Professional Documents
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964
INSPECTION SERVICES AND PLANT INSPECTORS
ON VARIOUS STANDARDS Rev.00
HSE Plan
PROJECT NO.
CLIENT:
CONTRACT.
TITLE:
HSE PLAN Doc. No. 964
INSPECTION SERVICES AND PLANT INSPECTORS
ON VARIOUS STANDARDS Rev.00
DISTRIBUTION LISTING
REVISION CONTROL
Region
MIDDLE-EAST & NORTH AFRICA/COMMONWEALTH OF INDEPENDENT STATES (MENA/CIS)
ASSOCIATED DOCUMENTS
CONTENTS
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1.0 INTRODUCTION...................................................................................4
2.0 PURPOSE AND SCOPE...........................................................................4
3.0 DEFINITIONS, ABBREVIATIONS & REFERENCES.............................................5
4.0 LIN SCAN HSE MANAGEMENT SYSTEM OVERVIEW.........................................6
5.0 POLICY, LEADERSHIP AND COMMITMENT...................................................7
6.0 HAZARDS AND EFFECTS MANAGEMENT PROCESS..........................................8
7.0 PLANNING, OBJECTIVES, TARGETS & LEGAL REQUIREMENTS..........................9
8.0 HEALTH SAFETY AND ENVIRONMENTAL PERFORMANCE TARGETS...................10
9.0 ORGANISATION, ROLES, RESPONSIBILITIES & RESOURCES.............................15
10.0 TRAINING & COMPETENCY....................................................................26
11.0 DOCUMENTATION, IMPLEMENTATION & OPERATIONAL APPROACH..................29
12.0 COMMUNICATION AND CONSULTATION....................................................32
13.0 CRISIS AND INCIDENT MANAGEMENT.......................................................36
14.0 COMPLIANCE ASSURANCE AND CORRECTIVE ACTION...................................39
15.0 PERFORMANCE REVIEW & IMPROVEMENT.................................................41
16.0 SUBCONTRACTORS MANAGEMENT AND REQUIREMENTS................................43
17.0 HEALTH MANAGEMENT........................................................................44
18.0 SECURITY MANAGEMENT......................................................................47
19.0 SOCIAL PERFORMANCE (SP)....................................................................48
1.0 INTRODUCTION
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Eni Iraq NV. hereafter referred to as ENI has requested LIN SCAN International (UAE)
LLC hereafter referred to as LIN SCAN, to submit a draft HSE plan as part of the
tender process for the award of general maintenance services carried out in the
Zubair Oil field, Iraq.
The purpose of the project HSE plan is to provide a system and strategy to enable the
execution of the health, safety, and environmental policies, the business objectives,
and ensures the Health Safety and Welfare of all personnel working on the project,
together with the protection of the environment whilst carrying out the project work
in compliance with ENI, LIN SCAN requirements, and the legal requirements of IRAQ.
This plan defines the framework for LIN SCAN employees and subcontractors working
on the project and defines their responsibilities, the execution strategy and
methodologies for implementation of the HSE requirements. It is designed to provide
a disciplined framework for management of all aspects of HSE activities for the
project. The plan identifies the procedures used for the mitigation of risk and the
subsequent elimination or reduction of evolving risks to LIN SCAN employees,
subcontractors and ENI employees or visitors. Continuous improvement is facilitated
in all health, safety, and environmental matters through effective management and
good working practices.
This is a ‘live document’ and is applicable to all phases and functional aspects of the
work scope of the project. All subcontractors shall align their HSE plans for their
scope of Work in line with this document.
3.1 Definitions
3.2 Abbreviations
Abbreviations Descriptions
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3.3 References
LIN SCAN HSE management system (HSEMS) provides the framework to enable
management of the implementation of specified standards, procedures and practices
in a consistent manner. It defines the application of HSE into the work practices,
processes, and systems for general maintenance execution and delivery. LIN SCAN
HSEMS identifies requirements relating to HSE and provides the baseline for
application and project execution in compliance with the health, safety and
environmental management systems requirements prescribed in OHSAS 18001:2007
and ISO 14001:2004 respectively.
designed to complement the project HSE plan and provide a disciplined framework
for management of HSE aspects for the project. It is the link document to ENI and LIN
SCAN HSE management system for project application.
The project HSE plan will utilise procedures, specifications and guidelines, forms /
check lists for potential application on the project. It is a “live” document and will
change in content as the project evolves. In addition, will include the following:
Waste management
Emergency & medical response
Project HSE forms & checklists
Job hazard analysis / Risk assessments
Safe Work Instructions
Subcontractors HSE plans
LIN SCAN and ENI HSE policies provide a framework for setting project HSE objectives
and will be applied overall to all project activities.
All subcontractors shall implement HSE polices during execution of their scope of
work in line with LIN SCAN and ENI HSE polices to achieve project HSE objectives. LIN
SCAN and subcontractors shall abide by ENI’s Drug and Alcohol policy when on ENI
managed locations.
LIN SCAN contract manager is responsible to develop a project HSE commitment
statement and the statement will be signed by the ENI representative project
management. This statement encompasses health, safety and environmental
protection and demonstrates the commitment throughout the project organisation.
LIN SCAN contract manager is responsible to ensure HSE policies and project HSE
commitment statement is communicated to all the project employees.
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6.1 General
The LIN SCAN contract manager is responsible to ensure that all project hazard and
effects are systematically managed to ensure maintenance is carried out on the
facilities to support immediate and long term HSE sustainability.
The Zubair Oil Field facilities will be given the highest priority to plant integrity and
to all health safety and environmental (HSE) issues during the shutdown phases. It
shall be the prime responsibility of the management team to ensure protection to the
health & safety of people inside and outside of the plant premises, the protection of
property and services, and protection of the environment.
During all general maintenance activities, LIN SCAN area co-ordinator is responsible
for ensuring that all hazards and risks associated with the general maintenance
activities are identified, to assess their likelihood and consequence, analysing the
cause and ensuring that LIN SCAN and subcontractors are implementing control
measures to manage the risk to ALARP effectively in consistency with ENI
requirements.
