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GWDC Rig HSE Case for Iraq Garraf Project

Part 2 – HSE Management System

PART 2.0 – HSE MANAGEMENT SYSTEMS

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GWDC Rig HSE Case for Iraq Garraf Project
Part 2 – HSE Management System

2.0 Introduction 4
2.0.1 Management System Elements...................................................................4
2.0.2 External Environmental, Health and Safety Standards.............................4
2.0.3 Core Business...............................................................................................4
2.1 Policies and Objectives 5
2.1.1 General HSE Objectives...............................................................................5
2.1.2 Project Specific HSE Objectives..................................................................6
2.2 Organizaiton, Responsibilities and Resources 7
2.2.1 Organization..................................................................................................7
2.2.1.1 Organization....................................................................................................7
2.2.1.2 Document Management..................................................................................7
2.2.1.3 Rig Organization..............................................................................................8
2.2.2 Responsibilities ............................................................................................8
2.2.2.1 Well Site Staff..................................................................................................9
2.2.2.2 Office Staff.....................................................................................................12
2.2.3 Resources....................................................................................................15
2.2.3.1 HSE Resources.............................................................................................15
2.2.3.2 HSE Committee Representation...................................................................16
2.2.3.3 Operational Support and Wells Organization................................................16
2.2.3.4 Communication with Clients..........................................................................17
2.2.3.5 Clients's Third Parties...................................................................................18
2.2.3.6 Catering and Accommodation.......................................................................18
2.2.3.7 Medical Support............................................................................................21
2.2.4 Competence and training ..........................................................................22
2.2.4.1 Selection of personnel...................................................................................22
2.2.4.2 Competence Assessment and Records........................................................22
2.2.4.3 Training..........................................................................................................22
2.2.4.4 Induction........................................................................................................22
2.3 Standards and Procedures 22
2.3.1 Planning and Risk Management................................................................23
2.3.1.1 Annual HSE Plan...........................................................................................23
2.3.1.2 Response and Recovery Plans.....................................................................23
2.3.1.3 Risk Management.........................................................................................23
2.3.2 Management of Change..............................................................................23
2.3.3 Emergency Response Overview................................................................24
2.3.4 Permit to Work System...............................................................................24
2.3.5 Safe Working Practices..............................................................................25
2.3.5.1 Empowerment to Stop...................................................................................25
2.3.5.2 Use of STOP and Unsafe Act Audit...............................................................15
2.3.5.3 DROPs Prevention........................................................................................15
2.3.5.4 TRIC..............................................................................................................15
2.3.5.5 Housekeeping...............................................................................................25
2.3.5.6 Personnel Protective Equipment (PPE)........................................................26
2.3.6 Environmental Management......................................................................26
2.3.7 Occupational Health and Hygiene.............................................................27
2.3.8 HSE Procedures..........................................................................................28
2.3.9 HSE Communication...................................................................................29
2.3.10 HSE Alerts and Bulletins............................................................................29
2.3.11 Rig Security.................................................................................................29
2.3.12 Drilling and Well Control Operations........................................................29
2.3.13 Transport Operations and Site Assessment............................................29
2.3.14 Engineering Management..........................................................................32
2.3.15 Lifting Operations and Material Handling On-site...................................32
2.3.16 Logistics Management...............................................................................33
2.3.17 Hazardous and Radioactive Substances..................................................34
2.3.18 Procurement Management.........................................................................34
2.3.19 Maintenance Management.........................................................................34
2.3.20 Sub-Contractor Management.....................................................................34

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2.4 Performance Monitoring 35


2.4.1 Periodic Monitoring.....................................................................................35
2.4.2 Incident Management and Reporting........................................................35
2.4.3 Behaviour-Based Observation Systems...................................................36
2.4.4 Environmental Monitoring and Measurement..........................................36
2.4.5 Audit and Audit Compliance......................................................................36
2.4.6 Verification of HSE Critical Tasks and Equipment...................................37
2.4.7 Certification.................................................................................................38
2.5 Management Review and Improvement 38
2.6 Concurrence Statement 49

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Part 2 – HSE Management System

2.0 Introduction
This part describes the Greatwall Drilling Company management system and in particular
those elements of it that deal with HSE. It aims to demonstrate the effective interfacing and
the definition of responsibilities of the Project HSE Management Systems of:

 Greatwall Drilling Company (GWDC)


 Petronas Carigali Iraq Holding B.V. (PCIHBV)
 Third Party Contractors

The document provides the reference point for the above companies during the drilling and
associated services operations phase of the Contract and gives evidence to the senior
management of all parties that operations will be conducted within the envelope of the
respective HSE management systems.

GWDC has a developed HSE Management Systems to ensure that operations are carried out
to meet the following principles:

 ensure the health and safety of all staff;


 to reduce environmental effects caused by its operations;
 to protect and utilize natural resource more effectively;
 to enhance the reputation of GWDC;
 to ensure GWDC’s profits are not harmed.

This part of the HSE Case summarizes this HSE Management System and demonstrates
how the corporate aims and objectives of GWDC will be met during the Garraf Project.

An integrated project Audit Schedule will also be developed to monitor the performance of
project related HSE issues (refer to part 6 for details).

2.0.1 MANAGEMENT SYSTEM ELEMENTS

The HSE Management System of GWDC is composed with elements as:

 Leadership and Commitment


 Policies and Objectives
 Organisation, Responsibilities and Resources
 Risk Assessment & Management
 Planning & Procedure
 Implementation & Monitoring
 Management Audit & Review

2.0.2 EXTERNAL ENVIRONMENTAL, HEALTH AND SAFETY STANDARDS

External environmental, health and safety standards are applicable for rig, e.g. ISO 14001
and OHSAS 18001 standards.

2.0.3 Core Business


Greatwall Drilling Company has the following core business functions:

 Health, Safety, and Environment (HSE)


 Human Resource
 Training
 Operations
 Procurement
 Maintenance
 Engineering
 Finance
 Marketing
 Service Supplier

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All of these functions are managed by the Great Wall Drilling Company management system
and all involve elements of HSE.

2.1 Policies and Objectives

2.1.1 General HSE Objectives


The general HSE objectives are summarized within the HSE policies of the different members
of the project. Detailed descriptions of the HSE management systems are contained in the
respective HSE management system ‘manuals’. The general HSE objectives of GWDC are
summarized as an integral part of the HSE Policy of GWDC, which follows on the next page.

The overall aim of the HSE Management Systems is to ensure the effective management of
risks to the health and safety of people, to the environment and to the assets and the
reputations of all parties involved in the campaign, are paid equal attention to and are not
compromised in any way in pursuit of other goals, such as financial targets.

The risk assessment and task activities required to ensure an acceptable level of HSE risk
are defined by the analyses undertaken in the remainder of this HSE Case.

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HSE Policy of Greatwall Drilling Company

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0 2.1.2 Project Specific HSE Objectives

HSE strategic objectives for Garraf Project are to:

 Prevent all injuries;


 Prevent occupational related ill health;
 Ensure that all personnel have the necessary competencies for their roles and implement
continuous staff competence training;
 Maintain a high level of local community interaction and acceptance;
 Control impact of logistics on local community daily routine and living;
 Ensure personnel security at the highest practical level;
 Have full management of waste and waste collection;
 Ensure that all accidents / incidents that could have or have caused loss or HSE
implications are reported, investigated and analyzed and appropriate remedial measures
taken.
 Minimize land take, maximize biological protection and return land in prime state as soon
as practically possible; in doing so prevent long-term negative impact on the
environment.
 Implement the necessary management systems and procedures to ensure that hazards
and risks are identified and that the impact of the drilling and correlative service activities
on the health and safety of personnel and on the environment is reduced to ALARP
levels.
 Prevent damage or loss of assets; and
 Prevent loss of reputation.

2.2 Organizaiton, Responsibilities and Resources

2.2.1 Organization
2.2.1.1 Organization
A management organigram showing the GWDC personnel, for office and rig site operations,
is shown in Figure 2.1 (following page).

2.2.1.2 Document Management


Document Control

Document Type Document Custodian Document Owner Classification


Procedure Project Manager Counter Manager Controlled

The Wellsite Documentation System of GWDC Garraf Project comprises:

PROJECT SPECIFIC DOCUMENTS


Master Bridging • Describes procedures are to be followed where there are overlaps or gaps
Document in PCIHBV and GWDC.
Project • In the case of routine well operation this may be prepared on a process or
Emergency area specific basis.
Response Plan • Prepared in conjunction with the PCIHBV to specify which procedures are
to be used in response to a range of incidents and emergencies.
• In some cases project specific procedures may be required (e.g. earth
quakes or heavy weather).
• This document also describes how GWDC organises itself in response to
incidents and emergencies.
HSE Plan • Includes key events, strategies and activities to ensure Wells targets are
met.
• Includes key events, strategies and procedures for minimising
environmental impact.

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Waste • Waste Management Plan addresses the safe disposal of all industrial
Management Plan waste.

Drlg Programme • The main output for drilling prepared in accordance with a standard
template including the Project Specific Well Control plan that bridges
between PCIHBV and GWDC Procedure.
SIMOPS • The main output from the SIMOPS Process, this document provides
Procedures detailed operating procedures for SIMOPS.
HSE CASES
HSE Case • Demonstration of the HSE Management System in action to show that HSE
risks have been or will be reduced to ALARP.
REFERENCE DOCUMENTS
GWDC SOP • The main purpose is to provide easy reference to which document should
be followed for design and operation issues that are important for controlling
risk, quality and integrity.
• Provide detailed procedures and work instructions.
GWDC HSE MS • Provide policies, procedures for a number of HSE operations activities.
Local Best • These document local best practices for overcoming hole problems and
Practices optimising well design and operations.
(Optional)
Specialist • Special documents have been issued for high-risk activities including
Subjects Response to Well Control Incidents and SIMOPS.
• These are designed to cover these issues from planning through execution
rather than breaking the issues into standards, process and procedures.
Documents from Wells uses documents from other departments including:
Other Disciplines • Supply Chain Management.
• Logistics, etc.
• Manufacturer Manual

2.2.1.3 Rig Organization

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GW52 HSE ORGANIZATION

HSE COMMITTEE OF GWDC IRAQ BRANCH

Other
Line
HSE Managers
GWDC PROJECT HSE Committee
Manager

Rig Manager (Qi hongjun, Xie kai)


HSE(Liang jiangzhong, Liao zhen)
ToolPusher(Li peifeng,Geng ruijie,Wang chong)
Rig Engineer (Wang xuguang,Li xiangyang)
Camp boss(Lin beijun)

Rig HSE
supervisor

Shift 1 Shift 2 Shift 3 Shift 4 Camp

Driller Driller Driller Driller Camp boss


Guo jiangwei Li li Liu jian Guo jiang wei Lin beijun
Assit Driller Assit Driller Assit Driller Assit Driller Chef
Hasan Jasim Ayad Motter Ali Hasan Hamid Lafta Mussa
Derrick man Derrick man Derrick man Derrick man Azam
Hussain Ali Dawod Muslim Shery Hameed Sary Mousa Waheed Azeez
Ali Mahdi Rahaif Haydar Hilal Ali Ghazi
Floor Man Floor Man Floor Man Floor Man
Mohammed Faraj Rasool Ateya Faisal Abbas Aayan Mohammed Hasan
Raad Raji Talab Khalil Flih Ali Rasheed Hussam Hasan
Mushtaq Mohsen Mohammed Majed Sadam Khashan Hussain Jasim
Saad Mohammad Ahmed Husseen Haider Katea Haider Hussan
Asaad Abdulrazaq Mohammed Hussein Haider Adnan Safaa Jasim

Roustabout Roustabout Roustabout Roustabout


Ali Mohsin Asee Hussein Salmen Maitham Kareem Hasan Ali
Barazan Shaker Iessa Khalaf Bander Faris Hmood Hussein Jasim
Haithem Edan Nazar Azizz Aswad Hayder Basim Isa Imad Lafta
Saget Khudhair Ayad Daem Ghalab Motor Man Mohammed Hilal
Motor Man Motor Man Ali Abed Motor Man
Dhyaa Jawad Kadhim Ali Jeber Zaet Electrician Rafid Radhi
Electrician Salih Mahdi
Anwer Hasssan

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2.2.2 Responsibilities

The roles of the principal companies involved in the drilling operations may be summarized as
follows:

GWDC Provision of drilling and integrated services

PCIHBV General control of the project, inclusive of providing overall security of the
Oilfield

Third Parties Provision of specialist services to supplement drilling and well services
activities.

