SHE Benchmarking for Meghnaghat Power Ltd

Close out meeting

April 12, 2018

Xia XiaoBo, Luo Song, He Wei

DNV GL China

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 1. Leadership 9. Risk Control

2. Planning 10. Asset Management

3. Risk Evaluation 11. Contractor management and

purchasing
4. Human Resources
12. Emergency Preparedness
5. Compliance assurance
13. Learning from events
6. Project Management
14. Risk Monitoring
7. Training and Competence
15. Results and Review
8. Communication and Promotion

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Slide 2
Question Types

5 Types of Questions :

 （XO-45）
 （3/57）
 （% x 15）
 （PJ-60）
 （FQ/45 ）

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Scoring Principle

3 & 90
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Process 1 Leadership- Strengths

MPL review HSE policy annually Management Team conduct weekly walkthrough

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Process 1 Leadership- Recommendation
1.2 Goal: MPL has made objective and target for 2018, but some of target are
unmeasurable, such as for review and update LOTO standard isolation, check
effective is unmeasurable. It is suggested that MPL set up leading and logging target
and ensure the target measurable.

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Process 1 Leadership- Recommendation
1.4 Strategy: EDRA(MPL) has not established the strategy plan for
business, which should conclude business, human resource, contractor, etc.

1.5 Stokehold management: There was no stokehold management

procedure, including interest identification, communication frequency, etc.

1.9 Management Commitment: MPL managers lack of HSE trainings,

including the incident investigation technique, emergency response, etc.

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Process 2 Planning and Administration - Strengths
There is a work planning and control system(Infor EAM System) for
coordinating operations, maintenance and project work. Assign the
Maintenance Planner for coordinating and tracking the action of each Work
Order.

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Process 2 Planning and Administration - Strengths
There is a effective handover process to ensure that all relevant information
is adequate communication between incoming shift and outgoing shift. The
handover meeting record is very detail and clear, including Important
Operation Issue, Manager’s Instruction, Shift Initial Condition, Shift
Activities, Signature etc.

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Process 2 Planning and Administration-Recommendation
2.1 Planning and Administration: Suggest to make a MPL Yearly Business
Plan which is consistent with Performance Targets, Resources Required
and Individual Responsibilities. Senior management, departmental
management, work sections should involved in the yearly business
planning process.

2.2 Planning and Administration: Suggest to add one category – Safety

Issue in the Handover Meeting Record Form, it can remind the Operators
thinking about safety issues, fill “None” in the category of the Form if
there are not any safety issues in the shift.

2.4 Management System Documentation: Suggest to make a Document

Control Program/Procedure and assign a full time Document Controller. It
is not only for document control processing, it is also for the relevant
person easy to accessing and searching. Currently, most of documents are
located at Plant Manager Office and related Departments, some common
documents and are located at HSSE Department, electronic documents are
similar condition.
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Process 2 Planning- Recommendation
2.4 Management System Documentation: Some of HSE procedures of MPL were
not set up based on the 3W1H(Who, When, What, How), such as training and
competence, incident management procedure, etc.

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Process 2 Planning- Recommendation
2.4 Record: MPL has many records form, but some of forms were not put into the
related procedures.

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Process 3 Risk Evaluation - Strengths
MPL has established a risk identification and evaluation management process.
According to the management process, the risks related to all operation and
maintenance activities are evaluated and registered in the risk registration table.

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 Process 3 Risk Evaluation - Recommendation
3.1/3 Health/Security Hazard Identification and Evluation: Occupational
health and security risks in the risk register are less in quantity, such as
illumination, biology, food, ergonomics, unauthorized personnel entry,
information security, theft, third-party damage, etc. are not included in the
risk assessment. It is recommended that MPL conducts a comprehensive
risks assessment against occupational health and security aspects, establish
acceptable risk standard to improve basis of corrective measures .

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 Process 3 Risk Evaluation - Recommendation
3.1/2/4 Health/Safety/Environment Hazard Identification and Evaluation:
It is recommended that MPL timely improve the risk register from a
variety of activities, such as engineering changes, STOP, routine
inspections, audits, etc., and classify the sources of the risks to
ensure the traceability of relevant risks.

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Process 3 Risk Evaluation - Recommendation
3.8 Process Hazard Analysis: MPL conducted process hazard
analyses in 2002 and 2016. However, the analyses did not include
all process facilities (such as GT1 and GT2). It is recommended
that MPL should establish a management process for process
hazard analysis to specify the method, frequency, and personnel
requirements for process hazard analysis to ensure the safety of
the process equipment.

