REVISION LIST

D0 Issued for Comment

HOLD RECORD
 TABLE OF CONTENTS
1. BRIDGING STATEMENT 4
2. RESPONSIBILITY FOR UPDATES 5
3. REFERENCES AND STANDARDS 5
4. ABBREVIATIONS TERMS AND DEFINITIONS 11
5. ORGANIZATION ( SEE ANNEX 2) 13
6. HSE POLICES AND OBJECTIVES ( SEE ANNEX 1) 13
7. SCOPE 14
8. PLACE OF WORK DESCRIPTION AND WORK PROGRAM 15
9. MANAGEMENT STRUCTURE AND RESPONSIBILITIES 16
10. AWARENESS,INDUCTION AND HSE TRAINING 20
11. HAZARD IDENTIFICATION AND RISK ASSESMENT 22
12. ACCIDENT INCIDENT AND NEARS MISS REPORTING AND INVESTIGATION 24
13. MAINTENANCE AND ASSET INTEGRITY 25
14. EMERGENCY RESPONCE AND PREPAREDNESS 26
15. HEALTH MANAGEMENT 31
16. ENVIROMENTAL AND WASTE MANAGEMENT 31
17. HAZARDOUS SUBSTANCES 32
18. LIFTING OPERATION PROCEDURE 33
19. ANNEX 35

1. BRIDGING STATEMENT

1.1 Objectives

The main objectives of this bridging document are to:

 Review the HSE management systems of COMPANY and CONTRACTOR and identify any
subject areas that are not aligned.
 Demonstrate that adequate arrangements have been made to bridge the HSE management systems
between COMPANY and CONTRACTOR.
 Identify the methods of communicating HSE issues between COMPANY and CONTRACTOR.
 Ensure a clear understanding of the documents and procedures that will control activities and that
specific responsibilities required of both COMPANY and CONTRACTOR personnel are identified.
  Summarize the minimum HSE requirement for identified activities.
 Identify controlling parties in the event of an emergency.
 Describe HSE reporting requirements between COMPANY and CONTRACTOR and external
parties.

1.2 Methodology
Primary, COMPANY HSE-IMS documents will always prevail. It is the obligation of the CONTRACTOR,
if he wants to use his standards and procedures during the duration of the project, to perform a detailed gap
analysis from which it is clearly visible that the requirements of they standards, procedures and/or
instructions are equal to or better than the COMPANY 's.
COMPANY is fully committed to the goal that more stringent and more binding standard prevail for the
purpose of preserving human health, protecting the environment, surroundings and assets.
A bridging document details areas of non-alignment or subject areas that have not been included either in
COMPANY or CONTRACTOR documents but are relevant to the Scope of Work (SoW).
The documents reviewed are referenced in each subject section.

2. RESPONSIBILITY FOR UPDATES

This is a live controlled document and as such, will only be amended by COMPANY and CONTRACTOR
during the scope of work due to changes in the scope of work or following lessons learned from incidents.
CONTRACTOR shall maintain the HSE Bridging Document up-to-date and communicate any updates to
the COMPANY throughout the period of the execution of the CONTRACT, upon any change occur.
Deviations from the document shall be approved only after written authorization from the COMPANY and
written notification to CONTRACTOR.

3. REFERENCES AND STANDARDS

Key reference documentation and relevant updates for project, as applicable to the extension of the works to be
performed are the following:
 Local statutory Italian laws and regulatory for all pre-fabrication and Construction activities carryout in Italy.
 Local statutory Libyan laws and regulatory for all activities carryout in Libya.
 Contractual Agreements.
 International Codes and Standards.
 Company Standards:
 Best Practices, Industry Guidelines and Standards.

Local laws and Regulation

[1] Decree no.39/2000-Environmental protection during petroleum activities.

[2] Law 5-04-Industrial Activities.

[3] Presidential Decree 117/20-Regulation for Environmental Impact Assessment and Environment

[4] Executive Decree n. 6/96-General Regulation of Occupational Health and Safety Services.

Company references

Libyan Regulations

[1] Legislative Act No. 2 of 1982 concerning the use of radioactive materials

[2] Legislative Environment Protection Act. No. 3 of 1982 about regulation of water exploitation

[3] Legislative Act. No. 7 of 1982 concerning the protection of the environment

[4] Legislative Environment Protection Act. No. 8 of 1973 about prevention of oil pollution to the sea
 [5] Decree of the Minister of Labor No. 8 for the Year 1974 A.D.- Concerning Issuance of Laboure’s Health and
Safety Regulations

[6] Legislative Act No. 15 of 1989 concerning the protection of animals and plantation

[7] Law 15 -2003 concerning Environmental protection

[8] Decision 448 of 2009 for issuance executive regulation of Law 15 of 2003

[9] Resolution n.96-2008 Environmental stipulations to protect the air from pollution – Environmental General
Department Management Committee Secretary

Branch- Gas Division procedures:

[1] “opi sg hse 012 e&p”.

