reasonably practicable. Where any significant hazards to people or the environment remain, then these residual risks should be recorded. Risk assessments must be carried out by competent personnel who have received appropriate training.

A Project SHE Dossier should be assembled for a project, which includes a record of all Hazard Studies and the Environmental Impact Statement together with other relevant SHE data. The master Project SHE Dossier should be filed by the Project Manager for future reference and review

The Project Manager must ensure that the changes made by the project have been explained, operating instructions written and operating staff trained in the use of newly installed equipment.

7.2 LOCATION AND USE OF BUILDINGS

Duty

Site Managers shall ensure that management responsibilities and arrangements are in place for authorising changes in population and the location and use of buildings, including temporary accommodation.


Arrangements shall take into account the hazards and risks to buildings and those persons within such buildings who are associated with both the existing activities or any proposed new activity. This risk assessment should take the form of a formal occupied buildings study.

Prior to the use and location of temporary buildings a formal study must take place to ensure that acceptable protection is provided to the occupants from an identified explosion, fire or release of toxic material.

No significant changes in population, land use, or plant on the site should take place without formal risk assessment and written approval from the Site Manager.

Developments and development proposals external to the site are required to be monitored so that appropriate action can be taken to minimise impact on existing and proposed refinery activities.

RDSHE 8 – MANAGEMENT OF CHANGE

SUMMARY OF STANDARD

Managing change over the life of a facility is one of the essential elements of Process Safety. A management of change (MOC) system helps ensure that changes do not inadvertently introduce new hazards or unknowingly increase the risk of existing hazards.

There shall be arrangements in place to ensure that both permanent and temporary change is managed in such a way that it does not compromise SHE, operations or off site activities. Necessary risk assessments using the corporate risk assessment matrix shall be carried out, appropriate design considerations made, action management plans implemented and all changes properly engineered and recorded.

8.1 THE DEFINITION OF “PLANT CHANGE” OR “MODIFICATION”

Duty

To ensure that when a modification is made the risk of a process safety incident is not increased Site Managers shall ensure that all personnel are aware of what constitutes a plant change or modification and also of the need to carry out risk assessments on plant changes or modifications. They shall further ensure that personnel are aware that authorisation is required from Site managers with authority before any plant change is implemented.

In addition, Site Managers shall ensure that all those in positions of leadership including Shift Team Leaders, Shift Supervisors, Shift Managers and all technical and managerial staff are trained in the use of the site plant change or modification system.

Modification definition:

Any change in the approved method of operation as described by the plant operating instructions.

The introduction of new substances into part of the process or plant equipment. Any alteration or change in specification, whether temporary or permanent, to

plant hardware or a component there of, including the removal or addition of equipment, which is either in contact with process fluids, steam or piped services, or which could affect the control or integrity of the plant or storage facility in any foreseeable transient or steady running situation.

Any change to buildings, structures, pipelines, corridors, link lines, drains, roadways or railways which could affect their fitness for purpose or the safety of personnel who work in or around them.

Any material change to manning levels on the plants

Examples of modifications:

1. A change which will require alteration of the existing P&I diagram of the plant.2. A change in material of construction, size or shape of any component which is in

contact with process fluids, steam or piped services or which could affect the flow, temperature, pressure or composition of such fluids.

3. A change in the means of permanent support of plant items, pipe work and fittings or means of temporary support such as installed lifting appliances and lifting beams.

4. A repair to an existing item of equipment or plant component which represents a departure from the existing design.

5. Introduction of a new process material.6. An alteration to the process flow, temperature, pressure or composition outside

known operating experience.7. Any substantial change to the amounts or composition of emissions or any

change to the means of disposal of effluents or any change which affects its notification to the Environmental / Safety or Inspection authorities

8. A change to the process control computer's software or hardware. 9. A change in electrical/instrument equipment design, layout or materials of

construction.10. A change to the setting of trips, alarms or relief devices. 11. A change to any plant protective system such as shutdown, smoke, fire, toxic

gas, and any other types which are installed for personnel /equipment protection.12. A relocation or reduction in number of, or supervision of, people (e.g.

centralisation of control rooms). 13. A change to plant/office layouts which involves doors/means of escape/fire

fighting equipment or the installation of temporary or permanent buildings, or any other change which affects the existing arrangements.

14. A change to a pipe or cable route within a pipe bridge or corridor.15. Addition, removal, modification, change of use or abandonment of a pipeline, or

for any modification to operating plants which will alter, directly or indirectly, the operation or design conditions of a pipeline.

16. Where these are the responsibility of Petroplus, equipment or procedural changes related to a transportable container or road or rail tanker or for storage or any material under pressure.

17. Where these are the responsibility of Petroplus, any change in the layout or configuration of a roadway or railway.

18. Permanent shutdown and demolition of plant and buildings.

Exclusions:

1. Process changes within the approved method of operation, such as settings of “Process Alerts” which are designed to be “aids” to operating teams and hence will be altered in line with plant configuration.

2. Replacement of a plant hardware component by a new component of identical design, i.e. a repair.

3. Changes in instrument controller parameters. These are not considered to be modifications, but should only be made by competent Control and Electrical personnel or by a Process Control Engineer.

4. Temporary repairs e.g. injecting quick setting epoxy resins into leaking joints, clamping or heat exchanger tube plugging. The circumstances and conditions under which such a repair may be carried out shall be clearly specified in an established maintenance procedure, a system for monitoring the reinstatement of the repair to the original design standard shall be established and the repair shall be authorised by a nominated engineer.

8.2 THE CONTROL OF MODIFICATIONS

Duty

Site Managers shall ensure that a system to control modifications is in place that ensures any proposed changes are properly reviewed and authorised and that the implementation of risk controls appropriate to the proposed change are in place before implementation.


Modifications shall be subject to the following:

a) Clear definition

b) Individual registration and recording.

c) A systematic assessment of introduced risk including occupational safety, process safety, health, environment, business interruption etc, and then approved by a competent person who is independent of the assessment.

d) Approval of design and construction method and confirmation of installation by the manager responsible for the operation of the equipment or process, prior to commissioning.

e) Commissioning review and acceptance by the manager responsible for the operation of the equipment or process.

f) Updating of process knowledge including relevant engineering records, engineering line diagrams and operating instructions etc.

g) Communication to people likely to be affected by the modification and where appropriate specific training and validation.

h) If after a period of operation the change is not performing as design / definition then a review of the causes of this underperformance should be undertaken.

There may be certain exceptional circumstances where work may be undertaken without following the prescribed modification procedure. These circumstances and the required authorisations should be specified.

8.3 TEMPORARY REPAIRS TO PLANT AND EQUIPMENT

Duty

Site Managers shall ensure that all temporary repairs are properly assessed, authorised, recorded and replaced by a permanent repair as soon as is reasonably practical.


Each temporary repair and the procedure for carrying it out should be assessed and approved by an authorising engineer before the repair work is started unless the equipment/contents have been previously defined as being a low hazard system

There shall be a system to record all temporary repairs and specifies an expected reversal date and which requires periodic review of all temporary repairs.

Temporary repairs should be replaced at the earliest practicable opportunity.

8.4SUBSTANCE HAZARDS

See RDSHE 6.1.

8.5PERSONNEL AND ORGANISATIONAL CHANGES

Duty

Site Managers shall establish appropriate processes to identify, assess and manage the risks associated with changes to individual personnel and to the organisation.


The following issues will need to be taken into consideration whenever roles are changed, combined, abolished, new personnel are appointed or personnel leave employment for whatever reason. This is especially important when these involve manning levels of operating teams.

Key issues to be considered will involve:

Minimum staffing requirements Loss of corporate knowledge Possession of relevant competencies, skills and experience Training requirements Handover management Succession planning

Such processes will not be required for minor changes in responsibilities and or job descriptions.

RDSHE 9 – ASSURANCE

SUMMARY OF STANDARD

Assurance helps to ensure that equipment is properly designed, installed in accordance with specifications and remains fit for purpose until it is retired. It is therefore a critical element of Process Safety.

Arrangements must be in place to ensure that periodic reviews of hazards and routine inspections of plant, equipment and premises are undertaken to ensure continued fitness for purpose and compliance with regulatory requirements.

In order to ensure safe process operation, the health and safety of personnel and the minimum practicable adverse environmental impact all facilities need to be maintained to an appropriate standard.

9.1 SHE ASSURANCE PROGRAMMES

Duty

Maintaining containment of hazardous materials and ensuring that safety systems work when needed are two of the primary process safety responsibilities of any facility. To achieve this Site Managers shall implement a SHE Assurance programme for existing operations.


The SHE Assurance Programme shall ensure the following:

a) Hazards are identified and their associated risks are assessed, via Process Hazard Review, HAZOP revalidation, or other equivalent risk assessment processes. Where deficiencies are identified these must be assigned to an owner who shall be responsible for mitigation of the risks, and tracked until completion.

9.1.ana te vragen bij Marina of Koen Verlackt Marina Hazop gebeurt 5-jaarlijks op alle systemen (proces en offsites) In de offsites voornamelijk de eenheden waar manipulaties gebeuren zoals belading en blending. Op proces komen alle units aan bod, ook flare-,Fuel gas en sweet gas systemen. Hazop gebeurt volgens procedure 06 WER 0002.Daarnaast doen we ook vlinderdasstudies op de meest risicovolle onderdelen uit de installatie. Dit gebeurt conform procedure 06-WER-0003

ActieRisk RatingActionee Kurt verzamelt infoOK

Andere risk assessment processen (gevaar vr terrorisme, beveiliging instalatie,…) ?--> procedures?Are deficiencies assigned to an owner, resp for mitigation of the risk and tracking until completion?

ActieRisk RatingActionee Kurt kijkt na wat we allemaal hebben. Ton vraagt bij Ronny Stijleman waarmee rekening wordt gehouden

b) Appropriate safeguarding shall be provided and maintained to prevent the release of hazardous material or a sudden release of energy and to ensure high availability of critical safety or utility systems that prevent or mitigate major hazard events.

