Attachment 18 - HSE Manual

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REV: 01
HEALTH, SAFETY & ENVIRONMENT
DATE: 01/06/2016
MANAGEMENT SYSTEM
(INTRODUCTION)
Revision History
Revision No. Revision Description Date
00 Original 01/08/2011
01 Revise 01/06/2016
Proprietary Information
This document contains proprietary information belonging to BERMUDA SUBSEA (M)

SDN BHD and must not be wholly or partially reproduced nor disclosed without prior
permission from BERMUDA SUBSEA (M) SDN BHD.
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MANAGEMENT SYSTEM
(INTRODUCTION)
1. INTRODUCTION
Bermuda Subsea (M) Sdn Bhd’s (herein after referred to BSSB) Health, Safety &
Environment Management System (herein after also referred to as HSE
Management System, abbreviated HSEMS) defines the Company’s HSE policy,
strategic objective s, organization and the arrangements which are necessary
to manage the identified health, safety & environmental.
The purpose of the HSE Management System is to ensure that:

 The health, safety and environmental risk inherent in Bermuda Subsea
(M) Sdn Bhd’s operations have been systematically identified;
 Arrangements are in place to control this risk and to deal with the
consequences should the needs arise; and
 The necessary information, training, auditing and improvement
processes are in place to achieve these objective.
Unless otherwise specified, all requirements contains in this HSE Management

System shall apply equally to BSSB’s operations offshore / marine, Supply Base
and HQ.
The meaning of the abbreviations, acronyms and definitions used in the HSE
Management System Manual are as define in the Glossary of Abbreviations,
Acronyms and Definitions.
Unless, otherwise specified, where the work describing the male gender (e.g.
he, him. Etc.) is used, this shall also be constructed to include both the male
and female genders.
The recommendations for the course of action are made degrees of emphasis.
As a rule:
May - indicates a possible course of action;
Should - indicates a preferred course of action; and
Shall - indicates a mandatory course of action from

Which deviations not allowed without written
authority from BSSB’s Management HSE Committee
(BSHSEC)
The owner of this HSE Management System is BSSB’s Group Managing Director. As the
owner, he is responsible for issuing the HSEMS Manual under his signature and issuing
clear directives to the Custodian on HSEMS changes.
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The custodian of the HSE Management System Manual is the HSE Manager, who shall
also be the management Representative for all matters relating to health, safety and
environment throughout BSSB.
Reviews and amendments to the HSE Management System Manual are approved by
BSSB’s Management HSE Committee (BSHSEC).
The HSE Management System Manual-seven (7) elements as follows:
Management System Elements
Describe BSSB’s HSE Management System element, under the following headings:
 Leadership and Commitment

 Policy;
 Organization;
 Risk Management;
 Planning and Procedures;
 Implementation and Monitoring; and
 Auditing and Management Review.
Leadership &
Policy
Organization
Corrective Actions for
Continual Improvement
Risk Management ARRANGEMENTS
from Audits and
Management Review
Planning & Procedures
Implementation &
Auditing &
Management Review
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The MD / General Manager, Operations Manager, Marine Superintendent, PC/Vessel

Master and Supervisors shall be responsible for coordinating the implementation of
the HSEMS remedial action plans that are concluded following audits
The progress of implementation of the remedial action shall be reviewed by BSSB’s

Management HSE Committee (BSHSEC) and the respective Master and Supervisor.
2. General HSE Standards
Current Malaysian legislation includes the Occupational Safety and Health (Act 514)
1994, Factories and Machinery Act 1967 (Act 139) and all other associated
Regulations. Listed below are the applicable for government Safety Regulation:
1. OCCUPATIONAL SAFETY AND HEALTH ACT (ACT 514) 1994:

i. General duties employers and self-employed person (Part IV)
ii. General duties of designers, manufactures and suppliers (Part V)
iii. General duties of employees (Part VI)
iv. Safety and health organization (Part VII)
v. Notification of accident, dangerous occurrence, occupational poisoning
and occupational diseases and injury (Part VIII)
vi. Industries code of practice (Part X)
2. THE PETROLEUM (SAFETY MEASURES) ACT, 1984

3. THE MERCHANT SHIPPING ACT, 1974
4. THE ELECTRICAL INSPECTORATE ACT, 1983
5. ENVIRONMENTAL QUALITY ACT 1988 AND REGULATIONS
6. OTHER RELATED ACTS, REGULATIONS, RULES AND CODE OF PRACTICES
Listed below are the following is a list of applicable International Safety Legislation:
1. International Convention for SOLAS 1974 (and the PROTOCOL thereafter)

2. IMO MODU CODE
3. International Convention for the Prevention of Pollution from Ships (MARPOL
73/78) Annex I, II, III, IV, V and VI
4. Vessel – IMCA Marine / IMCA TCPC
5. International Safety Management (ISM)
6. Factories and Machinery Act 1967 (FMA) and Regulations.
7. Fire Services Act 1988 and Regulations
8. Employees’ Social Security Act 1969, Regulations and Rules.
9. International Safety Management (ISM)
10. Other related National or International Acts, Regulations, Rules and Codes of
Practice.
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ABBREVIATIONS AND ACRONYMS
HSE Health, Safety and Environment
PIC Person In-Charge
DCMP Document Control and Management Procedure
BSSB Bermuda Subsea (M) Sdn Bhd
Rev Revision
BSHSEC BSSB Management Health, Safety and Environment

Committee
MD / GM Managing Director / General Manager
REFERENCED DOCUMENT
Document No. Document Title
(OGP) Report International Association of Oil & Gas Producers

6.36/210 Guidelines for the Development and Application
of Health, Safety and Environmental Management
System
(OGP) Report Glossary of HSE Terms

6.52/244
(OGP) Report Quantitative Performance Measure of HSE

6.61/260 Management System Effectiveness
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(LEADERSHIP & COMMITMENT)
Section 2
LEADERSHIP & COMMITMENT
Paragraph Page
2.1 Purpose 2
2.2 Scope 2
2.3 Procedure 2
2.4 Record 3
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2.1 LEADERSHIP AND COMMITMENT
2.1.1 Purpose
This HSE Leadership and Commitment Element defines BSSB’s expectation, from
employees at all levels, for visible expression of leadership and commitment that is
consistent with the Company’s aspiration to create and sustain a culture that
support the effective functioning of the HSE Management System.
2.1.2 Scope
The leadership and commitment for HSE, including a readiness to provide

adequate resources for HSE matters, is expected of all Employees, including
Contractors engaged in work for, or on behalf of BSSB.
2.1.3 Procedure
2.1.3.1 Employees at all levels in BSSB shall demonstrate, including by personal

example, their commitment to HSE requirements and ensure that these
are given priority and not compromised in any activity.
2.1.3.2 As a general guideline, the commitments expected from the various

levels of leadership are as follows:
i) Senior Management (MD and Director)
Senior Management personnel shall provide strong, visible

leadership and commitment, and ensure that this commitment is
translated into the necessary resources to develop, operate and
maintain the HSE Management System and to attain the HSE Policy
and Strategic Objectives.
ii) Line Management (Superintendents, Offshore PIC and Supervisors)
Line Management personnel shall ensure that full account is taken

of the HSE policy requirements and shall provide support for actions
taken to protect health, safety and the environment.
iii) All Employees and Contractors
Employees of BSSB as well as Contractors shall actively contribute to

the creation and sustenance of a culture that support the HSE
Management System through its policy, strategic objectives,
initiatives and action plan.
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2.1.3.3 Senior management should foster active involvement of Employees,
including Contractors in improving HSE performance by encouraging a
Company culture that:
i) Believe in the Company’s aspiration to improve HSE performance.
ii) Provide motivation to improve personal HSE performance.
iii) Putting HSE matters, including HSE performance data, on the

agenda of meetings, from the Board downwards.
iv) Allocating the necessary resources, such as time, manpower and

finance, to HSE matters.
v) Demonstrate acceptance of individual responsibility and

accountability for HSE performance.
vi) Communicating the importance of HSE considerations in business

decisions.
vii) Developing on open approach to external liaison with authorities

and the general public.
viii) Encourage participation and involvement at all levels in the

implementation of the HSE Management Systems; and
ix) Demonstrate commitment to an effective HSE Management

System.
2.1.3.4 Demonstration of commitment to the HSE Management System from

senior and line management personnel includes, but are not limited to:
i) Setting a personal example in the day-to-day work.
ii) Being actively involved in HSE activities and reviews onshore &
offshore.
iii) Communicating with Contractors, including Sub-Contractors, on

HSE matters.
iv) Setting specific HSE tasks and targets for individuals and
departments.
v) Recognition of performance when objectives are achieved.
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vi) Encouragement of Employees’ suggestions for measures to improve
HSE performance.
vii) Conduct site visits.
2.1.3.5 Demonstration of leadership and commitment to the HSE Management

System from all levels of Employees, including Contractors, including
amongst others:
i) Attending, including chairing, HSE meetings.
ii) Reporting HSE incidents including receiving and acting on HSE

reports.
iii) Promoting HSE topics in meetings.
iv) Participating in HSE audits and inspections.
v) Participating in formulation of plans for achieving HSE objectives.
vi) Participating in the execution of HSE plans.
vii) Holding and participating in HSE review and analysis sessions.
viii) Participating in incident investigation.
ix) Participating in HSE initiatives.
x) Providing constructive feedback on HSE matters.
xi) Take reasonable care for the safety and health of him and other
persons who may be affected by his acts or omissions at work.
xii) Co-operate with management in the discharge of any duty or

requirement imposed by BSSB an/or by any legislative requirement.
xiii) Comply with any HSE instructions or measures given by supervisory

personnel.
xiv) Refuse to work or to continue working when their health, safety

and/or the environment is compromised.
The requirement for individual employees’ demonstration of leadership

and commitment to BSSB’s HSE Management System, commensuration
with the respective employee functional roles in the Company, should be
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included in all Position/Job Description and Individual Employee’s Annual
Objectives and Targets.
2.1.4 Record
All record requirements pertaining to Position/Job Description as well as

Employees’ Annual Objectives and Targets shall be maintained in accordance
with Human Resource Manual (HRM).
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(POLICY)
Section 3
POLICY
Contents
Paragraph Page
3.1 Policy on Health, Safety and Environment 2
3.2 HSE Strategic Objectives 5
3.3 HSE Governance 9
3.4 HSE Legislation, International Convention and Protocol 11

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3.1 POLICY ON HEALTH, SAFETY AND ENVIRONMENT
3.1.1 Purpose
Bermuda Subsea (M) Sdn Bhd’s Policy on Health, Safety and Environment
(hereinafter also referred to HSE Policy) provides the direction on how issues
relating to health, safety and the environment are to be managed and
integrated into the overall business process throughout Bermuda Subsea (M)
Sdn Bhd.
This HSE Policy is adopted by BSSB and is in line with the following Bermuda
Subsea (M) Sdn Bhd policy statements, as follows:
 Bermuda Subsea (M) Sdn Bhd’s HSE Policy.

 Bermuda Subsea (M) Sdn Bhd’s Drug &Alcohol Policy;
 Bermuda Subsea (M) Sdn Bhd’s Stop Work Policy.
3.1.2 Scope
Bermuda Subsea (M) Sdn Bhd’s Policy on Health, Safety and Environment shall
apply equally to all BSSB’s Employees and Contractors engaged in work for, or
on behalf of BSSB.
In managing and integrating HSE into the overall business process and
operations, strict adherence to the intents, objectives and requirements of this
HSE Policy is expected. Consequently, all specific HSE policies, HSE systems,
procedures and guidelines shall conform to and be aligned with this HSE Policy.
3.1.3 Procedure
Bermuda Subsea (M) Sdn Bhd’s Policy on Health, Safety and Environment,
quoted hereunder, states as follows:
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QUOTE
In conducting its business, Bermuda Subsea (M) Sdn Bhd is committed to the following
objectives:
 To ensure that the health and safety of the company’s employees are
safeguarded;
 To ensure that the environment is protected; and
 To comply with national and international regulations that relate to health, safety
and the environment.
In ensuring that the objectives are met, the Management of Bermuda Subsea (M) Sdn
Bhd will:
 Inform all employees of the company’s commitment;

 Promote a high standard of safety consciousness, discipline and individual
accountability;
 Provide qualified, medically fit and suitably trained personnel for its operations;
 Make every effort to prevent accidents; and
 Take corrective action to avoid any recurrence of any accident.
UNIQUOTE
The above Policy on Health, Safety and Environment was endorsed by the Managing
Director BSSB.
Bermuda Subsea (M) Sdn Bhd’s Policy on Health, Safety and Environment shall be
reviewed, as and when circumstance dictates, during a management review carried
out by BSSB’s Management Health, Safety and Environment Committee (BSHSEC).
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3.2 HSE STRATEGIC OBJECTIVES
3.2.1 Purpose
This HSE Strategic Objectives Guideline defines BSSB’s HSE strategic Objectives;
a framework standard on how the intents and objectives of Bermuda Subsea
(M) Sdn Bhd’s Policy on Health, Safety and Environment shall be implemented
throughout BSSB.
3.2.2 Scope
The HSE Strategic Objectives shall form the basis and provide the standards on
deliverables for all HSE initiatives implemented throughout BSSB’s operations.
The appropriate HSE Strategic Objectives shall be applied in all activities
carried out throughout Company’s operations; including that of Contractors
engaged in work for, or on behalf of BSSB.
3.2.3 Procedure
The implementation of Bermuda Subsea (M) Sdn Bhd’s Policy on Health, Safety
and Environment shall cover, but need not necessarily be limited to, the
following Strategic Objectives Guideline.
3.2.3.1 BSSB shall give occupational, health, safety and environmental

considerations equal status with other primary business objectives.
3.2.3.2 BSSB shall promote HSE issues within the company and encourage
all employees to be proactive in their approach.
3.2.3.3 BSSB shall ensure to staff the company’s activities within competent,
adequately trained personnel.
3.2.3.4 BSSB shall develop on all encompassing HSE Management System

to oversee all Offshore Operations.
3.2.3.5 BSSB shall provide facilities designed to minimize risk to personnel,

equipment and the environment and to develop working practices
that ensure hazards are minimized.
3.2.3.6 BSSB shall minimize adverse effects of our activities upon the public.
3.2.3.7 BSSB shall audit and continually improve HSE standards and
procedures.
3.2.3.8 BSSB shall share HSE experience with all personnel and relevant
external organizations.
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3.2.3.9 BSSB shall ensure that the company’s partners, contractors and third
parties clearly understand and adhere to BSSB’s HSE policy and
where necessary, assist in achieving them.
3.2.3.10 Employees at all levels in BSSB shall demonstrate, including personal

example, their commitment to the HSE policy issues and ensure that
these are given priority and not compromised by any activity.
3.2.3.11 Employees at all levels in BSSB shall be aware of their roles and
responsibilities for HSE.
3.2.3.12 BBSB shall provide opportunities for employees at all levels to equip
themselves with the necessary awareness, knowledge and skills to
be fully effective in their current jobs, and to prepare them for
planned future assignments in support of BSSB’s HSE strategic
objectives and business plans.
3.2.3.13 BSSB shall provide open and effective communications on HSE

matters with employees, clients and contractors affected by BSSB’s
operations.
3.2.3.14 For all HSE-critical activities, the appropriate health, safety and
environmental risk assessment shall be carried out, with a view to
implementing control measures that eliminate or reduce the risks to
a level as low as reasonably practicable (ALARP).
3.2.3.15 BSSB shall implement risk control measures through safe work
practices, operating procedures, asset integrity plans, quality
assurance programs and other systems to secure BSSB’s HSE
strategic objectives and targets.
3.2.3.16 BSSB shall periodically re-evaluate potential HSE risks from all
activities to ensure continual validity of risk control measure.
3.2.3.17 All technical information including Process and Instrument