International Standards and Guidelines

[1] ISO 45001: Occupational health and safety management systems- Requirements with guidance for use.
[2] ISO 14001: Environmental Management Systems - Requirements with guidance for use

Italian Laws and standards

[1] Italian legislation (D.Lgs 81/08 and 624/96 e s.m.i)

GA procedures
OPERATING PROCEDURES

PG-SA-01 REV 01 Yard Risk Assessment Procedure for Specific Job Activities

PG-SA-02 REV 01 Work permits

PG-SA-03 REV 03 Audit e report

PG-SA-04 REV 01 Management of request and use of badges

PG-SA-05 REV 02 Management of subcontractors

PG-SA-06 REV 01 Training, awareness and competencies of the system.

PG-SA-07 REV 01 Welding operation management

PG-SA-08 REV 01 Mobile technical gas management

PG-SA-09 REV 01 Load handling management with trolleys and bridge cranes

PG-SA-10 REV 01 Machine tool activity management

PG-SA-11 REV 01 Management of Works in Confined Spaces

PG-SA-12 REV 01 Management of painting and sandblasting processes

PG-SA-13 REV 01 Scaffolding construction management and delivery

PG-SA-14 REV 01 Management of works at height

PG-SA-15 REV 01 Office activity management

PG-SA-16 REV 04 Choice, distribution, and control of PPE

PG-SA-17 REV 01 Analysis of accidents and near accidents

PG-SA-18 REV 01 Health surveillance

PG-SA-19 REV 01 Manual handling of loads

PG-SA-20 REV 01 Various radiographic checks

PG-SA-21 REV 01 Maintenance of electrical systems, lifting equipment and machines

PG-SA-22 REV 01 Management and drafting of HSE Plan

PG-SA-23 REV 01 Lifting operations management

PG-SA-24 REV 01 Works on electrical systems

PG-SA-25 REV 01 Pressure test

PG-SA-26 REV 01 Work near water

PG-SA-27 REV 01 Housekeeping

PG-SA-28 REV 01 Lock out e tag out

PG-SA-29 REV 01 Pre-commissioning e commissioning

PG-SA-30 REV 01 Management of dangerous substances and treatment of safety data sheets

PG-SA-31 REV 01 Hauling, storage and storage of boats

PG-SA-32 REV 01 Incentives management

PG-SA-33 REV 01 Truck crane use

PG-SA-34 REV 02 Definition and response to potential accidents and emergency conditions Pertusola

PG-SA-34 REV 04 Definition and response to potential accidents and emergency conditions Groppoli

PG-SA-34 REV 04 Definition and response to potential accidents and emergency conditions Arcola

PG-SA-35 REV 01 Forklift trucks

PG-SA-36 REV 01 Heat treatment

PG-SA-37 REV 01 Pressure flushing

PG-SA-38 REV 01 Leak Test

PG-SA-39 REV 01 Sanctioning system

PG-SA-40 REV 06 Equipment check - PPE - Workshop and building site

PG-SA-41 REV 01 Method of Use Angle Grinder

PG-SA-42 REV 04 Job Safety Analysis

PG-SA-43 REV 01 Heat management procedure in the workplace

PG-SA-44 REV 01 Color Code identification

PG-SA-45 REV 06 Covid 19 Virus Emergency Management Procedure Groppoli-Arcola

PG-SA-45 REV 07 Covid 19 Virus Emergency Management Procedure Pertusola

PG-SA-45 REV 04 Covid 19 Virus Emergency Management Procedure in yard

PG-SA-46 REV 01 Managing the use of machines/equipment in an Atex environment

MANAGEMENT PROCEDURES

PG-GSA – 01 REV 01 Identification and management of safety issues

PG-GSA – 02 REV 01 Identification and management of the legal and normative prescriptions

PG-GSA – 03 REV 01 Safety and health objectives and targets

PG-GSA – 04 REV 01 Safety and health management plan

PG-GSA – 05 REV 01 Organization structure, roles, responsibilities, authorities

PG-GSA – 06 REV 01 Training, awareness and competences of the system

PG-GSA – 07 REV 01 Internal and external communication management

PG-GSA – 08 REV 01 SMS documentation management

PG-GSA – 09 REV 01 Operating check

Management of non-compliances, corrective and preventive actions
PG-GSA – 10 REV 01