9.1.bprovided OK, alle items zijn voorzien van safeties, TRV’s -> dekkingsgraad werd in het verleden nagekeken beschikbare documenten?--> BartESD systemen worden periodiek gecontroleerd en getest procedures?Idem voor safeties en TRV’s procedure?--> nog te officialiseren wie is verantwoordelijk voor wat en hoe worden periodiciteiten bepaald. Ook nog een procedure voor trevitesten te schrijven

ActieRisk RatingActionee Bart kijkt na of de studie vd dekkingsgraag TRV’s makkelijk beschikbaar kan worden gesteld

Koen is bezig met nazicht safeties nav huidige doorzetten info opgevraagd Externe specialist zal dit doen, gecoördineerd door Marina. Eerst worden de verschillende scenario’s bepaald voor de studie (blocked inn, fire,…). Daarna zal hij unit per unit alle safeties bekijken (U600 duurt 4 maanden). Nadat alle units aan beurt kwamen wordt het volledige flaresysteem bekeken en indien er nog ruimte is wordt gekeken of de safeties van de sferen er bij kunnen. Koen vind dit een gap. Redenen van de vernieuwde studie: Laatste studie gebeurde door Technip en Kellogg, ze is al 12 jaar oud en er zijn merkwaardige verschillen tussen beide studies. Door MA’s (vooral reïnstrumentatie) is er sindsdien heel wat gewijzigd mbt flare… Deze volledige studie zal 4 a 5 jaar in beslag nemen

Ton bekijkt: Dekkingsgraad instrumentele beveiliging dient ook gereviewed te worden. Dit gebeurt normaal periodiek dmv HAZOP studies. Voor de betrouwbaarhedssudie U600 wordt dit mee bekeken. Andere units/systemen zullen nadien volgen. Ton kijkt ook de pocedure voor nazicht ESD systemen na ( 12-PRO-0003)

FilipTRV’s &safeties procedure officialiseren (Risk Ratinglaag tot gemiddeld risico 4D) & procedure voor trevitesten (Risk Ratingis geen gap, toch een gemiddeld risico)Gapsafeties van de sferen er bij op flare systeem-- Koen vindt dit een gap risico 1D

c) Systems and procedures exist to operate critical equipment safely within design criteria to maintain its integrity.

9.1.c procedures to operate critical eq within their design.--> actieplan zoals voor U600 waar het design van alle items wordt opgelijst en kritisch wordt bekeken ook voor de andere eenheden uitvoeren Risk Rating gemiddeld tot hoger; risico 3Cnagaan of er voldoende safeguardings aanwezig zijn om binnen design te blijven Risk Rating gemiddeld tot hoger—3BAanpak en/of procedure voor opvolging van de safeguarding Risk Rating gemiddeld tot hoger—3B

ActieRisk RatingActionee Ton schrijft op wat we nu hebben & hoe we binnen het window dienen te blijven Risk Rating ??

d) Appropriate persons are provided and given sufficient tools, information, supervision and training to operate, inspect and maintain the equipment, systems and procedures competently.

9.1.d-??9.2 GENERAL REQUIREMENTS FOR PLANT ENGINEERING DESIGN, MAINTENANCE

AND OPERATION

Systems designed to contain hazardous materials or protect against their release shall be designed to internationally recognised codes.

9.2 Ontwerpcodes voor SV’s? ESD systemen? in een procedure?Drukvaten, Exchangers beschreven in procedure?Leidingen beschreven in procedure?

ActieRisk RatingActionee ontwerpcodes zijn voldoende gedefinieerd & gebouwd door internationaal erkende ontwerpersOK

Systems designed to contain hazardous materials or protect against their release shall be manufactured and tested to specifications agreed by the responsible member of the site team (usually the Site Engineer or equivalent) and the organisation shall be supplied with supporting documentation, which will be retained for the life of the equipment.

Na ontwerp worden de gegevens door de betrokken vakingenieurs nagekeken

ActieRisk RatingActionee Bart kijkt na of dit in de globale bestelspecificatie wordt beschreven (Na ontwerp worden de gegevens door de betrokken vakingenieurs nagekeken).

Procedure voor flow van documenten bij nieuwbouw (is er en zit in vivaldi) & hoe registreren dat deze documenten wel degelijk op de afgesproken plaatsen terecht komen

Ook voor instrumetele beveiligingen en bespreken hoe dit binnen tekenkamer IEI gebeurt en hoe alles in IN tools komt en wanneer dit gebeurt

ActieRisk RatingActionee Bart denkt over hoe registreren dat deze documenten wel degelijk op de afgesproken plaatsen terecht komen. Nakijken of afmelding na aanpassen docs door tekenkamer gebeurt door registratie tekenkamer Risk Rating gemiddeld tot laag – 4B – 4C

Ton kijkt na Ook voor instrumentele beveiligingen en bespreken hoe dit binnen tekenkamer IEI gebeurt en hoe alles in IN tools komt en wanneer dit gebeurt. Misschien een meeting inleggen met Serge en Bart erbij om na te gaan hoe het bij de anderen gebeurt datum klaar

Systems designed to contain hazardous materials or protect against their release shall be installed and commissioned in accordance with the processes defined in RDSHE 7 and then operated in line with RDSHE 11.

Commissioned according RDSHE 7 & operated accoring RDRSHA 11 wordt in deze twee hoofdstukken behandeld

ActieRisk RatingActionee

The frequency and nature of reviews and inspections shall be decided based on regulatory requirements and the risks of equipment failure. Inspections shall be performed by suitably experienced and qualified personnel and shall be performed before the due date. When any of the above cannot be carried out, the matter shall be referred to management team level for review and a decision regarding the appropriate authority for approval.

Inspectiefrequentie en review gebeuren conform de wettelijke bepalingen en risico gebaseerd OK

In procedure nog te beschrijven hoe periodiciteit voor inwendige inspecties dient te worden geëvalueerd.

periodic review of routine inspections gebeurt 1 procedure te schijven voor review voor alle onderzoeksmethoden. Hoe resultaten van het onderzoek beoordelen, zo nodig correctieve acties initiëren volgens de inspectieaanbevelingsprocedure of aanvullende onderzoeken, inspectiefrequentie en plandatum toevoegen en/of herbeoordelen. Dient binnen 5 maanden na uitvoering van de inwendige inspectie. Merkteken in mape aan te brengen telkens na iedere review & lijst van nog te reviewen inwendige inspecties =(A).

o UT appn & leidn review dmv trending procedure in de maak (A) Risk Rating->laag (enkel procedure) – 3D

o UT Op tanks nog een systeem & procedure uit te werken. (A) Risk Rating->hoger daarom prio aan uitwerken van een systeem, procedure heeft lagere prio (B)-3C-3B

o Andere UT(A) (B) – 3Do Inw inspectie nog een systeem & procedure uit te werken. (A) Risk Rating->laag

(enkel procedure). Review rapporten gebeurt reeds consequent (C) – 3Do Uitwendige inspecties(A) (C) – 3Do SBN’s conform procedure (C) – 3Do CUI nog een systeem & procedure uit te werken (A) (C) – 3Do Andere onderzoeken (A) (C) – 3D

Systeem uitwerken voor periodieke reassessment van de RBI/HPI studie.--> nakijken per CC of er wijzigingen dienen te gebeuren Risk Rating->gemiddeld – 3D

Risk RatingActionee Filip & Kurt

Inspecties door gekwalificeerd personeelBRCOK (enkel visuele inspecties, voldoende ervaring en opleiding)

RTD visueel opleidingsprocedure Risk Rating gemiddeld- 3C-3Bandere via levelsprocedure voor ever green en voor BRC raadpleegbaar houden

Anderenvisueel procedure te schrijven hoe te werk te gaan bij selectie (CV vooraf voorleggen en archiveren). Risk Rating gemiddeld– 3D

andere???-->actie uitwerken en implementeren Risk Rating gemiddeld– 3D IVT?? actie uitwerken en implementeren Risk Rating gemiddeld– 3D

ESD testen gebeurt door eigen mensen en Cegelec procedure - wat vermeldt deze ivm qualificaties?--> niets. Bij de werkvoorbereiding van de ESD test wordt dit geval per geval door de werkvoorbereider bepaald en beschreven geen gapElectrical systems keuringen door Vincotte procedure wat vermeldt deze ivm qualificaties?

Wanneer due date overschreden dreigt te worden dispensatieprocedure13-PRO-0011 “Verzekeren van de integriteit van de BRC-installaties” & 13-FOR-003OK

Hoe gebeurt dit mbt overdue ESD testen & Elektrische systemen?

ActieRisk RatingActionee Kurt en Filip om dit verder uit te werken en met IEI &IEE opnemen (jan bosmans)uiterlijk tegen………

Individual equipment files containing appropriate original documentation, details of subsequent modification and or repair and inspection records relating to equipment, plant and facilities shall be retained.

Plant and equipment shall be operated within the original design envelope unless an engineering study leads to subsequent re-rating, in accordance with RDSHE8. This process will be accompanied by provision of documentation and updating of engineering records.

Archivering van documenten flow in procedure vastleggen voor nieuwbouw & MA’sis in orde procedure vermelden actie Bart

Re-rating volgens MA procedureis OK

In het verleden gebeurde dit niet steeds met een voldoende gefundeerde studie

Voor U600 wordt dit bekeken met voldoende assistentie van externe deskundigen. Andere units volgen.--> Risk Rating gemiddeld, actieschema op te stellen Kurt?—3B-3C

Mbt verwerken van andere crudes of stoken van Andre fuels/gas Iedere raffinaderij dient een operating window te hebben voor crudes/condensaat. Indien we daarbuiten gaan procedureSoms worden additieven geïnjecteerd upstream (crudes/condensaat)

Actie Filip/Tonopvragen operating window Bij navraag bleek emma al allerlei naar Ton te hebben toegestuurd

Opstellen operating window Risk Rating gemiddeld tot groot-3B-3C procedure om binnen window te blijven Risk Rating gemiddeld tot groot-3B-3C

Operations will be kept within the original design envelope by use of equipment such as relief valves or instrumented protective systems.

Geen voldoende informatie stroom wanneer bepaalde windows niet gerespecteerd kunnen worden en hoe er op dient gereageerd te worden

Integriteitsbewakingspunten Voor U 600 zal Kurt die meenemen bij het functional team. Er zal ook gekeken mbt de injectie van chemicaliën (welke aanwezig / in dienst,/ functie/frequentie/opvolging,…)

9.3 PRESSURE SYSTEMS (INCLUDING BOTH VESSELS & PIPEWORK)

Duty

Site Managers shall implement processes to ensure that pressure systems are correctly designed, manufactured, installed, commissioned, operated, inspected, maintained, modified and retired in accordance with the requirements of section 9.2.

9.3Duty Dient volgens mij reeds in andere hoofdstukken behandeld te worden (Hst 7 &11). Is ook al hoger besproken


As a requirement of the maintenance process for pressure vessels, periodic routine inspections shall be undertaken to assure their ongoing fitness for purpose.

§1 Opleiding inspecteurs om meer naar staat isolatie van leidingen en apparaten te kijken en waar nodig suggesties/aanbevelingen te schrijvenActie door Kurt/Filip (opleidingsprocedure RTD’ers & procedure)Risk Rating gemiddeld-3C-3B

Inspections will be carried out in line with professional engineering assessments of corrosion or erosion rates and minimum allowable wall thicknesses. Inspections may only be deferred before the due date is reached and then only on the basis of an acceptable outcome of an engineering assessment. This deferral process will be authorised by designated members of the site’s management team (usually the Site Engineer or equivalent and Site Manager).

§2 deferrement alleen via engineering assessment door inspectieing. en ook Technisch directeur ondertekent mee het formulier. Ondertekening ook door site manager is OK

Pressure systems operating after their due inspection dates will be recorded in monthly KPIs and routinely audited.