Diagrams, shutdown systems, engineering/mechanical drawings
and material/chemical safety data sheets associated with BSSB’s
facilities/operations shall be kept up-to-date.
3.2.3.18 BSSB shall maintain emergency response plans and a crisis

management plan appropriate to BSSB’s HSE risks.
3.2.3.19 BSSB shall conduct inspections surveys and measurements to

determined compliance with HSE strategic objectives targets and
plans.
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3.2.3.20 BSSB shall report, investigate and analyze all accidents/incidents
that could have or have caused loss or HSE implications and take
appropriate remedial measures.
3.2.3.21 BSSB shall conduct periodic internal and independent HSE

Management System Audit, as well as other technical and legal
compliance audit, to verify that the implementation of Company’s
activities conform to the requirement of the HSE Management
System.
3.2.3.22 BSSB shall conduct periodic management review of the HSE policy,
organization and arrangements that are necessary to achieve
continual improvement of the Company’s HSE performance and to
verify that the HSE Management System is working as intended
throughout the Company.
3.2.4 Record
All record requirement pertaining to BSSB’s Strategic Objectives and BSSB’s

Management Review shall be as provided in Management System (Section 7)
of this HSE Management System Manual.
3.3 HSE GOVERNANCE
3.3.1 Purpose
This HSE Governance defines BSSB’s policy on HSE Governance, and these shall
be the guiding principles in the management of HSE throughout BSSB.
3.3.2 Scope
BSSB guiding principles in the management of HSE, which shall be applicable

throughout the Company’s operations, is aimed at achieving a HSE
performance that is consistent BSSB’s HSE Policy, Strategic Objectives, Initiatives
and Targets.
3.3.3 Procedure
The management of HSE in BSSB shall be governed by the following principles:
2.3.3.1 BSSB’s Management Health, Safety and Environment Committee

(BSHSEC) approve all matters relating to Company’s HSE policy,
strategic objectives, standards, targets, procedures and guidelines
and also is the decision body for the implementation of all matters
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relating to the HSE policy, strategic objectives, standards, targets,
procedures and guidelines.
3.3.3.2 The execution of work in accordance with the Company’s HSE

policy, procedures and guidelines is a line responsibility. Deviation,
where required, shall be subject to approval at the appropriate
level in the line management, in accordance with established
procedures. Where the deviations have significant impact to the
Company, these shall be highlighted to the BSSB by the respective
PIC or Superintendents.
3.3.3.3 HSE Manager develops, maintains and provides advisory support to

the line management on policy, strategic objectives, standards and
procedural matters, and report HSE performance.
3.3.3.4 HSE Managers shall provide advisory support to the line

management on the application of HSE tools and techniques. The
line management shall oversee HSE performance within their
respective units.
3.3.3.5 HSE Managers shall develop and drive the implementation of

Company’s HSE Strategic Objectives, Initiatives and Targets. Line
management shall be responsible for the co-development and
implementation of the HSE Plan, in line with the Company’s HSE
Strategic Objectives, Initiatives and Targets.
3.3.3.6 An internal HSE Focal Points within each Division and Department
provide advisory inputs supporting services on implementation of
HSE activities and all initiatives to Division and/or Department’s
management and line staff, including Contractors.
3.3.3.7 The appointed internal HSE Focal Point also has an access to the
database and records within HSE matters.
3.3.3.8 BSSB’s HSE Managers is the Company focal point for external (i.e.
regulatory authorities) liaison on all HSE matters.
BSSB’s principles on HSE governance shall be reviewed as and when

circumstance dictates, during a management review carried out by BSSB
Management Health, Safety and Environment Committee (BSHSEC).
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3.4 HSE LEGISLATION, INTERNATIONAL CONVENTION AND PROTOCOL
3.4.1 Purpose
This HSE Legislation, International Convention and Protocol defines BSSB’s policy
in respect of compliance to international conventions and protocols ratified by
the respective host country.
3.4.2 Scope
The retrospective country’s HSE legislation as well as ratified international

conventions and protocols shall be complied with by BSSB. These requirements
shall apply equally to all BSSB’s Employees and Contractors engaged in work
for, or on behalf of BSSB.
3.4.3 Procedure
3.4.3.1 For BSSB’s current operations, Malaysia’s HSE legislation and

international conventions and protocols ratified by Malaysia shall
be complied with.
3.4.3.2 Specific register shall stipulate, where applicable, areas and details
of non-compliance, and shall also include proposed action plans to
attaining compliance.
3.4.3.3 To verify conformance to the relevant national HSE legislation,

international conventions and protocols, periodic Legal
Compliance Audit should be carried out by HSE Department.
3.4.3.4 Any changes in Malaysia’s HSE legislation and/or international

conventions and protocols shall be reviewed, as and when
circumstances dictates, during a management review by BSSB’s
Management Health, Safety and Environment Committee.
3.4.5 Record
The site-specific register on legal compliance register shall be kept up-to-date,

and shall be made available for review, during a management review carried
out by the BSSB’s Management Health, Safety and Environment Committee
(BSHSEC).
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3.5 DRUG AND ALCOHOL POLICY
In conducting its business, Bermuda Subsea (M) Sdn Bhd. Including its group of
companies, is fully committed towards providing a safe, healthy and
productive workplace for its employees.
We recognize that alcohol or drug abuse impairs one’s ability to perform well
and poses a serious adverse effect on the safety, efficiency and productivity
of others. Therefore Company prohibits:
 The abuse of drugs or the use, possession, distribution or sale of illegitimate

or unprescribed controlled drugs on company’s business premises and
facilities; and
 The consumption of liquor and alcoholic beverages on company business
premises and facilities.
Breach of this policy is a ground for termination.

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(ORGANIZATION)
Section 4
ORGANIZATION
Contents
Paragraph Page
4.2 Roles, Responsibilities and Accountabilities 2
4.3 Resources, Training and Competency 12
4.4 Contractors 17
4.5 Communication Process 19
4.6 Standards and Documentation 25
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(ORGANIZATION)
4.1 ROLES, RESPONSIBILITIES AND ACCOUNTABILITIES
4.1.1 Purpose
This HSE Roles, Responsibilities and Accountabilities define the salient HSE roles,
responsibilities and accountabilities of personnel, both Company and Contractors,
in the implementation of BSSB’s HSE Management System.
4.1.2 Scope
BSSB’s organization structure, as shown in Appendix I, reflects the overall

responsibility of Company’s Line Management for the implementation of the HSE
Management System within their area of authority. The HSE roles, responsibilities
and accountabilities for specific positions not provided herein shall be the
responsibility of the respective Line Management.
4.1.3 Procedure
The HSE roles, responsibilities and accountabilities of personnel working for and on
behalf of BSSB are as outlined below:
4.1.3.1 Group Managing Director (Bermuda Subsea (M) Sdn Bhd)
a) The Group Managing Director shall have the overall ultimate

responsibility and accountability for health, safety and
environment.
b) He delegates the responsibility and assigns the accountability for

the implementation of the HSE Management System via the
Managing Director or MD/General Manager of its Business
Units/Subsidiaries.
c) He ultimately authorizes the necessary resources to meet HSE

strategic objectives and targets throughout Bermuda Subsea
Group of Companies.
4.1.3.2 Managing Director/MD/General Manager (Bermuda Subsea

Services/Bermuda Diving)
a) He is responsible to the Group Managing Director, and shall have

the responsibility and accountability for the implementation of HSE
Management System.
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b) He, in turn, delegates the responsibility and assigns the
accountability for the implementation of the HSE Management
System via Superintendents, Site PIC/Vessel Master and Supervisors
(respective Line Managers), to every employees working for and on
behalf of BSSB, according to the respective employees’ area of
responsibility and level of authority.
c) He, also, delegates the responsibility and assigns the accountability

for activities, including agreed HSE objectives, plans and targets to
respective Superintendents, Site PIC and Supervisors (respective
Line Managers).
d) He assigns accountability for advice on HSE matters and services to

BSSB’s HSE Executives.
e) Ensure that subordinate staffs are trained and competent to carry

out their assigned duties.
f) On an annual basis, assess (measure) subordinate staff HSE

performance.
g) Shall ensure that all foreseeable risk associated with activities within
their area of operations has been adequately identified, assessed
and the necessary risk control measures effectively implemented.
h) Meeting the HSE strategic, objectives.
i) Preparation of Annual HSE Plan.
j) Shall ensure internal audits carried out that demonstrate

compliance with the HSE Management System.
k) Delegation of responsibility for HSE.
l) Adequate resources, including competent staff, to implement the

arrangements specified in the HSE Management System and
Annual HSE Plan.
m) Provision of adequate expertise and resources to the respective

Line Managers.
4.1.3.3 Manager, Human Resource and Administration Department
The Manager, Human Resources and Administration Dept. is responsible

to the Group Managing Director (Bermuda Subsea (M) Sdn Bhd), and
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shall have the responsibility and accountability for matters relating to
human resources development and administration in BSSB.
The Manager, Human Resources and Administration Dept. is

accountable, amongst others, for:
a) Ensuring that the relevant management of change requirements

relating to organizational changes is compiled with.
b) Ensuring that Position/Job Description are in line with the

requirement of the HSE Management System.
c) Provision of support in maintaining organization charts up-to-date.
d) Coordination of Training Program and Annual Training Plan.
e) Maintaining Executive and Non-Executive Development within

BSSB.
f) Agrees with and delegate/assign individual HSE responsibilities and

accountabilities to subordinate staff, as appropriate and in
accordance with staff capability, and include this is in the
Position/Job Description.
g) Ensure that subordinate staff are trained and competent to carry

h) On an annual basis, assess (measure) subordinate staff HSE

performance.
i) He is accountable for meeting agreed HSE Objectives, Plans and

Targets.
4.1.3.4 HSE Manager
The HSE Manager is responsible to the Group Managing Director and:
a) It is custodian of the HSE Management System Manual and acts as

“Management Representative” for the HSEMS.
b) Maintains an HSE organization appropriate for the purpose of

providing adequate health, safety and environmental support for
the implementation of the HSE Management System in BSSB.
c) Is responsible for providing advice, guidance and technical support

to line managers in meeting their HSE Management System
responsibilities/accountabilities.
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d) Acts as the focal point of contact with federal-level government
regulatory authorities, industry associations and clients on all HSE
matters.
e) Provides an independent HSE auditing program for the effective

implementation of the HSEMS on behalf of the Group Managing
Director.
f) Maintains an Emergency Coordination Centre (HQ-ECC) suitably

equipped manned to deal with any emeregency or other major
event within BSSB Operations.
g) Is responsible for the implementation of the HSEMS.
h) Coordinate internal HSE Management System audits.
i) Custodian of HSE database.
j) Coordinate HSE monitoring activities including incident

investigations, planned inspection and emergency drill/exercise.
k) Maintain all HSE documentation related to operations/activities of

the respective division.
l) Acts as Secretary to the BSHEC.
m) Records and analyses accident/incident reports.
n) Prepares periodic (monthly, quarterly and annual) HSE Report.
o) Acts as the focal point of contact with state-level government

regulatory authorities and industry associations all HSE matters.
p) Agrees with and delegate/assign individual HSE responsibilities and

accordance with staff capability, and include this in the
q) Ensure that subordinate staffs are trained and competent to carry

r) On an annual basis, assess (measure) subordinate staff’s HSE

performance.
s) Shall ensure that all foreseeable risk associated with activities within
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t) He is accountable for meeting agreed HSE Objectives, Plans and
Targets.
4.1.3.5 Operations/Project Manager
a) The Manager reports to the MD/General Manager and shall have

all the responsibility and accountability for the implementation of
HSE Management System within his work scope.
b) He, in turn, delegates the responsibility and assigns the

accountability for production activities, including agreed HSE
objectives, plans and targets to the respective PICs/Supervisors.
c) He is accountable for operating and maintaining the facility in

accordance with the requirement of the relevant legislation and
HSE Management System.
d) Is responsible for providing advice, guidance and technical support

to line managers in meeting their HSE Management System
responsibilities/accountabilities.
e) He shall be responsible for the following:
I. Overall responsibility to the MD/General Manager for the

HSE performance of their facility, including that of
Contractors.
II. Ensuring that all foreseeable risk associated with operations
have been adequately identified, assessed and the
necessary risk control measures effectively implemented.
III. Ensuring that adequate resources are available, including
those that form the support departments and contractors,
for the ongoing integrity of the facility.
IV. Ensuring the commitment to BSSB’s HSE Policy and
achievement of Annual HSE plans, objectives and targets.
V. Ensuring that each Contractors HSE performance is
monitored whilst working on a production facility.
VI. Ensuring that the required HSE monitoring requirements are
complied with.
VII. Is responsible for the implementation of the HSEMS within his
respective area of authority.
VIII. Agrees with and delegate/assign individual HSE
responsibilities and accountabilities for subordinate staff, as
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appropriate and in accordance with staff capability, and
include this in the Position/Job Description.
IX. Ensure that subordinate staff is trained and competent to
carry out their assigned duties.
X. On an annual basis, assess (measure) subordinate stagg HSE
performance.
XI. Shall ensure that all foreseeable risks associated with
activities within their area of operations have been
adequately identified, assessed and the necessary risk
control measures effectively implemented.
XII. He is accountable for meeting agreed HSE Objectives, Plans
and Targets.
4.1.3.6 Senior Procurement Executive
The Procurement Executive is the custodian of BSSB’s Procurement

Manual.
He shall be responsible for:
a) Ensuring that the relevant requirement of the HSE Management

System is adhered to in the procurement of goods, equipment and
services from contractors and/or suppliers.
b) Ensuring that all BSSB’s contractual documents contain the

appropriate HSE requirements.
c) Maintain Contractors (and/or Suppliers) HSE Performance

Database, for reference during a contracting activity.
4.1.3.7 PIC/ Supervisors
The Supervisors report to the HSE Manager and shall have the
responsibility and accountability for the implementation of hSE
Management System within his respective facility/area of responsibility.
Supervisors report to PIC on HSE issues.
He is accountable for meeting specific HSE objectives/targets under the