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Process 4 Human Resources- Strengths
Each person has BOP qualification book and conduct candidate evaluation,
also do some practical test for candidate.

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 Process 4 Human Resources- Recommendation
4.1 Human resource system:

 Has not set up travel risk management, such as define the high risk areas(e.g.
restricted country, LOGO areas, etc.), control the travel risk, etc.

 MPL has not set up the core competence individuals Management for the key
personnel.

4.6 Management of organization: There was no management of change

procedure for the plant. It is recommended to set up PMOC to Manage key
personnel and organizational changes from the perspective of risk
management.

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 Process 4 Human Resources- Recommendation
4.3 Performance Management: MPL has conducted performance review for
individuals yearly, but the action plan(training needs) was not sent to training
department and one person with a bit low performance in Dhaka office didn’t get any
action for improvement.

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Process 5 Compliance Assurance - Strengths
There is a applicable regulatory requirements and Industry Codes/Standards
list, the related detail items are identified and available. Worked/Consulted
with Consulting/Legal Company(Barristar Rafuqwl Haque and CO. and
Shakhawat and Associates) to identify these related detail items to meet the
needs of MPL’s business.

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 Process 5 Compliance Assurance - Recommendation
5.1 Regulations: Suggest to assign the people to search the laws and
industry codes/standards frequently and working/consulting with the
consulting/legal Company regularly for identifying the related items for
updating.
5.4 Reporting to Authorities: Currently, MPL only report to two Authorities(1.
Department of Environment and Department of Labor). Suggest to identify
if there are other events/controlled materials which MPL have to report to
Authorities, for example: medicine at ambulance and first aid boxes,
epidemic situation, exploding, fire fighting certification change ，
hazardous chemicals etc..

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Process 6 Project Management - Strengths
We select the Overhaul Maintenance(overall outage duration is 15 days,
September, 2017) as a project. The Project was good planning and execution.
The Plant Manager was the Project Director. There was a good and detail
presentation and the Presentation was used to training all the involved person.

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 Process 6 Project Management - Recommendation
6.2 Project Planning: Suggest to make a Project Accident/Incident
Prevention Program for next similar project, the Program should consist
the following items, but not limit: Organization Chart, Individual HSE
Responsibilities, Risk Assessment, Risk Mitigating Method Statement, PPE
Requirements，Correcting Safety Violations and Disciplinary Action, Work
Permit system, equipment and tools inspection, Emergency Response etc.,
and using this Program to training all the involved person.

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Process 7 Training and Competence-Strengths

MPL has made integrated training plan and made training presentation

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Process 7 Training and Competence-Recommendation
7.2 Training needs: MPL has set up training matrix for the plant, but
individuals didn’t know which training he should attend after interviewing
several personnel. Auditor found that there was one, who is emergency
team, but not attend the chemical handling training.

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Process 7 Training and Competence-Recommendation
7.2 Delivery of Training: MPL has set up training PPT for most of
training, but some of training is awareness training, which was not specific
training, such as chlorine, ammonia emergency response training for
emergency team.

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Process 7 Training and Competence-Recommendation
7.3 Training inductor: MPL has external and internal trainer, but there
was no management for internal trainer, including selection
criteria(experience, training skills, etc.), periodical evaluation, etc.

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Process 7 Training and Competence-Recommendation
7.4 Delivery of Training: KLPP has delivered internal training and
external training for staff, but lack of training course package base on
the importance of training, such as training objective, PPT, training
schedule, guideline for each PPT, etc.

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Process 8 Communications and Promotion - Strengths
 MPL has established several communication channels between top
management and first line workers, including meetings (daily morning
meeting, management meeting, operation meeting, maintenance meeting,
safety committee meeting, tool box meetings, etc.), documents, corporate
magazine, intranet, brochures, email, whiteboards, etc.

 MPL holds a monthly safety committee meeting to review the issues

arising from HSE system operation, major accidents and activities, and the
progress of the EHS KPI, etc. MPL forms a corresponding follow up action
list after the meeting.

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Process 8 Communications and Promotion - Recommendation
8.4 Group Meeting: It is recommended that MPL organizes group meetings
on regular basis. The group meeting should be led by front-line supervisors.
MPL could provide appropriate specific materials and outlines for group
meeting, including accident incident reports, EHS target indicators, external
accident events, and regulations.

8.8 Promotion Campaigns: At present, MPL's EHS promotion activities are

mainly safety bulletin and family day. It is recommended to further improve
employees' safety awareness through more forms of promotion activities,
such as group knowledge competition, EHS seminars, and employee health
activities etc.