§4 Ok

All maintenance on pressure vessels should be to internationally recognised codes and recorded for the life of the equipment.

§5 procedure voor archivering van onderhoudswerken (lasherstellingen)

Mape als registratiesysteem voor historisch onderhoud Hoe consequent up to date houden?--> hersteldossiers tot bij inspectie?Actie door Kurt/Filip & Bart (systeem en procedure uitwerken)Risk Rating gemiddeld tot laag – 4B

9.4 CRITICAL MACHINE SYSTEMSMail met vragen verstuurd naar Gerrit ik zit hopelijk vrijdag namiddag 1500-1600 uur met gerit samen om hierover en over andere punten te praten

Duty

Site Managers shall implement processes to identify critical or vital machine systems through detailed assessment of SHE and business interruption risk to ensure their continued fitness for purpose. Fitness for purpose will include their design, construction, commissioning, classification, registration, periodic examination, testing, monitoring, maintenance and modification.

Veso lijsten voor machines bestaan en worden beheerd door Guy MertensCondition monitorig gebeurt foor Guy Mertens, mede op basis van de veso lijst (freq vibratiemonitoring is VESO klasse gerelateerd). Verder zijn er ook de thermografie onderzoeken en de olieanalysesVoor alle inspecties heeft Guy een opvolgingsprogramma met plandata, maar geen procedure. Flow Serve is betrokken bij opvolgen van seal lekkages.

Actie Systeem uitwerken om VESO lijst up to date te brengen en te houden (waarschijnlijk gekoppeld aan MA procedure) risico 3D

Werkwijze voor bepaling van plandata en review ervan uitwerken in een richtlijn (risico 3D)

In bijlage de volledige uitleg van Gerrit (ook de triptesten procedure)


A critical machine system is a machine system which has been assessed to present unacceptable consequences if the machine or its protective system should fail. This includes all failures or malfunctions which could result in a fire, explosion or toxic release from the discharge of hazardous materials, danger to life, significant harm to any person or to the environment.

All critical machine systems need to be registered, periodically examined, operated within their design limits and have their protective systems tested regularly (hebben we dat? Volledig, deels, procedures? graag uitleg) . Overspeed trip testing of all turbines shall be carried out after modification or having been dismantled for maintenance. (hebben we dat? Volledig, deels, procedures? graag uitleg) Gap mbt protective system test, overspeed testen,Elektrisch bijspringen van elektrisch aangedreven oliepompen wordt nog niet getest

All critical machine systems should be designed, manufactured, installed, commissioned, operated, and modified in line with the principles described in section 9.2. -->Hoe doen we dit? hebben we procedures om dit te borgen?

9.5 LIFTING EQUIPMENT

Duty

Site Managers shall implement processes to ensure that lifting equipment is designed, manufactured, installed, commissioned, inspected and modified in accordance with the principles described in section 9.2.

9.5

Alles dient geborgd met de MA procedure. Periodieke inspectie gebeurt door EDTC (Erkend organisme) volgens de wettelijke bepalingen.Davits van mangatflenzen worden nog niet geïnspecteerd gapeenmalige inspectierondgang en oplijsten waar acties Risk Rating gemiddeld – 3-CBoven op sommige kolommen (+-20 stuks) staan grote davits. Deze worden niet gebruikt en worden best verwijderd MA initiëren om ze er af te halen Risk Rating gemiddeld- 3-DSysteem uitwerken om na te gaan of alle vast geplaatste hijsmiddelen in keuringsprogramma zitten (bv. Door opschrift max. hijsvermogen) Risk Rating gemiddeld – 3C

Actie davits Risk Rating gemiddeld

Each permanently installed piece of lifting equipment shall have a unique identifier attached.

Niet voor davitsNiet allen gelabeldbv. De balken aan de exchangers U700 waar loopkatten kunnen worden gehangen om eventueel bundles meet e trekken zijn niet gelabeld. Bij volgende rondgangen zal hier een overzicht worden van opgemaakt.Actie opnemen in richtlijn keuren hef en hijswerkruigen (13-PRO-0006) Filip Risk Rating gemiddeld tot klein – 3DRetroactieve actie Filip & MarinoRisk Rating gemiddeld tot klein – 3D

9.6 ELECTRICAL SAFETY IN HAZARDOUS AREAS

Duty

Site Managers shall implement processes to ensure that electrical equipment for use in areas that may contain flammable gases, vapours or dusts is suitable for that duty and that it is designed, manufactured, installed, commissioned, inspected and modified in accordance with the principles described in section 9.2. Bespreken met Jan Bosmans procedures, verwijzingen nr. Wettelijke bepalingen Alle elektrische werken gebeuren conform AREI. Deze is voldoende dekkend voor alle werken op BRC. Al deze werken worden door het erkend organisme (AIB Vincotte) gecontroleerd.Er is een opvolgingsprocedure (12-PRO-0002) waar onderandere ook de opvolging van gebreken en inbreuken wordt beschreven.

9.7 SAFETY INSTRUMENTED PROTECTIVE SYSTEMS

Duty

Site Managers shall implement processes to ensure that instrumented protective systems installed for process safety are identified and assessed to demonstrate that they provide the required availability and robustness to mitigate the identified event. These assessments shall be used in the, design, manufacture, installation, commissioning, operation, and proof testing of the systems in accordance with the principles described in section 9.2. . Bespreken met Jan Bosmans & Carl Heirman procedures, verwijzingen nr. Wettelijke bepalingen Design gebeurt zoals periodiek behandeld in de periodieke HAZOP studies en zoals in de SIL studies. Na Installatie worden deze systemen steeds gecommissioned. Hiervan zijn documenten beschikbaar. In gebruiksfase worden de veiligheden periodiek getest (ESD testen) conform 12-PRO-0003

9.8 PROGRAMMABLE ELECTRONIC SYSTEMS

Duty

Site Managers shall implement processes to ensure that Programmable Electronic Systems (PES), including PLCs, supervisory computers, micro-processor applications and distributed control systems are registered and periodically reviewed. They shall also be manufactured, installed, commissioned, operated, and modified in line with the principles described in section 9.2. Bespreken met Jan Bosmans procedures, verwijzingen nr. Wettelijke bepalingen Wijzigingen aan nieuwe installaties gebeuren volgens 11-PRO-0002. Testen gebeurt volgens vaste intervallen zoals opgenomen in de SIL database. Ook niet vergeten dat deze systemen een grote mate van zelfcontrole hebben. Aankoopspecificatie is TSI-006

9.9 CIVIL STRUCTURES

Duty

Site Managers shall implement processes to ensure that the design, registration, inspection, modification and repair of civil works such as structures, pipebridges, bunds, drains and sewers are adequate to avoid the loss of chemical containment or major incident from failure of the civil works.

When installed, fixed fire protection associated with structures shall be considered as an integral part of the structure and inspected, modified, repaired as such.

Actie werkroep (Bert, Bart, Kurt & Filip) Inspectieprogramma Civil dient nog volledig te worden uitgewerkt. Er wordt twee maandelijks samen gezeten om hiertoe te komen programma & procedures

Risk Rating gemiddeld tot groot (voor bepaalde inspecties) daarom binnen dit inspectieprogramma prioriteit te geven aan de grotere risico’s – 1D- 2D

Wat met ondergrondse leidingen en sewer systems Sewers werden eenmalig geïnspecteerd bij de hervergunning in 2000. Ondergrondse leidingen worden niet opgevolgd.Actie Kurt en Filip Uitzoeken hoe het bij de zusters gebeurt, wat de beste technieken zijn, actieprogramma en procedures uitwerken en implementeren Risk Rating gemiddeld – 3C

9.10 LOW PRESSURE STORAGE TANKS

Duty

Site Managers shall implement processes to ensure that vessels that are outside of the scope of section 9.3 above, such as those tanks used for the storage of raw materials, intermediates and products are designed, constructed, commissioned, operated, inspected, maintained, modified, verified for change of duty and retired in accordance with the principles described in section 9.2.

Dit alles dient geborgd met de MA procedure. Periodieke inspectie gebeurt door Erkend milieudeskundige volgens de wettelijke bepalingen.Daarnaast gebeuren eveneens andere niet wettelijke opvolgings- wanddiktemetingen

Actie Kurt en Filip Er volgt een peer assist bijeenkomst welke een aanzet gaat vormen tot een best practice voor RBI bij opslagtanks.Actie wordt om deze best practice te implementeren (uitvoerings- en proceduretechnisch)Risk Rating gemiddeld – 2D

9.11 RELIEF AND BLOWDOWN SYSTEMS

Duty

Site Managers shall implement processes to ensure that relief and blowdown devices, vents, overflows, vacuum breakers and their associated pipework systems, are designed, constructed, commissioned, operated, inspected, tested, maintained and modified in accordance with the principles described in section 9.2.

Relief pipework systems are defined as the line from the item protected to the device and from the device to the final release point. This may include flare headers, knock out drums, scrubbers etc.

Dit alles dient geborgd met de MA procedure. Periodieke inspectie gebeurt

Nakijken of alle druk-vacuum breakers op de tanks allen periodiek worden getest

Zie 9.1.b hoort in feite hier thuisprovided OK, alle items zijn voorzien van safeties, TRV’s -> dekkingsgraad werd in het verleden nagekeken beschikbare documenten?--> BartESD systemen worden periodiek gecontroleerd en getest procedures?Idem voor safeties en TRV’s procedure?--> nog te officialiseren wie is verantwoordelijk voor wat en hoe worden periodiciteiten bepaald. Ook nog een procedure voor trevitesten te schrijven

ActieRisk RatingActionee Bart kijkt na of de studie vd dekkingsgraag TRV’s makkelijk beschikbaar kan worden gesteld

Koen is bezig met nazicht safeties nav huidige doorzetten info opvragen

Ton bekijkt: Dekkingsgraad instrumentele beveiliging dient ook gereviewed te worden. Voor de betrouwbaarhedssudie U600 wordt dit mee bekeken. Andere units/systemen zullen nadien volgen. Ton kijkt ook de pocedure voor nazicht ESD systemen na

FilipTRV’s procedure officialiseren (Risk Ratinglaag tot gemiddeld) & procedure voor trevitesten (Risk Ratinggemiddeld)

9.12 REDUNDANT PLANT AND EQUIPMENT

Site Managers shall implement processes to ensure that redundant plant and equipment are managed so that they do not pose a threat to the process safety of remaining assets, safety and health of individuals or surrounding environment.

Redundant equipment should be removed; where this is assessed as not possible it must be de-inventoried and physically disconnected from running assets.

Where redundant units remain they should be clearly identified in plant and engineering records and periodically inspected to ensure structural integrity. Access to these units should be restricted.

- Procedure te schrijven hoe om te gaan met buiten dienst zijnde delen. Eerste draft hebben we van Teesside

- Oplijsten buiten dienst zijnde delen- Procedure uitvoeren

Risk Rating gemiddeld tot groot – 2D-3D

RDSHE 10 – SYSTEMS OF WORK

SUMMARY OF STANDARD

Safe work systems are used to control hazards and manage risk associated with maintenance, construction and other non-routine work not covered by operating procedures. (Provision of operating instructions is detailed in RD SHE 11.1).