Annual HSE Plan.
Compile and monitor implementation of Annual HSE Plan.
He shall be responsible for the following:
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a) Implementing and enforcing the HSE Policy arrangements including
all the practices and procedures within his area of responsibility.
[These arrangements includes, but not limited to, operating
procedures, management of change procedures, permit-to-work
system, control of contractors/third party services, inspections,
incident reporting and investigation, emergency system,
communications arrangement].
b) Ensuring that employees and contractors personnel under his

supervision are fully competent to carry out tasks allocated to them
and holds the necessary competency certificates.
c) Delegating/assigning the day to day responsibility and

accountability for the facilities to individual employees, dependent
upon their area of responsibility.
d) Ensuring that adequate personnel protective equipment (PPE) are

provided as required.
e) Does not depart from written rules/regulations unless authorized

through appropriate management of change procedures.
f) Reports non-compliance issues and initiates incident reporting and

investigation procedures.
g) Coordinate to ensure that incidents are investigated and incident

reports compiled.
h) Ensuring that each Contractors HSE performance is monitored whilst

working on a facility.
i) Report the Department/Division, including Contractors, HSE

performance.
j) Conducts or participates in Site HSE Committee Meetings and

ensures, through “pre-job” and “tool box” meetings, adequate
communication of BSSB’s HSE requirements.
k) Provides feedback to management on any HSE issues that have

been raised by employees, contractors or other third parties.
l) Undertake a program of regular inspection of site.
m) Co-ordinate and carry out inter department hSE audits and

inspections.
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n) Ensure readiness of location/immediate emergency response plan.
o) Conduct or attend daily supervisors meeting.
p) Ensuring that the required HSE monitoring requirements are

complied with.
q) Is responsible for the implementation of the HSEMS within his

respective area of authority.
r) Agrees with and delegate/assign individual HSE responsibilities and

accordance with staff capability, and include this in the
s) Ensuring that subordinate staffs are trained and competent to carry

t) On an annual basis, assess (measure) subordinate staff HSE

performance.
u) Shall ensure that all foreseeable risk associated with activities within
4.1.3.8 All Employees/Contractors – General Duties
a) All Employees and Contractors shall work towards creating and

sustaining a culture that support the HSE Management System
through its policy, strategies and action plan.
b) Under the Occupational safety and Health Act 1994 (Law of

Malaysia), all employees (BSSB and Contractors) are required to
take responsible care for the safety and health of themselves or of
other persons who may be affected by their acts or omissions at
work.
c) In addition, every employee shall cooperate with BSSB (or

respective employer, in the case of contractor) in the
implementation of BSSB HSE Policy, Strategic Objectives and
Targets, and all associated arrangements put in place for the
purpose of operationalizing the implementation of the HSE
Management System.
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d) The HSE elements of each position in BSSB (roles, responsibilities,
accountabilities and reporting relationship) shall be clearly in writing
(e.g. in Position/Job Description) and issued individually.
e) The principal accountabilities for all BSSB’s Position/Job Description

shall include, as appropriate, elements of BSSB’s Strategic
Objectives as well as the respective job/position’s HSE roles,
responsibilities and accountabilities.
f) Each BSSB’s employees shall be given the necessary authority

commensuration with the individual’s level of responsibility.
g) In the event of a requirement to initiate disciplinary procedures

relating to HSE issues in respect of BSSB personnel, these shall follow
the course of action in accordance with the Human Resource
Manual.
4.1.4 Record
BSSB’s Human Resources Department shall ensure that organization charts and
position/job descriptions, or equivalent arrangement, are kept up-to-date.
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4.1.5 HSE Department Organization Chart
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4.1.6 Offshore Organization Chart
4.2 RESOURCES, TRAINING AND COMPETENCY
4.2.1 Purpose
This HSE Resources, Training and Competency section defines BSSB’s requirement
for the provision of adequate resources to ensure the effective implementation of
the HSE Management System, and that the available personnel resources are
sufficiently trained and competent to meet their job requirement.
4.2.2 Scope
The requirement for adequate resources, as well as sufficiently trained and

competent personnel resources, shall apply equally to BSSB’s own operations as
well as activities carried out by Contractors engaged in work for, or on behalf of
BSSB.
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4.2.3 Procedure
4.2.3.1 Resources
Senior Management shall allocate sufficient resources to ensure the

effective implementation of the HSE Management System, taking
account of advice from line management.
Resource allocation should be considered as it applies to all parts of the

HSE Management System. Areas to consider should include, amongst
others:
a) Facilities, plant and equipment to meet statutory requirements.
b) Personnel, equipment and infrastructure to respond to and mitigate

emergency situations.
c) Availability of management personnel for HSE audits and reviews.
d) Resource allocation for upgrade and new development.
The allocation of resources should include, but not limited to:
a) Prompt rectification of HSE-related deficiencies identified internally

or by external authorities.
b) Ongoing verification that the HSE-critical systems function in

accordance with the design intent and objectives.
c) Undertaking specific structured risk management techniques such

as HRA (Health Risk Assessment), EIA (Environmental Impact
Assessment), QRA (Quantitative Risk Assessment), HAZID, HAZOP,
JHA (Job Hazard Analysis.
d) Ongoing training requirements to maintain and enhance

competencies.
Where personnel resources are contracted, the minimum level of

competencies, including HSE competencies, required to carry out the
contract activities must be defined and allowance made for any training
necessary.
4.2.3.2 Training
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The BSSB’s TRAINING MANUAL shall be used to define the competency
requirements personal profile/job specifications including responsibilities
and accountabilities required for each position in BSSB.
VESSEL Masters and supervisors are responsible for ensuring that their
subordinates are competent to meet their responsibilities and
accountabilities by annual performance appraisal,
Human Resources and Administration Department shall provide:
a) Advice and guidance on the preparation of the job/position

description and competency requirements.
b) Coordination of the Training Program.
c) Maintenance of training records and as necessary the competency

assurances of all employees.
d) The training matrix for each position offshore and onshore covering:
i) Core knowledge and skills.

ii) Job-specific skills.
iii) On-the-job experience.
iv) Competency certification.
e) Coordination with line managers on positions to fulfill the business

plans.
f) An annual training plan endorsed by the Managing Director to

accommodate the organization needs.
4.2.3.3 Competency
BSSB shall maintain procedures for ensuring that personnel performing

specific HSE-critical activities and tasks shall be competent on the basis
of appropriate.
a) Personal abilities and awareness.

b) Acquired knowledge.
c) Skills developed through experience.
System for competency assurance should apply both to initial recruitment

and to selection for new activities, and to both Company and
Contractors employees.
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The continuing competency of personnel to perform their duties should
be regularly reviewed and assessed, including appropriate consideration
of personal development and training required to achieve competence
for changing activities and technologies.
Procedures for competency assurance should include, amongst others:
a) Systematic analysis of requirements for tasks.
b) Assessment of individuals’ performance against defined criteria.
c) Documented evidence of individual competence.
d) Programmers for periodic re-assessment.
The HSE-critical jobs and tasks listed in paragraph below shall require
personnel to have undertaken a recognized training course including
passing the requisite tests/examinations, if any.
The following HSE-critical jobs and tasks fall into this category:
a) All offshore workers shall have a “Safety Passport” (from attending

an approved offshore training course).
b) The following personnel shall require certificates and formal

appointment to confirm their competency to carry out the following
jobs/tasks:
i) Gas Tester
ii) Crane Operator
iii) Medic
iv) Electrician, specific to class of works (voltage, etc)
v) Safety Health Officer
vi) Riggers/Slingers
vii) Scaffholder and Scaffolding Supervisor
viii) Welders
ix) Lifeboat Coxswain
x) First Aider
xi) Helicopter Landing Officer
xii) Issuing Authority for Permits-to-Work
xiii) Chemical Handling
xiv) Emergency Response Team Leader and Members
xv) Mooring tankers at VESSEL
xvi) Seafarers
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The listings in paragraph above are by no means exhaustive, and may be
change as and when there are changes in BSSB and/or regulatory
requirement pertaining to certification and appointment for specific
job/occupation.
In some cases, it may be necessary to obtain confirmation that the person

has had the appropriate supervised experience before assuming full
accountability for these tasks/jobs. This confirmation shall be obtained
from the employee’s Line Manager.
Specific HSE training requirement, for the various job categories of

employees including Contractors, shall be as provided in BSSB’s Training
Manual.
4.2.4 Record
4.2.4.1 For BSSB employees, the company’s secretary & radio medic shall
maintain records original and copies respectively of all necessary
certificate holders for all HSE-critical jobs.
4.2.4.2 For Contractor employees, the respective Contractor’s management

shall maintain the relevant records for the identified HSE-critical jobs. Such
record, including copies of the relevant certificates shall be made
available to BSSB and maintained by company’s secretary.
4.2.4.3 A record shall be kept of every employee’s training by the respective

Human Resources and Administration Department.
4.3 CONTRACTORS
4.3.1 Purpose
This section defines BSSB’s HSE requirements in respect of Contractors, including

Sub-Contractors, engaged in work for, or on behalf of BSSB.
4.3.2 Scope
Unless otherwise stated, the requirements contained herein shall apply equally to
all Contractors and Sub-Contractors engaged in work for, or on behalf of BSSB.
4.3.3 Procedure
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4.3.3.1 The procurement of all contracted services shall be controlled in
accordance with BSSB’s Procurement Manual.
4.3.3.2 BSSB’s overall strategy in managing Contractors HSE is as follow:
BSSB has Prevailing Influence in respect of Contractors working in the

Company’s premises. Consequently the Contractors shall be required to
conform to the requirements of BSSB’s HSE Management System.
BSSB has limited influence for Contractors working in their own premises.
Under such circumstances, the Contractors may elect to use their own
standards provided these are in line with relevant statutory legislation.
4.3.3.3 During the pre-qualification/pre-screening stage of a contracting

activity, any Contractor who fail to meet BSSB’s minimum HSE requirement
shall be disqualified forthwith.
4.3.3.4 During the bidding stage, any specific HSE risks and requirements for the
specified scope of work shall be communicated to bidders, and in the
tender document, bidders shall be expected to provide, amongst others,
such information as:
a) Details of working methods, including how the identified HSE risks are
to be managed.
b) Skills/qualifications/competency assurances of personnel.
c) Responsibilities of individual personnel.
d) System to ensure effective management of interfaces between the

different organizations including Sub-Contractors.
4.3.3.5 During the pre-mobilization stage, the successful contractor shall be

required to carry out a risk assessment and demonstrate to BSSB that
foreseeable risks associated with the scope of work have been assessed,
and the appropriate risk control and recovery measures identified. The
implementation plan for these risk reduction measures shall be
documented in the Contractor’s HSE Plan accordingly. The level of HSE
risk assessment for a contracted service shall be dependent upon the risks
associated with the service(s) to be provided.
4.3.3.6 Additionally, all other HSE requirements, e.g. training, inspections, audits
program shall be identified and implemented accordingly.
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4.3.3.7 During the mobilization stage, the salient HSE requirements as contained
in the Contractor’s HSE Plan, including agreed HSE Key Performance
Indicators, shall be communicated to the general work force
accordingly.
4.3.3.8 The implementation of the Contractor’s HSE Plan shall be monitored to

completion during the work execution and de-mobilization phase.
4.3.3.9 On completion of the contracted work, a Close-Out Report, to include

highlights of the HSE performance of the Contractor shall be prepared, to
be used as a basis for assessment in future work involving the Contractor.
4.3.3.10 All Contractors working for and on behalf of BSSB should operate a HSE
management system that is in line with the requirements and provisions
of the accepted industry’s practice such as OGP’s and Petronas.
4.3.3.11 Prior to the commencement of any contracted activities, an interface

document should be prepared to facilitate the interfacing of activities
between BSSB’s with that of the Contractor and with other Contractors,
as appropriate.
4.3.4 Records
The Procurement Department shall keep records of the HSE performance of all
Contractors that have performed work for or on behalf of BSSB.
4.4 COMMUNICATION PROCESSES
4.4.1 Purpose
This Communication Process section defines BSSB’s organizational structure for the
management of HSE, including the communication of HSE issues, throughout of
BSSB.
4.4.2 Scope
Where indicated, the communication processes described herein shall apply

equally for all Contractors, including Sub-Contractors, engaged in work for or on
behalf of BSSB and Third Parties associated with the Company activities.
4.4.3 Procedure
4.4.3.1 Health, Safety and Environmental Committees
A) BSSB Management HSE Committee (BSHSEC)
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(ORGANIZATION)
Chaired by the Group Managing Director, this committee coordinates,
guides and monitors all activities related to health, safety and
environment including the effectiveness of the HSE Management System.
Chairman : Group Managing Director
Secretary : HSE Manager
Members : General/Operations Manager

Operation Superintendent
Scheduler
Senior Procurement Executive
HRA Manager
Engineers
Document Controller
Frequency of meeting: At least once every three month
Main roles/functions are as follows:
a) Review the effectiveness of the HSE Management System

and approve changes to the HSE Management System
Manual.
b) Provides Company’s HSE strategies, objectives and targets.
c) Review Company’s HSE performance indicators.
d) Review audit reports and provide necessary directives and

resources to correct deficiencies for continual HSE
improvement.
e) Review major incidents and losses and follow up

recommended actions.
f) Communicate with SITE SAFETY COMMITTEE through

exchange of minutes for discussions at respective meetings,
g) Approve long term and short term Company’s HSE

Strategies and Initiatives.
h) Approve Annual Audit Plan.
i) Approve HSE Standards/Procedures/Manuals.
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j) Review and endorse recommendations on Major Incidents
such as LTI’s, Oil Spill (> 5bbls) and other significant or
potentially serious incidents.
k) Promote HSE particularly through involvement in training

and education programs.
l) Ensure that all relevant statutory/industry requirements are

not only met but exceeded where practical.
m) Review and endorse Long Term and Annual HSE Plan,

objectives and key performance indicators.
n) Set direction for and approve annual HSE inspection and

internal audit plans and other programs relating to HSE.
o) Review “off-the-job” accident causation, if any, and

requirements for special promotion activities.
B) SITE/OFFSHORE HSE Committee
Chaired by the PIC this committee reports to BSSB HSE Committee

(BSHSEC) and is responsible for all issues relating to health, safety and
environment for the OFFSHORE/VESSEL.
Chairman : PIC (VESSEL Master)
Secretary : HSE Focal Point
Members : All Supervisors