PG-GSA – 11 REV 01 Editing of operating procedures and instructions

PG-GSA – 12 REV 01 Recording Management

PG-GSA – 13 REV 01 Re-examination

PG-GSA – 14 REV 01 System audits

PG-GSA – 15 REV 01 Performance check and measurement

PG-GSA – 16 REV 01 New employees’ procedure

Regulation management procedure for reporting wrongdoings and irregularities
PG-GSA – 17 REV 01
"Whistleblowing".
PG-GSA – 18 REV 01 Technical safety committee management procedure

PG-GSA – 19 REV 01 HSE document control

OPERATING INSTRUCTIONS

I.O.-4.4.6.01 WASTE DISPOSAL

IO.- 4.4.6.02 PRODUCTION WASTE MANAGEMENT

IO - 4.4.6.03 DANGEROUS MATERIAL STORAGE

IO - 4.4.6.04 EMPTYING TANKS

IO - 4.4.6.05 FILTERS CHECK

IO – 4.4.7.01 LIQUID SPILL

IO – 4.4.7.02 EMERGENCY

IO – 4.4.7.03 FIRE

IOA-01 REV 01 ENVIRONMENTAL EMPLOYEE (SHIPYARD)

P - 4.3.1.01 IDENTIFICATION AND ASSESSMENT OF ENVIRONMENTAL ASPECTS

ENVIRONMENTAL - SYSTEM PROCEDURES

PGA-01 REV 01 Identification and evaluation of environmental aspects

PGA-02 REV 01 Management of legislative and other requirements

PGA-03 REV 01 Objectives, targets and environmental management program

PGA-04 REV 01 Organizational structure, roles and responsibilities

PGA-05 REV 01 Training, awareness and skills

PGA-06 REV 01 Management of internal and external communications

PGA-07 REV 01 Management of the EMS documentation

PGA-08 REV 01 Operational control and emergency responses

PGA-09 REV 01 Surveillance and measurements

PGA-10 REV 01 Management of Non-Conformities, Corrective and Preventive Actions

PGA-11 REV 01 Internal system audits

PGA-12 REV 01 Management review

ENVIRONMENTAL - OPERATIONAL PROCEDURES

POA-01 REV 01 Atmospheric emissions management

POA-02 REV 01 Management of wastewater like civilians

POA-03 REV 01 Waste management

POA-04 REV 01 Management of material containing asbestos

POA-05 REV 01 Management of dangerous substances

POA-06 REV 01 Management of Suppliers and Contractors

POA-07 REV 01 Identification and response to potential accidents and emergency situations

POA-08 REV 01 Hull washing water management - Nautical area

HSE project documents

Title Document reference

HSE PLAN FOR CONSTRUCTION xxxxxxx x x xx xxxxx
HSE OPERATING PROCEDURES xxxxxxx x x xx xxxxx
WASTE MANAGEMENT PLAN xxxxxxx x x xx xxxxx
EMERGENCY RESPONSE PLAN xxxxxxx x x xx xxxxx
HSE AUDIT PROGRAMME xxxxxxx x x xx xxxxx