Safe systems of work shall be established and maintained to ensure the safety and health of people and the protection of the environment. Risks shall be eliminated or reduced as far as is reasonably practicable. Control measures shall be implemented and monitoring programmes organised to deliver safe and environmentally responsible work.

10.1 SAFE AND ENVIRONMENTALLY RESPONSIBLE SYSTEMS OF WORK

Duty

Site Managers shall implement an integrated system of procedures and permits that help protect workers from work place hazards and prevent the sudden release of process materials or energy during non-routine work activities.


Procedures shall be written to ensure that;

Work activities are planned. Hazards are identified. Risks are assessed and effective controls put in place. The training requirements and responsibilities of individuals are clearly defined.

10.2 PERMITS TO WORK

Duty

Site Managers shall implement a “permit to work” system to be used in all circumstances where there is a transfer of responsibility of plant or equipment to a third party.

10.2.1 GENERAL WORK PERMITS

a) Site “permit to work” procedures must define;

The situations in which permits to work must be used.

Detailed instructions for how permits are written, how they are issued, accepted, handed back and how they are cancelled.

Detailed instructions to cover the situation where work is not complete when the validity of the permit expires.

The competencies and training requirements of those with responsibilities for operation of the permit system.

The responsibilities of those involved in the operation of the permit system.

How the permit system is used for multiple tasks involving the same equipment or in the same location, and for multiple permits dependant on the same isolation(s).

The types of activities or situations in which additional written procedures, such as a written job method, are required.

The types of high risk activity for which specialist permits are required. Specialist permits must include but are not limited to;

Hot work.

Entry to confined spaces.

Excavation activities.

The types of work that are exempted from the requirements of permit to work. e.g. office cleaning activities.

Any additional requirements required during shutdowns or turnarounds.

b) The Basic Permit to work must include;

A precise description of the work covered by the permit, including where possible the unique equipment identification number(s) or the workplace identification tags attached.

Details of the precautions to be taken by those doing the work to minimise the risks during the activity. E.g. Additional PPE, gas detectors etc.

References to any associated specialist permits to work.

References to additional instructions or risk assessments.

The time the permit was issued and the period of time for which it is valid.

Locations for signatures of those persons responsible for issue, acceptance and hand back.

10.2.2 HOT WORK PERMITS

a) Hot work permit procedures must define;

The situations in which a hot work permit is required.

Detailed instructions for how hot work permits are written, accepted, issued and how they are handed back or cancelled.

Requirements for the isolation of equipment in preparation of equipment for hot work.

Requirements for hot work on equipment which is on line.

Requirements for the provision of screening around hot work to control sparks.

Requirements for atmosphere testing where flammable vapours could be present by trained persons, with flammable gas detectors checked and calibrated by competent persons.

Requirements for the provision of fire fighting equipment during the hot work.

Requirements for the provision of fire watch personnel and their responsibilities during the work.

The training requirements and responsibilities of hot work permit issuers.

b) Hot work permits must include;

A precise description of the work covered by the permit, including where possible the unique equipment identification number(s) or the workplace identification tags attached.

confirmation that fire prevention and protection requirements have been met prior to issue of the permit, including atmosphere analysis where flammable vapours could be present.

The signature of the person who carried out the atmosphere test.

Signature locations for issue, acceptance and hand back.

The period of time for which the atmosphere test and hence the permit is valid.

10.2.3 CONFINED SPACE ENTRY PERMITS

a) Confined space entry permit procedures must define;

The situations in which a confined space entry permit is required.

Detailed instructions for how confined space entry permits are written, accepted, issued and how they are handed back or cancelled.

Requirements for the isolation of equipment in preparation for entry and during entry.

Requirements for checking the atmosphere in the confined space before entry by qualified persons, with equipment checked and calibrated by competent persons (both for oxygen content and any other potential contaminants).

Requirements for monitoring the atmosphere during the confined space entry.

Requirements for entry point signs to control access to the confined space.

Detailed instructions on the provision and duties of attendants to monitor those inside the confined space.

Detailed requirements for the contents of a written rescue plan.

The training requirements and responsibilities of confined space permit issuers.

b) Confined space entry permits must include;

A precise description of the area to be entered, including where possible the use of unique equipment identification number(s) or the workplace identification tags attached.

Confirmation that isolations are in place, that atmosphere testing has been satisfactorily completed and those precautions to control entry and for rescue are in place before entry.

The results of atmosphere testing and the signature of the person who carried out the test.

Reference to the written rescue plan.


The period of time for which the permit is valid.

10.2.4 EXCAVATION PERMITS

a) Excavation permit procedures must define;

The situations in which an excavation permit is required.

Detailed instructions for how excavation permits are written, issued and how they are handed back or cancelled.

Requirements for identification and checking of underground pipelines, drains, electrical cables and contaminated ground by competent persons in relation to the proposed excavation.

Requirements for ensuring that any necessary isolations have been identified and applied.

Requirements for ensuring that excavations cannot collapse during work.

The training requirements and responsibilities of excavation permit issuers.

b) Excavation permits must include;

A precise description of the work area covered by the permit.

Confirmation of the location of any pipes, drains, cables or contaminated ground in the work area before beginning.

Confirmation that any isolations required are in place.

Details of the precautions to be taken by those doing the work.


The period of time for which the permit is valid.

10.3 SAFE AND ENVIRONMENTALLY RESPONSIBLE USE OF EQUIPMENT

Duty

Site Managers shall ensure systems and procedures are put in place to ensure the safe and environmentally responsible use of equipment.


There shall be procedures covering control and use of the following equipment:

a) Personal protective equipment.

b) Machinery guarding.

c) Cranes and other heavy or abnormal vehicles on site.

d) Power-operated mobile work platforms.

e) Fork lift trucks.

f) Railways and railway vehicles.

g) Motor vehicles on site.

h) Abrasive wheels and grinding machines.

i) High pressure water wash equipment.

j) Compressed air tools.

k) Fixed and portable gas detectors.

l) Scaffolding.

m) Vacuum trucks.

n) Electrical equipment on site

o) Plugs and caps.

All relevant personnel including contractors shall be adequately trained in the above procedures.

10.4 MAINTENANCE OF PLANT AREAS, WORKSHOPS AND STORES

Duty

Site Managers shall provide systems to ensure that all plant areas have been risk assessed and are maintained in a safe condition until demolished. (Also refer to RDSHE 9 Assurance)


There shall be procedures for the maintenance of the following systems:

a) Temporary accommodation.

b) Housekeeping.

c) Work at heights

d) Safe storage of packed chemicals and products in warehouses.

All relevant personnel, including contractors shall be adequately trained in these systems. This is not a comprehensive list, but all of the above activities require formal procedures.

10.5 MAINTENANCE OF OFFICES AND LABORATORIES

Duty

Site Managers shall ensure that offices and laboratories are maintained in a clean, healthy, and safe condition.


There shall be systems to ensure the safety of the following:

a) Non-Manufacturing Locations.b) Laboratories or similar workplaces.

RDSHE 11 – PLANT OPERATION

SUMMARY OF STANDARD

Plant operation and management must be conducted in a deliberate and structured manner. Systems of operation must describe the process, hazards, tools, protective equipment and controls in sufficient detail that operators understand the hazards, can verify that controls are in place, and can confirm that the process responds in an expected manner. When process excursions occur, alerts and ultimately shutdown systems should be installed to prevent process safety or environmental incidents from occurring.

11.1 PLANT AND EQUIPMENT OPERATING INSTRUCTIONS

Duty

Site Managers shall ensure that there are written operating instructions for plant and equipment and that these instructions are complied with.

Operating procedures complement systems of work and assurance procedures which are addressed in RDSHE 10 and RDSHE9 respectively.


(a) Operating instructions shall define the “safe working envelope” of the plant and how this is protected by alarm, trip and relief functions.

(b) Clear operating instructions for plant and equipment should be provided for all activities in planned operations and foreseeable unplanned and emergency operations where it is important to follow a specified practice or sequence. These shall include, as a minimum; normal operation, start-up, shutdown and loss of services.

(c) Start up and shutdown instructions should be written in a step wise manner and include sign off capability against each appropriate step to ensure that no step is omitted or duplicated especially during changes in operational personnel.

(d) They should further define the actions required of operators in the event that the plant moves outside the safe working envelope.

(e) Operating instructions shall define emergency response actions required by the plant team, including specifying when management would expect the plant to be evacuated of all non-essential personnel.

(f) Operating instructions should take due account of the complexity, hazard and risk and of the competence of the operating personnel.

(g) Operating instructions should be readily accessible to employees, kept up-to-date, by reviewing on a periodic basis and also as necessary in the light of learning from operating experience and incidents. They should be managed as controlled documents.

11.2 TRIPS AND ALARMS

Duty

Site Managers shall ensure that plants are operated within the envelope defined by trips and alarms. A trip and alarm philosophy document shall describe the systems required to ensure that all trips and alarms are effectively assessed, displayed and maintained according to their criticality.

Systems and procedures shall ensure that trips and alarms shall not be by-passed or key-defeated without written authorisation and then only in clearly defined circumstances with alternative protective arrangements in place.

Authorisation paperwork associated with trip and alarm defeats must be available in a form that enables review and understanding by the operating team.

11.3 RESPONSE TO ALARMS

Duty

Site Managers shall ensure that operator response to alarms is appropriate to their criticality.

Operating instructions shall explain the actions to be taken in the event that alarms are activated, stating that every alarm requires a response to bring the plant back within the operating envelope. Routine operation of the plant should not require it to be taken into an alarmed state.

Where plants are provided with Extra High or Extra Low alarms, activation of one of these devices should be regarded as signifying an unacceptable operating condition and should result in an appropriate rapid response from the whole operating team. Returning the plant to a non-alarmed state should take priority over all other non-urgent activities.

The incidence of alarms should be monitored and reviewed by operating management on a monthly basis, with a target of no more than 10 alarms per hour per panel operator.

11.4 HANDOVER

Duty

Site Managers shall ensure that a structured written handover takes place between outgoing and oncoming shift teams.

The handover must include but not limited to;

A detailed review of the status of partially completed start up or shut down operating instructions, product transfers etc

Alarm inhibits and trip overrides in place over shift change.

Unexpected events that happened during the shift.

RDSHE 12 – MANAGEMENT OF CONTRACTORS AND SUPPLIERS

SUMMARY OF STANDARD

Safe operation and maintenance of Petroplus facilities requires controls over the use of contracted services and suppliers. In order to achieve this, the SHE implications of all aspects of work carried out by others on behalf of Petroplus shall be properly assessed and managed.

Competent suppliers and contractors shall be selected, monitored and supplied with sufficient information on the sites and the operational hazards to ensure that the safety and health of their employees is not put at risk by site activities.