GWDC (Iraq) HSE Management Organization

Fig 2.1: Organigram of GWDC Iraq

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2.2.2.1 Well Site Staff

The roles and responsibilities of the rig site management team are summarized below:

PCIHBV Well Site Staff with Functional HSE Responsibility

TBA

GWDC Well Site Staff with Functional HSE Responsibility

Functional responsibility of Rig Manager

 To visibly propagate HSE commitment by promoting HSE initiatives and leading by


example.
 To be responsible for execution of HSE measures in accordance with HSE policies, plans
and regulations, such as waste management, road transport, security and occupational
health.
 To be responsible for all HSE issues (i.e. including security) related to the rig, the crews,
drilling site and the camp.
 To co-operate closely with site drilling supervisory personnel and related local authority so
as to enhance HSE site management.
 To ensure the implementation of the permit to work system.
 To ensure the implementation of the STOP system.
 To ensure as ‘Person-in-Charge’ (PIC) during emergencies that all personnel, including
those from PCIHBV and Sub-Contractors, will fulfill their roles as defined in the
emergency response plans.
 To carry out emergency exercises on a regular basis.
 To investigate and report near misses and incidents.
 To chair (daily/weekly) HSE meetings and to provide advice and direction in the Toolbox
Talks and JHA sessions.

Functional responsibility of Drilling Engineer/Toolpusher

 To visibly propagate HSE commitment.


 To be responsible for the integrity and safe use of drilling equipment.
 To instruct and supervise personnel on site in executing all the appropriate HSE measures
as instructed by the Rig Manager.
 To perform the drilling and completion activities in strict accordance with procedures written
for these activities.
 To make sure that personnel on duty wear PPE commensurate with the risks of their
activities. Personnel performing routine duties wear minimum PPE such as safety hat,
protective clothes, safety shoes, gloves, safety glasses and ear plugs (as required).
 To inform the drilling supervisory staff of hazardous situations in a timely manner.
 To guide staff engaged in well control activities to follow and implement the well control
procedures of GWDC and PCIHBV.
 To participate in all site safety meetings, Toolbox Talks and JHA sessions.
 To ensure the implementation of the permit to work system.

Functional responsibility of Driller

 To visibly propagate HSE commitment.


 To be responsible for the health and safety of his crew, company and sub-contractors staff
near or on the drill floor and to stop the job if there is any increased risk or unforeseen
hazard.
 To make sure all crew members as well as company and sub-contractors staff wear PPE
commensurate with the risks of their activities.
 To report any abnormal situation (well control or otherwise) on or in the well in a timely
manner and to take measures controlling the abnormal situation as instructed.
 To be responsible for implementation of the DROPS (or equivalent) programme.
 To be responsible for implementation of site safety meetings, Toolbox Talks and JHA

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sessions in anticipation of a new or changed activity.


 To ensure the implementation of the permit to work system.

Functional responsibility of the Mechanical and Electrical Engineer

 To be knowledgeable about HSE mechanical or electrical system procedures, to be


competent for the post assigned and to combine the HSE system procedures for day-to-
day practical work and preventative maintenance.
 All mechanical and/or electrical engineers shall possess the appropriate qualification
certificates through specialized training before being authorized to perform their tasks at
the well site and/or camp.
 All mechanical and/or electrical engineers must meet experience level requirements and
must possess the skills for equipment trouble-shooting and maintenance.
 To minimize the effect on environment as a result of rotating equipment, due to spills and
leakages of equipment, no matter how small, outside the contained area.
 Installation and positioning of equipment, electric systems, fuel tanks etc. shall be in
accordance with GWDC SOP system, in accordance with Hazardous Zones and/or
documented procedures.
 Maintenance of the power and drive systems during maintenance or replacement shall be
isolated and identified with tags.
 To restrict access to workshops and VFD control room to authorized personnel only.
 To implement welding and cutting procedures and inherent precautionary measures as
directed by GWDC and/or legislation.
 Oxygen and acetylene bottles shall be placed in accordance with requirements from
GWDC and/or relative authority.
 To report any abnormal situation (operational or/and HSE) in a timely manner and to take
measures controlling the abnormal situation as instructed.
 To ensure that all activities (maintenance or otherwise) are officially registered and
recorded to facilitate internal/external auditing.

Functional responsibility of the Site Doctor

 To provide medical services in the camp or on the rig site to any personnel and in
accordance with established medical procedures.
 To record the medical particulars (prescription drugs, bloodgroup etc.) of any new person
staying or working on the rig or camp.
 To provide the Rig Manager and Drilling Supervisor with a daily POB sheet on which all
staff in camp or on rig are listed with personal details (passport/identification, date in/out
etc.) as required by GWDC, PCIHBV and legislative bodies.
 To advice the Rig Manager in case of an incident whereby sick or injured people need
specialist medical care (hospitalization with or without Medivac).
 To have enough instruments/tools available and medicines in stock as per agreed
minimum stock lists.
 To accurately assess, measure and record the health condition of all staff in need of care
 To assist the camp boss in implementing in strict supervision of food hygiene by camp staff.
 To ensure that sanitation and cleanliness of the camp is of the highest standard.
 To take water samples on a regular basis and subsequently measure and record purity in
accordance with GWDC and/or legislative guidelines.
 To ensure that camp facilities and equipment are free of rodents and insects to minimize
the risk to food poisoning or diseases (e.g. poultry viruses) brought in from unknown
sources.
 To be fully conversant with the effects of all chemicals used on the rig or camp and to have
the skills to neutralize/minimize these effects in accordance with guidelines provided. To
perform this task he will have available to him a complete and up-to-date set of SHOC
and MSDS sheets for all chemicals in use on the rig and camp.

Functional responsibility of HSE Coordinator

 To visibly propagate HSE commitment.


 To assist the Rig Manager and Drilling Supervisor in implementing the HSE MS and HSE
Plans of GWDC.
 To perform inspections (e.g. on fire fighting equipment) and to advice personnel on HSE

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matters if poorly understood or in need of improvement.


 To conduct HSE inductions to all new personnel (working or visitors) arriving on site and to
ensure that all new personnel will have the understanding and awareness of the
applicable HSE regulations and procedures.
 To actively participate in HSE meetings, toolbox talks and JHA preparation or discussions.
 To demonstrate the HEMP techniques to all staff for timely recognition of hazards and how
to reduce the effect to reduce or eliminate the risk to personnel and/or assets.
 To timely report any near miss or incident to the Rig Manager or Drilling Supervisor.
 To assist and -if appropriate- to lead the investigation into any near miss or incident, to
keep the incident scene intact. To assist in incident report writing on behalf of the Rig
Manager.
 To promote suggestions from personnel and make proposals to improve HSE.
 To actively promote and/or implement all of the GWDC and PCIHBV HSE initiatives by
presentation and distribution to all drilling and sub-contractor staff.
 To actively cooperate and liaise with the PCIHBV HSE Coordinators.

Functional responsibility of the Camp Boss

 To be responsible for overall camp management (operational and HSE).


 To implement strict supervision of food hygiene by his camp staff to prevent diseases from
entering or spreading.
 To ensure that food storage and refrigerators are in excellent working condition. Cooks
shall wear appropriate work clothes when on duty.
 To ensure that potable water remains free of contamination.
 To ensure that the camp facilities remain free of any fire hazards and by strict
implementation of the non-smoking policy (except for dedicated area).
 To ensure that emergency equipment (fire extinguisher and fire control facilities) for the
camp are in the correct location and in good condition.
 To organize and record fire drill exercises in the camp on a regular basis.
Functional responsibility of Service Company or Sub-contractor

 Follow GWDC HSE Management System and Site rules;


 Regard safety as a central theme in their actions;
 Participate in safety performance reviews with line management;
 Develop work method statements/ Job Safety Analysis for their scope of work;
 Provide when requested representation to all site meetings;
 Consult with line management to coordinate work place activities;
 Conduct formal & informal work place hazard inspections;
 Participate in the Site Safety Program and weekly safety meetings;
 Participate in the STOP program;
 Conduct toolbox/pre-job meetings when required associated with the scope of work of
their activities;
 Immediately report/ investigate all incidents and report back findings and close out actions;
 Provide safety related data to GWDC Site Management;
 At all times, comply with the relevant guidelines formulated and disseminated through
inductions, toolbox meetings and daily site instructions.

Functional responsibility of each individual

 Each individual shall be clear and actively pursue to create and maintain a safe, healthy
working environment.
 Each individual shall on duty shall wear PPE commensurate with the risks of their activities.
 Each individual shall report and -if possible- correct any unsafe condition or act to the Rig
Manager and/or PCIHBV Drilling Supervisor.
 Each individual shall STOP the job if the situation or equipment or the people performing
the job are considered to be unsafe. Any follow up can then be discussed with
supervisory staff.
 Each individual shall report any near miss or incident and any chemical spill or leakage to
his immediate supervisor.
 Each individual shall obey HSE regulations (PPE, PtW, JHA, drills etc.).
 Each individual shall follow clear HSE instructions as given by supervisory staff to perform
the ultimate safe operation. If instructions are not fully understood, the individual shall

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immediately seek a clarification.


 Each individual shall participate in a positive constructive manner when exercises are
conducted in fire control, first aid and well control, so as to improve the ability of self or
group rescue.

2.2.2.2 Office Staff


The roles and responsibilities of the office management team are summarized below:-

Functional Responsibility of Country Manager

 Liaise with the Client Representative (Such as Contractor Holder) to assure compatibility
and agreement between Client’s and GWDC’s HSE systems, plans and objectives;
 Commit the resources to meet and/or exceed the requirements agreed to in the HSE-MS;
 Demonstrate the commitment to high HSE standards through regular visits to site during
which he will be involved in audits, Job Safety Analyses, safety meetings and through
providing the resources to effect recommended improvements;
 Ensure that GWDC staff are trained as per the agreed requirements in the training matrix,
such that they develop the necessary competence to enable them to work safely and
avoid damage to the environment;
 Ensure all GWDC employees receive appropriate induction and training in all aspects of
their work and observe such safety requirements as the work situation warrants;
 Liaise with Client to monitor the work of service companies and Sub-contractors and
ensure that they meet the HSE Standards in HSE-MS;
 Make suitable arrangements for consultation with GWDC line supervisors, employees and
service and Sub-contractors' representatives on health, safety and environmental
matters;
 Make certain that all incidents involving injury to persons, damage to property/equipment
or the environment, and those having potential for serious effect are reported
immediately and that they are thoroughly investigated and that effective follow-up action
is taken by:
 Establishing remedial action requirements;
 Identifying action parties;
 Establishing completion targets;
 Regularly reviewing progress.
 Establish and discuss with GWDC line management and supervisors individual
responsibilities, targets and accountabilities for health, and safety of personnel and the
protection of the environment;
 Ensure that personnel safety equipment is provided to all GWDC personnel;
 Set a clear leadership example by his own actions.