The LIN SCAN project team shall guide subcontractors and participate as stakeholders
to ensure all hazards analysed and control measures identified to reduce the risk to
an ALARP condition for respective scope of works.
These assessments will be conducted such that they can reflect how the identified
HSE hazards and risks are to be managed throughout the applicable project phases.
The results of the assessments will be incorporated into the work execution plans,
method statements and further reflected in the Permit to Work, where applicable.
The hazard and effects register lists all hazards and control measures /actions
identified from HAZID, HSE WORK SHOP/ HSE Case etc. Its purpose is to provide a
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system to enable the project to identify and review hazards, assess potential risks
and implement appropriate control measures.
progressively hazards can be added from review of hazard / Near miss reports,
incident reports, safety inspections and audits etc.
During all general maintenance activities, LIN SCAN area co-ordinator is responsible
for ensuring necessary precautions are taken to protect the environment. All
environmental aspects and impacts associated with the general maintenance
activities are identified, to assess their likelihood and consequence, analysing the
cause and ensuring that subcontractors are implementing control measures to
mitigate the effects on the environment and to reduce the risk effectively in
consistency with ENI requirements.
7.1 Objectives
The LIN SCAN contract manager is responsible for setting and implementation of
Project HSE objectives and targets. He may delegate the coordination of such activity
to the LIN SCAN HSE manager for implementation and ensure all subcontractors
implement HSE objectives in line with following project HSE objectives.
Activities involving the general maintenance of the Zubair Oilfield facilities are
to be carried out, to enable operations to a high and consistent standard
To execute the project in accordance with ENI & LIN SCAN HSE polices and
defined standards on HSE at work
To ensure sufficient hazard assessments are carried out, that risks are identified
through the risk assessment process and suitable controls are in place to mitigate
any residual risk, ensuring work activities are carried out to meet ‘As Low as
Reasonably Practical’ (ALARP) principles
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Maximize the efficiency of resources and energy usage throughout the execution
of the project
To implement the HSE management system and deliver best in class performance
in the execution of the project
Identification of HSE training and delivery, and skills requirements for all
employees and Subcontractors
An HSE audit and review programme assuring compliance with, and effectiveness
of, systems and processes, reviewed and acted on by Project Management
Project HSE performance targets in the form of Key Performance Indicators (KPI’s)
have been developed for HSE compliance. Both “leading” and “lagging” HSE KPI’s are
used with a focus on “leading” indicators. This philosophy will ensure an emphasis on
the execution of proactive measures identified as those that reduce the risk of
incidents rather than relying on “counting” the number of incidents.
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Each month the LIN SCAN HSE manager will compile a KPI report to present to project
management for presentation/discussion in the monthly project HSE management
committee meeting. The LIN SCAN contract manager is responsible to review the
KPI’s and identify and implement measures to achieve continual HSE performance
improvement and also ensure all subcontractors implement initiatives to achieve
these targets.
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The contract manager will ensure all such information is issued to all relevant
disciplines. Should this information change as new legislation comes into force, it is
normal for the LIN SCAN HSE manager to bring this to the attention of the Contract
manager who is responsible for disseminating throughout the team.
A legal register will be established during the early stages of the project. The legal
register will be developed at our head office and later transferred during the
execution stage, the register will be handed to the site team to maintain and update
as and when necessary. The register provides evidence of legal review and describes
the aspects and impacts of relevant clauses in legislation. All applicable Iraq
Government safety, health and environmental regulations and all ENI standards,
Procedures, Instructions, rules and regulations applicable to the work shall be
updated in the legal register.
At any time during the performance of the WORK, the LIN SCAN contract manager
will ensure that all applicable local laws, rules and regulations and other
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international regulations shall be adhered to and complied with by all parties with
particular attention to:
LIN SCAN HSE management system is included as Figure 8.2.1. It is further explained
within Section 8.3
8.3 LIN SCAN HSEMS Alignment with OHSAS 18001 & ISO 14001
LIN SCAN HSE management system has several interlinked elements developed to
align with OHSAS 18001:2007 and ISO 14001:2004 management systems. These
elements are as follows:
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The LIN SCAN contract manager is responsible to ensure all subcontractors comply
with the applicable local laws, labour law requirements, rules and regulations and
other international regulations pertaining to the work execution at all related
locations.
The LIN SCAN contract manager with the assistance of the LIN SCAN HSE manager is
responsible to develop an HSE activity plan considering project activities, hazards
and risks and ENI requirements. A further requirement is to identify Key Performance
Indicators against HSEMS standards and implement an effective HSE management
system and project HSE plan. The annual HSE activity plan shall be reviewed and
updated periodically.
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HSE Manager
The LIN SCAN contract manager is responsible to provide required HSE resources and
ensure subcontractors establish and maintain sufficient and competent resources
(people, equipment, materials, and information) needed to implement LIN SCAN HSE
requirements, comply with regulatory requirements and laws and deliver the project
HSE plan effectively.
LIN SCAN project HSE organization structure for Iraq is provided as Appendix
3.02.d.1.2. All subcontractors shall submit their HSE organisation charts along with
their HSE plans for LIN SCAN and ENI review if appropriate.
LIN SCAN shall have a dedicated HSE Manager assigned to the project during the
planning and execution of the work and is supported by site HSE personnel and
independent specialists where required. The HSE manager shall, on behalf of LIN
SCAN, be responsible for coordinating all health, safety, and environmental (HSE)
matters or aspects related to the activities and shall work with the Security Manager
for the safe execution of the subcontractors’ work activities, meeting the Pre-
mobilisation and start of deliverables, launching the Key HSE programmes; the
preparation of the related safety procedures and the monitoring/control of their
implementation.
LIN SCAN shall ensure subcontractors provide dedicated HSE resources for the project
including HSE manager and safety officers for the scope of work in accordance with
LIN SCAN requirements. Overview of LIN SCAN organisation (Project management
team) roles and responsibilities are described below. Subcontractors shall describe
their HSE organisation, roles and responsibilities in their respective HSE plans.
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The Project management team members and supervisory positions have key roles in
implementing and monitoring the Project HSSE management plan. The Key team
members and project personnel are:
Contract manager
Area co-ordinators
Employees
The contract manager has overall responsibility for the effective implementation of
the project HSE management system and plans throughout all phases of the project.