Contractors and suppliers shall be required to provide sufficient information to ensure that the safety and health of Petroplus employees and others is not put at risk or environmental compliance compromised.

Monitoring shall take place during the conduct of the contractor activities to ensure the maintenance of high standards of safety performance.

12.1 THE USE OF CONTRACTORS AND SUPPLIERS

Duty

Site Managers shall implement systems and processes to ensure that work carried out by contractors and suppliers is both safe and environmentally responsible.

Site Managers shall ensure the purchase and supply of equipment, raw materials and services shall be specified and monitored to satisfy SHE requirements, including relevant regulations.


All sites shall have a formal contractor management system in place which is appropriate to the nature and extent of the associated risks. Contractor management systems shall include the requirement for formal contractual safety arrangements to be in place to ensure that their activities are carried out in accordance with regulatory requirements.

All contractors and suppliers are to be subject to a risk based evaluation prior to contractual arrangements being established. This evaluation shall consider the nature of their products, activities or services provided and previous safety performance. Contracts shall provide Petroplus with the ability to terminate the contractual relationship with a contractor for unacceptable SHE compliance. The requirement for reporting and the investigation of accidents, occupational diseases and environmental incidents involving contractors should also be agreed as a condition of the contract.

Contractor management systems shall contain documented reporting relationships, lines of consultation and communication roles, responsibilities, accountabilities and system interfaces between contractors and suppliers and the site management.

All sites shall appoint specific representatives to act as a focal point for the management and the oversight of the key contractor and suppliers employed on site. This representative shall review contractor and supplier SHE compliance and liaise with the contractor and supplier management to ensure continuous improvement in their SHE management systems.

There shall be mechanisms in place to notify contractors and suppliers of specific hazards associated with the site applicable to the works to be undertaken (i.e. asbestos).

There shall be processes in place to ensure that the planning of turnarounds and shutdowns includes details of how to manage contractors and suppliers appropriately.

There shall be processes in place to ensure the effective review of the sites contractor management system to ensure that it remains relevant and appropriate to the nature and extent of the associated risks.

There shall be a requirement for all contractors and suppliers to have formal SHE Management systems in place. The following requirements must be included in their SHE Management System:

Arrangements and responsibilities for the selection and use of sub-contractors and the SHE monitoring of their activities.

Arrangements for contractors and suppliers to undertake their activities based upon risk assessment methodologies which reflect legal obligations.

Where Petroplus has notified the contractor of the potential hazards associated with the site, the contractor must provide adequate information, instruction and training to all the individuals concerned, suitable records should be kept and only those individuals should be permitted to undertake the work.

It is the contractor’s duty to, where appropriate, provide suitably detailed job methods so that the SHE compliance implications may be assessed by the company. The contractor’s activities should be audited and monitored regularly against any method statement or other clearly understood criteria.

It is the contractor's duty to supervise his own employees and Petroplus should not assume this responsibility unless it is specifically agreed in the contract.

There shall be arrangements for the evaluation and risk assessment of equipment, materials or services prior to purchase, hire or lease, to ensure their suitability for use and to prevent the introduction of safety hazards and risks. This shall be performed by competent persons.

RDSHE 13 – ENVIRONMENTAL IMPACT

SUMMARY OF STANDARD

Petroplus has undertaken to ensure that the activities in all aspects of the company’s operations do not cause any adverse effect on the environment. There must be procedures in place to identify and manage processes where the groundwater, air, surface water, land in and around the company’s facilities could be harmed by the company’s operations and to monitor the interaction between the company’s operations and the environment.

13.1 THE ENVIRONMENTAL IMPACT ASSESSMENT

Duty

Site Managers shall develop and maintain an assessment of the environmental load or footprint resulting from activities on their sites. In many cases, this assessment will form part of permit applications or periodic reporting in accordance with permit requirements or legislation. The assessment shall take into account the results of environmental monitoring.

Another key part of the assessment will be the arrangements to minimise the risks of contamination of groundwater, land, air and surface water in and around the company’s facilities.


The Environmental Impact Assessment should address the following, for normal operations, start-up, shutdown and overhauls:

Emissions to water.

Emissions to air (including CO2).

Emissions to land.

Waste disposal.

Noise and/or vibration levels.

Usage of natural resources, such as energy and natural water.

Visual impacts.

Odours.

Potential impact from major incidents.

For this purpose the environmental load or footprint for any type of emission shall include a quantity, frequency or emission level when available and a brief description of fate or effect in the environment. The assessment should include the significance and consequences of the identified emissions and relate them to any relevant environmental quality standards or guidelines and (anticipated) emission level values.

The assessment shall be updated whenever a material change in operations or knowledge occurs, or whenever a change in emission level values or legislation can be anticipated.

13.2 ENVIRONMENTAL MONITORING

Duty

Site Managers shall implement a programme to monitor the environmental impact of their activities and to take any corrective action necessary to ensure that they remain within the limits relevant to any government issued permits, or consent limits imposed by relevant legislation, and to identify improvement opportunities.


A monitoring plan and schedule shall be developed and managed by competent persons. Monitoring results will be communicated to relevant departments and, if necessary, changes made to the operations of the site to ensure continued operation within permit limits or consent limits.

Analytical results of sampling will be communicated on an agreed basis to the regulatory authorities.

Monitoring shall include:

Parameters that are suspected to have a significant environmental impact, dependent on value of monitoring and availability of techniques.

Analyses necessary for ensuring continued operation within permit limits or consent limits.

Requirements related to permits or other agreements with authorities. Soil or groundwater contamination near potential sources and in case relevant

migration or exposure risk is identified.

13.3 LAND AND WATER PROTECTION

Duty

Site Managers shall have arrangements in place for the protection of land and water which recognise the need for environmentally responsible site operations.


Operations are to be managed in a way that avoids the contamination of land, surface water, and groundwater. There should be arrangements for preventing and containing any spillages and for providing effective clean-up.

Design of new installations and management of change of existing installations, need to protect land, surface water, and groundwater and to ensure that any spillage or leakage of chemicals or effluent that could cause significant environmental harm is prevented from reaching the environmental receptors. See RDSHE 7 New plant, equipment and structure design.

For existing installations, a strategy should be developed that ensures the progressive achievement of improvement and compliance.

All infrastructures designed for, or having a function in, preventing soil, surface water, and groundwater contamination shall be inspected and maintained on a regular basis. This includes pavement, curbing, drains, sumps, pumps, sewers. See RDSHE 9 Assurance.

Any spillage of liquid hydrocarbons or other hazardous materials on unmade ground or water and any other uncontained spillage of such materials > 5 litres , should be recorded as an incident allowing appropriate follow up..

Any contamination resulting from new spills shall in principle be removed. If a contamination can not be removed (e.g. for technical reasons), this shall be properly documented and include measures taken to prevent any environmental impact.

An ongoing record shall be maintained of spillages, leaks and contamination and remedial actions taken. This record will demonstrate that any contamination resulting from new spills has been removed or otherwise dealt with in an appropriate way. For this purpose “new spills” shall have the meaning of spills occurred after one of the following dates whichever is the earliest:

Date of entry into force of the obligation for the operator of the site to remediate contamination resulting from current operations.

Date of a baseline investigation to determine the status of soil and groundwater contamination.

Date of acquisition of the site by Petroplus.

The record shall be suitable for minimising the liability for soil, surface water, or groundwater contamination to the lowest extent possible.

Documentation should further record:

Details of historical land use and historical contamination. Reports of assessments of contamination, monitoring and remedial activities

undertaken. Permits, orders and minutes with external organisations including regulators. Site plan with monitoring wells and references to entries in the spill record.

A spill contingency plan shall be available for a brief identification of the risks of failing secondary containment and major pollution of off site water or land. The plan shall include the arrangements and equipment available for an effective response.

Each site should identify, assess and at regular intervals review, possible other hazards and risks to human health and the environment and the need for further investigation, protective containment, control, or other remediation measures.

RDSHE 14 – EMERGENCY PREPARDNESS

SUMMARY OF STANDARD

The consequences of any particular incident can be significantly reduced with effective emergency management and response capabilities.

For this reason, the nature and scale of all reasonably foreseeable emergencies shall be identified and adequate systems and procedures to deal with them shall be implemented. Arrangements put in place shall include links with the public emergency services and voluntary co-operative schemes. Plans shall be communicated, regularly exercised and reviewed.

14.1 EMERGENCY PLANS

Duty

Site Managers shall ensure that emergency plans are developed to be able respond to all categories of reasonably foreseeable on-site incidents, and any credible off-site incidents, such as from neighbouring facilities, which may affect assets or personnel on the site.

Categories of incident include; Fire Explosions Toxic Releases Injuries to persons on the site Rescue of personnel and other persons on the site Oil spill leading to, or having the potential to lead to, environmental contamination

or pollution

Principles

a) Assessments shall be made of the type and scale of all reasonably foreseeable on-site and off-site incidents where Petroplus has or may be considered to have responsibility for operation. This will include off-site pipelines where Petroplus has direct responsibility or where pipeline issues can have a direct impact on site activities, other than through the cessation of oil flow. These shall be included in site safety reports and shall be the subject of Pre-Incident Plans based on a systematic approach to risk assessment and management.

.b) Priority should always be given to minimising the risk to persons at the scene of

any incident.

c) Written procedures shall define the actions to be taken by specified job holders and by all other persons on site in the event of such incidents.

Most incidents will be minor in nature and will be managed close to the scene by the on site team.

Incidents that are more serious in nature i.e. those classified as “Major Incidents” (see 14.2), shall be managed by the senior on-site manager in the role of the “Site Main Controller”, from a remote location if this is justified by the nature and scope of the incident.

d) Procedures shall be established to define the processes by which incidents of increasing seriousness are escalated to Major Incidents within the site organisation.

e) Each site should consider the need for procedures for dealing with threats of terrorist or direct action, which should be given serious consideration in consultation with local law enforcement officials.

f) Public Relations support of a local nature should be available either through refinery staff or as a contracted service to the Site Manager. The purpose of such support in preparation for an incident should include ensuring that relevant site historical information is kept up to date for use in advising those making any statement. This support would be backed up in the event of a Major Incident by Loepfe & Partners of Zug who have a contract with the Corporate Communications Manager for this purpose. Loepfe & Partners have associates in the UK, Germany and Belgium.

g) Legal support shall, in consultation with your Petroplus Law Department Attorney, be engaged to deal with investigations, regulatory compliance, law enforcement officials who may seek access to the site, and assist with Public Relations Support efforts.

h) During planning, full consideration should be given to the restoration and recovery activities following any incident.