Bosun
Compboss
Frequency of meeting: At least once every three month
Main roles/functions are as follows:
a) Coordinate, guide and monitor all activities and

arrangements associated with the HSEMS.
b) Review audit reports and provide necessary directives and

resources to correct deficiencies for continual HSE
improvement.
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(ORGANIZATION)
c) Review major incidents and loses and follow up
recommended actions.
d) Review HSE performance indicators.
e) Communicate with BSHSEC the exchange of minutes of

meeting and discuss these at respective meetings.
f) Review recent incidents/accidents in BSSB and other

locations and ensure the dissemination of lessons learned.
g) Provide management feedback and discussion forum on

relevant HSE issues, procedures, and policy matters.
h) Promote safety awareness through safety talks, safety

publications, etc.
i) Review all action items raised in safety inspections and

audits and monitor their implementation to completion.
j) Review effectiveness of emergency drills and exercises and

propose further improvements.
k) Review and evaluate safety suggestions put forward by staff

for the improvement of HSE and forward these suggestions
to the appropriate line department.
l) Review measure/arrangements to ensure the safety and

health of employees at their work place.
m) Investigate any matter at the workplace that any employee

considers a risk to safety or health.
n) Carry out a site inspection once per month to detect any

unsafe conditions or unsafe practices.
o) Review and publish minutes of meeting on notice boards.
4.4.3.2 Other Communication Process
A) Contractors Management HSE Meeting
For contractors carrying out HSE-critical activities, the BSSB shall ensure
that Contractors Management HSE Meeting is held, to provide avenue
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for Company and Contractors management personnel to discuss hSE
matters, including HSE performance, relating to the work scope.
B) Site Supervisors Meetings
A daily supervisors meeting shall be held by the PIC to:
a) Review work permits issued/renewed and their continued

validity.
b) Review work plan for subsequent days.
c) Review major equipment failures and their cause and

follow-up recommendations to prevent a recurrence as
determined by the investigation.
d) Follow up any actions from the inspection and hazard hunt

reports.
C) Pre-Job Meetings
Pre-job meetings shall be held by the supervisors where the job involves
personnel from more than one department or when contractors’
personnel are involved. The opportunity shall be taken at these meetings
to run through the procedure and work permit conditions for the job.
D) Tool Box Meetings
Tool box meetings shall be held daily between supervisors and

technicians and/or contractors that cover planned topics including:
a) HSE Committee minutes

b) Hazard reminders
c) Incident and ‘Near Misses’ reports
d) Daily work program
E) Orientation
All new employees and transferees, including contractors, to a facility or

installation shall be given a formal orientation of the site that includes
familiarization with the emergency procedures.
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4.4.4 Record
The Minutes of Meetings of the various committees, working groups, as well as all
other communication processes shall be duly recorded; and this should include a
listing of attendees (including absentees).
4.5 STANDARDS AND DOCUMENTATION
4.5.1 Purpose
This HSE standards & documentation section defines BSSB’s requirement relating to
the use and management of standards and documentation, including the control
of such documentation, throughout BSSB.
4.5.2 Scope
The requirements contained herein shall be applicable to all internally generated

standards and documentation as well as external documentation approved and
adopted for use by BSSB.
4.5.3 Procedure
4.5.3.1 BSSB Standards
Internally generated BSSB standards, including but not limited to the

following:
a) Policy
b) Management Systems
c) Strategy
d) Procedures and Work Instruction
e) Guide
f) Guidelines
g) Plan
… shall be controlled documents, and shall be managed in accordance

with BSSB’s Document Control Manual.
In generating BSSB’s Standards, the requirement where appropriate, the

provisions of the relevant approved internationally accepted industry
Standards, Codes of Practices and Guidelines may be used as a basis
and/or referred to.
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Each BSSB’s standards document shall have a Document Custodian and
shall be approved by the appropriate Approval Authority. The custodian
should be the Superintendent/Executive who has direct responsibility for
the processes or requirements being prescribed in the respective
document.
4.5.3.3 External Standards, Codes of Practices and Guidelines
Only internationally accepted Industry Standards, Codes of Practices

and Guidelines approved and adopted for use by BSSB shall be
implemented in any administration, procedural, design or engineering
work.
The document custodian for those internationally accepted industry

Standards, Codes of Practices and Guidelines approved and adopted
for use by BSSB shall be the HSE Executive.
All BSSB’s controlled documents shall be reviewed as and when

circumstances dictates or at least once in every 2 years, and monitored
to ensure correct usage and revised against actual performance.
4.5.4 Record
4.5.4.1 The HSE Manager shall be responsible for maintaining an up-to-date list of
BSSB’s Standards and those industry Standards, Codes of Practices and
Guidelines as approved and adopted for use by BSSB.
4.5.4.2 The technical Superintendent shall maintain all “Management of

Change” authorizations to depart from BSSB or approved internationally
accepted Standards and Procedures.
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(EVALUATION & RISK MANAGEMENT)
Section 5
RISK MANAGEMENT
Contents
Paragraph Page
5.1 HSE Risk Management Process 2
5.2 HSE Risk Screening Criteria 6
5.3 Critical HSE Risk Management Activities 10
5.4 Statutory HSE Risk Assessment Requirement 12

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5.1 HSE RISK MANAGEMENT PROCESS
5.1.1 Purpose
This Risk Management Process shall be adopted as a standard throughout BSSB

and applied in managing the risk that may arise out of and in the course of
Company’s operations.
5.1.2 Scope
The requirement for a structured HSE risk management shall apply for all activities
carried out throughout BSSB operations including operation and maintenance
activities.
Additional, this requirement shall apply equally in all activities carried out in
Company’s operations; including activities carried out by Contractors engaged in
work for, or on behalf of BSSB and Third Parties associated with the Company
activities.
5.1.3 Procedure
5.1.3.1 All HSE risks (hazards and effects) that may arise out of and in the course
of BSSB’s activities, including Contractors activities, and from materials
which are used or encountered in these activities shall be reduced to a
level that is as low as reasonably practicable (ALARP).
5.1.3.2 Leadership at all levels within BSSB shall provide the required support and
resources to enable the implementation of the required risk management
activities.
5.1.3.3 Personnel at all organizational levels shall be appropriately involved in the

identification of HSE hazards and effects, and the subsequent
implementation of risk control and recovery measures.
5.1.3.4 As a standard, the risk (hazards and effects) management process shall
be based on the 4 basic principles of hazard identification, Assessment,
Control and Recovery; i.e:
• Identify the hazard.

• Assess the possible consequences of hazard release or
exposure.
• Control the hazard.
• Recover from a failure to control the hazard.
DOC: BSSB-MAN-HSE
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The following essential steps of HSE risk management shall be adhered to,
as follows:
a) Identify Hazards and Effects.

b) Establish Screening Criteria.
c) Assess (evaluate) Hazards and Effects.
d) Document Significant Hazards and Effects and applicable
Statutory Requirements.
e) Define detailed Objectives and Performance Criteria.
f) Identify and Evaluate Risk Reduction Measures.
g) Implement selected Risk Reduction Measures.
BASIC
PRINCIPLE MAIN STEP/PROCESS BRIEF DESCRIPTION
IDENTIFY 1. Identify Hazards and • What is the hazard?

Effects • What could go wrong?
ASSESS 2. Assess (evaluate) • How serious can it be?

Hazards and Effects • How probable is it?
3. Document
Significant Hazards
and Effects and
applicable Statutory Refer BSSB’s HSE Key
Requirement Performance Indicators (KPI)
as defined annually by the
4. Define detailed BSHSEC
Objectives and
Performance
Criteria
CONTROL 5. Identify and • Prevent/Eliminate the

Evaluate Risk Hazard:
Reduction Measures  Is there a better
way?
 How to prevent it?
RECOVER 6. Implement selected • Mitigate

Risk Reduction consequences
Measures  How to limit the
consequences?
 How to recover?
 How to restore?
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Identification of HSE hazards and effects typically requires the application of

specialized techniques which include, amongst others:
a) Potential Problem Analysis (PPA)
b) Job Hazard Analysis (JHA/Job Safety Analysis (JSA))
c) Hazard Identification (HAZID)
d) Quantitative Risk Assessment (QRA)
BSSB shall have the required procedures on HSE Risk (Hazards and Effects)
Management Process, specifying the methodology for a structured hazard
analysis and assessment, as well as procedures relating to the identification and
implementation of risk control and mitigating measures.
5.1.4 Records
All HSE-critical hazards and effects, including the associated risk control and
recovery measures, identified during the risk (hazards and effects) management
process shall be documented and to be kept and maintained by the process
owner.
5.2 HSE RISK SCREENING CRITERIA
5.2.1 Purpose
This HSE Risk Screening Criteria defines BSSB’s HSE risk screening criteria that shall be
adopted, as a minimum standard, in all hazards and effects assessment carried out
throughout BSSB.
5.2.2 Scope
The application of BSSB’s HSE risk screening criteria shall apply equally for all HSE risk
assessment carried out throughout Company’s operations including activities
carried out by Contractors engaged in work for, or on behalf of BSSB’s and Third
Parties associated with the Company activities.
5.2.3 Procedure
4.2.3.1 Limits/Standards
i) Once the hazards or effects, have been identified and assessed,

they shall be considered against on HSE risk screening criteria.
Screening criteria are values or standards against which the
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identified hazards or effect can be judged; examples –
occupational exposure limits, engineering standards and
environmental quality standards.
ii) In cases where the relevant HSE risk screening criteria is defined by
local legislation, such legislative requirement shall be complied with.
However, where BSSB’s HSE risk screening criteria is more stringent,
the more stringent requirement accepted criteria.
iii) In cases where no specific legislation exist, BSSB shall adopt the
appropriate BSSB standards or approved internationally accepted
criteria.
iv) In managing HSE risk, BSSB shall adopt the principle of ALARP; i.e. to
minimize risk to a level that is as low as reasonably practicable.
Additionally, a cost/benefits analysis may be required to determine
when the risk is as low as reasonably practicable.
5.2.3.2 Quantitative Risk
i) For a qualitative risk assessment, the assessed risk can be refarded

as either:
a) INTOLERABLE – where the number of incidents and the

severity are clearly intolerable; or
b) INCORPORATE RISK REDUCTION MEASURES – where the

frequency and severity is fairly and warrant specific risk
reduction measures, such as the use of procedures for
controlling the risk or making hardware improvement; or
c) MANAGE FOR CONTINUOUS IMPROVEMENT – is an area

where the risk is low and the existing arrangement for HSE
management is adequate.
ii) The HSE Risk Assessment Matrix (see Page 6) shall be used for the
qualitative portrayal of risk and screening criteria in risk assessment
carried out throughout BSSB operations.
5.2.3.3 Quantitative Risk
i) Where quantitative assessment is required, the quantitative criteria

for ALARP shall be based on various indices, with distinction made
between employees and the public.
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ii) When seeking to lessen the estimated risk, consideration of
prevention measures to reduce probability should be the first
choice, as opposed to risk reduction by mitigating the
consequences of an incident.
The basic principle on how ALARP can be achieved is as follows:
a) Wherever possible, design out risks; or
b) Incorporate risk reduction measures; or
c) Where risk is clearly intolerable, decide if the continued presence in

that area of business is contrary to BSSB’s HSE policy and strategic
objectives.
5.2.4 HSE PERFORMANCE TARGET
5.2.4.2 BSSB Project HSE Goal Statement
It is our pledge to demonstrate respect for the environment and to work constantly and
relentlessly to achieve our HSE goals:
GOAL 1
“Our Mission is to perform our work safely with ‘0’ INJURY and ‘0’ FATALITY till the end of
the project”
GOAL 2
“We will Commit and Participate in improving Safety at our worksite by reporting on all
UNSAFE ACT and UNSAFE CONDITION daily”
GOAL 3
“We will choose a healthy lifestyle to avoid illness that will affect our work and project lost
time”
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5.2.4.2 Performance Target
BSSB commitment to HSE performance sets clear aspirations, our HSE Project Goal Target
are as follows:
Sec Project HSE Target Goal Remarks

1 Fatality Case ‘0’
2 Lost Time Injury Case ‘0’
3 Total Recordable Injury Less than ‘0.5’
Frequency
4 Occupational Illness Lost Time ‘0’
Case
5 Environment Case ‘0’
6 U-See-U-Act Submission Daily 1(one)
report for every
200 man-hour at
every worksite
Company project HSE targets shall be SMART; Specific, Measurable, Achievable, Realistic
and Timely.
The HSE Plan framework provides the processes that links the company commitment to
Health, safety and environment performance and the ultimate objective of Target Zero.
The HSE Committee in conjunction with the Project Manager shall continually review the
plan’s effectiveness, recommend appropriate changes to systems of work and / or the
structure and content of this plan to reflect best practice in the overall health, safety and
environmental management of the project.
5.2.5 Record
The HSE risk screening criteria used during any hazard analysis/assessment shall be
recorded and documented as part of the risk (hazards and effects) management
process report.
5.3 CRITICAL RISK MANAGEMENT ACTIVITIES
5.3.1 Purpose
This portion on Critical Risk Management activities defines BSSB’s requirement in

respect of carrying out the structured HSE risk management and analysis, during
the various stages of the Company’s operations and maintenance activities.
5.3.2 Scope
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The requirement for carrying out the structured HSE risk management and analysis
at the prescribed phases of Company’s activities shall apply equally for activities
carried out by Contractors engaged in work for, or on behalf of BSSB and Third
Parties associated with the Company activities.
5.3.3 Procedure
The requirement for structures for HSE risk management and analysis, at specified
stages of operations and maintenance.
5.3.3.1 Operation and Maintenance
During the operation and maintenance phase, the General/Operation

Manager of the respective Division shall be responsible in ensuring that
the appropriate HSE risk management and analysis are also carried out.
As a minimum requirement, the following HSE risk management and

analysis activities shall be carried out, as follows:
a) Prior to the commencement of any simultaneous operations with

the offshore facility/installation, the appropriate health and safety
risk management and analysis shall be carried out.
b) An environmental risk assessment (i.e. Environmental Impact

Assessment) shall also be carried out prior to the commencement
of activities that are deemed to have an impact on the
environment.
All risk control and recovery measures identified as part of the risk analysis
and assessment process shall be documented in a HSE Plan or Operations
HSE Case, to be implemented as appropriate, either prior to or during the
execution of the respective activities.
Where there are requirements to have the HSE Risk Assessment Report
(e.g. Environmental Impact Assessment Report) submitted for regulatory
approval, this requirement shall be complied with accordingly.
The implementation of the required HSE risk management and analysis,

appropriate to the anticipated risk level encountered, is required for
effective functioning of BSSB’s HSE Management System and attainment
of a sustained improvement in the Company’s HSE performance.
5.3.4 Record
All HSE-critical hazards and effects, including the associated risk control and
recovery measures, identified during the risk (hazards and effects) management
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process shall be documented in a Hazards and Effects Register to be kept and
maintained by the process owner.
5.4 STATUTORY HSE RISK ASSESSMENT REQUIREMENT
5.4.1 Purpose
This section on Statutory HSE Risk Assessment Requirement defines the statutory
requirement in Malaysia in respect of HSE risk management and analysis, and the
associated requirements relating to report submission and approval by the
appropriate Malaysian regulatory authorities.
5.4.2 Scope
The requirement of this section shall be applicable to BSSB’s Malaysia Operations.
All requirements contained herein shall apply equally for activities carried out by
BSSB’s Operations, as well as activities carried out by Contractors engaged in work
for, or on behalf of BSSB and Third Parties associated with the Company activities
in Malaysia.
5.4.3 Procedures
4.4.3.1 General
BSSB’s Operations shall comply with the relevant statutory requirements

currently in force in Malaysia pertaining to HSE risk management and
analysis. The relevant statutes are as follows:
a) Marine Department’s Requirements
b) Classifications Societies Requirements
For detailed requirements, reference should be made to the respective

Regulations and Guidelines.
5.4.4 Record
All Reports shall be retained by the MD/General Manager for a period of not less
than 7 years.
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(PLANNING & PROCEDURE)
Section 6
PLANNING AND PROCEDURES
Contents
Paragraph Page
6.1 HSE Plan 2
6.2 Asset Integrity 4
6.3 Procedures and Work Instructions 5
6.4 Management of Change 7
6.5 Contingency and Emergency Planning 23
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6.1 HSE PLAN
6.1.1 Purpose
This Section defines BSSB’s requirement in respect of HSE Plan, and the integration
of HSE planning into the overall business planning process throughout BSSB.
6.1.2 Scope
Planning in the context of HSE management involves developing strategies to

meet the Strategies Objectives for BSSB. The use of the HSE Plan is critical in
improving HSE performance, as improvement is often a long-term process requiring
advance budgeting and allocation of resources.
The requirement for a structured HSE Plan, and the integration of HSE planning into
the overall business process shall apply equally for activities carried out by BSSB, as
well as activities carried out by the Contractors engaged in work for, or on behalf
of BSSB.
6.1.3 Procedure
6.1.3.1 Company HSE Strategies and Initiatives
BSSB Management HSE Committee (BSHSEC) shall, on an annual basis,

approve the Company’s Long Term and Annual HSE Strategies and
Initiatives.
BSSB’s HSE Strategies and Initiatives shall, as a minimum, be consistent with

attaining and strategic objectives of the BSSB HSE Policy and the
commitment to continual improvement.
Additionally, the Company’s HSE Plans shall define the HSE performance
requirements to be achieved and, where possible, this is to be quantified.
Key HSE Performance Indicators (KPI) shall be an integral part of the HSE
Strategies and Initiatives.
5.1.3.2 HSE Plans
The MD/General Manager, following the issue of BSSB’s HSE Strategies and
Initiatives, shall e responsible in formulating Long Term and Annual HSE
Plans. The HSE Plan shall be approved by the BSHSEC.
The long term HSE Plans, prepared annually, provides a long-term view of
the objectives and activities. The Annual HSE Plan detail out the activities
for the current year for implementation of the intent and objectives of the
Company’s HSE Strategies and Initiatives.
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6.1.3.3 BSSB shall have the required procedures relating to the preparation of an
HSE Plan, specifying the methodology for a structured HSE planning.
6.1.3.4 As far as possible, an HSE plan shall incorporate all relevant aspect of
planning relating to health, safety and environment. As a consequence,
all distinct and separate H, S and E planning document shall be
consolidated into one integrated Health, Safety and Environmental Plan.
6.1.4 Record
The progress of implementation of HSE Plan shall The progress of implementation of