The project management Team shall support the contract manager in this endeavour.
The contract manager is required to demonstrate visible leadership and commitment
and provide resources to enrich the project’s HSE culture. The key responsibilities
are as follows:
Ensure legislative obligations are met and ENI and LIN SCAN HSE policies are
effectively deployed to the operational areas through the planning process;
Promote positive safety culture and obtain commitment from all the project
personnel to achieve project “Horizon Zero” target.
Ensure required HSE studies are carried out to assess, reduce/eliminate project
risks to ALARP.
Develop and implement HSE objectives and targets and review performance
periodically to achieve continual improvement.
Ensure all incidents are documented via incident reports and investigations
reviewed and review all incident reports.
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Take action to immediately rectify any unsafe situations or acts and undertake
appropriate disciplinary action against persons and subcontractors who fail to
fulfil their HSE responsibilities;
Ensure safe work procedures are defined and documented for each task and
implemented.
9.3 LIN SCAN Area Co-ordinator – There is no position like this. Use title from existing
position
Reports to the contract manager, and is responsible for all site and associated
activities. He works closely with the site HSE manager and all other Managers in co-
ordination and execution of HSE plans & procedures.
The LIN SCAN area co-ordinator has the overall responsibility and accountability to
ensure that Project HSE plans and procedures are developed and implemented with
prescribed processes, procedures and safe working practices and that employees and
Subcontractors reporting to them are aware of HSE policies and managements HSE
expectations.
The LIN SCAN area co-ordinator plays a critical role at the interface of the planning
and implementation/monitoring phases of the project HSE plan
Provide leadership to the LIN SCAN and subcontractors project team as it meets
the overall objectives of the HSE program
Ensure all subcontractors are aware of ENI and LIN SCAN HSE policies and HSE
plans and further effective implementation
Ensure comprehensive risk management practices are engaged by LIN SCAN and
Subcontractors for hazards specifically relevant to the project
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Allocate responsibilities for safety critical positions at the workplace and ensure
those responsibilities are understood and carried out in compliance with the
project HSE plan
Ensure developing safe working practices for all potentially hazardous tasks
where there is potential to injure persons or damage plant or equipment
Ensure procedures and facilities to manage first aid, firefighting and emergency
response capabilities
Ensure all subcontractors comply with the relevant legislative, policy and LIN
SCAN requirements
Attend toolbox meetings and meetings as required as per the frequency and
schedule
Ensure all personnel (LIN SCAN and subcontractors) are suitably qualified,
experienced, fit to work and trained to undertake their work activities in a safe
manner
LIN SCAN HSE manager reports directly to the contract manager and is supported by
site HSE personnel and independent specialists where required. Reviewing project
requirements and developing required HSE plans, procedures and standards for
maintenance HSE activities. Working closely with the other managers of technical,
Quality assurance/Quality control to ensure HSE requirements are included in project
documents and procedures.
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The responsibilities and accountabilities of the LIN SCAN HSE Manager are:
Provides support to contract manager and his team on all technical and HSE
related issues throughout all project phases
Ensure that all the hazards associated with the development of the project HSE
management system, HSEMS supporting plans and procedures are identified and
assessed, and that appropriate controls are put in place to reduce risks to ALARP
Monitor, audit and review implementation of the HSEMS and HSE plans
Provide advice to the project team to resolve HSE issues in a timely and
effective manner
Provide advice and information on HSE matters relating to all site / facility
personnel
Coordination and scheduling of HSE review activities and meetings with ENI and
subcontractors
Coordinate and organise HSE meetings, workshops etc as per the project HSE
plan and schedule with LIN SCAN, subcontractors and ENI management
Co-ordinate with subcontractors and ensure all incidents are reported and
investigated
Ensure LIN SCAN and subcontractors comply with the legal requirements of Iraq
and review compliance periodically
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Review the effectiveness of the HSE performance and report to ENI and as
required
Directs, manages and trains other field health and safety staff as necessary to
attain HSE management standards set by the project;
The HSE coordinator reports to the LIN SCAN area co-ordinator and functionally to
the HSE manager and is responsible for supporting the LIN SCAN area co-ordinator and
reviewing, monitoring, auditing and reporting HSE performance of the general
maintenance activities.
The HSE coordinator’s main duty is to advise and guide the area co-ordinator on HSE
management issues and oversee Subcontractors HSE performance and implementation
of this HSE Plan. Responsible for coordinating all health, safety, security and
environmental (HSSE) matters or aspects related to our activities, and those of our
subcontractors, launching the Key HSE programmes, preparation of related safety
procedures and the monitoring/control of their implementation, including those
related to workers welfare. Key responsibilities are:
Ensure subcontractors develop HSE plans and procedures and are consistent with
LIN SCAN requirements as applicable and are approved for LIN SCAN & ENI
implementation
Co-ordinate with all subcontractors for HSE performance data collection to meet
project reporting requirements
Maintain a daily working relationship with the HSE team, line management and
Subcontractors in relation to their compliance with the provisions of the Project
HSE Plan and regulatory requirements
Ensure effective implementation of LIN SCAN golden rules of safety, JHA, and
other HSE programmes and cascade the requirements to the Subcontractors for
implementation
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Ensure LIN SCAN personnel and the personnel of Subcontractors are fully trained
and competent with respect of all HSE aspects of the work. Ensure Inductions are
given to all project personnel
Ensure the project HSE requirements are communicated to all and verify
compliance through follow-up meetings and audits
Ensure emergency preparedness and response plans and resources are readily
available at all the times and drills conducted regularly
Ensure medical facilities and medical resources are adequately provided for the
project
Review and monitor environmental control plan i.e., Waste management plan
The Security manager reporting to the contract manager is responsible for developing
the project security management plan. The main responsibilities including:
Develop project Security management plan in line with the ENI security
philosophy, Security policy and ENI Security arrangements for effective
coordination and implementation
Coordinate / Liaise with ENI Security Dept for day-to-day Security management
Take active part in emergencies for evacuation and medical emergency etc and
coordinate with ENI
Develop and implement access control systems for the project in line with ENI
requirements
Coordinate with ENI for personnel screening with regard to security and criminal
threats to the project LIN SCAN and ENI
Liaise with ENI, local and Iraqi law enforcement, security and government
agencies as required
The HSE Officer (if required, otherwise responsibilities will be reallocated) reporting
to the HSE Manager shall provide specialist day to day information to the
management team, for all maintenance activities in the Zubair field for maintenance
and shutdown personnel and Subcontractors staff.