14.2 EMERGENCY ARRANGEMENTS AND RESOURCES

Duty

Site Managers shall ensure that arrangements are in place to deliver emergency plans

Principles

a) In the event of an emergency, there should be a means of warning people on site and if necessary, off-site.

b) Evacuation procedures should be established and assembly points should be designated in safe areas.

c) There should be arrangements for summoning assistance from the Fire, Ambulance and Police (and other law enforcement) Services and mutual aid services, as necessary.

d) There should be arrangements for maintaining effective communications with the emergency services if the incident develops further.

e) Emergency procedures should include the arrangements for notifying the regulators and other authorities where necessary and for keeping them informed of developments.

f) As part of the emergency response, roll calls should be held to identify positively the whereabouts of all individuals known to be on-site. If these indicate missing persons, search and rescue procedures should be initiated.

g) There should be arrangements for the prompt treatment of any person injured on site and for the provision of necessary medical back up.

h) There should be arrangements for mitigating, where practicable, the effects of liquid, solid or gaseous emissions which could cause environmental damage.

i) Where incidents are identified as having potential off-site consequences, arrangements for assessing their impact should be made, including the activation of off-site monitoring. Based on this information, arrangements for minimising their effects should be agreed with the external emergency services and other relevant authorities.

j) Where incidents which could attract media attention are identified, there should be arrangements for appropriate briefings to be provided. If an outline written press statement has been pre-approved by the relevant Head of Department (for refinery based incidents, this will be the Refining General Manager), then it may be completed and issued on the authority of the Site Main Controller. If no pre-approval has been granted, any written statement will need to be approved by the relevant Head of Department with review by and support from the local and corporate legal teams.

k) Following an incident, it is the responsibility of the Site Main Controller to declare the immediate incident closed and to notify the appropriate parties of this decision. At this point, arrangements for the restoration and recovery phase of the management of the incident should be made.

14.3 EMERGENCY TRAINING

Duty

Site Managers shall ensure that emergency training needs are assessed and that training is conducted, recorded and reviewed to ensure that individuals are aware of their roles and responsibilities in the event they are called upon.

Principles

a) Each person who comes on to an operating site should be made aware of the basic emergency procedures and the actions that they are required to take in the event that the alarm is raised.

b) All those who may have specified roles in emergency procedures should be given appropriate regular training.

14.4 EMERGENCY EXERCISES AND PRACTICES

Duty

Site Managers shall ensure that plans are exercised and practised to ensure that they can be delivered when required.

Principles

a) Emergency exercises should be carried out regularly and should be based on incident scenarios identified in pre-incident plans. At a minimum, this will include periodic exercise of response to release of hydrocarbon from a typical pipe, pool fire and tank seal roof fire.

b) Restoration and recovery exercises shall be included on a periodic basis to ensure that this phase of incident management is covered.

c) Reviews of exercises or practices shall be published and, where appropriate, the lessons from such practices should be incorporated in revised procedures and shared with all relevant personnel.

14.5 MAJOR INCIDENT MANAGEMENT

Duty

Whilst most incidents will be within the capabilities of sites to manage both in respect of the incident itself and its repercussions and implications, a very small percentage will require additional responses from others in the Petroplus organisation. This might apply as a result of an inability to bring the incident under control within a limited timescale or because the implications or results are significant and require communication. In planning for such incidents, Site Managers shall ensure that procedures exist to manage such “Major Incidents”.

Such procedures shall include, as a priority, reporting of the incident to corporate Petroplus management immediately following the decision to declare a Major Incident. This process will allow the relevant Head of Department in consultation with other Petroplus corporate management to respond to the strategic implications of the incident. In particular, they will be able to decide if implementation of the Crisis Management Plan is appropriate.


a) Corporate senior management responsibilities in the event of a Major Incident together with contact details are summarised in the following two documents.

CORP-SHE-001 “Major Incident Response Procedure”

The Emergency Contact list

These documents are to be found on Sharepoint under the SHE Portal.

b) Petroplus recognises three levels of response to incidents, each one of which will be managed by a named individual:

“Operational” – The Incident Controller at the location of the incident manages the direct response to the incident itself.

“Tactical” – In the event that an incident is declared to be a Major Incident, the Site Main Controller, usually the Site Manager, at the location of the incident assumes command of all local activities, to the extent that local legislation permits. The focus of the Site Main Controller’s concerns will be the consequences of the incident. In this he/she will need to think “one hour ahead” and about the off-site implications of the incident. The Site Main Controller is responsible for on-going communications with off-site senior management and with the local regulators and authorities.

“Strategic” – When a Major Incident has been declared, the Strategic Response Manager (SRM) manages the issues of company reputation, the legal implications and coordination of other company functional links. Normally the relevant Head of Department (HOD), for example the relevant Refining General Manager, Marketing Manager or Shipping Manager would fulfil this role. The strategic response will initially be managed remotely, probably from Zug, but the SRM may well conclude that relocation to the site is appropriate after a period of time.

c) Declaration of a Major Incident is a site responsibility based on the guidelines below. It is not possible to be fully prescriptive with respect to the nature of Major Incidents as they can vary in nature. In general, however, if an incident has one of the following characteristics, it would justify categorisation as a Major Incident.

Involving fatal, serious, or multiple reportable injuries.

Resulting in fire, explosion or release of material potentially causing, or causing, serious adverse effects to people or major damage to property or the environment.

With significant, or potentially significant, environmental off-site impact.

Likelihood of media interest or significant adverse public reaction.

Involving kidnapping, sabotage or direct action by terrorist or pressure groups.

Product contamination having a direct SHE related impact on customers or public.

It has serious, or potentially serious, legal repercussions for Petroplus.

d) If a truck transport, railcar, or waterborne vessel incident occurs, which has sufficient business repercussions that it is escalated to the level of Major Incident, it is important that a Petroplus representative attends the scene as soon as possible. Liabilities in the event of truck transport, railcar, or waterborne vessel incidents can be complicated, but where appropriate, the local representative should be of sufficient knowledge and experience to be able to assume a role equivalent to Site Main Controller in terms of authority.

e) All Major Incidents shall be reported IMMEDIATELY following declaration of a Major Incident to the corporate representative assuming the role of Strategic Response Manager.

f) The SRM shall initiate immediate onward reporting including notification to the Executive Committee, Corporate SHE Manager, the Corporate Legal team, the Corporate Communications Manager and the Group Insurance Manager.

g) Where deemed necessary, due to the severe implications of a Major Incident, further escalation to “Company Crisis” would be possible on the authorisation of an

Executive Committee member. In such an eventuality, the strategic aspects of the incident would be managed by a Crisis Management Team (CMT) comprised of senior managers from the Company. In such cases, communication from the site shall be as required by the Crisis Management Team. Site Managers shall have measures in place to allow them to meet the needs of the CMT in these circumstances.

h) Site Main Controllers should be trained to give public statements and have achieved the necessary standard of competence. In order to provide 24/7 cover, this is likely to require a minimum of 3 people at each site to be trained.

i) Requirements in the event of media briefings are referred to above in paragraph 14.2 i. above. With respect to Major Incidents, it is more likely that pro-active briefings will be necessary with the local population and media. Arrangements must be made to support such briefings. Any briefing should always have the approval of the SRM, the Corporate Communications Manager and the Corporate legal team.

j) In the event of a major oil spill, or other high profile shipping incident, the Shipping Manager and Corporate SHE Manager have access to Oil Spill Response Ltd (OSRL), of which Petroplus is a shareholder. This company has global reach and a capability to provide expert assistance around the clock. Contact details are provided in CORP–SHE–001 and contact should be made through the above links with that company.

k) Following the initial response to the Major Incident an investigation team shall be established using the guidance contained within CORP–SHE–002 “Investigation of Serious Incidents”.

14.6 FIRE SAFETY MANAGEMENT

Duty

Site Managers shall ensure that any assessments of the fire hazards associated with the site are carried out and periodically reviewed. For new plant, the fire assessment could be carried out as part of the Hazard Studies.


In addition to the requirements contained with section 14.1, the following topics should be considered under the fire hazard assessment:

a) Fire Prevention

The fire and explosion hazards of materials used on site should be made known to those who work with them, together with the appropriate means of handling such materials so that fire can be avoided.

b) Fire Protection

Appropriate separation distances should be provided and maintained between potential sources of fire and equipment or facilities that could be affected.

Fire detection systems and passive and/or active fire protection measures should be provided as appropriate.

All fire protection and detection systems should be inspected, tested and maintained according to defined procedures.

c) Fire Fighting Facilities

Appropriate equipment (portable extinguishers, hose reels etc) should be provided for use by personnel. On-site specialist fire fighting personnel and equipment should be provided as judged necessary. Fire fighting equipment should be inspected, maintained and where appropriate, tested according to defined procedures.

d) Emergency Response

Each site should have a system of raising an audible fire alarm which can be heard throughout the facility. Suitable systems should be established for notification of the on-site and/or external fire brigade or professional fire service. There should be a system of ongoing liaison with the external fire brigade to ensure they are appropriately familiar with the site.

The required response to fires (local fire fighting, site fire brigade and assistance available from external emergency services, etc.) should be defined in Fire Plans. Fire plans should, where necessary, detail the actions to be taken to minimise harm to the environment from airborne or water borne contamination.

e) Adequate Means of Escape

There should be a written and tested plan covering the means of evacuation of all site personnel in the event of a fire.

f) Suitably Qualified and Experienced Personnel

Persons responsible for site fire safety management should have sufficient knowledge and awareness to discharge their responsibilities and know where to obtain additional professional support.

g) Fire Water Runoff

There shall be an assessment of the risks to the environment from fire water runoff. The requirements for drainage and containment systems to cope with fire water should be assessed and appropriate provisions made, taking into account possible harm to the environment.

RDSHE 15 – SHE RISK MANAGEMENT

SUMMARY OF STANDARD

Risk management is the active process of identifying, assessing, communicating and managing the risks facing our organisation to ensure that the company meets its objectives.

1.1 SHE RISK MANAGEMENT

Duty

Site Managers shall ensure that SHE risks are identified, assessed and appropriately mitigated. Risk assessment processes shall be carried out on routine and non-routine activities and before changes to operations, processes and personnel.

Site Managers shall ensure all personnel, including contractors, are responsible for undertaking risk assessment on their activities, both before and during the work.

Site Managers shall ensure risk assessments can vary in complexity from a simple mental risk assessment to formal studies such as HAZOP and Quantified Risk Assessment. The type of risk assessment required will depend on the risk being assessed.

Site Managers shall ensure written risk assessments are seen as a means of demonstrating that appropriate consideration has been given to the management of risks. Such demonstration is a vital aspect of our licence to operate and written risk assessments shall be produced for the most serious risks.


All sites shall establish and maintain systems for the identification of SHE risks, the assessment of these risks and the implementation of appropriate control measures to ensure that remaining risk is reduced to a tolerable level.

In the event that SHE risks defined by the corporate risk assessment matrix as “serious” are identified, where appropriate the site shall document the basis for continued operation. Plans must be in place to reduce these risks to an acceptable level in a timely manner.

The risk analysis shall define the residual risks which remain after the control measures have been put in place. When these residual risks are significant, an authority approval sign-off shall be in place which accepts the remaining risk.

All SHE risk management processes shall be developed in consultation with competent persons and applied using a consistent approach and documented in a systematic way.