HSE Plan shall be monitored by HSE Manager/BSHSEC.
6.2 ASSET INTEGRITY
6.2.1 Purpose
This Section defines BSSB’s requirement to assure the technical and operational
integrity of asset (facilities and equipment) that BSSB, procures, acquires operates
and maintains; including the requirement in respect of testing, inspection and
monitoring of these facilities and equipment.
6.2.2 Scope
The requirement contained herein shall apply for facilities and equipment that are
ready-built facilities and equipment that BSSB procures and/or acquires; including
facilities and equipment that are designed, built, procured and/or acquired by
Contractors engaged in work for, or on behalf of BSSB and Third Parties associated
with the Company activities.
6.2.3 Procedure
6.2.3.1 General
BSSB shall have in place the required system and procedure to ensure the
technical and operational integrity of facilities and equipment that the
Company, procures, fabricates, install, acquires, operates and maintain,
including but not limited to those related to testing, inspection and
monitoring of the technical and operational integrity of these facilities
and equipment.
All personnel who perform the activities related to asset integrity are
required to have the appropriate experience, qualifications and training
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to ensure their competency in undertaking these important risk
management activities.
The MD/General Manager shall ensure that all facilities and equipment
that BSSB acquires shall be suitable for the required purpose, and shall
conform to country’s statutory requirements, internationally accepted
and BSSB standards.
Non-conformance to BSSB Standards and/or those internationally

accepted Industry Standards, Codes of Practices and Guidelines as
approved and adopted for use by BSSB is permitted only after review and
approval by the MD/General Manager through the Management of
Change Procedures.
6.2.3.2 Operations and Maintenance of Asset
The MD/General Manager shall ensure that all required technical and
operational integrity requirements are complied with, and that thses
conform to country’s statutory requirements and BSSB Standards.
To ensure that the continued integrity of asset (facilities and equipment)

is safeguarded, the following should be in place:
a) Clearly defined responsibility and custodianship.
b) A practical and widely understood facility/equipment

change control system (management of change).
c) A transparent inspection and maintenance philosophy and

program.
d) A program of recorded management and cross-

discipline/cross-facility inspections.
The requirements of BSSB’s Operations Philosophy, Maintenance

Philosophy, Inspection Maintenance Guideline and other related
Technical and Operational Integrity Standards and procedures shall be
an integral part of the asset management plan.
6.2.4 Record
All records pertaining to approve deviations from BSSB Standards and/or those
internationally accepted Industry Standards, Codes of Practices and Guidelines as
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approved and adopted for use by BSSB shall be documented and kept by the
Operations Manager.
6.3 PROCEDURES AND WORK INSTRUCTIONS
6.3.1 Purpose
This Section defines BSSB’s requirements for written procedures and work
instructions in respect of all HSE-critical activities carried out throughout BSSB.
6.3.2 Scope
The requirement for written procedures and work instruction shall apply equally for
all HSE-critical activities carried out by BSSB, as well as activities carried out by
Contractors engaged in work for, or on behalf of BSSB.
6.3.3 Procedure
6.3.3.1 General
Written procedures and work instructions shall be developed for all

activities that are critical in ensuring compliance to BSSB’s HSE
Management System, BSSB Standards and the relevant statutory
requirement.
All written procedures and work instructions shall be clear, simple and
unambiguous, and shall indicate the person responsible, the methods to
be used and, where appropriate, performance standards and criteria to
be satisfied.
The requirements for written procedures and work instructions is

applicable for all HSE-critical activities,
Written work instructions shall be developed for all HSE-critical tasks (i.e.
tasks which have the potential for adverse HSE consequences if
incorrectly performed). Work instructions define the manner of
conducting tasks at the work-site level, whether conducted by
Company’s employees or by others acting on the Company’s behalf.
All procedures and work instructions shall be:
• Subject to a regular and formalized system of review, approval

and update.
• Dated and easily updateable.
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• Identified with a custodian.
• Accessible (not just physically evident but user-friendly and well
indexed).
The responsibilities for the required procedures and work instructions shall
be on the MD/General Manager, who in turn, assign the responsibilities
and custodianship for specific procedures and work instructions to the
respective Line Manager.
6.3.3.2 Operating Manual
The MD/General Manager shall ensure that the facility’s Operating

Manual is up-to-date and reflects current operating procedures.
The Operating Manual shall be prepared based on, amongst others:
a) Vendor’s information and operating procedures.
b) Design information and operating procedures, operations

representatives.
c) Experiences and lessons learnt from past incidents.
The information contained in the Operating Manual shall include, but not
limited to the following:
a) Description of the facility.
b) Start-up procedures.
c) Normal operations procedures.
e) Temporary operations procedures.
f) Emergency shutdown procedures and emergency isolation

arrangements.
g) Evacuation, escape and rescue procedures.
h) Description of fire/safety systems including trips, interlocks, fire and

gas detection and fire water system.
Additionally, the following process design information shall also be

included:
a) Operating limits and the consequences of deviation from the

operating limits (cause and effect matrix).
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b) The steps required to correct or avoid such deviations from taking
place.
During the Initial Operations Audit (or alternatively a Pre-Start Up Review)

of the facility, the review of the Operating Manual shall include provisions
made relating to the associated training of operations and maintenance
personnel.
Prior to start-up, all operations and maintenance personnel identified to

work on the facility shall be trained to operate the facility in accordance
with the Operating Manual.
The MD/General Manager shall be responsible in ensuring that all facility-

specific Operating Manuals are kept up-to-date.
Any proposed changes to the Operating Manual shall be approved by

the BSHSEC and subsequently authorized through the Management of
Change Procedures.
Supervisors in charge of a specific activity or task shall be familiar with the

relevant systems, procedures and work instructions and shall cascade the
information to the workforce via HSE meetings, toolbox talks and where
critical operations are involved to manage the operations through the
Permit-to-work System.
6.3.4 Record
All procedures and work instructions shall be controlled document and shall be
managed in accordance with BSSB’s Documentation Management Procedures.
All procedures and work instructions shall be kept up-to-date and shall be reviewed
as and when circumstances dictate or at least once in every 2 years.
6.4. MANAGEMENT OF CHANGE
6.4.1 Purpose
This procedure provides the route to follow to ensure that changes are managed safely
and efficiently offshore.
6.4.2 Scope
This procedure applies to all aspects of Bermuda Subsea (BSSB) related offshore
operations, including but not limited to Project, Marine, ROV, etc; and including
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spoolbases and other operational bases directly or indirectly connected to offshore
operations. This procedure covers:
• Deviation from AFC procedures

• Deviation from Standard Company Procedures
• Unplanned modifications to vessels and equipment
• Changes to the sequence of offshore operations
• Deviation from specified safe working practice or work instructions
• Use of an existing piece of equipment for a new task
• Weather limitations (as it determines safe operating parameters)
• Implementation of new systems
• Significant changes of Safety Critical personnel, as defined under the IMCA
Competence Scheme
• Change instigated and/or request by Client (Site Instruction, Variation Request and
Deviation Request)
6.4.3 Abbreviations and Definitions
Abbreviations
AFC Approved for Construction: a Project procedure which has been “Approved
for Construction” by the Project Manager, and where appropriate, the client.
NB:-Project procedures are also deemed to include any client, and third party
supplied procedures. Changes to these procedures are subject to the
requirements of this procedure in addition to any client specific change
control requirements.
ALARP As Low As Reasonable Practical: The principle of ALARP is to balance any
potential gain in safety against the actual cost in terms of time, effort or
money.
CRF Change Request Form:
JHA Job Risk Assessment: Risk Assessment process developed based upon a task
based risk assessment model to ensure a risk level that can be considered As
Low As is Reasonably Practicable has been achieved.
MOC Management of Change Procedure
PMT Project Management Team
OM Offshore Manager
PTW Permit to Work
Definitions
Responsible Within the context of this Procedure shall be the Project Engineer or
Engineer Chief Engineer depending on requirements.
Responsible Within the context of this Procedure, where a Project is involved this will
Manager be PM. Where there is no offshore Project, it will be the Ship Services
Manager.
Risk The likelihood that a specific hazard will be realised as a function of the
probability of it’s occurrence and severity of the consequences.
Senior Within the context of this Procedure includes Master/Chief Engineer, OM
Offshore or their on-shift deputies.
Management
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Site Within the context of this Procedure shall mean any instruction from a
Instruction client to change or deviate from the planned work. Such instructions
must always be obtained in writing and may include, without limitation,
site query forms, deviation requests or any other form of variation
request.
Supervisor Within the context of this Procedure includes all offshore supervisory
personnel.
Project Within the context of this Procedure, a Project may be either a work
scope being executed on a vessel on behalf of a client for a BU in the
conventional sense, or, a Marine/RSU/etc., upgrade, dry-dock or other
piece of substantive work to which an internal Project number has been
assigned and is being managed by a nominated Project
Manager/Team.
Equipment Equipment may include, but not be limited to; metal, stock and fittings,
stationary, fuel, lubrication oil, burning gases, protective clothing, lifting
equipment, cordage, tools, services or software.
6.4.4 Important Notes
Note 1
Should a situation arise in which the Senior Offshore Management, or their shift deputy
consider immediate action is required to minimise the effect of potential risk to personnel
or equipment, they shall have the authority to take whatever measures are necessary to
re-establish a safe situation. Only once the situation has been stabilised and safe shall the
requirements of this procedure be followed to record any changes made before
undertaking any subsequent work.
Note 2
Text within this procedure should be used in conjunction with the 16 Step Offshore
Management of Change Process Flowchart (see section 3.1 Offshore Management of
Change Process Flowchart).
6.4.5 The 16 Steps to Manage Change
The PRIMARY TOOL for Management of Change is the Offshore Management of Change
Process Flowchart (See section 3.1 Offshore Management of Change Process Flowchart).
Guidance for each step is given below.
STEP 1 – IDENTIFICATION OF CHANGE
When a need for change has been identified, before any Risk Assessment is carried out,
the intent shall be communicated to the Responsible Engineer who will liaise with the Senior
Offshore/Onshore Management and Client as appropriate. Change can include ALL of
the following but not limited to:
• Deviation from AFC Procedures
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• Deviation from Standard Procedures
• Unplanned modifications to vessels and equipment
• Changes to the sequence of offshore operations and Project schedules
• Deviation from specified safe working practice or work instructions
• Using and existing piece of equipment for a new task
• Weather (As it determines safe operating parameters)
• Implementation of new systems
• Significant changes to personnel holding critical competencies
• Vessel change/substitution
• Change instigated and/or requested by client (Site query, Variation Request,
Deviation Request, etc.)
Change and Approval to AFC Procedures
AFC Procedures are developed by the Project team for a given work scope to meet the
contract specification. The procedures are compiled from approved work practices and
methodologies for specific activities, refined through formal operational reviews and Risk
Assessment and other studies prior to final approval by the Project Manager and the Client,
where appropriate.
AFC Procedures which require to be revised due to a change in method, unforeseen work
or other circumstances shall be subject to change management and as a minimum, a
JHA shall be carried out. Changes to AFC Procedures are to be documented between
the Client Representative onboard the vessel and the nominated Project representatives
(Senior Offshore Management, or their on shift deputy). Changes are permitted
Changes to Standard Company Procedures
BSSB has implemented suites of standard operating procedures which control routine
operations offshore (e.g. Diving Operations, Diverless Operations, Trenching Operations,
Pipelay Operations, etc.). Changes to these standard operating procedures and practices
during offshore operations are not permitted without prior approval of the relevant Line
Manager who has responsibility and ownership of the Procedure.
This does not apply to routine revision requests which shall continue to be dealt with in the
normal way.
Changes to Equipment
Modification to plant and equipment and the authority levels for approval and
implementation of such changes are controlled and documented by existing systems and
procedures in Company Management Systems. Changes are not permitted without prior
approval of the relevant Line Manager who has responsibility and ownership of the
equipment and/or Procedure.
Managers and Supervisors both offshore and onshore are responsible for ensuring
compliance with these procedures within their areas of responsibility to ensure that any
risks arising from changes to plant and equipment are effectively controlled and
managed.
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Changes Brought About by Client’s Site Instruction
Some change may be instigated by the Client such as additional tasks on a project
workscope. This change must be managed effectively on the worksite with the same level
of control and risk assessment required in this procedure. These changes are permitted if
this procedure is followed and approvals are received as per the Change Authority Matrix.
STEP 2 – PLAN THE CHANGE
The level of effort required to successfully plan a change will obviously depend on the level
of complexity of the changes. However involved the process becomes, the basic steps of
planning change remain the same during this stage of the MOC process:
• Define the change

• Plan the change through consultation with personnel involved in the change, using
the knowledge and experience of the workforce
• Identify resources needed to make the change
• Confirm technical integrity and safety of the proposed change
• Have a continuity plan
STEP 3 – RAISE CHANGE REQUEST FORM
The raising of the CRF will be actioned by the Responsible Engineer after identification of
change outlines in Step 1 and Step 2 above.
Defining the change has to be made clear to all parties at this early stage and that any
subsequent Risk Assessment will be to Risk Assess that Change only and not the original
procedure. Nevertheless, the risk(s) arising from the change(s) identified at this stage
should take due account to other steps within the procedure.
The raising of the CRF, is self explanatory, however, it is vitally important that all sections are
completed and that the CRF has been allocated a designated reference number for
approval purposes and filing in the project file.
(See Attachment 2 – HSE-F-007 Standard Change Request Form)
STEP 4 – ASSESS INITIAL CHANGE CATEGORY
After reviewing the original Risk Assessment to determine whether the original risks will still
maintain the same ranking after initiation of the change. The Responsible Engineer, OM
and relevant Supervisor (Chief Engineer for vessel integrity/safety) involved in the change
will determine the initial change category.
The Risk Assessment Matrix included in this procedure will always be used to determine the
level of risk associated with a particular hazard based upon the Probability x Severity
(Consequence).
Therefore generally speaking:
Minor Change is equal to LOW RISK

Major Change is equal to MEDIUM RISK
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Critical Change is equal to HIGH RISK
And, if, after a MOC, risk assessment, procedures or activities originally classified as a
“medium risk” remain a “medium risk”, then the Change shall be categorised as “Minor”
and be managed accordingly.
An example of this is the landing of a pipeline valve in a crowded seabed environment.