Provide field support to LIN SCAN Area Co-ordinators and Supervision to guide
HSE Safe working practices, Project HSE Requirements etc;
Co-ordinate the workplace inspection program and assist with regular internal
HSE audits of the system and / or associated processes, procedures and work
practices; Perform inspections and audits as per Project Compliance Assurance
Schedule
Communicate LIN SCAN golden rules of Safety and Company Rules to all project
personnel and ensure proper implementation
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Ensure all project activities are carried out safely and guide site supervision on
the day-to-day safety issues
Participate in Emergency Response Drills and ensure all resources are readily
available
Ensure and monitor the requirements for P.P.E, Lifting Operations, and Working
at Heights, using power tools, Hazardous material storage etc
Ensure the Project HSE requirements are communicated to all and verify
compliance through follow-up meetings and audits
Our personnel will utilize our Security first aiders and the facilities of the first
responders, and they will assist the project team to facilitate the following actions:
Ensure all major Subcontractors establish satellite first aid facilities as per LIN
SCAN requirements
Conduct health & hygiene inspections per HSE plan inspection schedule
Ensure effective fitness to work process for LIN SCAN personnel and ensure
Subcontractors have the fitness to work process to assure all the personnel
engaged on the project are fit for their work.
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LIN SCAN HR department will ensure the following through the pre-employment
process:
Review / Audit pre-employment medical testing to ensure employees are Fit for
Duty
Ensure entire project personnel fitness to work certificates are provided and
verified.
Accept they are “key” to HSE performance and responsible for their crews’
implementation of HSE practices
Identify and control hazards by ensuring Job Hazard Analysis and WMS developed
for critical activities and implemented
Know, understand and supervise their work with the expectations and standards
of HSE policies and procedures and fully apply the Project HSE Plan
Take all reasonable action to optimize the HSE performance of his subordinates
Initiates incident/ near miss investigations and participate and assist in the
preparation of required reports
Communicate the LIN SCAN golden rules of Safety and implement throughout the
project
Implement project PTW where applicable and ensure precautions taken as per
the PTW
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Use Tool Box Talks, JHA’s Risk Assessments & Safe Work Instructions to identify
hazards in work tasks of their crews & implements controls to keep the job site
safe & incident free
Check with work crews for any health-related issues prior to starting work /
monitoring health of work crews
All personnel employed on the Project are responsible and accountable for:
Accepting individual responsibility for their own safe behaviour as well as sharing
responsibility with their fellow workers and line supervision to “look out for their
own as well as their co-workers” safety
Work in a safe manner at all times and contribute to the implementation of the
“Incident and Injury Free” philosophy
Take reasonable care for the safety of themselves and other personnel who are
at the workplace and who may be affected by any acts or omissions on their part
Comply with the safe working policies, procedures and practices adopted by LIN
SCAN as part of the safe working system
Co-operate with their employer in ensuring that their workplace is as safe and
healthy as is reasonably practical
Report to their supervisor any hazard or potential hazard in the workplace or any
incident, personal injury, accident or near miss that may have occurred during
the course of the work to the supervisory staff immediately
Correctly use, store and maintain personal protective equipment issued for the
protection of workers against workplace hazards
Follow all verbal or written safe work procedures, practices and directions
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The LIN SCAN contract manager will ensure that all Subcontractors provide sufficient
HSE resources for their scope of work. Subcontractors shall submit organisation charts
along with the HSE Plans. The LIN SCAN Contract Manager shall cascade these
requirements to the Subcontractors, and shall verify and monitor that these
requirements are complied with throughout the execution of the work. The number
and performance of the Subcontractors HSE Officers shall be reviewed and the
number of Site HSE Officers may be adjusted as agreed between ENI and LIN SCAN in
keeping with the requirements of the work.
9.12 Resources
The LIN SCAN Contract Manager is responsible to ensure that all personnel and the
personnel of Subcontractors are fully trained and competent with respect to all work
activities to be performed, including all HSE aspects of the work. For personnel, with
roles responsible for the execution of HSE critical activities, where action (or
inaction) while performing such tasks could lead directly to a significant Incident,
special safety training modules and competence assurance requirements, including
licensed third party certification as required by local regulations shall be
implemented and ensure that the line management and supervisory personnel
including Subcontractors are competent to identify and assess HSE risks
systematically.
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Prior to commencement of work, The LIN SCAN Area Co-ordinator/ HSE Manager shall
ensure that all personnel engaged on the worksites attend a HSE Induction to make
them fully aware of the associated hazards and precautions to take with respect to
the related work and work site.
LIN SCAN and Subcontractors Key Personnel shall attend the LIN SCAN HSE induction
training before commencing the work. All Subcontractors workforce will be inducted
by the Subcontractors HSE Team before undertaking any workplace duties. LIN SCAN
Project /Site HSE manager shall review and approve the induction contents.
10.2 Training
In the course of execution of the Project, the LIN SCAN Contract Manager with the
help of LIN SCAN HSE Manager shall ensure that all personnel including
Subcontractors provide the required training for the appropriate work scope and shall
monitor the quality of the training provided. Should LIN SCAN require the quality of
training to be improved, LIN SCAN shall work with the Subcontractors until the
quality of training issue is resolved.
A strong health, safety and environmental training program are the key to an
effective health, safety and environmental management system. Personnel must
possess the necessary knowledge and skills to perform their tasks in a safe and
healthy manner and without causing any harm to the environment.
LIN SCAN and Subcontractors shall develop a Training matrix for the respective scope
of the work in line with project requirements and shall be updated as appropriate.
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LIN SCAN HSE Dept is responsible to ensure the successful delivery and coordination
of planned training for project requirements.