Functional Responsibility of Project Manager

 To propagate, fulfill and execute laws, decrees of the country and local government on
‘Health Safety and Environment’ and GWDC’s HSE Policy. To be available with HSE
management system qualification.
 To perform the HSE managing power on behalf of the Manager of GWDC.
 To coordinate HSE management between GWDC and sub-contractor so as to make them
consistent.
 To guide operational teams to perform to the GWDC’s HSE regulations and policies.
 To ensure that the rig is always staffed by experienced and competent professionals and
with the ‘hearts and mind’ culture that is necessary to achieve the HSE objectives.
 To organize HSE training for working staff regularly and make them qualified with
certificate.
 To regularly organize health examination for working staff.
 To regularly educate the staff in first aid, fire control, well control and H 2S prevention
knowledge, to be able to perform such activities on demand.
 To organize professionals for routine HSE inspection on construction site.
 To examine the execution of HSE management on operation site according to the
requirements of management committee.
 To have the duty to stop any activity when HSE problems are found.
 To ensure that the HSE Management System, which includes this document, has been fully
implemented and is functioning as intended by conducting regular audits.

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 To analyze the overall HSE execution of this Garraf Project and take corrective actions
correspondingly.
 To report the HSE management of this project to the manager and management committee
of GWDC regularly and provide reliable basis for HSE review and evaluation.
 To collect and integrate original records of HSE management, to participate the review and
evaluation of HSE system procedure when possible.

Functional Responsibility of HSE Manager

 Develop programs and plans to meet defined and agreed to HSE objectives which derive
from the contract, and this HSE-MS;
 Revise HSE Management System of the Project, and monitoring the implement of such
system;
 Propagate HSE Policies of the Company;
 Draft HSE policies and rules for the Project;
 Organize HSE inspection and periodic assessment for the working units of the Project, and
reporting the result to Project Manager;
 Revise and update Emergency Response Procedure;
 Carry on Inspection and treatment for HSE incident, participating in inspection and
treatment of LTI or DAFW and more serious incident, and supervising the implement of
following treatment and creative action taken by the responsible unit;
 Draft annual HSE Work Summarization for the Project, and Work Plan of HSE Emphasis
for the next year;
 Review HSE daily report, weekly report and monthly report submitted by working units,
 and provide feedback opinion;
 Arrange HSE daily work, and assess employees of HSE Department according to their
performance and competence;
 Provide technical support to Logistic Department regarding procurement of HSE equipment
for working units;
 Coordinate with project training manager and HR Department regarding HSE training for
project employees;
 Communicate with the Clients regarding HSE issues, and communicate and coordinate
with other projects of the company.

Functional Responsibility of Operation/Drilling Manager

 Liaise with the Client Operation Manager to assure compatibility and agreement between
Client and GWDC’s safety systems, plans and objectives;
 Commit the resources to meet and/or exceed the requirements agreed to in HSE Plan;
 Demonstrate the commitment to high HSE standards through regular visits to site during
which he will be involved in audits, Job Safety Analyses, safety meetings and through
providing the resources to effect recommended improvements;
 Ensure that GWDC staff are trained as per the agreed requirements in the training matrix,
such that they develop the necessary competence to enable them to work safely and
avoid damage to the environment;
 Ensure all GWDC employees receive appropriate induction and training in all aspects of
their work and observe such safety requirements as the work situation warrants;
 Make suitable arrangements for consultation with GWDC line supervisors, employees and
service and Sub-contractors' representatives on health, safety and environmental
matters;
 Make certain that all incidents involving injury to persons, damage to property/equipment
or the environment, and those having potential for serious effect are reported
immediately and no later than hours after the incident has occurred to GWDC General
Manager by oral and that they are thoroughly investigated and that effective follow-up
action is taken by:
 Establishing remedial action requirements;
 Identifying action parties;
 Establishing completion targets;
 Regularly reviewing progress.
 Establish and discuss with GWDC line management and supervisors individual
responsibilities, targets and accountabilities for health, and safety of personnel and the
protection of the environment;

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 Set a clear leadership example by his own actions.

Functional Responsibility of HSE Department Manager

 To assist Management and Support Functions in:


 Establishing, maintaining, implementing and improving the HSE Management
System;
 Planning, Executing, Maintaining HSE Statistics of GWDC Iraq branch;
 Liaising with Clients, third party Sub-contractors, and agencies regarding HSE;
 Assessing risks;
 Establish Branch and Project HSE standards and procedures;
 Preparing HSE plans and Annual Schedule as per required ensuring optimum
minimization of the above and compliance to policies, standards and
procedures;
 Implementing above;
 Advice controls required to verify and ensure proper implementation and
maintaining all related HSE records;
 Conducting Monthly Management review meetings to assess the effectiveness
of the HSE Management System and identify required improvements;
 Advise Management on corrective action required;
 Conduct accident / incident investigation and reporting;
 Conduct HAZAOP / HAZID Studies if required by GWDC Management;
 Guide site HSE staff to conduct Risk-Assessments, Job Safety Analysis and Hazard
Identification;
 Advise on Waste Management plans, Environmental Impact Assessment keeping in views
the requirements of ISO 14001;
 Co-ordinate and actively participate in the screening and training of all personnel, including
Sub-contractors;
 Keep abreast of any new development or policy related to HSE and inform management
accordingly;
 Ensure that the relevant HSE documentation is readily available in office;
 Advise Management on the compliance of the local HSE program with all local and
national regulations of the host country;
 Participate in liaising with third party Sub-contractors, Clients and local agencies regarding
HSE; Conduct Sub-contractor regular HSE audit;
 Actively follow-up on HSE related subjectsand participate in HSE audits and investigations
of major failures and accidents;
 Develop and maintain a high level of awareness among all personnel through
communications, training, and active personal involvement of employees in HSE
through prevention and reporting of nonconformities;
 Recommend changes to the HSE program;
 Ensure regular updating of personal qualifications and attend to personal training as
required;
 Technically support Logistic Department for purchasing HSE materials or HSE service;
 Communicate with Client HSE Department regards all HSE affairs;
 Draft GWDC Monthly HSE report to Client;
 Attend Client’s HSE meetings;
 Set good HSE example for all the crews.

Functional Responsibility of HSE Department Deputy Manager

 Be knowledgeable and ensure all items implementation in camp which are detailed in the
HSE Plan and Annual HSE Schedule;
 Commit the resources to meet and/or exceed the requirements agreed to in HSE-MS;
 Make certain that all incidents involving injury to persons, damage to property/equipment
or the environment, and those having potential for serious effect are reported
immediately and no later than 2 hours after the incident has occurred to HSE Manager
and/or Operation Manager by oral and that they are thoroughly investigated and that
effective follow-up action is taken by:
 Establishing remedial action requirements;
 Identifying action parties;
 Establishing completion targets;

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 Regularly reviewing progress.


 Establish and discuss with GWDC line management and supervisors individual
responsibilities, targets and accountabilities for health, and safety of personnel and the
protection of the environment;
 Ensure that personnel safety equipment is provided to all GWDC personnel in -Warehouse
and - Camp;
 Lead base crews to participate in the STOP program;
 Set a clear leadership example by his own actions.

2.2.3 Resources
2.2.3.1 HSE Resources
Effective management and implementation shall be achieved with adequate resources.
GWDC (Iraq) Country Manager would be responsible for ensuring that adequate resources
are allocated to satisfy HSE requirements. Financial and other resource requirements for
effective HSE management shall be identified during the preparation of budgets and business
plans.

Direct HSE support from GWDC Iraq Branch and Garraf Project is provided by:
 Country HSE Manager and Project HSE Manager.
 Health Advisors.
 Environment Advisors.

Rig team have dedicated HSE supervisors supported by Project HSE Department. Operation
and Drilling Managers are from time to time assigned to the HSE Teams.

GWDC Iraq Branch are also to assign HSE Advisors and Line HSE Focal Points as
appropriate to the type and scale of their operations, for example:

 GWDC Iraq: Direct HSE support provided by GWDC Head HSE Office as focal Point
 Garraf Project: Direct HSE support provided by GWDC Garraf HSE Team.
 Site HSE Supervisors: Two Chinese and two local HSE Supervisors as HSE Focal Point.

2.2.3.2 HSE Committee Representation

Project HSE committee shall be set up for the GWDC Garraf Project. HSE experience sharing
was the first step in meeting, and all in turn. GWDC Iraq Branch Project Management Team
and Company Representatives shall be the member of the committee. The HSE committee
shall once 3 months review the status of the HSE plan and Annual HSE Schedule
implementation in order to improve the HSE performance. ( E.g. Training Matrix and Road
safety, STOP card Review, Incident Review, Improvement Strategy.)

GWDC recognize the need to discuss and resolve items of concern with regard to HSE. Rig
crew and Sub-contractors shall be encouraged to organized Rig Safety Committee with the
following aims:

 Confirm that all the parties concerned are properly carrying out the management of HSE;
 Ensure that the operation is being performed safely and smoothly, complying with safety
and rules and regulations and method statements;
 Coordinate and control congested or hazardous working conditions among Company and
Sub-contractors;
 Resolve safety issues raised by Company / Sub-contractors;
 Increase Sub-contractors’ safety knowledge and safety awareness;
 Enforce Safety Training;
 Participate and organize Safety Promotional Activities;
 Promote and maintain housekeeping and waste disposal at the highest standards.
 Promote and review progress on behaviour based safety process;
 Analyze trends from the HSE data, and adjust safety plan as required.

By encouraging strong GWDC Project HSE Committees issues concerning HSE may be
resolved prior to their becoming disruptive to the project. This not only promotes a safer job,
but also raises the level of safety consciousness and encourages the personnel on the site to

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be constructive rather than critical. The Project management teams shall attend the meeting
to discuss management, engineering, project control, procurement, subcontracting and, not
only including HSE issue at some time.

2.2.3.3 Operational Support and Wells Organization

Operational Support:
Throughout the drilling campaign, operational support, such as engineering, personnel,
logistics and emergencies, will be provided by the office management teams based in Garraf
Base, Dubai and Beijing.

The Wells organization will be responsible for the planning and execution of the well
construction activities and manage all Wells-related service contracts. Well Services
Managers is responsible for the planning and execution of all routine Well Services activities.
When WS activities are executed with the rig ‘on-site’ the overall responsibility of the
operations, including HSE, lies with the Rig Manager.

Wells Organization:

Project Manager Company Contract


Reporting Line Holder

Communication
Company
Project HSE Operation Representative
Manager Manager

Company man on Location

Rig manager

Rig CREW
worksite

2.2.3.4 COMMUNICATION WITH CLIENTS

The communication between GWDC, PCIHBV, and the service companies is the key towards
effective and efficient operations. It is important that these communication links are refined, in
particular to suit the language barriers and any organizational changes within or between the
parties.

There are three main areas of communication between parties:

 routine communication;
 management of change; and
 emergency communication.