This task has already been risk assessed, has controlled measures allocated to this task and
it carries a MEDIUM risk. A decision has been made by the Offshore Team to land this valve
on pre-installed grout bags, which actually adds a step to an AFC procedure. This change
does not increase the risk of the operation therefore it can be deemed Minor.
The exception to this rule is if the Change results in one of the mandatory “Critical”
categories given in this section “Critical Changes”.
Minor Change Example

A change in the size or position of a shackle in a rigging arrangement is assessed as having
no impact on rigging integrity or affecting the ability to install the associated item.
However, the proposed change will improve the ease of handling and reduce installation
time. The change was assessed as resulting in a LOW RISK as:
• No impact on safety
• No impact on technical integrity
• Schedule impact less than 12 hours
Therefore, the change would be categorised as Minor, and a JHA initiated prior to
proceeding with the work.
Major Change Example

It is proposed to change the sequence of installing sub-sea flow-lines which could result in
a potential clash with a drilling rig due to arrive in the field within the next 48 hours. The
change was assessed as resulting in:
• A departure from an approved Project AFC Procedure(s)

• An increase in Risk resulting in a MEDIUM RISK
• A schedule impact of 12 hours or greater
• Significant impact on other operations in the area (e.g. FPSO offloading schedule, Third
party vessel operations, etc)
Therefore the change is categorised as Major, and a Risk Assessment and JHA is needed,
together with the necessary approval authorisation, completion of CRF, prior to any work
commencing.
Critical Change Example

The original plan was to use valves in the platform facilities to provide a hydro-test isolation
barrier during test and commissioning of a new sub-sea system. The client advises the
topsides commissioning is behind schedule and this option is no longer available but
alternative isolation methods might be possible which could allow work to continue. The
change was assessed as resulting in:
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A significant increase in Risk resulting in a HIGH RISK categorisation due to the alternative
isolation method proposed being a single block with no bleed on a medium pressure
system (i.e. the assessment of probability and severity, in accordance with the matrix,
identified an increase in Risk from medium to high).
Therefore, the change is categorised as Critical, then a Risk Assessment and JHA are
needed.
All of the following circumstances shall be treated as ‘Critical’ and appropriate approvals
sought prior to continuing with the work:
• Any reduction or alteration (other than an increase) to the standard of isolation

originally agreed for the work (mechanical, electrical, etc)
• A change which could affect the technical integrity of 3rd party products (e.g. and
interface issue) in which case it must be formally approved by the relevant 3rd party
supplier
• Structural modification to installation aids which involve significant changes in loading,
functionality or intended use
• Alternations to approved commissioning, isolation and test procedures for pressure
retaining systems (e.g. manifolds, trees, pipelines, flow-lines, etc)
• Use of different materials or variations to cathodic protection systems which could
affect ability to withstand corrosion over the life of the system
• Impact on statutory or code compliance
STEP 5 – IDENTIFY RISK ASSESSMENT TEAM
The composition of the team may vary depending upon the operation being considered.
However, supervisors and subcontractor personnel (where applicable) from the relevant
disciplines should be present. The goal of Risk Assessment is to bring together the key
personnel who have the right competencies and relevant experience for the purpose of
discussing, collecting and assessing concerns, ideas and safety inputs that will reduce risks
and ensure the safe execution of the change(s) or task(s) under consideration. The Risk
Assessment team will typically be a combination of the following disciplines relevant to the
task:
• Senior Offshore Management

• Responsible Engineer
• Safety Officer/Rep. or HSE Coordinator
• Client Rep. (where applicable)
• Offshore supervisory personnel (e.g. Rigging, Diving, Construction, etc)
• Sub-contractors (where applicable)
• Other relevant personnel as required (e.g. crane operator, etc)
STEP 6 – CONDUCT RISK ASSESSMENT
Managers and Supervisors are responsible for ensuring that suitable Risk Assessments are
carried out when managing changes within their area of responsibility.
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The Risk Assessment team shall review the original Risk Assessment and then carry out an
assessment of both the change and the associated risks to allocate correct
categorisation.
Which Risk Assessment is to be used?

All risks must be assessed and all changes must be managed irrespective of when or where
they occur either offshore or onshore.
Throughout the BSSB there is no common Risk Assessment method/process whereby, many
BU’s utilise their own established Risk Assessment methodology (i.e. HIRA, RAR, HAZID, QRA,
HAZOP, HAZAN, SJA, JSA, etc). It is essential therefore that the results from any risk
assessment method are consistent with BSSB.
To achieve this, a BSSB Risk Assessment matrix has been developed to ensure that a
consistent approach is adopted. (See Attachment 1: HSE-014 Standard Risk Assessment
Matrix).
Therefore, whatever risk assessment process is used only the risk assessment matrix
contained within this procedure shall be used. On no account must any other matrix be
used.
Standard Risk Assessment Matrix – Severity Criteria

For each identified hazard determine the worst credible consequence from the following
five headings:
• Harm to people
• Environment
• Damage
• Schedule
• Facility
Various consequences may arise in which case the risk based on the most severe outcome
but each consequence should be mitigated accordingly. For example – ignition of
flammable liquids may result in fire/explosion, environmental release, personal injury, and
delays to schedule. The most severe outcome might be a DAFWC, but measure to mitigate
all the other consequences MUST be considered and implemented, as appropriate.
Standard Risk Assessment Matrix –Probability Criteria

Assess the Probability of the Risk and select the highest letter based upon any one of the
five headings:
a. Very Unlikely
b. Unlikely
c. Possible
d. Likely
e. Very Likely
After making a change, look at the relative increase / decrease of risk. The change should
bring about a decrease. However, it is important to treat this as a qualitative risk assessment
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based on judgement and select the appropriate probability letter without being
distracted by the precise probability descriptions.
Standard Risk Assessment Matrix – Plotting the Outcome

Plot the Severity against the Probability, on the Matrix Table, to determine if the risk is LOW,
MEDIUM or HIGH. Make sure the actual number/letter designation from the Standard Risk
Assessment Matrix is recorded on the completed Risk Assessment paperwork as this will
accurately record the level of Risk within each criteria. For example 1A LOW is very different
from 3B LOW.
Standard Risk Assessment Matrix – Risk Tolerability Criteria

LOW Tolerable. Control measures fully identified and effectively implemented.
MEDIUM Greater residual risk than Low but remains tolerable with full and effective
implementation of control measures.
HIGH 1 Intolerable if the risks involve hazards to personnel or environment. Must be
mitigated further or the work must be cancelled
HIGH 2 Tolerable only if risks involve hazards to equipment, schedule or facility
availability. This must be approved by the relevant Line Manager and/or
Client and documented prior to the work going ahead.
STEP 7 – RECORD RESULTS OF RISK ASSESSMENT
It is important that the risk assessment is recorded in sufficient detail with accurate detail
of the control measures and mitigating factors implemented, so that it can be
demonstrated that a suitable and sufficient assessment has been undertaken and also so
that if circumstances change the analysis can be readily reviewed and, if necessary,
revised.
STEP 8 – CHANGE ACCEPTANCE
The outcome of the Risk Assessment will depend upon the findings and recommendations
and that the team are satisfied that the risks identified from the change are ALARP, then
proceed to Step 10. If there is any doubt, then Step 9: TIME – OUT should be implemented.
STEP 9 – TIME-OUT, REJECTION OF CHANGE REQUEST
Rejection of change may be based on the following criteria if after conducting the Risk
Assessment any of the following are recognized:
• Requirement for a more detailed risk analysis

• Requirement for more Engineering
• Further training required
• Additional Permit-to-Works
• Modification to equipment
• Safeguards that cannot be put in place due to lack of resources (specialised PPE)
• Change to material specification
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STEP 10 – COMPLETE CHANGE REQUEST FORM
Completion of the CRF by the Responsible Engineer should summarise how the change is
to be implemented and any actions identified to reduce risk to the change to ALARP.
STEP 11 – APPROVAL OF CHANGE REQUEST FORM
Change Authority Matrix

IMPORTANT NOTE: All applicable individuals, marked with a , as shown below, approve
the CRF prior to any work going ahead.
This can be achieved by the scanning/faxing of the CRF and Risk Assessment between the
worksite and the Line Manager to obtain the requisite approvals. This can also be achieved
in exceptional circumstances by an email quoting the unique reference CRF number with
the required approval. See Section 4.2/3 Project/Line Manager Responsibilities. CRF’s are
to be authorised in accordance with the following matrix.
STEP 12 – TRANSFER OF INFORMATION
Transfer of information will be completed to ALL INVOLVED IN THE CHANGE by the copy
and distribution of the CRF and Risk Assessment to Senior Offshore Management, Senior
Onshore Management, Client (if required), Relevant Personnel/Sub Contractors,
Immediate Supervisor and Third Parties.
This transfer of information must take into account shift handovers and crew changes.
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STEP 13 – IMPLEMENT CHANGE
The key factor to be addressed when implementing change is to ensure that a JHA is
held at the coal face prior to work commencing (guidance on the development is
included in the Job Risk Assessment Procedure report sheet which is appended to this
document. See Attachment 3: HSE-084). The Responsible Engineer and relevant
Supervisor shall brief the workforce on the change by informing all the personnel involved
and providing the necessary resources needed for the change.
STEP 14 – MONITOR CHANGE
Active monitoring of activities by the responsible Managers and Supervisors is of pivotal

importance to safe operations. Two types of monitoring are essential in managing
change as shown below. The level of monitoring required will vary with the complexity of
the change and it’s associated hazards. To be effective, monitoring must be active
throughout the change process.
During The Change

Is the change going to plan?
Are all the controls for the hazards in place?
Note: If none of the above are in place, Stop and Review.
After the change

Is implementation complete?
Are personnel happy with it?
STEP 15 – CLOSE OUT CHANGE REQUEST FORM
It is important that:
• All actions are closed out and that all drawings and procedures are updated as
appropriate
• It can be demonstrated that a suitable and sufficient assessment has been undertaken
• If circumstances change the analysis can be readily reviewed and, if necessary,
revised.
• A completed Risk Assessment report shall be maintained in a central file held by the
worksite.
• All change documentation is sent to the relevant Project Manager for inclusion in any
Project debrief report documentation upon completion of the work.
STEP 16 – REVIEW CHANGE
Review of change must be undertaken to:
• See if a change has been successful then it may be worth implementing elsewhere in the
organization.
• Identify if a change has been unsuccessful, and take steps to prevent unnecessary work
or risk elsewhere in the organisation.
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• Identify and record in Project Debriefs
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Offshore Management of Change Process Flowchart

OFFSHORE MANAGEMENT OF CHANGE PROCESS FLOWCHART
RESPONSIBLE RELEVANT
S MANAGER CLIENT
SENIOR PERSONNEL/ FRONT LINE SAFETY
T ACTIVITY CHANGE RESPONSIBLE REP THIRD
OFFSHORE SUB- SUPERVISO OFFICER/
E DESCRIPTION IDENTIFIER ENGINEER LINE (WHERE PARTIES
MANAGEMENT MANAGER CONTRACTOR R REP
P PRESENT)
S
1 IDENTIFICATION OF
CHANGE 11
Identify need for change and advise
Responsible Engineer. Do you need a
Client Site Instruction?
2 PLAN THE CHANGE

Define the change. Involve the IF IF IF
22 IF
REQUIRED
REQUIRED
IF
REQUIRED
REQUIRED
IF
REQUIRED
REQUIRED
experience of the workforce. Identify
resources, confirm technical integrity
and have contingency.
3 RAISE CHANGE REQUEST

IF IF
FORM 33 IF
REQUIRED
IF
REQUIRED
REQUIRED REQUIRED
State how change will be conducted.
4 ASSESS INITIAL CHANGE MINOR

CATEGORY 44 44 22 22 44
using Risk Assessment Matrix (on page
12) i.e. Minor, Major, Critical MAJOR
CRITICAL
5 IDENTIFY RISK
ASSESSMENT TEAM 55 55 22 22
Involve the experienced workforce
6 CONDUCT RISK
IF IF
ASSESSMENT 66 66 IF
REQUIRED
IF
REQUIRED
REQUIRED REQUIRED
Identify hazards, perform risk
analysis & appraise risks, mitigate risks
with control measures
7 RECORD RESULTS OF
RISK ASSESSMENT 77
and retain on file
8 CHANGE ACCEPTANCE
YES
Does everyone agree with the change?
88 88 88 88
YES NO IF
REQUIRED
9 TIME OUT
Advise Originator change request is
rejected or requires clarification 99
10 COMPLETE CRF
Responsible engineer to complete 10
change request form.
10
11 APPROVE CRF
and obtain other approvals in
11
11 APPROVE
APPROVE APPROVE
APPROVE APPROVE
APPROVE APPROVE
APPROVE
accordance with change authority
matrix (as applicable) IF IF
IF MAJOR REQUIRED REQUIRED
OR CRITICAL
12 TRANSFER OF
INFORMATION 12
12
Copy & distribute approved CRF and COPY COPY COPY COPY COPY COPY COPY
risk assessment to: Master/OIM, OCM,
IF
Original Supervisor & Client and all REQUIRED
Parties involved with the change
13 IMPLEMENT CHANGE
ENSURE JRA IS HELD AT 13 13 13
13 13 13
ENSURE JHA IS HELD AT
COALFACE
COALFACE
14 MONITOR CHANGE
During and after change. 14 14 14 14
14 14 14 14
15 CLOSEOUT CRF KEY

All actions from risk assessment and 15
JRA are to be closed out and
15
ACTION BY
documented.
APPROVED BY
16 REVIEW CHANGE SUPPORTED BY

Effectiveness and potential for future 16 16
application elsewhere in the 16 16 DECISION
organisation. Capture lessons learned
WK MISC 3481 Re 2 (09/03/04) (JNW) Prod ced b TOUK Dra ing Office (DTP)
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6.4.6 Responsibilities
Introduction
It is the responsibility of all personnel to identify changes during the Project workscope. All
personnel both onshore and offshore must:
• Be familiar with the scope of work and all AFC Procedures.