10.3 Competency
The LIN SCAN Contract Manager shall ensure provision of an integrated HSE team
comprising of LIN SCAN and Subcontractors HSE Personnel for site activities fulfilling
the minimum qualification, experience and number of personnel requirements.
LIN SCAN Area Co-ordinator shall ensure that the line management and supervisory
personnel are competent to identify and assess HSE risks systematically and versed
with and capable to define the standards, plans, procedures and resources necessary
to manage the work.
The LIN SCAN Contract Manager with the support of LIN SCAN HSE Manager shall
ensure establishment of a robust competence assurance process subcontractors
competence process will be audited at award and periodically.
Identify and record the positions that require competence assurance and the
respective Proficiency Levels, basing these on craft and HSE-related competence
requirements described in: local legislation, industry standards for technical and
operational competence, LIN SCAN and ENI requirements.
Assess, verify and record the Competence of individuals against the requirements
defined for each individual’s position.
Verify that all required training and certification/licensing has been completed
to meet legal requirements.
Verify that individuals have the required HSE-related Technical and Operational
competences before allowing him/her to perform the respective duties.
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Retain records of the assessment, including the date of the assessment and name
of the assessor.
Manage any Competence gaps through an agreed and documented plan, inclusive
of level of supervision and support required.
The LIN SCAN contract manager shall ensure the effectiveness of the competence
assurance process for all subcontractors.
The LIN SCAN HSE manager shall perform regular audits on the subcontractor’s
competence assurance process and quality of training provided and shall take specific
actions to bring align with the legal and ENI requirements as necessary.
HSE documentation for the project forms the basis for implementation of the HSE
Management System. The main Project HSE documents are the Project HSE Plan and
the HSE Strategy, which identify project document requirements and will remain a
“live document” throughout the Project.
The Project HSE plan document is the prime document in the HSE document
hierarchy for the Project, and for the activities to be performed on the Zubair
Maintenance Project. It specifies the commitment, the approach and the
methodology for HSE Management System implementation
developed to support the HSE Management System based on own standards and
procedures and Contract HSE requirements.
The key plans, procedures, guidelines which will be developed as a minimum are:
Scaffolding
Lifting Operations
The list mentioned above is not the final list and various other required
plans/procedures will be developed as required as the project progresses.
Effectively implementing LIN SCAN Golden rules of Safety will be a further key
element of operational control. LIN SCAN Golden Rules of Safety are provided as
Appendix 3.02.d.1.3.
The LIN SCAN Contract Manager with the support of LIN SCAN HSE Manager is
responsible to develop required HSE Plans and Operational control Procedures and
implement them effectively.
LIN SCAN recognizes that significant hazards can be created due to changes in the
following aspects of the Project:
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The LIN SCAN Contract Manager shall appoint a Management of Change Process Owner
with responsibility to:
Verify that staff in HSE Critical Positions know how to recognise change and
know how to initiate the Management of Change process
Inform and train personnel affected by the change and what they must do
differently
Any impact on the risk level posed to the Project and work HSE aspects due to the
above will be evaluated and any recommendations for alteration in existing HSE
controls will be appropriately implemented e.g., through updating Project
procedures or HSE trainings etc.
The LIN SCAN HSE Manager shall coordinate with Subcontractors and provide a
consolidated weekly and monthly reports of HSE performance to ENI, including injury
and occupational illness; security and environmental statistics and the results of
monitoring effectiveness of HSE management elements such as training, toolbox talks
quality and attendance, field inspections and audits, inspections of equipment,
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housekeeping, etc. LIN SCAN HSE Manager shall prepare a monthly HSE report in a
format template agreed with ENI.
The records for monitoring and measurement are to be identified through the
requirements of the Contract, the EIA, and local legal requirements. LIN SCAN and
Subcontractors shall maintain appropriate Project HSSE records to demonstrate
conformance to the Project HSE Management Systems as applicable. Comprehensive
Safety records will be properly identified, collected, indexed, and filed at the Site
HSE Manager office.
LIN SCAN HSE Manager shall maintain applicable / required records at LIN SCAN’s HSE
office.
The LIN SCAN Contract Manager, LIN SCAN Area Co-ordinator and LIN SCAN HSE
Manager are responsible to ensure proper communication, frequency set for the
project with ENI and Subcontractors and ensure implementation. In addition to
education and training programs for transmitting the HSE principles to the
employees, additional methods of communication will be routinely used to
disseminate information. The following methods as a minimum will be implemented
during the execution of the project:
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The LIN SCAN Contract Manager will chair these meetings and shall comprise the
following members of the Project Management Team as a minimum:
The Monthly Management meetings will be used as a forum to advance health, safety
and environmental awareness. The HSE focus of the Management Meeting is to discuss
HSE progress, seek to advance co-operation on matters affecting HSE issues between
all parties.
Weekly HSE meetings shall be chaired by the LIN SCAN HSE Manager, and provide the
means for LIN SCAN, Subcontractors and the ENI HSE Representatives to participate in
active discussion; promoting and considering ideas and suggestions from any member
of the meeting on any matter affecting health and safety of the work force and
protection of the environment; resulting in action items, recommendations and
safety campaigns as appropriate.
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protection, and in addressing project HSE issues and concerns in a timely and
effective manner.
The LIN SCAN Area Co-ordinator shall ensure daily Toolbox Talks are undertaken at
the start of each shift. These will be conducted by the line or task supervisors, in a
language understood by the workforce and should address the application of safety
rules and procedures to the hazards of current work.
Tool Box talk record sheets must be filled in and held at the workplace for the
duration of the work, before being returned for filing. LIN SCAN and Subcontractors
senior management shall participate in Tool Box talks regularly to demonstrate
commitment and leadership.
The LIN SCAN Area Co-ordinator shall ensure Subcontractors implement LIN SCAN’s
JHA program. JHA is a requirement for all task assignments. To ensure maximum
effectiveness JHA briefings shall be conducted at the location where the task will be
performed. LIN SCAN and Subcontractors shall train all employees in the principles
and application of JHA as part of the induction.