During emergency control, the Duty Manager, who resides in the Camp, will play a critical
role, not only in establishing and maintaining communication ‘between’ parties, but also to
ensure that all communication media are available 24 hrs a day.

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A variety of communication tools will be utilized on a routine basis to establish and maintain
effective lines of communication between the rig site and office management teams and
within the rig site itself. The tools to be used will include but are not limited to:

 Near miss and injury reporting *


 Daily drilling report *
 Weekly rig crew safety meetings *
 Pre-shift safety meetings
 Log books
 Daily planning meetings
 Pre-operations safety meetings
 Tool box safety meetings prior to non-routine operations
 Office/rig site communications*#
 Operational instructions#
 Drilling/completion/well services programmes and amendments to such programmes#
 Service contractor communications*#
 End of well reports *
 HSE statistics #
 Safety newsletters #

Items marked * will be communications from the rig site to the office, and items # from the
office to the rig site. Additionally all the above will remain resident on the rig site to permit
audits when required. There will be an emphasis on single form reporting for all parties.

In addition to the project specific reporting detailed above, GWDC require that each drilling
location must report to the liner manager at 0700 every morning.

HSE issues are disseminated to the crews through the Rig Manager and the HSE
Coordinator. Communications Equipment has been listed in Part 3.

If changes to the ‘work program’ (in effect the daily activities to maintain the rig in support of
the drilling or well services programme) are necessary, such changes must be approved by
the Project Manager following consultation with PCIHBV. Procedures for changes to the work
programs or physical plant are detailed in sections 2.3.2 respectively. If such changes impact
upon the HSE Case, then the Case Custodian will task the HSE Manager to make any
updates required.

Changes in personnel roster at the rig site will be communicated as part of the normal
reporting procedures from rig site to office. All new personnel arriving at the site will receive
an initial HSE briefing (induction) which will be provided by the GWDC HSE Coordinator
and/or the PCIHBV Drilling Supervisor. Details will be recorded in a log book.

Details of the communication requirements for an emergency situation has been contained in
Garraf Project Emergency Response Plan as well as Part 5 of this HSE Case.

2.2.3.5 CLIENTS’S THIRD PARTIES

 Clients are required to notify GWDC in advance of sending any 3 rd party contractor to the
well site, with acceptance letter of the management systems of those 3rd parties.
 Client’s 3rd party contractors might be inspected by GWDC site HSE coordinator prior to
allowing commencement of activities after arriving at the well site.
 Client 3rd party contractors operating on the well site are required to follow client’s HSE
management system including PtW system.
 Client 3rd party contractors are subject to regular audits via the contractor audit system –
see Part 6 of this HSE Case for details.

2.2.3.6 CATERING AND ACCOMMODATION

All accommodation would be constructed to provide protection against pests and adverse
weather conditions. The basic requirement includes but not limited to the following:

Environment Temperature: -30° ~ 55°

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Seismic Capability: 10 levels above

Beds with firm springs or suitable hard-board (without curvature) shall be provided and fitted
with a suitable mattress of at least 6 cm thickness, a blanket, two sheets, two pillows and two
pillow cases. Bed linen shall be washed at least once a week. Any evidence of bed bugs shall
be reported immediately to the camp supervisor. Provisions would be made for adequate
heating of accommodations during cold weather conditions.

All sleeping accommodation shall be air-conditioned. Sufficient natural and artificial light
(minimum of 150 Lux intensity) shall be provided in all rooms.

The kitchen shall be air-conditioned and vented. A hood shall be fixed over cooking ranges
and an extractor fan of a suitable size shall be installed. Cloths shall not be used to wipe and
dry dishes / crockery and cutlery - air drying or paper cloth shall be used. Where large pots
are used, large pot washing sinks shall be provided. Separate wash hand basins shall be
provided in kitchens, together with a plastic nail brush, a liquid soap dispenser and liquid
soap. Hands shall be washed after every stage of food preparation. Disposable paper towels
or an electric hand drier shall be provided.

Sufficient number of refrigerator and chest freezers shall be provided. As fish tends to taint
other food, a separate freezer is preferred. Where this is not practical, fish shall be placed in
separate compartments or shelves. Pork and pork products would be not available for the
religion reason in GWDC camp.

Separate areas/surfaces shall be provided for preparation of cooked and uncooked foods.
Colour coded cutting boards made of polypropylene or other non-absorbent synthetic
materials shall be provided for meats, chicken, fish and vegetables. These shall always be
kept clean and disinfected after each use. A purpose made polypropylene chopping block
shall be provided for cutting large joints of meat. It shall always be kept clean, disinfected,
smooth and free of cracks or fissures.

Cooked food shall be stored either above 63 degrees C or below 5 degrees C to prevent food
poisoning pathogens from developing. A food thermometer with probes shall be used to check
that all cuts of meat weighing more than 1kg have been thoroughly cooked to a minimum
internal temperature of 75 degrees C.

Samples of all meals served during each meal shall be marked and kept in a freezer for 96
hours after serving.

A cleaning schedule shall be prepared and implemented for kitchen and equipment.

The mess would be large enough to seat 30% of the camp's population one time. Tables and
chairs of reasonably comfortable type shall be provided and maintained in a clean condition.
The mess shall be air conditioned and well lit (minimum light intensity of 300 Lux). At least
two electronic fly-killers shall be installed, but advice on numbers & positioning shall be per
manufacturer’s specifications. All doors to the outside shall be self-closing. Self-closing doors
shall not be wedged open. Wash hand basins shall be provided. The basins shall be provided
with soap. Cold drinking water in clean water jugs shall be provided on each table.

All food items shall be stored in a well lit and air conditioned room large enough to ensure that
an adequate supply of food, which includes extra stock for emergencies, is available at all
times. Food shall be stored in a way that enables good stock rotation. "First In, First Out"
practice shall be established and applied. All dry food shall be stored on shelves or benches.
The area underneath shall be kept clean at all times (for this reason wooden pallets shall not
be used to store food products). Metal or plastic bins with tight fitting covers shall be used for
loose grains, flour, etc. Food shall be stored such that it is readily accessible and proper
shelving shall be provided where appropriate. Nothing shall be stored underneath benches.
Shelves shall have a non-absorbent finish that is easy to clean. Cupboards shall not be used.
Cleaning chemicals, detergents, mops and brushes shall not be kept in food stores. The store
shall always be kept in a clean and tidy condition, and free of any spillages and pests.

Fish and fish products shall be stored in a separate freezer. Where this is not practical, fish

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shall be placed in separate compartments or shelves. Walk-in freezers/chillers shall have


metal shelves and good lighting. They shall be equipped with safety devices to prevent
accidental lock-in. A thermometer gauge shall be fixed outside the unit to give temperature
readings of the equipment. The gauge shall be maintained in good working order. Ice-cream
and ice shall not be stored in the same freezer as meat, fish or poultry to avoid cross
contamination.

All fresh fruits and vegetables consumed without peeling or cooking and eaten raw are to be
disinfected. 80 ppm of chlorine dilution with a contact time of 20 minutes shall be applied and
then rinsed to remove all traces of chemicals. Wash salads thoroughly before eating.

Food handlers, catering supervisor and camp boss shall be trained in food hygiene. The
training shall include elements of:

Causes of food poisoning


Basic bacteriology
Personal hygiene
Prevention of food contamination
Pest control
Cleaning
Food Hygiene and Food Safety

Unauthorised persons shall not be allowed in areas where food is prepared / handled. A
notice to this effect shall be placed outside these areas.

All food handlers must possess a current Medical Fitness Certificate issued by the Ministry of
Health or equal organization in IRAQ. The Certificate shall be carried by the individual during
working hours. The service company camp boss shall keep copies of all certificates readily
available on site. The GWDC HSE department shall have the right to review Medical Fitness
Certificates and to stop the work of any employee who fails to produce their Certificate.

Any food handler suffering from diarrhoea, vomiting, high temperature, or who has septic
sores or cuts in his hands or body shall immediately report to his supervisor and shall be kept
away from food handling work until he gets clearance from a GWDC-approved Medical
Practitioner. Each food handler shall be provided with a minimum of three uniforms, aprons,
caps and non-slip footwear.

Food handlers must have a clean and tidy appearance, clean hands with short fingernails and
short hair which should be covered during food preparation. Jewellery shall not be worn while
working with food. Food handlers shall wear plastic disposable gloves whilst serving of food.
Gloves should be replaced after every use.

Food handlers shall maintain good personal hygiene. Food handlers shall wash their hands
after visiting the toilet, after smoking, before touching food and between handling raw and
cooked food. Smoking shall not be allowed in food preparation or storage areas.

Domestic wastes (including kitchen wastes), office wastes and clinical wastes shall be stored,
collected and disposed of in accordance with GWDC's Waste Management.

Water for drinking, cooking, washing and toilets in camps shall be provided from GWDC and
Client-approved sources.

Water shall be distributed from source by pipes made from UPVC, steel or cast-iron materials
approved by the company. No lead pipes shall be used.

Water shall be stored in aboveground tanks made either in stainless steel, galvanised steel or
reinforced fibre glass.

Water supplies for domestic use shall be disinfected by chlorinating so that a residual free
chlorine level of 0.2 mg/l to 0.5mg/l is maintained throughout the distribution system. Site
Manager shall check and record the chlorine level every two weeks.

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If water is trucked in, the tanker truck shall be licensed in accordance with local traffic
requirements. All water tankers shall be painted blue and shall have the words "POTABLE
WATER" written in white on both sides of the tanker in Arabic and in English.

Water tankers shall not be used for any other purpose and shall be kept clean and in good
repair. Each water tanker shall be inspected by GWDC Project HSE Department before
renewal of its licence/registration.

Water supplied to camps shall comply with the chemical and bacteriological limits specified in
WHO Standard. Bacteriological limits in water storage tanks shall be checked monthly and
the tanks shall be cleaned annually.

Laundry services shall be provided for all personnel accommodated in camps. The service
shall include washing of bed linen, towels, work clothing and personal clothing.

Laundry facilities shall be kept clean and maintained in working order.


Laundry from any individual that has an infectious disease shall be stored and washed
separately from other laundry. A Client Medical Officer would be consulted to determine any
specific washing and handling requirements.

Detergents and other laundry-related chemicals shall be stored in a ventilated clientm, well
apart from clean clothes.

A drying area that is protected against dust and animals shall be provided.

Recreational facilities shall be provided in GWDC camp. As a minimum, indoor facilities in


Recreation Room would include TV, DVD, and videos.

2.2.3.7 MEDICAL SUPPORT

First Aid treatment would be available at all GWDC sites, at all times people are at work. First
Aid treatment shall include having competent ‘First Aiders’ and fully-stocked First Aid kits.
When more than 10 people are working at a particular location, a minimum of 10% of staff
shall be competent First Aiders with access to suitable First Aid kits. When less than 10
people are working at a particular location, at least 2 persons are to be competent First Aiders
with access to suitable First Aid kits . Additional competent First Aiders with access to First
Aid kits shall be provided if the workgroup is more than 20 minutes by road from the nearest
clinic or if the work poses a high level of risk.

Competent First Aiders (Medic) shall possess a valid certificate of competence in First Aid,
The First Aiders shall undertake refresher training at least every 6 months. The training shall
be performed by a Sub-contractor Nurse or approved teacher. The refresher training shall
include familiarisation with the Medical Emergency Plan, the layout of the clinic and the
location of equipment.