Sites shall ensure methods used for identification of SHE risks and their assessments are appropriate to the nature and extent of the task. These methods shall be formally developed, implemented and maintained by competent persons and shall include the prioritisation and classification of risks to determine the level of significance. The hierarchy of control should be used to reduce the risk to tolerable levels.

SHE risk assessment processes shall consider routine and non-routine activities, planned and unplanned changes, changes to products, procedures, services, work organisation, installations, all equipment and facilities, the design, commissioning and operation of the workplace and human behaviour as appropriate.

The interests of personnel, contractors, suppliers, visitors and local communities and neighbouring businesses should also form part of the overall SHE risk assessment process.

All sites shall ensure that the results of the SHE risk assessment processes are fully communicated to all relevant persons. Where work activities are involved this shall be before the start of the activity. The results of SHE risk assessment processes should be considered when establishing awareness, competency and training requirements.

1.2 CORPORATE RISK MATRIX

Duty

Site Managers and their management teams shall ensure that hazards are risk assessed using the corporate risk assessment matrix (CRAM). Guidance for the use of the CRAM is contained within CORP-SHE-003.

RDSHE 16 – INCIDENT INVESTIGATION AND FOLLOW-UP

SUMMARY OF STANDARD

Arrangements for the investigation and follow-up of SHE incidents need to be in place to ensure that incidents are sufficiently investigated and to identify root causes of such incidents so that actions may be taken, as needed, to prevent a similar occurrence. A process for managing lessons learnt from SHE incidents is also an important part of preventing incidents from occurring on site.

16.1 THE INVESTIGATION OF SHE INCIDENTS

Duty

Site Managers shall ensure that all incidents are investigated appropriately and in a timely manner following such incidents. All investigations should be recorded on the IMPACT system.


The minimum level of investigation carried out following an incident should be in accordance with IMPACT system requirements.

Investigations should be conducted by competent persons who have received adequate training. This should include any persons involved in the incident whenever possible.

Investigations should identify the contributing factors, immediate and root causes of the incident as a basis for recommendations to prevent recurrence.

The root cause techniques used should take into consideration human factors by determining the reason for any intentional or unintentional human behaviour determined during the investigation process as being potentially contributing factors to the incident.

Where appropriate following completion of an incident investigation the results of the root cause analysis undertaken shall be recorded in accordance with the Corporate Root Cause Verification Model in IMPACT.

Investigations should identify and prioritise corrective and preventative actions to reduce or eliminate the risk and recurrence of a similar incident.

Each Investigation lead should consult with the site’s Petroplus Attorney to ensure that legal defences are not compromised during initial and further internal and external investigation processes.

Where it is established that a repeat incident has occurred, a review of actions associated with previous events, and preventative action steps recommended from prior incidents, may or may not have been sufficiently investigated to prevent the current incident.

All sites shall ensure that competent management level employee(s) sign off the investigation process to demonstrate that an appropriate review and assessment has been undertaken as appropriate.

16.2 THE MANAGEMENT OF CORRECTIVE ACTIONS FOLLOWING SHE INCIDENTS

Duty

Site Managers shall ensure that corrective and preventative actions are identified and implemented following an incident investigation. All recommended action steps are to be recorded on the IMPACT system and followed up until completed. A periodic review of the effectiveness of corrective and preventative actions shall be undertaken.


Any corrective or preventative action identified during an investigation shall be thoroughly reviewed prior to implementation to ensure that the action is appropriate to the nature and extent of the hazards and associated risk.

In the event of a significant incident or near miss work shall cease and shall only be allowed to continue once the necessary actions, including re-evaluation of any relevant risk assessments, have been undertaken to reduce the risk of recurrence. Work shall only be permitted to recommence following formal authorisation from appropriate level of management.

Where an action has been identified that results in a change to existing systems or procedures, there shall be systems in place to effectively communicate this information to all relevant personnel.

Each action identified should be reviewed against the appropriate standard in the Corporate SHE Management System Manual to identify any gaps in current management systems.

All relevant information following an incident investigation will be gathered and analysed to identify lessons learned and to identify major trends on a periodic basis. This information shall be reported to management to assist in identifying and assessing the existing or proposed additional control measures.

All sites should use the IMPACT system to physically track action items to ensure that they have been adequately completed and implemented. There should also be a periodic review of control measures implemented to ensure that they remain effective and appropriate.

There should be procedures to investigate all complaints from members of the public and report back to the complainant on the outcome of the investigation. A record should be kept of actions taken to prevent recurrence of the condition that caused the complaint.

16.3 THE COMMUNICATION OF SHE INCIDENTS

Duty

Each site should ensure that important SHE information, such as ‘high learning events’ are communicated to the other sites within Petroplus. See RDSHE 3 Communication.

Each site should have mechanisms in place to ensure that important SHE information, such as lessons learned that have been communicated from Corporate SHE and other Petroplus sites are acted upon accordingly.

RDSHE 17 – SHE PERFORMANCE REPORTING

SUMMARY OF STANDARD

The SHE performance of the company shall be monitored to identify any trends to enable continual improvement in SHE performance. Clearly defined and consistent corporate reporting criteria should be in place.

Arrangements for recording and reporting SHE performance information and statistics to Corporate should be in place at each site.

The Petroplus approach to categorisation of incidents is based on OSHA categories. More detail can be found in the glossary.

17.1 DUTIES TO RECORD SHE RELATED INCIDENTS

Duty

Site Managers shall ensure that systems are in place to record within the IMPACT system, all work related incidents including incidents with the potential to cause:

a) Work related injuries and occupational illnesses to Petroplus employees (including whilst travelling on company business), contractors hired by Petroplus and visitors to premises controlled by the company.

b) Harm to a member of the public or justified complaints from the public.

c) Damage to plant, material or the environment.

d) A breach of or non-compliance with any SHE related legislation.

Site Managers shall ensure that there are systems in place to record the numbers of hours worked by employees and contractors working for the company. The number of hours worked when calculated for employees should include paid overtime and training. Hours worked should be calculated separately for company and contractor personnel.

Site Managers shall comply with all national incident reporting requirements.

17.2 SHE PERFORMANCE REPORTING

Duty

Site Managers shall ensure that the following SHE performance reporting requirements are adhered to.


Each site will report SHE incidents:

a) Immediately by telephone or in person and by e-mail notification to all to the Chief Executive Officer, Chief Operating Officer, Corporate SHE Manager, Petroplus Legal Department, and Refining General Manager.

Major incidents include, but are not limited to:

The death of an employee, contractor working on behalf of the company or third party whilst on a Petroplus controlled premises.

Multiple injuries sustained by employees, contractors working on behalf of the company or third parties whilst on a Petroplus controlled premises that are likely to result in medical treatment.

Any process safety related incident where the business impact is likely to exceed US$2M (CRAM severity level I).

Any incident causing, or potentially causing, significant media/public attention at national or international level or potential reputational damage.

Any environmental incident with potential widespread, long term, significant adverse effects.

Any sabotage/direct action to any premises controlled by the company and any kidnapping of any Petroplus employee or contractor working on behalf of the company.

See RDSHE 14 and CORP-SHE-001 Major Incident Response Procedure for more details.

Note: The Site Main Controller must talk to a Corporate Manager acting as Strategic Response Manager, rather than simply leaving a message:

b) The same day by telephone to the Refining General Manager or the Corporate SHE Manager in person and by e-mail notification to both Managers:

A single major injury to an individual.

Any process safety related incident where the business impact is likely to exceed $500K (CRAM severity level II).

Any incident causing significant media/public attention at a local level or potential reputational damage.

Any environmental incident with potential localized, medium term, significant adverse effects.

Notification of prosecution by a SHE regulatory authority or if a SHE regulatory authority serves an enforcement notice on site.

Physical damage not involving a major incident if production has been affected for more than two hours.

Any incident involving product contamination to customer products.

c) Weekly

Site Managers shall ensure that all incidents and near misses are captured within the IMPACT system and appropriate incidents are submitted for inclusion in the SHE Conference call. Corporate SHE shall compile the SHE Conference call submissions for review by the Corporate Operations and Site Management Team. Material for inclusion in the Site Managers submission will include;

All lost work incidents, restricted work incidents, medical treatment cases and first aid cases and major near misses.

Any process safety related incident.

All incidents which had an (potential) impact on the environment, including any LOPC and non-compliances.

All losses such as financial impact on the company arising from a plant based 'non-major' incident > $100K (CRAM severity level III).

Any complaint received from neighboring properties or the local community.

Any breach of or non-compliance with any operating permit consent limits.

d) Monthly

Site Managers shall report the following information on a monthly basis to Refining General Management and Corporate SHE to allow the SHE performance of the company to be monitored:

Process safety indicator values and safety statistics required by the monthly Stewardship Report.

Personal safety indicator values and safety statistics required by the monthly Stewardship Report.

Environmental indicator values required by the monthly Stewardship Report.

The number of road incidents on site.

e) Annually

Site Managers shall report the following information to Corporate SHE for inclusion in the Annual Operations Performance Report for the Company’s Board of Directors:

A summary of the all incidents that have occurred at the site. This will include information on frequency rates, trends, analysis of root causes, and implications and corrective actions.

A summary of all issues associated with regulatory compliance. This will summarize all contacts with the regulatory authorities and will provide specific information about any statutory notices and breaches of consent. The summary should also include details of all current and new SHE-related litigation that has occurred during the year.

RDSHE 18 – MONITORING OF SHE PERFORMANCE

SUMMARY OF STANDARD

The monitoring of SHE Performance is an essential aspect of business operations. It helps management to identify areas of improvement so that action can be taken to minimise the potential of an incident occurring and to demonstrate compliance with legislative requirements and the Corporate SHE Management System Manual.

18.1MONITORING, AUDITS AND REVIEW

Duty

Site Managers shall ensure that SHE performance is monitored, audited and reviewed to identify trends, monitor progress, access compliance and identify necessary improvements and to share good practice.


All sites shall establish and maintain programs to monitor and measure SHE performance on a periodic basis. The criteria shall be consistent with the principles used in internationally recognised management system standards such as ISO 14001, ISO 9001 and OHSAS 18001.

18.2AUDITS

All sites shall establish, document and maintain a formal audit program that ensures the effective monitoring of conformance to the standards contained within the Corporate SHE Management System Manual.

The audit programs shall be based upon a risk based approach, the results of previous audits and be appropriate to the nature and scale of the hazards and associated risks.

The program shall be defined in terms of scope, frequency, methodologies, competencies, roles and responsibilities for conducting audits and reporting results.

Audit programs should include SHE management system audits, behavioural audits, department audits, appropriate technical audits, contractor audits and third party audits.

Management shall be actively engaged in appropriate audits ensuring effective, visibly felt leadership, mentoring and coaching are demonstrated.

18.3REVIEW

All sites shall have formal process (e.g. safety plans) for responding to and for the monitoring of actions resulting from the audit program to ensure that issues are completed appropriately and in a timely manner.