The JHA briefing is to be specific to the location and task in hand to ensure that the
work group is provided with the information and instructions required to fully
understand the hazards involved in completing the task and the safe work processes
required to safely execute the task – brief summary –JHA and PTW requirements,
tools fitness for purpose and service and location hazards, i.e., Access, egress,
emergency response, concurrent activities should be covered by the JHA.
TRA shall be documented and kept together with the specific PTW, if such, at the
work location.
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It is important that all LIN SCAN personnel and Subcontractors form an active part of
the health, safety and environmental process. Lines of communication need to be
developed from site personnel through their supervision and management to LIN
SCAN Senior Management.
Safety Suggestion program will be implemented so any site worker may submit
suggestions for improvement. Safety Suggestions boxes will be placed in key
areas on site
Any major issues on health, safety and environment generated by site personnel,
should be tabled at the weekly HSSE meeting, or raised at the monthly management
meeting if applicable. The conclusion of these discussions should always be
communicated back to the work force and source.
LIN SCAN will arrange for HSE notice boards to be erected in prominent position at
the Project and site offices, workshops, warehouses, accommodation blocks and
canteens. These Notice boards shall be used for the communication of safety
awareness bulletins, HSE Policies, current safety issues, safety awards etc.
Suitable and sufficient safety posters and slogans shall be displayed in prominent
positions throughout the Project facilities in order to raise personnel awareness of
HSE. Safety posters shall include LIN SCAN LSR, Golden Rules of Safety, current
Occupational Health, Safety and Environmental topics, in particular when used in
conjunction with HSE Campaigns.
Where possible, posters with a strong visual message shall be given preference to
written information.
12.8 Language
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All toolbox talks, TRA’s, safety bulletins and safety posters, “lessons learned”, etc.,
shall be conducted or compiled in a multilingual format in order to ensure full
comprehension amongst a multinational workforce.
The LIN SCAN HSE Manager shall ensure implementation of Safety Training
Observation Programme (STOP) or ENI approved equivalent, in accordance with
specifications / guidelines.
The prompt reporting and thorough analysis of all accidents, incidents, near miss
incidents and dangerous occurrences provides an important performance indicator.
The LIN SCAN Area Co-ordinator with the assistance of the HSE Manager is responsible
to develop and implement project Incident, Reporting, Investigation and analysis
procedures in line with the approved process, which includes as a minimum, Incident
reporting, classifications, investigation process, identifying root causes and analysis
etc.
The LIN SCAN Area Co-ordinator is responsible to cascade this procedure and
requirements to the Subcontractors and ensure effective compliance.
All Subcontractors shall immediately report to the LIN SCAN Area Co-ordinator/ HSE
Manager any incident, fire or explosion involving death or injury to personnel or any
other person and any other loss or damage to the facilities or equipment and shall
without delay also report such events to the appropriate authorised person
concerned, as required by applicable local laws. A copy of such report will be
simultaneously sent to a defined distribution list.
LIN SCAN HSE Manager shall submit all incidents reports to ENI using an agreed
template and within 24 hours of occurrence. LIN SCAN shall set up a system and a
database shared with ENI to manage the incident reporting, investigation and action
tracking.
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The LIN SCAN Contract Manager with the help of LIN SCAN HSE Manager/Security
Manager is responsible to develop an integrated Emergency Response and Medical
Emergency Response (MER) Procedures in line with ENI existing ERP & MER plans and
HSE Standard for Medical Emergency Response (MER).
Procedures shall detail the emergency organisation, responsibilities of ENI, LIN SCAN
and Subcontractors ERT, Co-ordination, communications and call-out, work site
evacuation, rescue of injured persons and co-operation with relevant local
authorities, national bodies, emergency services & local industry, emergency
management, command structures, emergency control resources and/or any other
aid to handle the potential emergency scenarios. All Emergency Response activities
shall be coordinated with the Security services where possible.
LIN SCAN shall ensure all major Subcontractors provide materials (equipment) and
resources as required by local regulatory requirements and ENI Emergency Response
Requirements.
Additionally, LIN SCAN shall agree with ENI for provision of any material /equipment
required centrally for Emergency Support and handling emergencies. ENI may provide
required centralised emergency equipment or if required LIN SCAN may provide if
requested by ENI.
LIN SCAN shall provide and ensure Subcontractors establish resources and maintain
medical Emergency Response, which provides:
Admission to and care at the nearest Local Hospital within four hours referral
to an appropriate Specialist Hospital (casualty specific).
LIN SCAN will establish and maintain a central medical facility at the main camp
location and arrange provision of medical services as needed to the Project
Personnel. LIN SCAN shall establish and manage satellite First Aid Stations at the
work Locations for their scope of work and provide at all WORK locations, a first-aid
kit and certified First-Aider a 4 (four) minute first-tier minimum response time in
case of an injury or medical emergency. First aiders’ staff from Subcontractors shall
be certified and verified by LIN SCAN.
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Objective is to provide assurance to ENI that the Project expectations are achieved
and to provide a vehicle for continuous improvement of the system.
These audits shall be conducted by ENI organization or any other external individual
or organization as per LIN SCAN audit schedule. These audits may include
LIN SCAN shall arrange for external audits of implementation of the HSE
requirements of the contract and the HSE management plans periodically
throughout the Project as applicable.
LIN SCAN Senior Management (HSE) from the Corporate Office will carry out Systems
and compliance audits at least once annually. HSEMS & Project HSE Audits – This shall
be performed against the Project HSE Plan to ensure the arrangements defined in the
plan are both understood and in place.
Objective: To provide assurance to the LIN SCAN Contract Manager that the
arrangements in place for the prevention, control and mitigation of hazards
associated with the relevant operation are in place and effective.
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LIN SCAN Site HSE Team will conduct Internal audit (Level-3) to a developed schedule
including audits against LIN SCAN Golden Rules of Safety and ensure Subcontractor’s
compliance.
LIN SCAN Line Supervision and HSE personnel shall carryout HSE inspections as per the
schedule to cover the activities at all work locations in line with the local regulatory
requirements and agreed standard requirements.
The LIN SCAN HSE Manager is responsible to review the schedule on a monthly basis
and ensure the Audits and inspections covering the current on-going works.