• Be aware of change and the risks which may arise at the worksite.
• Report any unplanned changes or departures from procedures or standard work practices
to their direct supervisor, so that they can be managed in accordance with this procedure.
• Advise their supervisors whenever they believe change is necessary.
• Take part in Risk Assessments when required
• Cooperate and assist in implementing changes safely and efficiently.
Key responsibilities to ensure compliance with this procedure are as described within the
following sections.
RESPONSIBLE MANAGER (PROJECT MANAGER)

Reporting directly to the Line Manager, is responsible for the effective management and control
of changes within their area of responsibility, as defined in the relevant BU Project Management
System, including, but not limited to the following:
• Any amendments to the scope of work and contractual requirements are identified and
that suitably qualified and experienced personnel have originated and checked the
proposed change.
• Assessing if Major/Critical changes require further review and approval from onshore
engineering or other specialist support.
• Ensuring any proposed changes are consistent with maintenance of overall technical
integrity and safe installation.
• Changes to the scope of work for any given vessel/equipment upgrade.
• Ensuring that all changes are adequately reviewed, assessed and the impact of the
changes on the Project are identified.
• For advising the Project team whether a change should be approved or rejected.
• Monitoring the progress of changes in their areas of responsibility.
• Reviewing the success of change and incorporating lessons learned into future operations.
• That the requirements of this procedure are adhered to.
• For consultation with the relevant QHSE department.
• Ensuring there are the necessary “out of office hours” communications set up to e-mail,
facsimile, or to scan documents which will provide the Site Team with time efficient
approvals for change if necessary.
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LINE MANAGER/ PROJECT ENGINEER
The Senior Onshore Manager is responsible for final approval of all critical changes in
accordance with the Change Authority Matrix. Key responsibilities are summarised below:
• Prior to granting approval, they should be satisfied that the requirements of this Procedure
have been fully implemented; that ALARP is demonstrated to their satisfaction; and, have
agreed to sanction the implementation of the change in consultation with their client
counterpart, if applicable.
• Is responsible for ensuring that all CRF’s have been assessed for their potential impact to
safety, the environment, installation schedule, cost, technical integrity of
permanent/temporary works and associated factors.
• Consulting with the relevant QHSE department.
• Ensuring there are the necessary “out of office hours” communications set up to email,
facsimile, or to scan documents which will provide the Site Team with time efficient
approvals for change if necessary.
MASTER
Responsible for:
• The assessment of proposed changes for impact on marine and vessel safety.
• Reviewing all CRF’s having due regard for potential impact to safety, the environment,
installation schedule, cost, technical integrity of permanent/temporary works and
associated factors.
• Consulting with the Responsible Engineer and/or Ships Services Manager prior to making a
decision.
• Determining whether a change request is to be defined as “Minor” “Major” or “Critical” in
conjunction with the Responsible Engineer.
• Ensuring that actions arising from Risk Assessments are recorded and acted upon.
• Consult with the relevant HSE department.
• Has the authority to reject any Change Request on concerns that the proposed change
can affect the integrity or safety of the vessel.
ROV MANAGER
Responsible for:
• Reviewing all CRF’s having due regard for potential impact to safety, the environment,
installation schedule, cost, technical integrity of permanent/temporary works and
associated factors.
• Consulting the Responsible Engineer prior to making a decision.
• Determine whether the change should be rejected, recommended to the Client for
acceptance, or submitted for further review.
• Ensuring that actions arising from Risk Assessments are recorded and acted upon.
conjunction with the Responsible Engineer.
• Consultation with the relevant BU QHSE department
• Has the authority to reject any Change Request on the lack of technical integrity, impact
on schedule and/or safety concerns.
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HSE MANAGER/ SAFETY OFFICER
Responsible for:
• Conducting audits to ensure that all CRF’s are correctly processed and authorised and
that risk assessments conducted are in accordance with HSE Manager.
• Making recommendations for improvement where appropriate.
• Where requested, providing advice on potential QHSE impact arising from proposed
changes.
RESPONSIBLE ENGINEER
Responsible for:
• Ensuring that all approved changes are incorporated into relevant Project documents,
including as-built reports.
• Ensuring that any proposed changes are consistent with maintenance of overall technical
integrity and safe installation.
• Preparation and submittal of the CRF to the OM and/or Master for review.
• Ensuring the requirements of this procedure are adhered to prior to the incorporation of
any changes into Project documentation.
• Reviewing technical query/change requests for technical input, recommending technical
solutions, providing clarifications and identifying any intra-Project interfaces.
conjunction with the OM and Master.
• Verifying that all equipment is supplied in accordance with specifications except as
otherwise approved.
• Raising and reviewing CRF’s and providing technical advice to the OM/Master during the
change process.
• Ensuring that the appropriate Risk Assessment is selected and conducted.
• Consulting with the relevant QHSE department.
• Has the authority to reject any Change Request on lack of technical integrity or safety
concerns.
FRONT LINE SUPERVISORS

Responsible for:
• Reviewing any CRF and subsequent risk assessment for possible impact on aspects within
their area of responsibility.
• Ensuring that the output of the Risk Assessment is attached to a JHA and that any further
changes or required additional control measures are documented within the JHA.
• Leading JHA’s and ensuring that the contents of any JHA are communicated to relief
personnel at shift handovers, crew changes and new members of their team.
FRONT LINE CREWS (RIGGERS, WELDERS, MARINE/DECK CREWS, DIVERS, ETC)

Responsible for:
• Participating in JHA’s
• The requirements of any CRF and subsequent Risk Assessment are adhered to.
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CLIENT REPRESENTATIVE (WHERE PRESENT)
Responsible for:
• Reviewing change requests.

• Participating in Risk Assessments and JHA’s where client input is required.
• Signing the completed CRF to acknowledge the agreed change.
• Has the authority to reject any CRF on the grounds it may affect the Technical integrity of
permanent works or for reasons of safety.
6.5 CONTIGENCY AND EMERGENCY PLANNING
6.5.1 Purpose
This Section defines BSSB’s requirement for an effective crisis and emergency
response system, including the associated plans and procedures, to manage
incidents that may be arise out of or in the course of BSSB’s activities.
6.5.2 Scope
The requirement for an effective crises and emergency response system shall apply
equally for all BSSB’s activities, as well as activities carried out by Contractors
6.5.3 Protective
6.5.3.1 General
BSSB shall maintain an effective crisis and emergency management

system, including the associated organization, plans, and procedures, to
cater for any incident that may arise out of or in the course of Company
activities, including Contractors activities.
The crisis and emergency management system shall address, amongst

others, the following areas:
a) Organization, responsibilities, authorities and procedures for crisis

and emergency coordination and response, including the
maintenance of internal and external communications system.
b) Procedures for communicating with authorities and other relevant

parties.
c) Systems and procedures for mobilizing Company equipment,

facilities and personnel.
d) Arrangements and procedures for mobilizing third party resources

for emergency support.
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e) Systems and procedures for providing personnel evacuation,
rescue and medical treatment.
f) Systems and procedures for preventing, mitigating and monitoring

environmental effects of emergency actions.
g) Arrangements for training response teams and for testing the

emergency systems and procedures.
To assess the effectiveness of BSSB’s crisis and emergency response

system, training and drills shall be conducted at intervals as stipulated in
the annual HSE Strategies and Initiatives.
Additionally, periodic assessment of emergency equipment needs and

the maintenance of such equipment in a ready state shall also be carried
out at a pre-defined frequency.
6.5.3.2 Crisis Management Plan
The HSE Manager shall develop and maintain, on behalf of BSSB’s

Managing Director, a Crisis Management Plan, to cater for the
management of potential crisis that may impact BSSB’s business, integrity,
image and reputation.
The scope of Crisis Management Plan shall include, but not limited to, the
following:
a) Crisis management philosophy, strategy, policy and guidelines.
b) Crisis management organizations.
c) Linkages with CLIENT’s Emergency Coordination and Response

Organization.
d) Resources requirement.
e) General procedures on plan activation.
6.5.3.3 Contingency Plan
The HSE Manager shall each develop and maintain the required
contingency plans to cater for any major risks/emergencies that may
occur.
The required contingency plans shall include, but not limited to the
following:
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a) Oil Spill Contingency Plan.
b) Inclement Weather Contingency Plan.
c) Search and Rescue Plan.
d) Facility Abandonment and Evacuation Plan.
A copy each of the respective contingency plans shall be kept at the

Head Office’s Emergency Coordination Center. Additionally, a copy of
the contingency plan should be kept at the facility.
6.5.3.4 Emergency Coordination Centre (ECC) Response Procedures
The HSE Manager shall develop and maintain, on behalf of BSSB’s

Managing Director, an Emergency Coordination Centre (ECC) Response
Procedures refining the roles and responsibilities of BSSB Head Office’s
Emergency Coordination Organization during an emergency.
6.5.3.5 Emergency Response Procedures
The MD/General Manager shall ensure that the facility shall have a site-
specific Emergency Response Organization during an emergency.
BSSB’s Crisis Management Plan, Contingency Plan, Emergency

Coordination Centre (ECC) Response Procedures and Emergency
Response Procedures shall:
a) Be clearly communicated.
b) Be well-rehearsed.
c) Include the coordination of internal and external emergency

response organization.
d) Pay particular attention to external communication.
e) Include provision for the reporting and investigation of incidents.
6.5.4 Record
Following the occurrence of any emergency, an incident investigation shall be

carried out and the required report prepared accordingly.
The crisis management plan, contingency plan and emergency response

procedures shall be kept up-to-date and shall be reviewed as and when
circumstances dictate or at least once in every 2 years.
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(IMPLEMENTION & MONITORING)
Section 7
IMPLEMENTATION AND MONITORING
Contents
Paragraph Page
7.1 Monitoring 2
7.2 Records 6
7.3 Non-Compliance And Corrective Actions 9
7.4 Incident Reporting And Follow-Up 11

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7.1 MONITORING
7.1.1 Purpose
This section defines BSSB’s requirement in respect to HSE monitoring activities,

including the monitoring of associated HSE performance indicators, with a view to
ensure conformance to agreed HSE targets.
7.1.2 Scope
The requirement for the implementation of HSE monitoring activities shall apply
equally for BSSB activities, as well as activities carried out by Contractors
7.1.3 Procedure
7.1.3.1 General
Consistent with BSSB’s objectives of pursuing continuous improvement,

the Company’s HSE performance, including that of Contractors, shall be
monitored against agreed targets. Where the HSE performance has
deviated from targets, the MD/General Manager shall ensure that the
gaps are identified and appropriate remedial actions implemented.
Monitoring of HSE performance shall include, but not limited to, such
activities as:
a) Regular monitoring of progress towards objectives and achieved

by implementation of HSE Plans.
b) Health surveillance of staff, including exposure monitoring and

medical surveillance.
c) Regular inspection of facilities, vessel and equipment against

specific performance criteria.
d) System observation of the work and behavior of first line supervisors

to assess compliance with procedures and work instructions.
7.1.3 Procedure
7.1.3.1 General
Consistent with BSSB’s objectives of pursuing continuous improvement,

the Company’s HSE performance, including that of Contractors, shall be
monitored against agreed targets. Where the HSE performance has
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deviated from targets, the MD/General Manager shall ensure that the
gaps are identified and appropriate remedial actions implemented.
Monitoring of HSE performance shall include, but not limited to, such
activities as:
a) Regular monitoring of progress towards objectives and achieved

by implementation of HSE Plans.
b) Health surveillance of staff, including exposure monitoring and

medical surveillance.
c) Regular inspection of facilities, vessel and equipment against

specific performance criteria.
d) System inspection of the work and behavior of first line supervisors

to assess compliance with procedures and work instructions.
7.1.3.2 Monitoring of Personnel Objectives and Targets
The staff appraisal system plays a key role in the setting and monitoring
of staff performance on all matters, including HSE performance. Line
management shall ensure that staff performance, including planned
HSE objectives and targets, be reviewed at intervals not exceeding 12
months.
7.1.3.3 HSE Monitoring and Performance Indicators
The MD/General Manager shall ensure that the following HSE monitoring
activities, amongst others, are carried out and the associated
performance indication monitored accordingly.
GENERAL HSE HEALTH SAFETY ENVIRONMENT
Proactive • Daily Site • Pre-Employment • Hazard Hunt • Environmental

Inspection and Periodic Program Aspect
• PGI Medical Check- • FESI Identification
• MHSEI Up and Impact
• HSE Training • Occupational Assessment
• Procurement Health Survey • Environmental
Control Monitoring
• Audit & Audit Program
Follow-Up • Waste
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• Campaign/Pro Minimization
motion Program
Reactive • Cost of • Total Sickness • LTIF • Effluent

Accident Absence Rate • TRCF Discharge
• Near Misses • Occupational • Fire Incident Quality
• Drug & Alcohol Illness Incident Frequency • Marine
Search/Test • Noise Induced Pollution Index
Hearing Loss • Environmental
• Exposure to CMT Incident
(carcinogens,
mutagens,
toxic)
Chemicals
The frequency of HSE monitoring shall be based on the nature and

extent of the risk, i.e. the “higher risk” activity or facility require a
more intense and frequent monitoring.
The scope of the respective activities, the methodology and

monitoring frequency, shall be as defined in the respective BSSB’s
procedures.
Additionally, the MD/General Manager shall, in conjunction with

the SITE HSE Committee (SHSEC) and BSSB’s Management HSE
Committee (BSHSEC), decide on the frequency of the HSE
monitoring activities, and such monitoring program shall be
documented in the HSE Plan accordingly.
Issues arising from HSE monitoring activities, including HSE

performance indicators, shall be reviewed by the SITE HSE
Committee (SHSEC), and where appropriate, by BSSB’s
Management HSE Committee (BSHSEC).
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The HSE Manager shall develop the required detailed procedures
and guidelines on, amongst others, the scope, methodology and
frequency of the various HSE monitoring activities.
On an annual basis, BSSB’s Management HSE Committee (BSHSEC)

shall formulate and define the Company’s HSE key performance
indicators and performance targets.
7.1.4 Record
7.1.4.1 Report associated with the SITE’s HSE monitoring shall be kept and
maintained by the HSE Manager for a period of 7 years.
7.1.4.2 Where there are legislative and requirements for record keeping, such
requirements, including those relating to duration for the records to be
retained, shall be complied with.
7.2 RECORDS
7.2.1 Purpose
This subsection defines BSSB’s requirement for the maintenance of a system of

requirement of a system of records to document and demonstrate compliance
to the requirement of the HSE Management System and the associated
procedures.
7.2.2 Scope
The requirement for the maintenance of records, to be made available as and

when required, shall apply equally for BSSB, as well as for Contractors engaged in
work for, or on behalf of BSSB.
7.2.3 Procedure
7.2.3.1 The MD/General Manager shall maintain a system of records in order to

demonstrate compliance to the requirement of the HSE Management
System and the associated procedures and to record the extent to
which planned objectives and performance criteria have been met.
7.2.3.2 The required records shall include, but not limited to, the following:
a) Situations of non-compliance with HSE Management System, and

of improvement actions.
b) Specific Register on Legal Compliance.