First Aid Teams exist to assist in emergency response, particularly in the Interior, where
resources are geographically dispersed.

The Medic/Nurse shall maintain a list of names, telephone numbers and locations of each
member of the First Aid Team. This list shall be available at the clinic and emergency control
room.

The Medic shall be assigned responsibility to check each First Aid Kit weekly, to maintain the
kit fully-stocked, and to record the checks. A record of the checks shall be retained. The
location of First Aid kits, and names, telephone numbers and locations of First Aiders shall be
centrally posted at each work location.

Any equipment, cupboards and doors shall be properly secured inside the vehicle. It shall be
possible for the nursing attendant to communicate directly with the driver. The vehicle shall be
fitted with a radio, siren, and flashing warning light. Each ambulance vehicle shall contain
medical items and equipment in accordance with GWDC Minimum Requirements for
Ambulances. Each ambulance shall be checked daily to ensure that it is road worthy,

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regardless of whether or not the ambulance has been recently used.

Medical Examination and other related reports see the attachment, as per the GWDC Incident
Investigation and Report Procedure.

2.2.4 COMPETENCE AND TRAINING


2.2.4.1 SELECTION OF PERSONNEL

The Project Manager will be responsible for ensuring the competency of personnel supplied
to the rig site. All operations staff will possess valid IADC/IWCF certification and The
competency of key GWDC personnel will be as detailed in the contract documentation.

Refer to Business & Logistics Department document, which would be the part of contract w/
service company for Selection of Sub-Contractor Personnel.

The competency of key personnel has been as detailed in the Contract documentation. HSE
responsibilities for all positions identified in the organisation are detailed in section 2.2.2.
These HSE responsibilities require personnel to possess identified competencies to be
capable of fulfilling these responsibilities. The following section describes the HSE
management system competency assurance processes utilised to ensure GWDC’s HSE
objectives can be achieved.

2.2.4.2 COMPETENCE ASSESSMENT AND RECORDS

The competence assessment processes and records would be maintained. This process is
used for identifying those individuals assessed as being “not competent” and who require
additional training or experience to carry out their current duties or prior to promotion/change
of duties.

2.2.4.3 TRAINING

GWDC HSE training is designed to familiarise employees with potential hazards, to highlight
and demonstrate safe and unsafe work methods, to inform employees of applicable laws and
regulatory requirements, and explain the HSE responsibilities.

Both the Manager of the Operations Department and the HSE Department are responsible for
selecting personnel to attend training courses. The training courses are held either in-house
by GWDC experts or by recognized training organizations.

A training database is in the process of being developed by HSE Department which will define
the training requirements of all rig personnel, their training records and refresher training
requirements.

Line Supervisors are responsible for obtaining the required training for their staff including
Wells induction and HSE House Rules induction. GWDC has developed their own training
matrices and competency templates. A quarterly check on the HSE training matrix against
staff requirements is performed to ensure that all staff has the requisite training as outlined
above.

All Team Managers and Leaders enroll in behavioral training programmes and unsafe act
auditing.

All staff will be trained in well control theory and practices. Some selected staff (Rig Manager,
Toolpushers, Drillers, Assistant Drillers) will sit the appropriate exams (theory and simulator
assessment) and obtain the IADC/IWCF certificate.

For the Garraf Project, all staff will be trained in STOP training by GWDC HSE Manager or
PCIHBV HSE Advisor.

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2.2.4.4 INDUCTION

GWDC will provide relevant industry standard training stauff for their staff on the work sites
and has specific briefing videos shown to all newly arrived crew members and visitors.

A HSE Induction briefing is conducted for personnel not holding a valid safety passport prior
to a site visit to make them aware of the position of Wells on HSE matters and assure them of
management’s support in their implementation of HSE, in particular the ‘Stop Work’ / ‘Safety
First Priority’ Policy.

2.3 STANDARDS AND PROCEDURES


2.3.1 Planning and Risk Management
GWDC Iraq Branch generate Annual Business Plans covering objectives, targets and main
activities and HSE is integral to these plans and principle HSE activities, particularly those
driven by GWDC, are specified.

2.3.1.1 Annual HSE Plan


Both GWDC Iraq Branch and GWDC Garraf Project compile Annual HSE Plans detailing Key
Focus Areas, including each of the seven elements of the HSE MS. HSE Plan is supported by
a detailed Action Plan specifying the activities for the year.

HSE performance against set targets is monitored through reporting of progress against the
implementation of the HSE Plans.

2.3.1.2 Response and Recovery Plans


Routine well drilling activities have process, country or field specific Incident and Emergency
Response Plans. These plans are a subset of the Master Bridging Document and describe
which procedure (PCIHBV Specific) to follow in the event of incidents and bridge to the
GWDC or Field Emergency Response Plans.

Wellsite has a Well Control Plan as an integral part of the Well Programme that details project
specific controls to avoid well control incidents and, if required, project specific procedures to
regain well control.

2.3.1.3 Risk Management


Risk will be managed according to be the principles of the Hazard and Effects Management
Process (HEMP). Hazard identification has been carried our as part of the preparation of the
HSE Case. The following techniques are an integral part of the Well Drilling Process:

 Kick-off Meetings and Operational Activity Planning Meetings.


 Job Hazard Analysis or Job Safety Analysis.
 Hazard Identification Plans, Toolbox Talks, 5x5, TRIC, etc.
 Application of Unsafe Act Auditing or STOP type systems.
 Audits and management visits.
 Health Risk Assessment.
 Impact Assessment– health, environment and social.
 Quantitative Risk Assessment (for New technology and SIMOPS).
 HAZID/HAZOP.
 Mobilization of rig and related unit.
 Logistics support including establishing/using support bases.

The initial identification of project hazards was the subject of a desktop HAZID (HAZard
IDentification) exercise by operation department manager and an independent safety
specialist. The HAZID addressed all of the three key activities of the project (Rig Operation,
Transportation Activities, and GWDC Garraf Camp Activities). The principal objectives were to
identify the potential major accident hazards associated with each key activity and the
controls and recovery measure in place to manage the hazards.

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2.3.2 Management of Change


Work arising from temporary and permanent changes to organization, personnel, systems,
process, procedures, equipment, products, materials or substances, and laws and regulations
cannot proceed unless a Management of Change process is completed, where applicable, to
include:

 a risk assessment conducted by all impacted by the change


 development of a work plan that clearly specifies the timescale for the change and any
control measures to be implemented regarding:
 equipment, facilities and process
 operations, maintenance, inspection procedures
 training, personnel and communication
 documentation
 authorization of the work plan by the responsible person(s) through operation.

Procedures for changes to the work program and physical plant are detailed in HSE-Manual
respectively. If such changes impact upon the HSE Plan, then the Plan Custodian (GWDC’s
Project Manager) will make any updates required .

Changes in personnel roster at the rig site will be notified as part of the normal reporting
procedures from the rig site to the camp office. All new personnel to site will receive an initial
HSE briefing which will be provided by the Rig HSE Officer and recorded in a log or POB.
Same action in Garraf camp site.

If there are changes in Drilling Program and such changes impact upon the HSE Case, the
Case Custodian will task the Operation and HSE Manager to make any updates required.

2.3.3 Emergency Response Overview


Project Emergency Response Plan has been compiled for Project operations in the Iraq. It
also help to establish the bridging document with each sub-contractors’ management
systems, and the local and remote emergency organisations and shows how each interface
with the overall emergency structure whilst operations are carried out.

Rig Emergency Response Procedure provide the planned lines of communication with
relevant contact numbers to cater for emergencies at rig site to ensure that any services or
assistance required are mobilised and utilised in the most efficient and controlled manner.

A brief description of the overall emergency response organisation and the elements of
emergency response organisations that shall be implemented by personnel in managing the
emergency responses are shown in the form of an program that can be entered at any stage
dependent upon the emergency.

Garraf Project emergency response arrangements will be the responsibility of GWDC as


detailed in the Project Emergency Response Plans and Site Emergency Procedures.

Copies of the Garraf Project Emergency Response Plans and Site Emergency Procedures
will be held at the rig site and at the designated locations in Garraf Base, Dubai and Beijing.

An overview of Emergency Response procedures and management is included in the Project


Emergency Response Plan.

2.3.4 Permit to Work System


All GWDC rigs will operate a permit-to-work system to ensure that activities other than normal
operation of a rig are properly controlled and coordinated. Please find the details in GWDC-
IRQ-ICGARRAF-HSE-L2-05 Permit to Work Procedure.

The Rig Manager issues and authorizes the PTW. Permits are raised by the responsible
supervisor, designated the person in charge of the works and who is also required to sign the
permit. Permits are displayed at the worksite and in the Toolpusher’s Office.

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The Rig Manager must sign all permits before the work can start. The authorisation by the
RM aims to ensure that no conflict exists with ongoing and/or planned activities and that it has
no impact on the Operator assets. The Rig Manager signs again when the job is complete
and the worksite has been inspected and made safe.

In principle, all personnel should be familiar with the PTW form and the PTW procedures. All
personnel new to the rig will receive PTW induction on site. This induction training will be
documented in a register that needs to be signed. The training will be the responsibility of the
Toolpusher, assisted by the HSE Coordinator.

Personnel will be issued with personal protective equipment (PPE) as required. Where such
PPE is rig specific it will be provided by GWDC. At all other times the provision of PPE will be
the responsibility of the individual companies (PCIHBV and third parties).

2.3.5 Safe Working Practices


2.3.5.1 Empowerment to Stop
All personnel have the authority and responsibility to halt any part of an operation they deem
to present an unacceptable risk or where they consider effective hazard management is
inadequate.

Should such a situation arise, the matter will be discussed with line supervision and brought
to the attention of the GWDC Rig Manager and Company Man. Work must not recommence
until effective measures are in place to manage the hazards, and the worksite has been
deemed safe.

2.3.5.2 Use of STOP and Unsafe Act Audit


All parties at the rig site agree to the use of STOP Program (Safety Training Observation
Program) to identify and record near miss incidents.

The HSE Department of GWDC has established management regulations for Unsafe Act
Audits. The HSE Department will conduct frequent Unsafe Act Audits at the rig location and
when any unsafe activities are witnessed or are known to have taken place, measures will be
taken to eliminate the cause. In certain instances fines might be imposed on the staff
concerned.

2.3.5.3 DROPs Prevention


 All equipment and loads shall be inspected prior to transportation, for secure retention or
removal of loose objects not intended for transportation to the operations site or return to
logistics base
 Routine DROPS inspections shall be performed bi-weekly and on rig-up of other well
intervention equipment and fill up DROPs inspection register.
 A documented SOP procedure for pre-mast raising, pre-mast lowering and skidding
inspections shall be in place and strictly followed.
 Dropped object inspections shall be performed following jarring of stuck pipe, activities
causing excessive vibrations or severe storms.
 All rig locations shall indicate No-Go Zones and Red Zones. All persons on location shall
be made aware of these zones.
 Conduct training of all staff to improve the awareness of DROPs and enhance people
hazards identification ability.
 All tools used at height should be logged out at the start of a job and logged in after the job
has been completed and before operations continue.

2.3.5.4 TRIC
As a kind of RISK IT TALK IT CHECK IT, GWDC requests the rig crew to apply TRIC
(Toolbox-talk Risk Identification Card) for each job in order to make proactive actions to
identify work-related hazards and minimize job risk.

TRIC can be used prior to each Tool Box Talk and also shall be collected and registered for
monthly trend analysis.