The LIN SCAN HSE Manager shall ensure those responses to non-compliance findings
and areas of improvement from its own and ENI audits, inspections and reviews are
documented and shall implement all agreed recommendations from such audits,
inspections and reviews within the timeframe mutually agreed between the parties.
Depending on the level of the audit / Inspection, the Project Management Team, HSE
Manager and/or HSE officers will specify the required corrective actions, delegate
appropriate responsibility for their implementation and set reasonable time frames
for their completion.
Corrective actions and their associated information are entered on to the Project
Action Tracking Register; these include actions from all relevant sources (audits,
inspections, incidents, observations etc.) and their close-out status is reviewed
regularly by Project Management. A close out evidence file provides confirmation of
the close out of the actions raised.
The review of HSE within the Project is a continuous process, nevertheless there shall
be formal reviews by LIN SCAN Management to ensure the HSE MS, HSE policies,
programs, plans, objectives and targets are effective.
The following are the minimum HSE Performance review and improvement process
and programmes to be implemented:
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The Project Management Team comprising of the Contract Manager and LIN SCAN HSE
Manager shall review the HSE Performance of the project annually to enable a HSE
improvements to be identified and plan developed. The improvement actions shall be
recorded in project HSE activity plan. The results of this review shall be
communicated in a joint workshop, facilitated by LIN SCAN to ENI, and to
Subcontractors Management.
Review of trends and learning, from the following sources, indicating where
strengths and weaknesses exist in Project HSEMS implementation, or other
opportunities for improvement
Review of compliance with ENI HSE standards and the HSE requirements
Verification that all HSSE risks receive adequate focus and management
attention
The Project Management Team comprising of the Contract Manager, LIN SCAN HSE
Manager, and LIN SCAN Area Co-ordinators shall review the Project HSE Performance
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and Key performance indicators (K.P.I) in the Monthly HSE Management Committee
meetings and improvement actions shall be identified for implementation.
Regional HSE Director shall each month review/report the Project HSE
performance to the LIN SCAN Executive Management through Monthly Report
LIN SCAN regional HSE Director and the Vice President will at their Review
Meeting review the performance of the Project
The regional HSE Director shall perform periodic reviews and inspections (at
site) throughout the execution of the Project
LIN SCAN recognises the importance of the Continuous Improvement process in its
pursuit of excellence in HSE performance and will establish a culture of continuous
improvement by requiring:
LIN SCAN Contract Manager with the support of LIN SCAN HSE Manager shall
coordinate the pre-qualification of all prospective Subcontractors Companies and
ensures that those Companies have the capabilities to comply with the CONTRACT
HSE requirements.
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The LIN SCAN Contract Manager shall develop a set of instructions for the
Subcontractors, which draws on local legal requirements, LIN SCAN’s HSE standards
and requirements as specified in this Project HSE Plan. These instructions shall be
included in the head contract clauses. The requirements shall be in a format and
level of detail that will be readily understood by the Subcontractors. LIN SCAN shall
provide and explain these HSE instructions to each Subcontractors management at
the HSE kick-off meeting.
The LIN SCAN Contract Manager shall ensure that all Subcontractors manage the HSE
in compliance with all specific HSE plans.
Subcontractors shall not be permitted to mobilise and start work until they have
HSEMS, plans and procedures in place, which are in line with LIN SCAN HSEMS,
Project HSE Plan and procedures. Prior to mobilisation, LIN SCAN shall conduct Pre-
mobilisation Audit on Subcontractors to ensure the compliance/ readiness of the HSE
requirements.
LIN SCAN shall review and monitor the performance of each Subcontractor regularly
to ensure the required HSE standards are maintained. In case any shortcoming(s) is
identified, the Subcontractors will be assisted to implement the necessary corrective
action(s).
Subcontractors shall take all reasonable measures to prevent damage, injury or loss
to property and personnel of LIN SCAN, ENI and all other persons who may be
affected by the Project. The subcontractors shall execute the work within the
framework of ENI and LIN SCAN HSE policies and the Project HSE requirements as
detailed in this Project HSE Plan.
Subcontractors shall comply with the requirements of the Project HSE Plan,
Environmental Management Plan and other plans and procedures for their Scope of
Work.
Subcontractors shall develop Safe working practices and procedures in line with
applicable HSE standard requirements, Method statements, and Risk assessments for
their scope of work and submit to LIN SCAN for approval.
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Subcontractors shall allocate sufficient, competent and fit for work resources to
ensure the effective implementation of HSEMS throughout the various phases of the
work.
Subcontractors shall provide required training consistent with this HSSE plan and in
line with their scope of work.
The LIN SCAN Contract Manager is responsible with the help of LIN SCAN HSE
Manager to ensure compliance and Subcontractors comply with ENI requirements
regarding Health Management such as Fitness to Work, Health Risk Assessments,
Drug & Alcohol policy, General health requirements, medical facilities, medical
emergency requirements etc.
LIN SCAN shall have and ensure Subcontractors have, as part of its HSEMS, an
effective fitness to work process for its personnel and Subcontractor’s personnel to
assure fitness to work. The fitness to work process shall as a minimum ensure
compliance with local labour law and regulatory requirements and LIN SCAN and ENI
Drugs and Alcohol Policies.
The LIN SCAN Contract Manager/ LIN SCAN HSE Manager shall ensure that all
personnel including Subcontractors prior to engagement for the performance of the
work have been examined by a medical professional and issued with a valid ‘Medical
Certificate of Fitness to Work, (with at least 1 year validity). LIN SCAN HSE Manager
shall ensure that all the project personnel including Subcontractors, Fitness to work
certificates are provided, verified and records kept with the HSE dept prior to
commencement of work.
For all mobilised personnel the fitness to work process should follow the LIN SCAN
Fitness to work guidance Protocols and Guidance Notes on the Medical Evaluation of
Fitness to Work.
LIN SCAN / Subcontractors shall conduct a Health Risk Assessment highlighting health
hazards and associated mitigation measures associated with the work. Sub-
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Contractors shall define the jobs and tasks to be included and prepare a Health
Hazard inventory. LIN SCAN Contract Manager/ LIN SCAN HSE Manager shall ensure
assessment of risk to health from each Health Hazard by applying the LIN SCAN Risk
Assessment Matrix (RAM) and shall submit to LIN SCAN/ENI for review the HRA
report, recommendations and agree a Remedial Action Plan.
