Professional Documents
Culture Documents
HSE99-CR-IN-RR-005-00
HSE Risk Register - 2021
INDEX
1 INTRODUCTION ....................................................................................................................................................... 4
1.1 Principles ................................................................................................................................................................... 4
1.2 Scope......................................................................................................................................................................... 5
1.3 External and internal context ................................................................................................................................... 5
2 MAIN REVISIONS IN RISK REGISTER 2021 ................................................................................................................. 6
3 APPENDIX A; ENI PAKISTAN HSE RISK REGISTER 2021 .............................................................................................. 7
HSE99-CR-IN-RR-005-00
1 INTRODUCTION
1.1 Principles
The purpose of risk management is the creation and protection of value. It improves performance, encourages
innovation and supports the achievement of objectives.
The principles provide guidance on the characteristics of effective and efficient risk management, communicating its
value and explaining its intention and purpose. These principles are the foundation for managing risk and are given
below;
a) Integrated
A structured and comprehensive approach is adopted for risk management that contributes to consistent and
comparable results.
c) Customized
The risk management framework and process are customized and are made proportionate to the organization’s external
and internal context related to its objectives.
d) Inclusive
Appropriate and timely involvement of stakeholders enabled their knowledge, views and perceptions to be considered.
This will result in improved awareness and informed risk management.
e) Dynamic
Risks can emerge, change or disappear as an organization’s external and internal context changes. Risk management
can anticipate, detect, acknowledge and respond to those changes and events in an appropriate and timely manner.
The inputs to risk management are based on historical and current information, as well as on future expectations. Risk
management explicitly takes into account any limitations and uncertainties associated with such information and
expectations. Information is made timely, clear and available to relevant stakeholders.
Human behavior and culture significantly influence all aspects of risk management at each level and stage.
h) Continual improvement
HSE99-CR-IN-RR-005-00
1.2 Scope
Eni Pakistan Limited, a business unit of Eni Upstream, is successfully involved in exploration and production of gas in
Pakistan since many years and conducts following activities in its operated fields:
Drilling (onshore)
Gas Production & Processing
Development projects related to engineering & construction of gas processing plants and wellheads.
Apart from the operated fields, the Company is also non-operated partner in some other gas production fields in the
country.
Eni Pakistan has developed an HSE Integrated Management System (IMS) to manage all pertinent aspects of business
in line with its HSE Policy, ISO 14001, ISO 45001, & ISO 39001 Standards, ISO 31000 Guidelines and HSE Management
System Guidelines issued by its HQ.
To ensure the continuity of all areas of Company business, HSE Risks are assessed and managed on continuous basis. A
comprehensive exercise is carried out on annual basis for review of Eni Pakistan HSE Risk Register and its outcome is
shared with Eni HQ.
the social, cultural, political, legal, regulatory, financial, technological, economic, health and environmental factors,
whether international, national, regional or local;
key drivers and trends affecting the objectives of the organization;
external stakeholders’ relationships, perceptions, values, needs and expectations;
contractual relationships and commitments;
the complexity of networks and dependencies.
The internal context is;
HSE99-CR-IN-RR-005-00
Residual Risk @
Hazard Category Risk New Measures to be Implemented
30/06/2022
1.1.3 Terrorist Activity 1. Installation of High Density searchlights on Pak Rangers,
/Sabotage/ Bunkering Police & Eni patrolling Vehicles.
B1 (CI) B1 (CI)
2. Provision of additional Ground Metal Detectors to
patrolling vehicles.
2.2.2 Surface
contamination
1. E&P activities. Skimming, collection, transportation and disposal of
2. Spillages during produced water / oily emulsion from evaporation ponds of
B2 (CI) Bhit plant & wellheads to be included in scope of work of B2 (CI)
diesel / condensate
haulage activity. new waste management contract.
Risk rating of following hazard categories has been revised after performing risk re-evaluation exercise considering the
existing controls, HSE Statistics and current operational conditions.
Risk Risk
2020 2021
Hazard Category
Inherent Risk Residual Risk Inherent Risk Residual Risk
2.1.1 Continuous
discharges to air (air
quality C2 (RRM) C1 (CI) C1 (CI) C1 (CI)
requirements)
HSE99-CR-IN-RR-005-00
2.4.1 Continuous
discharge to water
(legislative B2 (CI) B2 (CI)
C2 (RRM) B2 (CI)
requirements,
drainage systems,
oil/water separation)
2,8 Other (HSE Legal
Compliances,
D2 (RRM) B2(CI) C1(CI) C1(CI)
Noise)
HSE99-CR-IN-RR-005-00
1,1 Communities
& Security OC2.1. Hazard & Risk Management
1. Security manpowerfor static posts, escorting , patrolling and deployment at bunkers constructed for unforeseen incidents continues.