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2.3.5.5 Housekeeping
Housekeeping is a fundamental component in any operation. All work areas shall be kept in
as clean and tidy condition as possible. Trash, rubbish and waste shall be handled in
accordance with the waste management program. Waste shall be removed and disposed of
at regular intervals. All employees shall clean their work areas at the end of each shift.

To maintain high standards of occupational health and hygiene and reduce the potential of
industrial illness and incidents, GWDC Iraq Garraf Project requires that all areas at the rig
well site and the camp are maintained and organised at a consistently high level.

GWDC Site Managers and Supervisors shall be responsible for ensuring an informal
housekeeping inspection is conducted on a daily basis. The areas within their control are to
be maintained in a tidy, safe condition. Materials and equipment not in use shall be neatly
stacked away from the work areas and clear of access ways. Waste receptacles on the rig
and camp sites will be emptied on a daily basis and removed off site to designated waste
management areas. Housekeeping extends to the camp, and the maintenance of the camp in
an orderly fashion.

2.3.5.6 Personnel Protective Equipment (PPE)


Personnel will be protected by the mandatory wear of PPE and by a high standard in food
hygiene and sanitation. Additional procedures will be in place to allow work to proceed in the
Camps Handling Precautions.

Personal Protective Equipment (PPE) shall be manufactured in accordance with recognized


standards such as DIN, ANSI, Standards or equivalent. Basic issue to all personnel shall
comprise of:

 Safety helmet / hard hat,


 Safety footwear,
 Safety glasses.
 Fire Retardant coverall with long-sleeve.

All personnel at the rig site are required to wear the correct personnel protective equipment
(PPE) for the task being performed. The use of hard hat, coveralls, safety glasses and safety
footwear is mandatory at the rig site within the rig site boundary and outside the offices and
accommodation. Personnel with specialized jobs or working in additional risk areas shall be
provided with (as appropriate to the task/risk):

 Face shields / goggles,


 Hearing protection (high noise areas),
 Respiratory equipment,
 Safety harnesses and lanyards (with absorber).

Training in the use of PPE shall be given in the HSE orientation and induction course. Where
specialized equipment is to be used, prior to the work commencing, the Supervisors or
Designated Managers will give additional training. The use of specialized PPE shall also be
addressed as part of the pre-job safety meetings and as toolbox talk topics. Training shall be
based upon the manufacturer’s recommendations and the specific environment /risks the
PPE is intended for.

2.3.6 Environmental Management


The environmental management activities at each stage of the development of the GWDC
Project in Iraq are guided by environmental standards including those imposed by legislation
and those established by self regulating industrial codes of practice, oil industry standards
and company policy. GWDC will adopt China National Petroleum Company (CNPC)
standards and guidelines, industry standards such as those produced by international bodies
such as the ISO, WHO, IADC, API or others.

Environmental management will facilitate the minimization of environmental impacts and the

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integration of environmental protection into this part of the project. At the end, it will be
implemented to address significant environmental issues during all the activities of the
project. A training program will be developed to ensure that all employees are briefed on the
project specific environmental requirements.

GWDC Project Team will conduct audits of operations and those of its Sub-contractors during
all phases of the project to ensure compliance with the environmental objectives, procedures,
relevant regulations and good industry practices. Environmental audits will be conducted as
part of the HSE audits and will be scheduled in accordance with the overall project audit
schedule. External audit would be accepted and encouraged.

2.3.6.1 Environmental Protection


 To the extent that the work can be accomplished safely, spills of oil, petroleum products,
substances and sanitary and septic wastes should be contained and cleaned up
immediately.
 Store hazardous materials and wastes in covered containers and protect from vandalism.
 Place a stockpile of spill cleanup materials where it will be readily accessible.
 Train employees in spill prevention and cleanup.
 Designate responsible individuals to oversee and enforce control measures.
 Spills should be covered and protected from weather water run-on during rainfall to the
extent that it doesn’t compromise cleanup activities.
 Do not bury or wash spills with water.
 Do not allow water used for cleaning and decontamination to enter drains or watercourses.
Collect and dispose of contaminated water in accordance with Waste Management.
 Place proper storage, cleanup, and spill reporting instructions for hazardous materials
stored or used on the project site in an open, conspicuous, and accessible location.
 Keep waste storage areas clean, well organized, and equipped with ample cleanup
supplies as appropriate for the materials being stored. Perimeter controls, containment
structures, covers, and liners should be repaired or replaced as needed to maintain
proper function.

GWDC Project Team will conduct audits of operations and those of its Sub-contractors during
all phases of the project to ensure compliance with the environmental objectives, procedures,
relevant regulations and good industry practices. Environmental audits will be conducted as
part of the HSE audits and will be scheduled in accordance with the overall project audit
schedule. External audit would be accepted and encouraged.

2.3.6.2 Management of Waste


The objectives and goals of waste management are:

 Minimize the generation of waste material by judicious use of material and reuse or recycle
material, when feasible,
 Treatment or disposal of wastes such that the disposal activity and the treated waste have
minimal impact on the surrounding environment,
 Promote awareness of and adherence to proper waste management procedures by site
workers.

Refer to GWDC Waste Management Plan for more details

2.3.7 Occupational Health and Hygiene


Procedures for managing occupational health and hygiene are detailed in section 6.8.3 of
HSE Plan to GWDC requirements and to additional laws and regulations in the country of
operations, which describes GWDC's requirements for managing occupational health risks
associated with the activities of drilling and service companies.

The following Occupational Health risks have been be considered as well:

Physical
 Hearing Conservation/Workplace Noise
 Heat

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 Sunlight
 Dust

Chemical
 Benzene
 Hydrogen Sulphide (H2S)
 Paints and Coatings

Ergonomic
Manual Handling

Psychological
Stress

Biological health hazards refer to Public Health part

2.3.8 HSE Procedures


It is recognised that HSE procedures are important for managing HSE activities, for
operations and maintenance. All work shall be carried out in accordance with the written work
programs. No work will be performed which in any way conflicts with HSE objectives. In such
cases where conflict occurs, work will be stopped, when safe to do so as determined by the
relevant person in charge, and the work program re-assessed and amended as required.

All non-routine and HSE critical operations are carried out under a Permit to Work System.
The Permit to Work System to be used is agreed and is documented in the Master Bridging
Document.

2.3. 9 HSE Communication


Key HSE information and expectations are communicated through the weekly and monthly
reports. Monthly HSE meetings are used to consolidate these efforts. Posters, which
summarize the monthly meetings and highlight focus topics, are distributed after every
meeting.

Local legislative requirement for HSE activities e.g. the requirement for Country Safety
Committees are described in GWDC HSE Management Systems.

In addition to weekly and monthly HSE meetings the following methods are used to
communicate HSE issues:

• GWDC Web-sites. • HSE Information Sharing Packs.


• Incident Alerts and Updates. • Site Visits.
• Focused Risk Campaigns. • Time Out for Safety sessions.
• Manuals, Leaflets and Brochure Distribution.

2.3. 10 HSE Alerts and Bulletins


GWDC rig will provide safety notice boards that display information such as safety inspection
results, monthly accident summary report, and safety posters. These boards shall be
displayed at location where high volumes of movements of employees. This may be at rig and
site offices.

2.3. 11 Rig Security


GWDC Project Management is to assess and provide security for the rig site as required and
the Security Management System (SeMS) have been established in order to eliminate and/or
minimize the overall security risk exposure of GWDC employees, sub-contractors and
operations.

Protection of life takes priority over protection of company assets and interests. Therefore,
each employee and sub-contractor shall be responsible for following these guidelines in

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addition to relevant GWDC principles and policies.

Furthermore, all senior managers shall make every effort to cultivate a positive security
management culture and inculcate a common understanding of our vision, values and beliefs
by engaging in activities and programs which demonstrate visible and felt leadership. Refer to
Security plan in detail.

2.3. 12 Drilling and Well Control Operations


GWDC has adequate drilling and well control management procedures(SOP) in place.
Personnel on duty must operate in accordance with standard drilling and well control
procedures. However, specific procedures for Garraf wells might apply and these will be
cascaded to and consulted with the PCIHBV Drilling Supervisor on location. The general
principle for all staff is to ensure that primary well control is maintained at all times and that
staff is aware of the indications that primary well control could be lost, is about to be lost, or is
lost. If indeed primary well control is lost, then staff must be able to apply secondary well
control procedures safely and effectively. The Operation/Drilling Manager will perform audits
on the drilling teams to ensure that all team members demonstrate well control alertness and
proficiency.

Well Control Manual of CNPC will be the related document for reference.

2.3. 12.1 Simultaneous and Combined Operations


Where none routine Well Services and Production activities are to be conducted
simultaneously (SIMOPS), a Specific Instruction for Simultaneous Operation(SISO) will be
prepared using the PCIHBV and GWDC SIMOPS Process. A qualitative risk assessment
using the risk assessment matrix is a mandatory requirement. If ALARP cannot be
demonstrated, the risk level is further assessed using more complex Quantitative Risk
Assessment.

Prior to commencing SIMOPS Operations, a drill is held together with the platform personnel
to evaluate the emergency response of an integrated facility.

2.3. 12.2 Simultaneous and Combined Operations Risk Assessments


Undertaking Simultaneous Operations (SIMOPS) will involve the acceptance of increased
risk. Increased risk can arise in a number of ways. For example in the case of simultaneous
drilling and production drilling staff will be exposed to production process risks in addition to
the normal drilling risks. Similarly production operators and maintainers will be exposed to
development drilling blowout risk in addition to their normal day-to-day exposure to production
activity risk.

If the Business requires SIMOPS to be undertaken, associated risks has to be contained


within acceptable level and ALARP shall have to be demonstrated. In any case, the following
operations are too risky to allow SIMOPS and therefore during these activities, simultaneous
operations will have to be temporarily suspended likely:

a) Rig positioning
b) Rig up and rig down
c) Heavy lifting
d) Tie-in operations

Risk mitigation measures shall include elimination or reduction of non-essential activities that
would unnecessarily raise risk level if undertaken whilst under SIMOPS. For example; visits
by non-essential personnel to the drilling Locations should be eliminated during SIMOPS.
Another example would be the suspension of routine maintenance activities by ensuring that
essential maintenance (consistent with safe and sound operating practices) has been carried
out as a first priority.

Every proposal to undertake SIMOPS shall be considered in the light of a full evaluation of
the additional hazards and risk involved via the application of the Hazard and Effects
Management Process. A Quantitative Risk Assessment (QRA) may need to be undertaken.

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This is aimed at determining the increase in risk of simultaneous operations compared with
sequential operations and to identify ways in which risk can be reduced.

A Well Specific Instruction for Simultaneous Operation(SISO) shall be prepared and approved
in due operation.

2.3. 13 Transport Operations and Site Assessment


In GWDC GSCC camp and rig site security guards shall provide cover 24 hours a day, 7 days
a week, including holidays due to security situation. Fence or Perimeter Wall at the work site
shall be erected with gates and lighting for the entrance, storage yards, offices and
accommodations, etc. All gates at storage yards, offices and accommodations shall be
lockable. Areas outside of the fence shall be kept clear of obstructions. Storage shall be
adequate for the materials to be stored. Adequate protection against attack, damage and theft
shall be provided until completion of the Project. High value resources shall not be stored
adjacent to fence or Perimeter Wall , valuable resources shall be stored in containers and
warehouses and/or physically controlled, these areas shall be adequately illuminated. In the
event of accidental damage to a Fence or Perimeter Wall, repair work shall be performed as
soon as possible.