The findings from audits shall be analysed and utilised in the process for continual improvement.

Audit programs should be reviewed on a periodic basis to ensure that they remain applicable and relevant.

PART 3: GLOSSARY OF TERMS

An authority approval sign-off

A person who has been officially designated as competent to give approvals or sign off on a document.

Breach of any SHE Related Legislation or Governmental Regulation

Any matter which has to be reported to local government officials or national regulators which is not covered by any other Corporate reporting requirement.

Competent Person

A person who has suitable qualification, experience, skills and attitude to do the intended role or activity.

Complaint (environmental)

A complaint has been classified as a justified complaint received from the outside community, including neighbouring companies, persons or authorities, which are related to any environmental impact to which the company might have contributed.

Complaints from employees or contractors being on site and complaints that were addressed mistakenly to the company and can be rejected. Multiple complaints all arising from one single (no repeat) event can be counted as one complaint.

Critical Operating Instructions

Operating Instructions; are comprehensive written procedures (including procedures that are stored electronically and printed on demand) for operating plant and equipment.

They are designed for use by the operating team and include detailed information on all aspects including normal operation, plant start-up, shutdown, complex or infrequent tasks and action in the event of alarms and trips etc. They are specific to individual pieces of plant equipment, list the steps for a given task and describe the manner in which the steps are to be performed.

Damage to Company Reputation

A situation which could result in negative impact on company reputation as a result of an incident or near miss. The negative impact can be in the form of adverse attention from media or action groups or public concern about company activities.

Environmental Exceedance

An exceedance is a measure of the number of formal breeches or exceedances of any consent or permit limit, including emissions or emission limit values, or time periods for satisfying improvement conditions, as described in environmental regulations, permits and orders.

Explosion

An incident which results in a rapid increase in pressure caused by the ignition of flammable vapours. This may occur either within equipment (overpressure explosion) or in the atmosphere (vapour cloud explosion).

Fatality

A death resulting from a work related injury or occupational illness, regardless of the time between the incident causing the injury or exposure or causing illness occurring and the death.

Any non work related death of an employee, contractor working on behalf of the company or third party whilst on a Petroplus controlled premises should be reported to Corporate Operations Management but not recorded as a fatality with regards to SHE performance data.

Fire

An incident that requires the use of fire fighting equipment or other extinguishing means e.g. shut off fuel or switch off electricity supply. Fires with no visible flame, e.g. oil soaked insulation, should also be included.

First Aid Case (FAC)

Any single treatment and on going observation of a minor injury that does not typically require medical treatment by a medical physician. By the nature of the injury sustained, such treatment and observation is considered a First Aid Case even if provided by a physician or registered medical professional personnel.

The following injuries are classified as First Aid Cases:

Using medication at non-prescription strength Administering tetanus immunizations Cleaning, flushing or soaking wounds on the surface of the skin Using wound coverings such as bandages, plasters etc Using hot or cold therapy Using non ridged means of support such as elastic bandages Using temporary immobilization devices while transporting an person

who requires treatment Using eye patches Removing foreign bodies from the eye using irrigation or cotton swab Removing splinters or other foreign material from areas other that the

eye by irrigation, tweezers, cotton swabs or other simple means Draining of fluid of a blister Using massages (excluding physiotherapy treatment etc) Drinking fluids for relief of heat stress

For injuries that do not fit the criteria as defined further guidance on First Aid Cases can be found on the OSHA website.

Hierarchy of Control

The following hierarchy of control should be used to manage risks. Each step should be considered in order: elimination, substitution, isolation, reduction, safe systems of work, good housekeeping, information, instruction, training, supervision and personal protective equipment.

Incident

An unplanned event or chain of events that has, or could have, resulted in injury or illness or damage to assets, the environment, company assets or the reputation of the company.

Incidents do not include operations, maintenance, quality or reliability incidents which had no potential or actual SHE consequence.

Injury

A wound or other condition of the body caused by external force including stress or strain. The injury is identifiable as to time and place of occurrence and member or function of the body affected, and is caused by a specific event or series of events within a single day or work shift.

Lost Work Incident (LWI)

A work related injury or occupational illness which results in the person being unable to work on any day(s) after the injury or illness regardless of whether the person was scheduled to work.

Lost Work Incident Frequency (LWIF)

The number of lost time incidents per 200, 000 working hours.

Major Injury

Injuries with actual consequences to the company that rate as severe, major or serious on the Corporate Risk Assessment Matrix.

Mechanical Integrity Inspections

This can be defined as inspections carried out to measure the effectiveness of the process safety management system to ensure that critical plant and equipment is functional.

Critical plant and equipment; Plant and equipment is defined as being relied upon to ensure safe containment of hazardous materials and stored energy, and continued safe operation. This is to include the following:

Pressure vessels Piping systems Atmospheric storage tanks Relief devices

Medical Treatment Case (MTC)

An incident is classified as a Medical Treatment Case when the treatment received by a person who has sustained a work related injury goes beyond the first aid treatment provided. Medical treatment does not include first aid treatment even if a physician or registered professional personnel provide this. Diagnostic procedures, such as x-ray are not classified as a medical treatment.

Minor Injury

Injuries with actual consequences to the company that rate as significant on the Corporate Risk Assessment Matrix.

Must

This is an instruction and requires action to be taken.

Near Miss

An incident that could have caused illness, injury or damage to assets, the environment or company reputation, or consequential business loss, but did not have such results.

Number of alarms per DCS Berth

This metric is a measure of the time a distributed control system (DCS) or panel operator has to be aware of an alarm review if action is needed in response to the alarm and take the required action.

The alarms should be processed in such a manner as to avoid operator overload at all times (alarm floods). The alarm processing should ensure that fleeting or repeating alarms do not result in operator overload even under the most severe conditions.

Number of Temporary Modifications Overdue

This metric is a measure of the effectiveness of the process safety management system to ensure that temporary modifications are reversed in a safe and timely manner and they do not become permanent changes without further appropriate risk assessment.

There shall be a system which records all temporary modifications. This system must include an anticipated reversal date; unless there are exceptional circumstances the reversal date must be no longer then the time to the next overhaul.

If the temporary modification has not been signed-off as removed by the specified reversal date then this should be flagged as overdue.

The reversal date should not be extended automatically; the signatories must review the status of the modification to ensure that:

circumstances have not changed that either invalidate the original risk assessment, increase hazards or negate mitigation steps put in place against identified hazards, and

mitigation steps or controls put in place originally remain in place.

If these requirements can not be satisfied, then the status of the plant and the acceptability of continued operation should be reconsidered.

Occupational Illness

Any work related abnormal condition or disorder affecting the health of an individual, other than one resulting from an injury that is caused by or mainly caused by exposures at work.

Occupational illnesses include acute and chronic illnesses or diseases that may be caused by inhalation, absorption, ingestion or direct contact.

Permanent Total Disability (PTD)

Any work related injury or occupational illness that permanently incapacitates an employee that results in termination of employment.

Premises controlled by the company

Premises where Petroplus is the owner, lessee, or is otherwise responsible for the operation of property, structure or a building.

Process Safety Incident

An incident should be reported as a Process Safety Incident if it involves chemicals or chemical processes and also involves one or more of the following;

The sudden release of material above a threshold defined by the US Centre for Chemical Process Safety

A fire or explosion resulting in direct cost >$25,000 to Petroplus A lost time injury or fatality

Restricted Work Incident (RWI)

A work related injury or an occupational illness which results in the person being temporarily unable to perform routine functions of his or her job, or from working the full work day that he or she would otherwise have been scheduled to work.

If a physician or registered medical professional personnel recommends that a person who has sustained a work related injury or illness should not perform routine functions of their job or should be given alternative functions to perform during a period of recuperation then this would be classified as a Restricted Work Incident.

Review

A review should occur at a defined frequency to assess the validity of the instruction, be signed off the document owner for the procedure to be reissued. A review of an instruction may be made, outside of the formal review process, at any point as deemed necessary but must again be signed off the document owner to be reissued.

Critical operating instructions are defined as those provided for start up, shutdown and emergency use.

Road Transport Incident

An incident involving a vehicle driven by a company or contractor employee, whether on or off the road, that has resulted in injury, illness or damage to assets, the environment or the company’s reputation, irrespective of the cost of repair or responsibility for cause.

Safety Instrumented Protective Systems Reliability

This is defined as a measure of the effectiveness of the preventative maintenance programme for the Safety Instrumented Systems (SIS) on the refinery. i.e. Trip and alarm systems.

Many process safety excursions are prevented by either an alarm alerting an operator to make manual intervention or a trip system automatically operating to return the system to a safe state. It is therefore essential that these systems operate as intended and form an integral part of the preventative maintenance programme.

The measurement is for those systems when tested would not have functioned as they were designed to do so and would not have provided intended protection from a process excursion.

Safety Instrumented System Testing

This metric is a measure of the effectiveness of the process safety management system to ensure that safety instrumented protective systems are tested on a frequency associated with their criticality and reliability and often derived from SIL or LOPA assessment This involves the collection of data on the delivery of planned testing of Safety Instrumented Systems.

Shall

This is an instruction and requires action to be taken.

Should

Is used to indicate an obligation or duty that requires action to be taken where reasonably practicable.

Significant

Extensive or important enough to merit attention.

Spill

A spill is an unplanned or uncontrolled release of hydrocarbons or chemical substances to the ground or water. According to the Corporate SHE Management System, any spillage of liquid hydrocarbons or other hazardous materials on unmade ground or water and any other spillage of such materials > 5 litres, should be recorded as an incident and an appropriate investigation carried out.

Third Parties

Persons or organisations that are not employed by or contracted to a company or Contractor.

Total Recordable Incidents (TRI)

The sum of all lost time incidents, restricted work incidents and medical treatment cases.

Total Recordable Incident Frequency (TRIF)

The number of Total Reportable Incidents per 200, 000 working hours.

Total Recordable Occupational Illness (TROI)

The sum of all identified occupational illnesses. Cases involving no lost work or restricted work incidents and no medical treatment are included. A single exposure can give rise to several occupational illness cases.

Total Recordable Occupational Illness Frequency (TROIF)

The number of occupational illnesses per 200, 000 working hours.

Total Sickness Absence

Absence from work on grounds of incapacity to work due to any sickness and injury, work related or not, expressed as percentage of total workdays available. All other cases of absence such as pregnancy, childbirth, leave, training and seminars are not included in the definition of absence.

Vehicle

A vehicle is defined as a car, van, light vehicle, heavy goods vehicle, road tanker, bus, motorcycle or any unit under tow, e.g. trailers, caravans, mobile generators.

Vehicle Kilometres Driven

The number of vehicle kilometres travelled during work related activities whilst being driven by an employees or contractor working on behalf of the company.

Working Hours

Hours worked by own staff and contractors. Estimates should be used where contractor data is not available.

20100324 3rd Edition Corporate SHE Management System Manual

Documents

Transcript of 20100324 3rd Edition Corporate SHE Management System Manual