LIN SCAN Contract Manager shall ensure that relevant HRA Risks and Controls are
adequately reflected in the respective WMS and JHAs and are adequately
communicated to impacted staff.
LIN SCAN will arrange their own medical facility at site location and arrange
provision of medical services as needed to the Project Personnel.
The LIN SCAN Contract Manager shall ensure each of the Major Subcontractors shall
establish and manage satellite First Aid Stations at the work Locations providing Tier
1 response; and heat stress response to all personnel employed for the performance
of the work by Subcontractors. LIN SCAN HSE Manager shall assess the staffing level
and organisation for the Subcontractors First Aid Stations based on a risk
assessment. Staff manning the First Aid Station or acting as first aiders shall be
certified and proven competent.
LIN SCAN is responsible for ensuring that ENI guidelines are followed in the
establishment of the First Aid Stations, medical facilities, equipment and the
provision or access to medically qualified resources.
LIN SCAN shall ensure close adherence to Occupational Health requirements and
guidelines of Iraq laws and regulations, Ministry of Health and Governmental
Agencies and to be in line with the ENI standards and guidelines.
LIN SCAN shall ensure the required qualified personnel, measurement devices and
other resources, as deemed necessary to:
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Hot surfaces
Those tasks and areas where noise levels could induce hearing loss shall be identified
and assessed through the HRA and reduced to ALARP. The exposure of personnel to
noise shall be kept below 85dB (A) for an eight-hour noise dose. LIN SCAN and
Subcontractors shall ensure:
Employees working in high noise areas are trained on use of hearing protective
equipment and the hazards on noise
LIN SCAN and Subcontractors shall ensure up-to-date Material Safety Data Sheet
(MSDS) is available at work place and accessible to all employees.
The LIN SCAN Contract Manager with the help of the LIN SCAN HSE Manager is
responsible to ensure that all Welfare Facilities for the use of employees in
accordance with the requirements of the contract, LIN SCAN standard requirements
and local country directives on Improvement of Labour Conditions.
LIN SCAN is responsible to provide security to all expatriate personnel and property at
all times. ENI is responsible for all personnel inside Company facilities.
The responsible party ensures the actions are taken and all security measures are
implemented in compliance with legal requirements, LIN SCAN policies, and Security
standards. LIN SCAN Contract Manager shall ensure that, all Subcontractors develop
Security Plans and Procedures, reviewed, and approved by LIN SCAN and ENI. LIN
SCAN Security Manager shall co-ordinate with the Subcontractors and ENI Security
teams to ensure effective implementation of ENI requirements for security.
The LIN SCAN contract manager is responsible with the help of the Project Security
Manager and in consultation with ENI Security Manager to develop a Project Security
Management Plan and cascaded to Subcontractors to ensure compliance.
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Social Performance for LIN SCAN means how we manage the impacts of our business
on the communities and societies in which we operate. LIN SCAN will implement the
social performance obligations of LIN SCAN under guidance, direction and
coordination with ENI appointed representative, responsible for Social Performance
activities.
LIN SCAN will develop a site-specific social management plan to coordinate with ENI
in order to comply with the social conditions of approval and any additional
commitments made by ENI in the Impact Assessment and LIN SCAN’s Social
Performance Plan.
Any community engagement will be subject to ENI review and approval. Where
applicable, engagement activities are to be jointly planned and performed by ENI and
LIN SCAN.
The elements of the social management plan will include the following:
The LIN SCAN Contract Manager and ENI will jointly review the implementation of the
social management plan and activities and will jointly investigate LIN SCAN
compliance with the plan. LIN SCAN Key Personnel shall participate in these activities
to demonstrate leadership’s commitment and responsibility.
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Any breach or violation of the voluntary principles for security and human
rights
HSE Manager
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Appendix 3.02.d.1.4
Acceptance Procedure/
Key
Se Activities Frequenc Verifying
Action Party Performanc
r Criteria Standard y Record
e Indicator
No
1 Policy, Leadership and Commitment
Perform SIMOPS Work shop & HAZ SIMOPS & HAZCON Hazard and Effects
2.1 Workshops Conducted Project HSE Plan As required Project manager
CON /HSE works for green field and Brown REPORTS Management
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Review of COSHH assessments and Registers established Project HSE Plan HSE Manager/ Registers
2.4 As required
Hazardous materials used on the project and maintained Environmental
Engineer
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Develop HSE organization chart with Organisation Charts continuous Project manager / Site
4.1 Project HSE Plan Organisation Chart
names. Developed update HSE Manager
HSE Organisation
Review HSE resources in line with project Resources available on Chart developed for
HSE Resources Project manager / the project and
4.2 schedules and demands to maintain Project HSE Plan Monthly project against the
reviewed HSE Manager resources available
effective HSE-MS. planned.
as per planned.
Job Descriptions developed for various Job Descriptions Project HSE Manager
4.3 Project HSE Plan Continuous Job Descriptions
HSE functions. Developed
Continuous
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Incentive and
Develop and implement Safety Incentive disciplinary code Continuous Project manager / Safety incentive
6.4 Project HSE Plan
and Disciplinary Action procedure. implemented Project HSE Manager implementation records
HSE Management
Organise HSE Meetings as per schedule Meetings Conducted Continuous as Project manager Meetings and other
7.1 Project HSE Plan Meeting records
according to the Project HSE Plan. per schedule /Project HSE Manager scheduled meetings
conducted as per
schedule.
7.2 Ensure there is an effective system in place Project HSE Plan Project manager / MOM
for the timely transfer of HSE information Implement effective HSE Manager Effective
and feedback across all levels in the information means communication and
company and contractors. All employees consultation aids
are aware of key HSE information and implemented
expectations (Tool box talks, Craft considering local
Meetings, Hand Book, notice boards TSTI, language (Tool box
STOP ETC). talks, HSE Hand
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Support HSE Audits and provide adequate Adequate personnel As per Audit
Project manager / within 21 days.
9.5 personnel. deployed Project HSE Plan Plan Organisation Chart
HSE Manager
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