1.1.3 Terrorist Activity /Sabotage/ 2. Additional active support of Police in terms of manpower and police mobiles
Bunkering 3. Security policy implemented and security induction (security awarenss / clean desk policy) given to all staff
1. Prolonged confinement / detention during 4. Gate pass and access control
extended road blocks 5. A separate system software "e-page" is in place for effective reporting & Management of Security incidents.
2. Harassment through aerial / direct firing 6. Reporting and liaison with CPLC, Police is implemented as presence of police personnel (24/7) at field locations, visits of agencies’
3. Extortion representatives and meeting with head of Law Enforcement Agencies.
4. Theft cases within company premises Security Manager 31-Dec-21
7. Risk Assessments are carried out as per the expected contingencies and their actions are followed up.
5. Sabotage 9. Security Management Plan for Fields in place. 1. Installation of High Density searchlights on Pak Rangers, Police & Eni Patroling Vehicles.
6. Activity Interruption 10. Prior approval and armed escort is must for all road movements outside the concession area. B 1 CI B 1 CI
People P
7. Kidnapping P 11. Survey of Routes leading to field locations carried out on annual basis or as per situation demand. - ✓ ✓
2. Provision of additional Ground Metal Detectors to patroling vehicles.
8. Scuffle 12. Annual firing practice for security guards at all locations in place.
9. Threatening calls to employees 13. Proactive liaison with agencies to remain abreast with situational developments.
10. Increased theft vulnerability due to 14. Increased police and rangers presence & patrolling in the area.
considerable security manpower reduction 15. Contingency Rehearsals.
11. Plantation of spikes/Nails on access 16. Deployment of Pak Rangers Troops and establishment of Ranger's Static Security Posts at Bhit Gas Plant.
roads & Choke points by the culpirts. 17. Increased Rangers and Police patroling in vulnerable areas.
18. Due to reduction in security manpower amid COVID-19, effecting monitoring and patrolling is ensured for all below unmanned locations in order
to avoid /avert the risk of possible theft/intrusion by the opportunist outlaws :
Wellheads (Bhit 9, 15, 2, & Badhra 6) , Traffic Posts Badhra 1 & 2.
19. Security surveilence & Monitoring system on 24/7 hours basis.
20. Provision of a Ground Metal Detector in order to search hidden spikes and nails planted by culpirts on access roads.
2. Environment
HC1. Equipment
Environment P 1. Closed drainage system in place - ✓ ✓
2. Effective monitoring through Monitoring Wells to ensure the ground water quality remains unchanged due to produced water injection.
2.3.1 Pollution from operational wastes OC1.1. Activity / Product / Service information (process, design, changes, risk data, well monitoring, drawings
1. Minimum Hazardous waste generation by ensuring smooth operations and following best industry practices. B 2 CI B 2 CI
2. Effective waste segregation (Hazardous & Non Hazardous) through contracted service.
3. Waste pits management assessment for onshore operations is carried out & recommendations in place.
4. Waste disposal through 3rd party waste management contractors. ✓ ✓ ✓
Environment P
5. Periodic inspection plan for Produced Water injection pipe line developed & implemented.
6. Procedure " Waste Management " for onshore operations in place.
7. Drill cuttings stored in lined pits at all locations.
8. Used oil handed over to SEPA authorised / approved contractor for proper disposal
3.1.5 Risk from layout (lack of HC1.1. Item or assembly layout / route
1. Well designed layout with emergency escape routes marked.
containment, module proximity,
2. Exit sign boards displayed prominently. - ✓ ✓ A 3 CI
unfavourable wind directions, wrong People P A 3 CI
3. Mustering area allocated at safe distances.
escape routes and mustering)
4. Safe distances maintained on the basis of Bhit BART Review findings.
5. Wind socks provided with clear visibility from all directions / distance.
HC3.2. Emergency well isolation system (BOP, SSSV) different from process / equipment control system
- ✓ ✓ Well Ops. Manager / Production
Asset R 1. Sub-surface Safety Valves provided on all wells (except 4 wells at Bhit (Low Pressure Compressor Assisted wells). P Thorough risk assessment should be performed to re-evaluate the need of SSSVs considering the current pressure regime of wells. 30-Sep-21