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c) Position/Job Description.
d) Organization Charts.
e) Employees training record.
f) Records pertaining to certificates for HSE-critical jobs as required

by HSE Management System.
g) Appropriate Supplier and Contractor Information.
h) Contractors HSE performance record.
i) Product identification and composition data.
j) Listing of BSSB Documents and approved Industry Standards,

Codes of Practices and Guidelines.
k) Management of Charge documentation.
l) HSE Risk Assessment Reports.
m) HSE Plans.
n) Records relating to technical and operational integrity.
o) Inspection and maintenance report.
p) Monitoring data.
q) Incident Investigation Report, including incident follow-up actions.
r) Audits Report (including Audit Follow-up Record).
s) Records of Management Review.
7.2.3.3 Where are legislative and regulatory requirements for record keeping;
such requirements, including those relating to duration for the records to
be retained, shall be complied with.
7.2.3.4 The HSE Manager shall maintain, on behalf of BSSB’s Group Managing
Director/Chief Executive Officer, those records as required for corporate
purposes.
Procedure should be in place to ensure the integrity, accessibility and

control of records, including control of access to confidential records, as
required by the HSE Management System.
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7.2.4 Record
7.2.4.1 All records relating to BSSB’s HSE Management System shall be retained
for a period of not less than 7 years.
7.2.4.2 For records required by statutory requirement, the retaining period shall
be as required by the respective legislation.
7.3 NON-COMPLIANCE AND CORRECTIVE ACTIONS
7.3.1 Purpose
This subsection defines BSSB’s requirement relating to the management of

incidence of non-compliance to the requirements of BSSB’s HSE Management
System and the associated procedures.
7.3.2 Scope
The requirement relating to the management of incidence of non-compliance to

the requirement of BSSB’s HSE Management System and the associated
procedures shall apply equally for BSSB, as well as for Contractors engaged in
work for, or on behalf of BSSB.
7.3.3 Procedure
7.3.3.1 The MD/General Manager shall ensure that the relevant requirements of
BSSB’s HSE Management System and the associated procedures
complied with.
7.3.3.2 In the event of significant non-compliance to the HSEMS, the General

Manager/PIC shall initiate the necessary investigation, with a view to
establishing the causes of non-compliance and identification of
necessary corrective action; which may include, amongst others:
a) Restoring compliance as quickly as practicable.
b) Preventing recurrence.
c) Evaluating and mitigating any adverse HSE effects.
d) Ensuring satisfactory interaction with other components of the HSE

Management System, such as quality management
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e) Assessing the effectiveness of the above measures.
7.3.3.3 For incidence of non-compliance to statutory requirements, the

MD/General Manager shall initiate the necessary investigation and
corrective actions, and in consultation with the HSE Manager should:
a) Notify the relevant parties.
b) Determine the causation sequence and likely root cause.
c) Establish a plan of actions commiserating with the nature of the

non-compliance.
d) Apply controls to ensure that any preventive actions taken are

effective.
e) Revise procedures to incorporate actions to prevent recurrence,

communicate changes to relevant personnel and implement
them.
7.3.4 Record
Incidence of non-compliance to the HSE Management System as well as the

relevant statutory requirement shall be recorded, as stipulated in the HSE
Management System Section 5.3 – Records.
7.4 INCIDENT REPORTING AND FOLLOW-UP
7.4.1 Purpose
This subsection defines BSSB’s requirement relating to the investigation and

reporting of incidents, including near misses that arise out of and in the course of
BSSB’s activities.
7.4.2 Scope
7.4.2.1 All incidents, including near misses that arise out of and in the course of
BSSB activities, including Contractors activities shall be investigated and
reported in accordance with BSSB’s Incident Investigation and
Reporting Procedures.
7.4.2.2 The investigation and reporting of all incidents, including the

implementation of recommendations arising there from, is a line
responsibility.
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7.4.2.3 The purpose of incident investigation and reporting are, amongst others,
to ensure that:
a) All causes of the incident, both immediate and contributory

causes, are identified.
b) Lesson learnt from the incidents are identified and implemented,

with a view to prevent recurrence.
c) All relevant parties within BSSB, including senior and line

management, are promptly notified.
d) Legal issues relating to the incident, if any, are duly considered.
e) All relevant external parties including regulatory and other external

stakeholders, are duly informed.
7.4.3.4 Lesson – learnt from incidents shall be disseminated as widely as possible

throughout BSSB including, but not limited, during:
a) Daily tool box meeting.
b) Location, including office, safety meeting.
Additionally, where appropriate, the HSE Manager shall issue HSE Alert,
in particular where lesson – learnt from the incident has lateral
applications to others concerned.
7.4.4 Record
All incident investigation report shall be kept and retained, by the HSE
Department, for a period of 7 years.
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(AUDITING & MANAGEMENT)
Section 8
AUDITING AND MANAGEMENT
Contents
Paragraph Page
8.1 Internal HSEMS Audit 2
8.2 Independent HSEMS Audit 5
8.3 Other HSE Technical Audit and Review 7
8.4 Management Review 9

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8.1 INTERNAL HSEMS AUDIT
8.1.1 Purpose
This subsection defines BSSB’s requirement in respect of internal HSE Management

System auditing, to provide assurance to BSSB’s management that:
a) The HSE management conforms to BSSB’s HSE Management System.
b) The planning and implementation of activities are consistent with

achieving the intents and objectives of BSSB’s Policy on Health, Safety
and Environment, Strategic Objectives, Targets and Plans.
c) The level of understanding and implementation of the stipulated HSE

requirements and the extent to which they are adhered to is appropriate
and effective.
8.1.2 Scope
The minimum standard for an internal HSE Management System Audit shall be
BSSB’s HSE Management System.
The scope of an internal HSE Management System Audit of the operations shall
cover the whole operations, as follows:
a) All Area of Operations.
b) All relevant Support Departments.
c) Any other relevant support function (including contractors) that is integral

to the overall business process of the operations.
8.1.3 Procedure (Directive)
The MD/General Manager is responsible in ensuring that the operations shall be

subject to an Internal HSE Management System Audit once a year.
The internal HSE Management System Audit Team shall compromise, as a minimum,
the following:
1) Audit Team Leader
General/Operation Manager
2) Audit Team Members
The Audit Team shall compromise the following members:

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a) HSE Manager or representative.
b) Representative from Operations Department.
c) Representatives from Technical Services Department.
d) Representatives from other specialist departments as necessary.
The audit Terms and Reference shall include, amongst other, the
recruitment to verify:
a) Conformance to the HSE Management System.
b) Implementation of HSE Policy, agreed objectives plans and targets.
c) Compliance with legislation.
d) Identification of areas for improvement.
The audit methodology shall include:
a) Review of documentation.
b) Interview with selected personnel.
c) Observation of work practices and site inspections.
The implementation of the agreed audit recommendations shall be

monitored by the respective HSE committee, until completion.
8.1.4 Special Requirement
BSSB’s Contract Holders should also carry out Contractor HSE Management System
Audit, to assess the effectiveness of the contractor’s HSE Management System, and
where such a system does not exist, to audit the totality of those procedures and
practices used by the contractors to manage HSE.
Contractor HSE Management System, Audit should be initiated at specific timing

during the contract phase; these are as follows:
 Contractors Pre-Mobilization Audit.

 Contractors Mobilization Audit.
 Contractors Work Execution.
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Additionally, BSSB’s Contract Holders should also endeavor to endeavor to
encourage contractors working for and on behalf to BSSB’s to adopt similar internal
auditing program for their organization.
8.1.5 Records
Following each internal HSE Management System Audit, a written report shall be
prepared. The report shall present all findings and recommendations arising from
the audit, including an assessment of conformance to the HSE Management
System.
All reports arising from internal HSE Management System Audit shall be retained,
by the custodian, for a period of 7 years.
8.2 INDEPENDENT HSEMS AUDIT
8.2.1 Purpose
This subsection defines BSSB’s requirement in respect of independent HSE

Management System auditing, to provide independent assessment to BSSB’s senior
management that:
a) The HSE policy, organization and arrangements that are in place are
adequate and conducive to the underlying objective of achieving
continual HSE improvement; the HSE Management System is working as
intended throughout BSSB and that the required business controls
framework is appropriate and effective.
b) The level of understanding and implementation of the intents and

objectives of the HSE Management System and the extent to which they
are adhered to in is consistent, appropriate and effective.
8.2.2 Scope
The main consideration in deciding the scope for an independent HSE

Management System Audit is to sample the broad spectrum of BSSB’s operations;
and in particular, to verify the integrity of interfaces between offshore, supply base
with BSSB’s Office in Kuala Lumpur.
As a general guideline, the scope of an independent HSE Management System

Audit shall thus cover, as far as possible, the entire department within the
organization.
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BSSB’s HSE Manager in Kuala Lumpur is responsible in ensuring that the Company
shall be subject to an independent HSE Management System Audit once in every
5 years.
The independent HSEMS auditing program shall be drawn up, as part of BSSB’s 5 –
Years Business Plan, by the HSE Manager, after consultation with the MD/General
Manager and approved by the BSSB Management HSE Committee (BSHSEC).
The audit Terms of Reference shall include, amongst others, the requirement to
verify: consistency of implementation of the HSE Management System across BSSB;
and opportunities for continual improvement across all the business ventures:
a) Review of documentations.
c) Observations of work practices and site inspections.
All recommendations from independent HSEMS audits shall be monitored by BSSB’s

Management HSE Committee (BSHSEC), until completion or resolved by the
Superintendents.
On completion of an independent HSEMS audit, the Audit Team Leader shall

prepare a draft report, and shall verify the accuracy of such report with the
respective Superintendents and PIC, prior to the preparation of the final report for
BSSB’s HSE Committee (BSHSEC).
8.2.5 Record
All reports arising from independent HSE Management System Audit shall be
retained, by the custodian HSE Manager as well as the facility being audited, for a
period of 7 years.
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8.3 OTHER HSE TECHNICAL AUDIT REVIEW
8.3.1 Purpose
This subsection defines BSSB’s requirement for other HSE Technical Audit and/or
review, to provide assurance that the management of HSE and technical integrity
of facilities and/or specific activities is effective.
8.3.2 Scope
HSE Technical Audit and/or review are special focus audit, initiated to achieve a
specific objective, to be defined prior to the audit/review. As a general guideline,
the following are some of the HSE Technical Audit and/or review that shall be
carried out within BSSB’s operations:
Legal Compliance
a) HSE Legislation Compliance Audit
The BSSB’s MD/General Manager is responsible in ensuring that specific facilities

and/or activities shall be subject to a HSE Technical Audit and/or review, as and
when required.
The program for HSE Technical Audit and/or review shall be drawn up as part of
the 5-year Business Plan, by the BSSB and HSEC Committees.
An HSE Technical Audit and/or Review Team shall comprise members (Team
Leader and Audit Team Members); and may include expertise from within BSSB
and/or external consultants.
The Terms of Reference for a HSE Technical Audit and/or review shall be defined
by the facility/activity/project custodian, and agreed with the audit/review team.
a) Review of documentation.
c) Observations of work practices and site inspections.
8.3.3.1 All recommendations arising from HSE Technical Audit and/or Review
shall be monitored by BSHSEC and SHSE Committees until completion.
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8.3.4 Record
All reports arising from HSE Technical Audit and/or review shall be retained by the
custodian (HSE Manager), for a period of 7 years.
8.4 MANAGEMENT REVIEW
8.4.1 Purpose
This subsection defines BSSB’s requirement for management review to be

undertaken, at BSSB’s as at Facility’s level to:
a) Assess the extent of implementation of BSSB’s HSE Management System.
b) Assess the adequacy of the associated HSE policy, organization,

arrangements and associated procedure and guidelines.
c) Identify gaps and weaknesses in order that appropriate remedial actions

can be taken, with a view to ensure the achievement and sustenance of
continual improvement to BSSB’s HSE performance.
8.4.3.1 BSSB’s Management Review
The BSSB’s Management Review shall be carried out, at least once in 6

months, by BSSB’s Committee (BSHSEC).
The review should include, but not limited to, the following:
a) Assessment of the overall effectiveness of implementation of the

HSE Management System within BSSB.
b) Review the adequacy of each component element of the HSE

Management System, in line with industry and statutory standards.
c) Generally, addresses the HSE policy, organization and

arrangements necessary to achieve continual improvement of
BSSB’s HSE Performance.
The HSE Management System and the associated policy, organization

and arrangements shall be reviewed against:
a) Legislation (new and proposed).

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b) Advances in science and technology.
c) Client’s requirements and/or expectations.
d) Lessons learnt from past incidents.
e) Audit report findings/non-conformances.
f) Organizational aspects and culture.
g) Key HSE performance indicators.
h) Any changes in activities or new business ventures.
8.4.3.2 Site/Facility’s Management Review
The Facility’s Management Review shall be carried out, once a quarter,

by the respective Site’s HSE Committee.
The review should include, but not limited to, the following:
a) Assessment of Facility’s HSE performance in accordance with the

HSE targets set out in the respective Division’s HSE Plan.
b) Assessment of the overall effectiveness of implementation of the

HSE Management System within the facility.
Additionally, management review should also be carried out for,

amongst others, the following:
a) HSE Case Implementation and follow-up.
b) HSE Plan implementation and follow-up.
c) Incidents follow-up.
d) Non-compliance and corrective actions.
Findings and recommendations arising from the Site/Facility’s

Management Review shall be incorporated in the Division’s HSE Plan, with
a view to achieve continual improvement in HSE performance.
Additionally, findings and recommendations from the Site/Facility’s

Management Review should be presented to BSSB HSE Committee
(BSHSEC).
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The HSE Management Review shall be an integral part of the 5-year Business Plan
for BSSB.
8.4.5 Record
The findings and recommendations arising from both the BSSB and Facility
Management Review shall be recorded, and used to set future year’s HSE
Strategies and initiatives.

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DOC: BSSB-MAN-HSE

This document contains proprietary information belonging to BERMUDA SUBSEA (M)

The purpose of the HSE Management System is to ensure that:

Unless otherwise specified, all requirements contains in this HSE Management

May - indicates a possible course of action;

Should - indicates a preferred course of action; and

Shall - indicates a mandatory course of action from

The HSE Management System Manual-seven (7) elements as follows:

Management System Elements

 Leadership and Commitment

The MD / General Manager, Operations Manager, Marine Superintendent, PC/Vessel

The progress of implementation of the remedial action shall be reviewed by BSSB’s

2. General HSE Standards

1. OCCUPATIONAL SAFETY AND HEALTH ACT (ACT 514) 1994:

2. THE PETROLEUM (SAFETY MEASURES) ACT, 1984

1. International Convention for SOLAS 1974 (and the PROTOCOL thereafter)

ABBREVIATIONS AND ACRONYMS

HSE Health, Safety and Environment

PIC Person In-Charge

DCMP Document Control and Management Procedure

BSSB Bermuda Subsea (M) Sdn Bhd

BSHSEC BSSB Management Health, Safety and Environment

MD / GM Managing Director / General Manager

Document No. Document Title

(OGP) Report International Association of Oil & Gas Producers

(OGP) Report Glossary of HSE Terms

(OGP) Report Quantitative Performance Measure of HSE

LEADERSHIP & COMMITMENT

The leadership and commitment for HSE, including a readiness to provide

2.1.3.1 Employees at all levels in BSSB shall demonstrate, including by personal

2.1.3.2 As a general guideline, the commitments expected from the various

i) Senior Management (MD and Director)

Senior Management personnel shall provide strong, visible

ii) Line Management (Superintendents, Offshore PIC and Supervisors)

Line Management personnel shall ensure that full account is taken

iii) All Employees and Contractors

Employees of BSSB as well as Contractors shall actively contribute to

i) Believe in the Company’s aspiration to improve HSE performance.

ii) Provide motivation to improve personal HSE performance.

iii) Putting HSE matters, including HSE performance data, on the

iv) Allocating the necessary resources, such as time, manpower and

v) Demonstrate acceptance of individual responsibility and

vi) Communicating the importance of HSE considerations in business

vii) Developing on open approach to external liaison with authorities

viii) Encourage participation and involvement at all levels in the

ix) Demonstrate commitment to an effective HSE Management

2.1.3.4 Demonstration of commitment to the HSE Management System from

i) Setting a personal example in the day-to-day work.

iii) Communicating with Contractors, including Sub-Contractors, on

v) Recognition of performance when objectives are achieved.

vii) Conduct site visits.

2.1.3.5 Demonstration of leadership and commitment to the HSE Management

i) Attending, including chairing, HSE meetings.

ii) Reporting HSE incidents including receiving and acting on HSE

iii) Promoting HSE topics in meetings.

iv) Participating in HSE audits and inspections.

v) Participating in formulation of plans for achieving HSE objectives.

vi) Participating in the execution of HSE plans.

vii) Holding and participating in HSE review and analysis sessions.

viii) Participating in incident investigation.

ix) Participating in HSE initiatives.

x) Providing constructive feedback on HSE matters.

xii) Co-operate with management in the discharge of any duty or