NEOM OCCUPATIONAL SAFETY AND HEALTH

GOVERNANCE FRAMEWORK

PROJECTS STANDARD OPERATING PROCEDURE

ADMINISTRATION

NEOM-NPR-SOP-001 Rev 02.00, December 2020

Document history

Description of
Revision code Purpose of issue Date
changes

01.00 First Issue Issued for Implementation 20.07.2020

Second Revision – Inclusion of Construction

02.00 16.12.2020
Issue Requirements

Document approval

Prepared by Approved by

Name Robert Burns Osama Wahba

Job Title Senior Safety Manager - Director – Technical Services

ESCD

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Contents

Contents ........................................................................................................................................... 3
1. Introduction ............................................................................................................................... 4
2. Roles and Responsibilities ........................................................................................................ 4
2.1 NEOM-Loss Prevention and Fire Safety ............................................................................. 4
2.2 Sector Regulator ................................................................................................................ 5
2.3 Sector Regulator OSH Resource........................................................................................ 5
2.4 SR OSH Management System ........................................................................................... 6
2.5 Sector Emergency Management plans ............................................................................... 7
3. Sector Regulator Identification and Appointment ...................................................................... 7
3.1 General requirements......................................................................................................... 7
3.2 Sector Assessment Process ............................................................................................... 7
3.3 Appointment of a Sector Regulator ..................................................................................... 8
4. SR Performance Management .................................................................................................. 8
4.1 SR Annual Action Plans ..................................................................................................... 9
4.2 SR Performance Monitoring and Reporting ........................................................................ 9
5. Performance Monitoring of SR’s ..............................................................................................10
5.1 Withdrawal of Appointment ................................................................................................10

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 1. Introduction
This Standard Operating Procedure outlines all requirements related to the administration of the NEOM
Projects Occupational Safety and Health Governance Framework (NEOM-NPR-GFR), designed to comply
with the NEO OSH Governance Framework, including:

• The Roles and Responsibilities of NEOM-LP&FS and the Sector Regulators (SRs);

• Identification and Appointment of Sector Regulators; and

• Ongoing performance Management of Sector Regulators.

This SOP has been designed to ensure a fair, transparent and consistent implementation of the NEOM
Projects Governance Framework.

2. Roles and Responsibilities

(a) The following section describes the key roles and responsibilities of NEOM-LP&FS and the SR’s for the
administration and implementation of the NEOM-OSH-GF.

(b) Roles and Responsibilities for sector organisations are held within NEOM-OSH-GF – MSU 1 – Roles and
Responsibilities.

2.1 NEOM-Loss Prevention and Fire Safety

(a) Responsibilities of NEOM-LP&FS include, but are not limited to the following:

(i) Developing, implementing and updating the NEOM-OSH-GF and overseeing all issues relevant to
occupational safety and health including:
1. Ensuring the integration of NEOM-OSH-GF requirements with the requirements of concerned
authorities;
2. Developing plans to update the system (NEOM-OSH-GF) at NEOM level;
3. Coordination and cooperation with concerned authorities on all issues relevant to the system
(NEOM-OSH-GF);
4. Reviewing and approval of OSHMS of organisations as required in accordance with NEOM-
OSH-GF implementation requirements;
5. Monitoring the administration and implementation of the system through the appointment
of SR’s; and
6. Monitoring the performance of SR’s through means such as inspection, auditing and
performance reporting.

(ii) Establishing and maintaining an OSH database and a unified electronic system at NEOM level for
implementation by all concerned authorities and organisations;
(iii) Setting and implementing a system for assessing, registering and monitoring OSH practitioners
and professional organisations in coordination with relevant Authorities;

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 (iv) Setting, in coordination with relevant authorities, training and competency programs specific to
NEOM-OSH-GF in order to provide training on the system for OSH practitioners and other
stakeholders;
(v) Developing and implementing OSHMS awareness programs;
(vi) Developing an incentive program to promote and encourage system implementation;
(vii) Finalizing contracts and agreements related to the system;
(viii) Developing strategic partnerships with local, NEOM, regional and international parties;
(ix) Conducting relevant OSH surveys and collecting information on OSH issues in coordination with
the concerned authorities;
(x) Submitting periodic reports on OSHMS performance at NEOM level; and
(xi) Providing information and official publications on OSHMS to stakeholders.
(b) NEOM-LP&FS can delegate relevant powers for regulating a concerned sector. NEOM-LP&FS can also
revoke the delegation given to a concerned SR for supervising a sector.