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Process 9 Risk Control - Strengths
 MPL conducts regular occupational health examinations for all
employees, and continuously track results of the examinations. MPL
considers relevant physical conditions of employees, such as
occupational contraindications (Acrophobia), while assigning tasks to
employees.

 MPL has launched the STOP program recently to reduce unsafety

condition and unsafe behavior through behavioral observations. MPL
also summarized the contents of all STOP cards, and follow up the
issues found until it is closed.

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 Process 9 Risk Control - Strengths
 MPL has installed a lot of safety warning signs and notifications across the
plant, including PPE equipment requirements, risk warnings, confined
space warning signs, vehicle speed limit signs, restricted areas warning
signs, chemical labels, location of fire protection facilities, and tips for use.

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Process 9 Risk Control - Recommendation
9.6 Operating Procedures: Most version of operation procedures was 2008.
It is recommended that MPL could conduct regular reviews for operating
procedures and ensure that appropriate personnel participate in the review
process, such as operation staff, frontline supervisors, and technical
engineers.

9.7 Rules: It is recommended that MPL establishes EHS rules and

communicates rules to all employees through appropriate channels. And
develop the corresponding management process to recognize those who
comply with the rules and discipline violations of the rules.

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Process 9 Risk Control - Recommendation
9.10 Personal Protective Equipment: The cartridge on the respiratory
mask should also be considered on the cumulative time of use. It is
recommended that MPL could calculate accumulated time for employee
exposure against specific chemical during the routine tasks, and replace the
filter cartridge after the cumulative exposure time reaches the product
declaration limit.

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 Process 9 Risk Control - Recommendation
9.9 Warning Signs and Notices: Maximum load capacity sign for the racks in
the main warehouse is not post on the racks. Warehouse employee did not
know the racks’ maximum load capacity neither. It is suggested to post the
maximum load sign on obvious positions on racks.

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 Process 9 Risk Control - Recommendation
9.2 Safety Control: In the chlorine MCC room, although the electrical switch was
locked out, the distribution box was opened and the locking function failed. It is
suggested that MPL could enforce LOTO training for relevant employees to ensure
LOTO method and steps are correct.

9.2 Safety Control: There is no dedicated LOTO tools in the plant. It is recommended
that MPL is equipped with enough LOTO devices according to the specific conditions
of the process break point.

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Process 9 Risk control-Recommendation

One Helmet in CCR was produced in 2004

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 The drain valve in the chemical storage area was not closed.

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Process 10 Assets management-Strengths

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Process 10 Asset Management - Strengths
At Maintenance Department, there are detail registers of physical
assets(owned equipment, electrical tools, lifting gears, safety harness etc.),
the registers record: description of the asset, unique asset identification
name/number, location of the asset, responsibility person, inspection date,
condition of the asset etc.

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Process 10 Asset Management - Strengths
All lifting gears(sling, chain block etc.) and safety harness are regularly
inspected by the qualified Third Part Company(BVQ) and clearly Color Code.

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Process 10 Asset Management - Recommendation
10.5 General Conditions Inspection: Suggest to assign qualified person to
regularly conduct the inspection for all the SCBA(self- contained breathing
apparatus) which located at Plant and put the inspection tag on the SCBA,
similar with the Fire Extinguisher. Most of Pressure Gauges can not be
identified the calibrating date. Suggest to calibrate the Pressure Gauges.

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Process 10 Asset Management - Recommendation
10.8 Pre – Use Equipment Inspection: There are Pre-Use check list on the
most of welding machines, drill machines, electrical tools and equipment.
But related person are not familiar for the inspect. Suggest that HSE
Department should conduct the training to teach the related person how
to do the inspection or contact qualified person to conduct the training.

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Process 11 Contractor Management and Purchasing-Strengths

A qualified Contractor/Supplier list with detail information is available. There

are 930 qualified contractor/supplier in the list. etc.

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Process 11 Contractor Management and Purchasing-Strengths
MPL has effective system to assign a supervisor to in charge the contractor for
each task. The assign Supervisor are full time monitoring the activities of
contractors/agency supplied personnel.

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Process 11 Contractor Management and Purchasing-Recommendation
11.1 Contractor/Supplier Selection: There is a pre-qualification procedure –
Registration & De-Registration of Vendor, but most of pre-qualification
records of contractor/supplier can not be found. Suggest to re-qualify for
the Contractor/Supplier which record can not be found.

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Process 11 Contractor Management and Purchasing-Recommendation
11.1 Contractor/Supplier Supervision: It is suggested to enforce on the onsite
supervision.

The mobile scaffold should set second

handrail and should qualified person for
daily inspection and signature.