Manager
2. Blowout preventors (BOP) are used while drilling.
HC3.2. Emergency well isolation system (BOP, SSSV) different from process / equipment control system ✓ ✓ ✓ A 3 CI
Asset P A 3 CI
3.1.7 Risk of inhibits/overrides of 1. Well locations are provided with local & remote shut down facilities for safety.
safety critical elements
OC1.4. Start-up, shut-down, operating procedures (e.g. Permit-to-Work System) - ✓ ✓ A 3 CI
Asset P A 3 CI
1. PTW (Safety Defeat Certificate)
HC1.5. Risk monitoring (EG: black box, IVMS, flight follow, navaids) - ✓ ✓ ✓
People P
1. Annual calibration of navigational instruments is carried out by CAA.
HC1.5. Risk monitoring (EG: black box, IVMS, flight follow, navaids)
People P 1. Vehicle Tracking System on all the contractors'condensate transportation vehicles in place. - ✓ ✓ ✓
2. Only authorized vehicles are used as personnel carrier.
OC1.5. Procedures for non-routine / repetitive tasks (critical or driven by experienced errors or incidents)
1. HSE Risk Assessments (i.e. JSA, Environmental RAs etc.) are carried out. ✓ ✓ ✓ ✓
People P
3.2.6 Risk of substandard Contractors/ 2. Vehicle tracking data transmission/sharing with all contractor's for remedies.
Subcontractors (contractual clauses 3. Contractors' vehicles IVMS data is being monitored by Eni Pakistan.
and conditions, training and B 2 CI
B 2 CI
3,2 Operations competency)
Safety OC1.8. Contract HSE Requirements
Poor HSE System / equipment / vehicles 1. HSE guidelines are part of contracts
People P 2. 3rd party vehicles & equipment certification protocol in place. ✓ ✓ ✓ ✓
3. Contractor HSE Management procedure in place.
4. Pact for Safety project launched for two contractors.
OC5.1. Line manager Leadership, Commitment and Accountability to recognise / remove the hazard ✓ ✓ ✓ ✓
3.2.6 Risk of substandard Contractors/ People P
1. HSE Golden Rules and Management Site visits using e-GRUVIS checklists implemented.
Subcontractors (contractual clauses
and conditions, training and A 1 CI A 1 CI
competency)
Inadequate performance
Residual Risk @
In case there is no evidence of control in place - Reactive Method (see attached Risk Screening
Controls/Barriers in Place Reliability of Control in Place - Predictive Method (see attached Risk Screening Matrix - Table 1)
Matrix - Table 2)
Current Risk Figures Measures to be Implemented 30/06/2022
Responsibility Assigned for
Deadline for Close-out
Risk Area Hazard Category Impact Has the event already Has the event already Has the event already Has the event already Measure Implementation
(dd/mm/yyyy)
Opportunities
Is the control independent from (i.e.: Does 3 years accident Is this control covered by (indicate Dept.)
Is this control subject to occurred at least once occurred several times occurred several times occurred several times
Preventive doesn't rely on) previous one/ones (if records show failure of this technical Preventive /
/ Recovery
Description yes tick the box, otherwise jump to control has been a specifications/dedicated
periodical maintenance or in the last 10 years in in the last 10 years in a year in the Company? a year in one facility? Frequency Severity Risk
Recovery
Description Frequency Severity Risk
3.2.6 Risk of substandard Contractors/ periodical review/audit? the Company? the Company? Probability = D Probability = E
the next question) contributor to an event? work instruction?
Subcontractors (contractual clauses Probability = B Probability = C
and conditions, training and OC5.2. Contractor Leadership, Commitment and Accountability to recognise / remove the hazard A 1 CI A 1 CI
competency) 1. Contractors' Senior Management HSE workshops conducted on bi-annual basis.
Inadequate performance 2. Regular HSE Communication meetings are conducted with Contractors.
People P 3. Implementation of HSE pledge by contractors' senior management. ✓ ✓ ✓ ✓
4. Pilot project "Pact for Safety program" implemented on selected Contractors for improvement of HSE culture.
5. Safety Competence Assessment of Contractaor personnel is followed
OC6.1. Minimum level of staff (Company and Contractor) experience at all staff changes (turn over, shift, etc.) ✓ ✓ ✓ ✓
People P
1. Documented Job Descriptions available and communicated for each position with specific & clearly defined HSE responsibilities.