4. ABBREVIATIONS TERMS AND DEFINITIONS

COMPANY
CONTRACTOR
SUPPLIER Companies that supply goods to CONTRACTOR operations
SUBCONTRACTOR Companies that supply services and/or goods to CONTRACTOR operations
Works The Scope of Work detailed in this document
ALARP As Low As Reasonably Practicable
HSE Health, Safety and Environment
HSE MS Health, Safety & Environment Management System
A Work-related illness, injury or incident that causes the injured person to
LOST TIME
be away
from work for at least one normal shift following the shift during which the
INJURY (LTI) event occurred because they are unable to perform any duties. All LTI shall
be reported through the Event Reporting Procedure
MS Management System
POB Personnel on board
PPE Personal Protection Equipment
PTW Permit to Work
QA Quality Assurance
QC Quality Control
RA Risk Assessment
SIMOPS Simultaneous Operations
TBC To be confirmed
ERP Emergency Response Plan
First Aid Case - Cases that are not sufficiently serious to be reported as medical
treatment or more serious cases but nevertheless require minor first aid treatment,
e.g., dressing on a minor cut, removal of a splinter from a finger. First aid cases are
not recordable incidents.
An incident is classified as a First Aid if the treatment of the resultant injury
islimited to one or more of the 14 specific treatments. These are:
1. using a non-prescription medication at non-prescription strength
2. administering tetanus immunizations
3. cleaning, flushing or soaking wounds on the surface of the skin
4. using would coverings such as bandages, Band-AidsTM gauze pads, etc. or using
butterfly bandages or steri-StripsTM
5. using hot or cold therapy
FAC 6. using any non-rigid means of support, such as elastic bandages, wraps, non-rigid
back belts, etc.
7. using temporary immobilisation devices while transporting an accident victim
(e.g.splints, slings, neck collars, back boards, etc.)
8. drilling of a fingernail or toenail to relieve pressure, or draining fluid from a
blister
9. using eye patches
10. removing foreign bodies from the eye using only irrigation or a cotton swab
11. removing splinters or foreign material from areas other than the eye by
irrigation, tweezers, cotton swabs or other simple means
12. using finger guards
13. using massages
14. drinking fluids for relief of heat stress
JHA/JSA Job Hazard Analysis/Job Safety Analysis
LTIR Lost Time Incident Rate
MEDEVAC Medical Evacuation
MERP Medical Emergency Response Plan
MTC Medical Treatment Case - Cases that are not severe enough to be reported as
fatalities or lost workday cases or restricted workday cases but are more severe
that requiring simple first aid treatment.
An incident is classified as Medical Treatment (MT) when the management and
care of the patient to address the injury is above and beyond First Aid.
Medical Treatment does not include:
- the conduct of diagnostic procedures, such as x-rays and blood tests, including
the administration of prescription medications used solely for diagnostic purposes
(e.g., eye drops to dilate pupils)
- visit to a physician or other licensed health care professional solely for
observation or counselling.
The following may not involve any treatment but for purposes of
Classification severity, will be reported as Medical Treatment:
- any loss of consciousness
- significant injury diagnosed by a physician or other licensed health care
professional for which no treatment is given or recommended at the time of
diagnosis. Examples includes:
 - punctured ear drums, fractured ribs or toes.
- needle sticks injuries and cuts from sharp objects that are contaminated with
another person’s blood or other potentially infectious material.

5. ORGANIZATION (SEE ANNEX 2)

Role/Position Place of work

PROJECT DIRECTOR Italy
CONSTRUCTION MANAGER Italy
CONSTRUCTION MANAGER on site yard
PROCUREMENT MANAGER Italy
HSE MANAGER Italy
Q.A./Q.C. MANAGER Italy
PREFABRICATION MANAGER Italy
STRUCTURAL MANAGER Italy
MECH/PIPING MANAGER Italy
ELE/INSTR MANAGER Italy

6. HSE POLICES AND OBJECTIVES (SEE ANNEX 1)

6.1 Summary

COMPANY and CONTRACTOR (CONFIRM -HSE policies have been jointly reviewed and no areas of conflict
have been identified).

COMPANY and CONTRACTOR recognize the importance of having senior management visibly committed to
the management of health, safety and the environment. This commitment extends throughout the organization,
from senior management through to line supervision, and requires responsibilities to be acknowledged, understood
and accepted.

During whole duration of the Project/Service CONTRACTOR shall fully respect and implement HSE Disciplinary
policy.

COMPANY CONTRACTOR Alignment (Y/N)

ENVIRONMENTAL AND SAFETY ENVIRONMENTAL AND

POLICY REV 03 SAFETY POLICY REV 03
Y

NO SMOKE POLICY REV 00 NO SMOKE POLICY REV 00 Y

ALCOHOL AND DRUG POLICY ALCOHOL AND DRUG Y

REV 02 POLICY REV 02

SOCIAL POLICY REV 00 SOCIAL POLICY REV 00 Y

STOP THE JOB POLICY REV 00 STOP THE JOB POLICY REV Y
 00

6.2 Requirements

CONTRACTOR is responsible for:

 Posting COMPANY and CONTRACTOR HSE policies in visible locations within the location.
 Including both COMPANY and CONTRACTOR HSE policies in induction training.
 Use HSE policy compliance as a basis for HSE inspections and Leadership walk rounds.
 Reviewing and understanding COMPANY disciplinary policy and the potential disciplinary consequences of
noncompliance with HSE issues.
 Establishing a drug and alcohol random testing programme to comply with COMPANY requirements for
persons equivalent to COMPANY-designated positions.

7. SCOPE

The contents of this document apply to COMPANY and CONTRACTOR management and operational activities
during the agreed scope of work and the methodology to be adopted in performing the process of HSE Risk
Management involving the establishment for identification, analysis, evaluation, treatment, ongoing monitoring and
review, and communication of risks in operations relative to all project operation performed by Contractor during
installation activities. This document also covers the emergency response aspects with definition of responsibilities
during the execution of the above-described scope.

Furthermore, this document ensure clarity of responsibilities between Company during all activities onshore and
offshore. The purpose of establishing this document is to ensure that HSE performance standard, achieved by one
party through the application of its management system, are not compromised by another during shared activities.

8. PLACE OF WORK DESCRIPTION AND WORK PROGRAM

8.1 General description