Roads inside camp or access ways in camp and worksite may have to be restricted by signs
for specific security reason(s); Any related parties shall not block off or otherwise make any
road impassable or hazardous without Project Manager’s prior approval. Approval for road
closure will be based on availability of alternate roads for emergency vehicles.

All barricades and road-closed signs shall be strictly observed, as they are silent guardsmen
for hazardous areas or conditions. The removal of road barricades is limited to the individuals
who installed them initially, unless or except in extreme situations or emergencies.

GWDC’s Journey Management System will be used for all travel activity area (outside radio
frequency range), and all travel inside radio frequency range and site limit.

Journeys shall be planned to arrive before sunset. Vehicles will be equipped with IVMS. The
vehicle shall report to Journey manager at first time once it arrives the destination.

Common carrier type vehicles making deliveries or picking up materials shall only make
deliveries or pick up during normal working hours, unless special arrangements have been
made. Common carrier vehicles, which enter - camp site/ worksite, shall be logged in and out
by GWDC Security Guard.

On-site visitor's permits and safety equipment will be issued in accordance with established
policies. Third Partied drivers enter into working areas requiring hard hats and safety glasses
with side shields shall be required to comply policy and be advised to remain with their
vehicles at all times.

All vehicles will be subject to inspection. Any person removing any type of materials from/to
the site will be required to have an authorized material pass. The pass shall be signed by
persons authorized by the GWDC Project Management Team specifically covering material to
be removed from/to the site. This material pass will list, by items, a description of the material
being removed and company or sub-contractor markings and/or serial numbers.

Any parties in site should manage their equipment and materials, protect to be stolen or put in
disorder. Visitors or employees found with tools in their possession on leaving the project and
without a material pass will be detained. The Site Security Manager will be notified to
investigate and take appropriate action. Visitors and Employees taking their personal tools
on/off the job shall have those tools inventoried and recorded, prior to their leaving the site.

2.3. 13.1 Adverse Weather


The hazard of severe weather typically is the cause of another hazard. For example, strong
winds creating extreme storm factors can result in human physical effects and structural
failure of the mast or cranes; lightning can lead to fire; storm, fog or heavy rain can result in
vehicle accident or heavy rain can cause flooding leading to pit overflowing and subsequent

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environmental impact. Hot weather can result in heat stroke.

The Garraf Project will be conducted all year round. Extremely sandstorms are frequent in
Summer(July-August) with maximum wind strength occasionally. Given the above statistical
data, the principal hazard of extreme weather in the Garraf area is considered to be ‘hot
temperatures’ in combination with high sandstorms.

2.3. 13.2 Supports


Normally use of personal vehicles inside the Project is restricted, and will only be permitted
for genuine business purpose on special occasion. Expatriate Staffs of GWDC Garraf Project
was not permitted to drive vehicle in Project due to Security Integrity Management.

A Vehicles Permit Pass is required to be issued by GWDC Garraf Security Management


team, and must be show to security guard for check. GWDC and its Security Guard have the
right to inspect packages, bundles, toolboxes, equipment and motor vehicles at any time
while on GWDC property. Cameras shall be allowed to use without the permission of the Site
Manager.

Client or Other companies vehicles will follow up GWDC and its Security Guard security
check before site entrance.

Motor vehicle operators must be in possession of a valid driver’s license or applicable


operators’ certificate. Seat belts are to be used by all passengers while the vehicle is on
movement. This includes cranes, forklifts, automobiles, trucks and other mobile equipment.
Vehicles and equipments that to be used to carry people shall be fit for purpose, i.e. People
are not allowed to ride in the back of an open truck and loader of forklift.

Inspection of all major equipment shall be performed by approved third party service in
accordance with GWDC and Client requirements. GWDC would authorize the third party to
inspect all major equipments prior to its use on the work site. Equipment inspected and
accepted record by GWDC and Client for use shall be documented. The following list is an
example of items requiring inspection prior to use:

 Cranes.
 Forklifts.
 Excavators/ Bulldozers if any.
 Vehicles (light and heavy).
 Third party trucks.

If the equipment is found to be damaged or fails the inspection it is to be removed from


service and either sent for repair or removed from the project.

Diesel and heavy oil is required at the rigsite for the electrical generators. These materials will
be transferred to and from the wellsite by road and hence there is the potential for a road
traffic accident to result in spillage resulting in environmental damage or fire. Similarly, a road
traffic accident with a truck carrying other hazardous chemicals, such as highly toxic or radio-
active material could have severe consequences if these substances were able to leak to the
environment.

Although the likelihood for above incidents and respective consequences to happen is
relatively minor, the damage to the reputation of GWDC could be significant.

Control measures are similar to those in place for crew transportation. Some additional
measures apply to minimise the risks to spillage, emission or leakage. Mitigation measures
are addressed by the Emergency Response Plans, as developed by Garraf Projet.

2.3. 14 Engineering Management


The scope of work involved in the drilling campaign is initially defined by the Contract and the
drilling program. Reviews will be conducted amongst all members of the office and rig site
management teams prior to issue of this program.

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Prior to the commencement of drilling operations there will be a final pre-spud meeting. At this
point any queries or questions will be addressed, with agreed revisions resulting in
amendments to the drilling program.

Additionally it is the responsibility of the Operation and/or Drilling Manager and the Rig
Manager/Toolpusher to continually assess the suitability of this program and recommend any
alterations that may be required.

The implementation of the above within Well Engineering is detailed in the Wells
Management System. Drilling as a unit operating within Well Engineering adopts the
requirements in its entirety as key components of management system structure

HSE Critical Tasks maintain Hazard Controls such that when required, they perform as per
the original design intent. For engineering management most HSE Critical Tasks are identified
through therig HSE Case but others are identified during hazard assessment. It is the
responsibility of the operation manager to ensure these tasks are carried out and confirms all
operational staff has the appropriate level of competence in operations and HSE before
commencing operations.

2.3. 15 Lifting Operations and Material Handling On-site


A document describes recommended practices and recommendations for all mechanical
lifting and material handling operations in GWDC rig site in order to minimize the associated
risk.

Refers details in following procedure:


GWDC-IRQ-ICGARRAF-HSE-L2-14 Lifting and Hoisting Procedure
GWDC-IRQ-ICGARRAF-HSE-L2-18 Dangerous Material Handling Procedure.

2.3. 16 Logistics Management


2.3. 16.1 Person Tracking
Relate personnel in trades or disciplines where recognized industrial qualifications exist (e.g.
crane operators, forklift operators, and welders, etc) shall possess a current certification of
qualification.

GWDC would make effort to take action on it, the scope of that shall cover as a minimum:

 all trade/discipline skills engaged in the provision of the WORK.


 clear definition of the minimum level of specific knowledge and skills required for each
position.
 for each individual, a measure of their current knowledge and skills.
 for each individual, the preparation and implementation of a knowledge and skills.
 development program to take them up to and beyond that minimum defined for their
position.
 testing of individuals by personnel qualified to undertake such testing to verify that.
 knowledge and skills have been effectively acquired and are being implemented in the
work place.
 recording of all competency assurance activities in an auditable manner.
 monitoring of the competency assurance program.
 recognized industrial qualifications for all trades/disciplines to be established.

2.3. 16.2 Transport Operations


Common carrier type vehicles making deliveries or picking up materials shall only make
deliveries or pick up during normal working hours, unless special arrangements have been
made. Common carrier vehicles, which enter - camp site/ worksite, shall be logged in and out
by GWDC Security Guard.

On-site visitor's permits and safety equipment will be issued in accordance with established
policies. Third Partied drivers enter into working areas requiring hard hats and safety glasses
with side shields shall be required to comply policy and be advised to remain with their
vehicles at all times.

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All vehicles will be subject to inspection. Any person removing any type of materials from/to
the site will be required to have an authorized material pass. The pass shall be signed by
persons authorized by the GWDC Project Management Team specifically covering material to
be removed from/to the site. This material pass will list, by items, a description of the material
being removed and company or sub-contractor markings and/or serial numbers.

Any parties in site should manage their equipment and materials, protect to be stolen or put in
disorder. Visitors or employees found with tools in their possession on leaving the project and
without a material pass will be detained. The Site Security Manager will be notified to
investigate and take appropriate action. Visitors and Employees taking their personal tools
on/off the job shall have those tools inventoried and recorded, prior to their leaving the site.

Any Personnel Journey or Equipment / Material Delivery and Removal from/to site, the action
such as PSD/APT for expats, Journey Plan and Vehicle Checklist should be available.

All personnel shall strictly adhere to all directional, speed limit and other traffic control signage
on site, lease roads, and all public roads. And all personnel shall fasten the safety belts while
driving is the basic requirement. The regulation we should obey was following but not limited:

 All drivers operating vehicles within the GWDC Garraf Project must have a valid driver's
license.
 Seat belts are to be provided - and worn by - all occupants of any moving vehicle.
 Ensure that the vehicles are clean, licensed, serviced and maintained.
 All drivers are required to rest for a minimum of 15 minutes after a maximum of 2 hours
continuous driving or to swap with another driver.
 Obey all traffic signs including speed, STOP, and directional signs.
 Any automobiles and/or trucks entering the GWDC site must be maintained in a safe
operating condition.
 Vehicles must yield the right-of-way to pedestrians, forklifts and mobile crane equipment,
including yielding the right-of-way to emergency vehicles.
 Parking is allowed only in designated parking areas and spaces; parking in other locations
may be required to load/unload materials. At no time shall emergency equipment be
blocked by a parked vehicle.
 Violations of any of these rules may be cause for removal of driving or site access
privileges. Continuous violations are cause for dismissal.
 GWDC Security Guard may be utilized to direct/control employee vehicle traffic under
emergency condition at the gates if determined as necessary by GWDC Iraq Garraf HSE
Dept.

2.3. 17 Hazardous and Radioactive Substances


Hazardous and radioactive substances on site of the individual services companies are
described in seperated Drilling HSE MS and procedure which also inlcusive of an inventory of
all hazardous and radioactives materials (including names, specifications, quantities and
locations) whill be maintained on the rig site.

Materials Safety Data Sheets (MSDS) which specify handling procedures, protective clothing
requirements and emergency response procedures, will be provided for all hazardous
materials which should be stored at hazardous material storage areas, and in accordance
with the individual services companies’ HSE MS and/or related procedures.

Refer to GWDC Radioactive Standard Operation Porcedures and Handling Procedure of


Hazardous Substances.

2.3. 18 Procurement Management

A stock of original equipment strategic spares and consumables will be held at the location
warehouse. Additional items, if required, will be requested by the Rig Manager to the Project
Logistics Manager. This will be resourced locally or from abroad at the decision of the Project
Logistics Manager.

The procurement of all spares, replacement parts and materials will in no way conflict with QA

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and construction standards specified in rig Design & Construction Standards and
Certification.

Adequate documentation verifying any equipment as fit for purpose must be maintained. If the
documentation does not arrive with the equipment, the equipment will not be put into service
until such time as verification can be made to the satisfaction of the Rig Manager.

2.3.19 Maintenance Management


The maintenance of all 50DB rig equipment is carried out in accordance with the Preventative
Maintenance Program. These procedures will be utilized throughout the campaign and
Project supervisory/operation staff will be responsible for implementing the program under
guidance of the Rig Manager, but with overall responsibility resting with the Rig Manager.