2.2 Sector Regulator

(a) By recommendation from NEOM-LP&FS and appointment from NEOM, the Sector Regulator shall
supervise the implementation of the NEOM-OSH-GF in its concerned Sector and is specifically
responsible for the following:

(i) Identifying, nominating and registering organisations that shall develop and implement an
OSHMS in full compliance with the NEOM-OSH-GF;
(ii) Reviewing and approving the OSHMS developed by nominated organisations in compliance with
the requirements of the NEOM-OSH-GF;
(iii) Monitoring the implementation of the NEOM-OSH-GF through means such as periodical
inspection and auditing of sector organisations, to include as a minimum:
1. High Risk Organisations: one SR audit every three years;
(iv) Monitoring OSH Internal incident investigations conducted by their sector organisations as per
the requirements of NEOM-OSH-GF – SOP 2.0 – Incident Notification, Investigation and Reporting;
(v) Undertaking OSH incident investigations as directed or required by NEOM-LP&FS and as per the
requirements of NEOM-OSH-GF – SOP 2.0 - Incident Notification, Investigation and Reporting;
(vi) Reporting to NEOM-LP&FS on the performance of the OSH MS at Sector level as per NEOM-OSH-
GF – SOP 6.0 – OSH Performance Monitoring and Reporting; and

(vii) Encouraging sector organisations to participate in OSH related activities / campaigns.

2.3 Sector Regulator OSH Resource

(a) The top management of the SR’s shall ensure appropriate resources (human, financial, equipment, etc.)
to fully implement the roles, responsibilities and activities as outlined in:

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 (i) NEOM-OSH-GF – MSU 1 – Roles, Responsibilities;
(ii) NEOM-OSH-GF Mandatory Requirements (SOP’s, Standards and Guideline Values); and
(iii) Other roles, responsibilities and activities as approved by NEOM-LP&FS.
Note: as per Section 3.3(b), NEOM-LP&FS may grant limited specific SR powers.

(b) OSH SR’s shall ensure appropriate competent OSH resources are maintained to successfully implement
and monitor the NEOM-OSH-GF within their concerned Sector.

(c) Concerned SR’s shall provide support, training and other capacity building activities to develop and
maintain OSH personnel with the appropriate competency.

(d) The number of OSH personnel required by each concerned SR is dependent on several factors, which
include, but are not limited to:

(i) Number of organisations operating in and intended to be nominated or notified to comply with
the requirements of the NEOM-OSH-GF;
(ii) Complexity / nature and frequency of operations and activities undertaken; and
(iii) Level of OSH capacity and development in the sector.

(e) At a minimum all OSH SR’s shall each maintain 1 full-time dedicated OSH person that are registered
with NEOM-LP&FS as per NEOM-OSH-GF – SOP 7.0 – Organisation, OSH Practitioner Registration and
Appointment of Principle Contractor

(f) The senior manager in charge of the SR role shall report directly to a member of top management within
the organisation.

(g) A manager / team leader / section head shall be registered with NEOM-LP&FS as a Grade A Generalist,
as per the requirements of NEOM-OSH-GF – SOP 7.0 – Organisation, OSH Practitioner Registration and
Appointment of Principle Contractor, and the team shall include at least one person, additional to the
manager / team leader / section head, who holds an internationally recognized OSH Lead Auditor
qualification.

(h) SR’s shall ensure that staff utilized to undertake audits on behalf of the SR are competent and hold an
internationally recognized audit qualification.

(i) All audits undertaken by a SR shall be led by a member of staff holding an internationally recognized
Lead auditor qualification.

2.4 SR OSH Management System

(a) Upon appointment as a SR, the identified organisation shall commit to upgrade their organisation
approved OSHMS to include those undertakings associated with the role of an SR as required by the
NEOM-OSH-GF.

(b) NEOM-LP&FS shall verify this through audit.

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 2.5 Sector Emergency Management plans

(a) Each SR shall develop, document, implement and maintain systematic procedures for the management
of foreseeable sector wide emergencies within their concerned sector.

(b) The Sector emergency plans shall comply with the requirements of NEOM and relevant standards issued
by the competent authorities.
3. Sector Regulator Identification and Appointment
3.1 General requirements

(a) As per NEOM-OSH-GF– MSU 1 – Roles and Responsibilities, NEOM-LP&FS, as the Component Authority
for OSH in NEOM and also for the NEOM-OSH-GF, has the authority to identify and recommend to
NEOM, the appointment of a private / government organisation to undertake the role of a Sector
Regulator (SR).

(b) In monitoring the implementation of the NEOM-OSH-GF, NEOM-LP&FS may identify certain additional
economic sectors within NEOM that require a Sector Regulator to oversee the implementation of the
NEOM-OSH-GF.

(c) This identification process shall include identification of the most suitable private / government
authority / organisation for NEOM-LP&FS to recommend appointment to take responsibility to perform
the duties of the Sector Regulator. (Examples of this could be Airports and Ports)

(d) An assessment of identified sectors shall be undertaken as per Section 3.2 of this document.

(e) NEOM-LP&FS shall provide NEOM a recommendation, based upon the findings of the sector
assessment process, for approval of the concerned sector and for the identified private / government
authority / organisation to be appointed as an OSH Sector Regulator (SR).

3.2 Sector Assessment Process

(a) NEOM-LP&FS shall officially communicate with an identified authority / organisation to notify them of
being recognized as a potential future OSH SR and to gain relevant information to assist in the
completion of this assessment.

(b) NEOM-LP&FS shall consider incorporating new sectors, where possible, to existing SR’s to minimize the
number of SR’s and where allowed by existing mandates / laws.