1. Local Call points to be provided at main / exit points on 06 standalone booster compressors at Bhit.
HC4.1. Active emergency equipment (firefighting, anti-pollution, standing-by emergency devices)
3.3.1 Lack of emergency preparedness 2. Pending works on Camp-2 dedicated fire water system to be completed.
1. Fire & gas detection and alarm system in place at Bhit plant and wellhead compression facilities
(firefighting, spill clean-up, security
2. Fire suppression system (Fire Ring, Fire Hydrants, Fire Water Oscillating Monitors) in place.
support, evacuation) 3. Stand alone smoke detector units to be installed rather connect them to the main DCS unit for centerralization
3. First Aid Boxes and Potable fire extinguishers available. ✓ ✓ ✓
1. Inadequate Emergency response People P P E&C Coordinator 30-Jun-22
4. H2S detectors installed at sites.
Preparedness.
5. BA Sets available at processing plants / drilling sites.
2. H2S release during drilling operations &
6. Fire Tender available at Bhit Plant.
incompetence in handling
7. Fire Alarrm, Fire extinguishers, smoke deductors & Fire Hydrants installed at appropriate location of Karachi Office
3,3 Emergency B 2 CI
OC4.1. Emergency Response Plan (e.g. Safety, spill, health) B 3 RRM
Response
1. Eni Pakistan ER Strategy and ERP Procedure in place for Karachi office, onshore and offshore activities.
2. Procedure for Emergency Response Training in place. ✓ ✓ ✓
People P
3. ER Team and support Teams established and their Roles and responsibilities are defined in ERP.
4. Emergency drills are carried out at head office and field locations on routine basis.
5. Fire Risk Assessment of warehouse/yard facilities at Karachi is carried out.
3.3.2 Lack of communication for
emergency planning OC4.2. Scenario-based Contingency Plans
1. Well blowout contingency plan in place. ✓ ✓ ✓
People P
2. MERP in Place.
3. Oil spill contingency plans in place.
3.1.5 Risk from layout (lack of OC2.1. Hazard & Risk Management
People P - ✓ ✓ A 2 CI A 2 CI
containment, module proximity, 1. Camps / facilities located at reasonable distance from local dwellings/villages.
unfavourable wind directions, wrong
escape routes and mustering)
Loss of life / Injuries
3,5 Other OC1. Safe Systems of Work
(Public Safety) 1. Implementation of all applicable national laws and regulations
3.2.2 Land transportation and 2. Vehicle Speed Monitoring & tracking system in place
communication risk 3. Night time driving not allowed unless authorized specifically
Vehicular accidents while passing 4. Water sprinkling to minimize dust spreading near settlements
through/near community dwellings / People P 5. Regular trainings and awarness sessions for Eni & Contractor drivers on defensive driving. ✓ ✓ ✓ A 3 CI A 3 CI
villages and Condensate/diesel spill / fire or 6. Drivers incentive program in place.
Soil/water contamination during 7. Eni Pakistan Driving Policy in place.
transportation. 8. Due diligence for condensate and diesel transport carried out.
9. Oil Spill Contingency Plan in place.
Health
1. Medical Evacuation procedure available and implemented. Regular drills ongoing to check the emergency response.
4,2 Medical 2. Contingency procedure for Monsoon Medivac services in place.
4.2.2 Medical emergency response R ✓ ✓ ✓
Emergency 3. Pre and post maternity benefits available for female employees.
capabilities (EG: major incidents)
1. Inadequate Medical Emergency 4 .Disability/personal accidental coverage
Response People 5. Accidental Death coverage by Group Life Insurance B 3 RRM B 3 RRM
2. Vulnerable workers (Pregnant Women) 6. Revised / Updated MERP is in place for Covid-19 preparedness / drills carried out.
3. Accidental and Death coverage
OC2.1. Hazard & Risk Management
1. Multicasualty/Triage procedure for Bhit & Badhra gas field.
2. Guidelines for contractors medical facilities built in contract document through OH&MS guidelines.
3. Risk based Fitness to Work for ERT members.
4. Implementation of Emergency drills plan for Medical emergencies to test the emergency response procedures (MERP)
P 5. All the the contractor staff is bound to provide one week follow up for COVID 19 symtoms and fill a travel history form prior to come to the field. ✓ ✓ ✓
6. Regular Medivac drills for Covid-19 patient handling and transportation from Bhit field carried out.