Each sub-contractor to GWDC will be responsible for the preventive maintenance of their own
equipment, according to individual maintenance schemes. These sub-contractors are
required to satisfy the Rig Manager that such maintenance has been performed so that the
equipment is fit for purpose.

2.3.20 Sub-Contractor Management


All sub-contractors and major suppliers will be subject to a pre-qualification and HSE
evaluation. This evaluation will assess the Sub-contractor’s HSE procedures and standards
and their ability to fulfill the terms of the contract within the required HSE parameters. Prior to
any Sub-contractor selection being made, the candidate Sub-contractor(s) will be investigated
for:

 Safety performances and statistics,


 Recognition of HSE requirements of the project,
 HSE management structure and procedures,
 Safety and environmental record,
 Effective safety training,
 Environmental management system.

The above evaluation will provide a realistic and accurate HSE assessment of the Sub-
contractors ability to fulfil the HSE requirements of the Project. If the Sub-contractor
successfully completes the Project evaluation, he will be placed on the Approved Project Sub-
contractors list.

Also the Sub-contractors should undertake their respective tasks in a safe manner, and as
such shall:

 Follow GWDC HSE Management System and Site rules;


 Regard safety as a central theme in their actions;
 Participate in safety performance reviews with line management;
 Develop work method statements/ Job Safety Analysis for their scope of work;
 Provide when requested representation to all site meetings;
 Consult with line management to coordinate work place activities;
 Conduct formal & informal work place hazard inspections;
 Participate in the Site Safety Program and weekly safety meetings;
 Participate in the STOP program;
 Conduct toolbox/pre-job meetings when required associated with the scope of work of their
activities;
 Immediately report/ investigate all incidents and report back findings and close out actions;
 Provide safety related data to GWDC Site Management;
 At all times, comply with the relevant guidelines formulated and disseminated through
inductions, toolbox meetings and daily site instructions.

2.4 PERFORMANCE MONITORING


2.4.1 Periodic Monitoring
GWDC will use both active and reactive key performance indicators(KPI) to measure safety
performance and routine monitoring of the implementation of the HSE Management System

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is achieved through:

 HSE being an integral (and primary) part of all operational reporting.


 Regular inspections and site visits by departmental supervisors (Section, Division and
Department Heads).
 Maintenance and reporting of Remedial Action Plan and remedial close-outs.
 Monitoring of non-routine issues relating to HSE Management including: 
- Notifications of incidents. 
- Regular Meetings. 
- Regular reporting and analysis of STOP cards (or local variation).

The safety statistics generated by the various work sites are compiled by the HSE Advisor
and HSE Manager on a monthly basis and forwarded to the Project office. They are reviewed
by the Project General Manager and published in the Monthly Review. The Unsafe Act and
Unsafe conditions analysis is performed by the HSE Advisor and HSE Manager on a quarterly
basis and also reported in the Monthly Review.

2.4.2 Incident Management and Reporting


A formal system to investigate and analyse all incidents and accidents is in place on rigs.
Training in accident investigation is part of the HSE training given by the HSE Department.

When an incident/accident occurs an Incident/Accident Report is completed by the Rig


Manager. The Rig Manager is required to review and sign the Accident Report within 24
hours of the accident occurring. The Accident Report and the Accident Analysis & Protective
Report should both be completed within 4 days of the accident occurring and sent to GWDC
Project management.

For major or critical accidents or hazardous conditions, a more detailed accident investigation
may be undertaken following consultation between The Rig Manager, and the Manager of the
HSE Department.

Because involved parties will be required to complete and lodge their own company specific
incident report form they will also be party to the completion of the GWDC Incident Form. It is
intended that only one investigation team is formed, and that all reports be consistent in terms
of findings, corrective actions and close out. GWDC and PCIHBV shall monitor jointly the
closure of action items through their respective tracking systems. The Incident Report must
be written within 24 hours and completed with root cause analysis within 20 days of the
incident occurring. Reported incidents and follow-up actions, that apply to the rig or
associated location or well services unit are to be lodged in the respective Campaign Action
Register (CAR), such that they can be tracked and closed out.

Outstanding actions from any incidents are followed up as soon as practically possible and
are duly presented at the weekly meeting; this latter meeting will be held prior and in
conjunction with the weekly HSE teleconference.

2.4.3 Behaviour-Based Observation Systems


Behavior-Based Observation is a process that helps employees identify and choose a safe
behavior over an unsafe one. GWDC will strive for the elimination of all behavioral based
incidents and injuries by observation and communication of our behaviors. This will be
accomplished through management support and employee ownership to promote a safe
working environment.

GWDC Garraf HSE Department would plan, develop, implement, and supervise operation of
the Behaviour-Based Observation Process. During the Drilling, Well Service and other related
operation in rig site, this process would be encouraged to apply any time. Employees should
be trained to carry out the Process on a continuous basis and to establish and maintain a
high standard of safe work behavior.

2.4.4 Environmental Monitoring and Measurement


Monitoring and recording of all discharges, amounts of waste generated, and disposal

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methods will be implemented. An environmental monitoring program will be in place to:

 record any environmental incidents;


 compile and inventory of wastes and emissions through a monthly reporting system;
 measure the quality of discharges.

Further developments in operational control for the project include the need to document work
instructions and procedures for potentially environmental critical activities such as fuel
loading.

Targets for the drilling operation reflect the short term nature of the project addressing such
aspects as spills, waste control, and reporting:
 No oil spills;
 All waste stream discharges recorded.

2.4.5 Audit and Audit Compliance


During the Project development and according to the requirement of Client, GWDC believes
that the following Audit processes are adequate for its purposes and needs:

Unsafe Act/Unsafe Condition Audit

GWDC Unsafe Act/Unsafe Condition Audit is in place. As a fundamental employment


condition, all personnel are obliged to report all unsafe acts and unsafe conditions which
occur on GWDC work site. The Unsafe Acts and Unsafe Conditions are collated, analysed
and reported on a quarterly basis, Trends, areas of concern, action points, action parties, and
target dates for completion are established.

Internal Operations Audit

GWDC Internal Operation Audits are quarterly scheduled throughout the year. Audit reports
with Action points, Action parties, and Target Dates are recorded in the Monthly Review until
such time as the Action Points are closed out.

External Operations Audit

The Section covers external audits in Project, including review and audit in Companies where
GWDC Iraq Branch has contractual rights, excluding audits carried out by external auditors.
No matter the procedure or the plan, the periodically audit and review should be taken.

Audits of Maintenance, inspection and certification

Camp and rig site work as the base of operation and related activities, its function should be
kept at a effect level. For example at the first stage of construction, related certification would
be available. e.g. the permission from local and related party for the camp construction, the
monogram of accommodation OEM, the catering service health card, etc.

Site inspection would be carried out weekly according to checklist from Project HSE Team,
any fault or shortcomings should be record and corrected.

Audits of Service suppliers' compliance with GWDC HSE requirements

Periodically audit the service suppliers’ and reinforce the communication for promote the
service level.

Audits of training plans

Periodically audit the training effectiveness and alter it according to real condition.

Audits of emergency support including medical

Audits and formal inspections of catering facilities and catering service

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Periodically audit and alter it according to real condition.

Inspections of WORKSITES, work activities and support facilities

Periodically audit and alter it according to real condition.

2.4.6 Verification of HSE Critical Tasks and Equipment


Part 7 of the HSE Case lists those HSE Critical Tasks w/related equipment identified as
essential to provide or maintain the necessary controls and recovery measures for hazards to
meet the objectives of the HSE Case. It is only by performing such tasks, at the appropriate
times, that assurance can be gained that the major accident hazards are being managed.

The tasks may be design, inspection and maintenance, operational or administrative tasks,
i.e:

 Design tasks - which specify the necessary hardware and equipment;


 Inspection and maintenance tasks - to ensure that this hardware and equipment
maintains its integrity and reliability;
 Operational tasks - to ensure that the equipment is used within the defined limits of the
controls provided; and
 Administrative tasks - which provide the necessary training, awareness and behaviour
conditioning to ensure that people perform predictably in all normal and abnormal
situations.

The Garraf Project Manager is responsible for ensuring all personnel receive their tasks for
review. Personnel with designated HSE critical tasks are responsible for checking the
relevance, currency and accuracy of the list before spudding the well. They are required to
show the acceptance of their sheets by signing them.

The full specifications of the rig and its equipment are provided in the Operations Manual.
This also includes general arrangement drawings and schematics of the rig and its drilling
equipment. The design information and operating and maintenance instructions are contained
within the manufacturers’ data books, which are available on the rig.

Maintenance of all equipment on the rig is managed using a preventative maintenance


management system (PMS), which generates work lists detailing preventative maintenance
tasks. The system is planned to be computer based and implementation is imminent (before
or shortly after spud of first well).

2.4.7 Certification
Rig GW 52 is constructed in accordance with the standards described in Part 3 of the HSE
Case.

Additional equipment manufactured at the rig site will require appropriate certification prior to
use, e.g. pressure vessels and lifting equipment/padeyes. It is the responsibility of the Rig
Manager to ensure that any such additional equipment is fit for purpose and safe to use prior
to entering service.

All lifting equipment (i.e. slings, harnesses, shackles, etc.) will be inspected and certified prior
to use. Fixed equipment will be re-certified annually for continued use, slings etc. will be re-
certified on a six monthly basis. Details will be contained in the Rig GW 52 lifting equipment
register. It will the responsibility of the Rig Manager to ensure that all sub-contractor lifting
equipment is provided with equivalent lifting registers.

2.5 MANAGEMENT REVIEW AND IMPROVEMENT


2.5.1 Review
The Management Team of GWDC Garraf Project conducts Management Reviews of HSE
Performance at the monthly HSE Meetings. This basically includes a review of:

 Performance against plan.

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 HSE Statistics.
 Incident Reports.
 Follow-up Actions and Actions Progress.
 Management visit and audit reports.

Project performance is reviewed by comparing the actual operational phase times and overall
well performances in days against programmed times based on past wells. Equipment
performance is reviewed by analyzing rig downtime on monthly basis, periodic reporting and
is guided by Quality Policy. Safety performance and HSE statistics is reviewed against
company objectives as stated in the GWDC Garraf Annual HSE Schedule and published in
the Monthly Review.

The Internal Auditing described above is reviewed by the line managers of GWDC Garraf
Project Management on at 6 months basis and followed up in the Monthly Review.

Audit deficiencies will be reviewed and published in the Monthly Review and following up and
discussed at the Monthly HSE meeting on site, and at the Co-ordination Committee Meeting
held no less than once per month in the office. Feedback to the site is achieved through the
Monthly Review report and the Monthly HSE meeting minutes.

The Leadership Team of GWDC Iraq Branch reviews the implementation of this (HSE)
Management System annually as:

 HSE performance over the year and the results.


 Performance against Objectives and Targets, including the need to modify or generate new
ones.
 Annual HSE Management System, ISO14001 and any other audits.
 Progress on outstanding HSE Management System remedial actions.
 Failings of the HSE MS from the investigation of incidents.
 Assessment of implementation and use of the Hazard Register and HSE Critical Activities
Specification Sheets.
 Significant changes to the mechanisms described in the document.
 Proposals for improvements.
 Update of Strategic Objectives and Goals.

This review also considers the need for any update to this document.

2.6 Concurrence Statement

The HSE management systems detailed in this document are to remain in place for the
duration of the campaign and this document is acceptable to our respective companies.

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