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 One of the barricade chains of
the vertical ladder is losing

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 The chain blocks should be
hanging on the Stander for
storage.

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Process 12 Emergency Preparedness-Strengths

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Process 12 Emergency Preparedness-Recommendation
12.1 Emergency Need Analysis: The ERP scenario has discussed in the
meeting, including fire, oil spill, earthquake, etc. It is suggested to
evaluate the scenario based on the hazard identifications. For the high risk
of hazard, ERP should be needed in the plant.

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Process 12 Emergency Preparedness-Recommendation
12.2 Site emergency plan: some key steps of MPL ERP are not
contained in the ERP, including recovery plan, detailed information for
facility(emergency contact no., escape routines map, fire fighting system
layout, etc.). Auditor found that TITAS as fuel gas supplier was not in the
emergency contacts format of ERP.

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Process 12 Emergency Preparedness-Recommendation
12.8 Emergency Protection equipment: There were some deficiencies
related to emergency response protection equipment, such as emergency
response kit in chlorine cylinder room in mess, low pressure of SCBA
cylinder in the CCR. It is suggested to set up emergency protection
equipment list and conduct inspection.

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Process 12 Emergency Preparedness-Recommendation
12.11 Emergency drill: MPL conducted fire and chemical drill according
to plan, but there are similar action to be taken, e.g. Sulphur acid storage
tank leak drill in Nov 25, 2017 and chlorine leak in July 27, 2017, one
common actions is that some person was not able to use chemical PPE
and SCBA. But, training has only been completed for related person on
Jan, 2018. It was suggested to take actions immediately after each drill
and also verify the effectiveness of training.

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Process 13 Learning from Event-Strengths

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Process 13 Learning from Event-Strengths
Follow the formal immediate cause reference and actions were verified
by HSE manager.

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Process 13 Learning from Event-Recommendation
13.1 Event learning system: MPL has reported near miss proactively
and conduct investigation for all of near miss with the same process. It is
suggested to define the incident as different risk level and conduct root
cause analysis for all of the high potential NMs.

13.3 Participate Event investigation: The managers of MPL joined

some NMs investigation, but no one joined incident investigation skill
training. It is suggested to engage proper person to join incident
investigate training.

13.9 Event Report Verification: It is recommended to establish the

verification mechanism for checking whether all of the required incidents
have been reported, such as first aid kit use records, daily maintenance
records, inspection records, etc.

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Process 13 Learning from Event-Recommendation
13.8 Action follow up: One acetylene hose got burst due to gas leakage
from the improper coupling with nipple joint as it came into contact with
welding spatter in May 17, 2016. But preventive action contains welding
hose replaced rather than the equipment onboard check and routine plant
supervision. It is suggested to add requirement of contactor’s equipment
onboard check into the related procedure and implement this equipment
onboard check to prevent unsafe condition equipment accessing to the
plant.

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Process 13 Learning from Event-Recommendation
13.10 Event Analysis: The KLPP has carried out statistics on LTA, incident
numbers, etc. It is recommended to make statistics on the causes(direct
and root cause), finance loss, etc. so that take further actions for
improvement of incident management.

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 Process 14 Risk Monitoring - Strengths
MPL regularly monitors noise, air emission and waste water, and submit the
monitoring reports to local DOE. The current monitoring results show that MPL
continues to meet regulatory requirements.

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 Process 14 Risk Monitoring - Recommendation
14.1 Health Hazard Monitoring: It is recommended that MPL could conduct on-site
occupational health hazards monitoring, including noise, chemical exposure, and high
temperature, to ensure that occupational health hazards at the site meet the relevant
regulatory requirements.

14.7 Perception Surveys: Although HR department holds the meeting every year to
collect employee suggestions, no formal EHS perception survey has been conducted.
It is suggested to regularly carry out EHS perception surveys (e.g. EHS issues, etc.) to
understand employees' satisfaction with the organization. Secondly, we will analyze
the issues found in the survey and establish improvement plan.

14.8 Behavioral Observation: It is recommended that MPL could conduct trend

analysis for the results of STOP program in order to discover the fundamental
problems of the system and prevent accidents.

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Process 15 Results and Review - Strengths
The KPI meeting has been held regularly and the management review
meeting will be held at the end of the year. Data statistics and comparisons
were made for various KPI indicators. The data showed that the overall
performance is good.

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 Process 15 Results and Review - Recommendation
15.3 Residual Risk Management: It suggests that MPL carried out risks
review and assesses their current residual risk profile periodically after the
current control measures take. And make the risk acceptance criteria for
tracking.

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Safeguarding life, property and the
environment

www.dnvgl.com

SAFER, SMARTER, GREENER

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