(c) The assessment shall include, but not limited to:

(i) Risk and hazard assessment of the Sector:

(ii) Number of organisations operating in the Sector (e.g. Operating licences);
(iii) Approximate number of employees working in the Sector;
(iv) Level of complexity / nature and frequency of operations and activities undertaken;
(v) Storage and/or utilization of hazardous materials;
(vi) Operations in or near sensitive locations;

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 (vii) Profile of the Sector (e.g. Public profile, media profile and coverage, etc.);
(viii) Interactions with existing OSH Sectors and SR’s;
(ix) Current level of OSH implementation and capacity; and
(x) Possible timeframes of implementation of the NEOM-OSH-GF in the concerned sector.
(d) The process shall also assess the identified authority / organisation in terms of, but not limited to:

(i) OSH authority(s) under Establishment Law(s) and other relevant laws, decrees, regulations;
(ii) Being fully / partially government owned;
(iii) Other government authorities that may have powers in the concerned sector;
(iv) Current resources levels (including inspections / licensing, etc.); and
(v) OSH budget requirements.

3.3 Appointment of a Sector Regulator

(a) If results of the assessment lead NEOM-LP&FS to believe that the sector and the identified private /
government authority / organisation are ready to begin implementation of the NEOM-OSH-GF, NEOM-
LP&FS shall recommend the same to NEOM for approval.

(b) NEOM-LP&FS may decide that the identified sector and/or potential SR shall undertake a phased
approach to the implementation of the NEOM-OSH-GF. NEOM-LP&FS may also delegate limited SR
powers to an appropriate authority / organisation to perform several specific NEOM-OSH-GF tasks and
activities (e.g. collating and submitting OSH Incident and Performance data of subsidiary organisations).

(c) The recommendation to NEOM shall include:

(i) Overview of the proposed sector, including:

1. Number of organisations operating;
2. Level of risk within the sector; and
3. Current OSH capacity within the sector.
(ii) Budget requirements;
(iii) Staff / resource requirements; and
(iv) Implementation plan within the proposed sector.
(d) If the recommendation is approved by NEOM, NEOM-LP&FS shall initiate official communication and
planning with the new SR (e.g. to agree timelines and implementation action plans) for the new sector.

4. SR Performance Management
(a) NEOM-LP&FS shall, on an annual basis, issue Annual Performance Targets for all SR’s to comply with.
Refer to table 1 below for timelines.

(b) The annual performance targets shall be issued by official communication from NEOM-LP&FS.

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 (c) Annual Performance Targets may be issued as general targets across all SR’s or as targets per individual
SR, based on the specific SR previous performance.

(d) Annual Performance Targets shall be decided based upon the following:

(i) NEOM-OSH-GF – SOPs;

(ii) Previous year’s performance;
(iii) Available resource(s);
(iv) Other SR performance;
(v) Feedback from SR’s;
(vi) Objectives of NEOM-LP&FS strategic plans; and
(vii) Requirements set by NEOM.

Timescale August September October November

Owner NEOM-LP&FS NEOM-LP&FS SR NEOM-LP&FS

Initial targets set for Targets communicated SR develops Action Action Plan for the
each year will be based to, and agreed with, plan based on targets next calendar year
Action on previous mid-year SR’s. and submits to NEOM- approved.
performance LP&FS.

Table 1: Action plan timelines

4.1 SR Annual Action Plans

(a) Each SR shall develop and document an annual action plan in compliance to the SR’s Annual
Performance Targets as defined in section 4 of this document.

(b) SR’s shall utilise the SR action plan template prescribed by NEOM-LP&FS.

(c) The annual action plan shall be reviewed internally by the SR and approved by its top management.

(d) Following internal approval, the annual action plan shall be sent to NEOM-LP&FS for formal approval
prior to implementation.

(e) NEOM-LP&FS shall officially notify the SR of approval or otherwise.

4.2 SR Performance Monitoring and Reporting

(a) Requirements of this section shall be in addition to sector performance requirements described within
NEOM-OSH-GF – SOP 6.0 – OSH Performance Monitoring and Reporting.

(b) Each SR shall report progress against each of the identified Annual Performance Targets quarterly.

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 (c) Where the SR is not meeting identified targets, this shall be communicated internally to its top
management for resolution.

(d) Quarterly and annual reports to NEOM-LP&FS shall include:

(i) Justification for current performance levels;

(ii) Corrective actions to rectify poor performance; and
(iii) Request to change / update performance target (if required).

5. Performance Monitoring of SR’s

(a) NEOM-LP&FS shall monitor the performance of SR’s for implementation of the NEOM-OSH-GF and its’
requirements through several means including but not limited to:

(i) Audits;
(ii) OSH Performance reports; and
(iii) Performance review meetings.
(b) Issues identified as a result of performance monitoring shall be officially communicated to the relevant
SR.

(c) Where SR’s are seen to consistently fail to meet annual action plan / performance requirements:

(i) NEOM-LP&FS shall invite the SR for a meeting to discuss performance and corrective action. The
meeting shall be documented and attended by a member of top management from the SR.
(ii) The meeting agenda shall cover:
1. Current status of the SR;
2. Issues leading to current performance; and
3. Corrective action plan.
(iii) The relevant SR shall develop a detailed action plan to rectify the performance issues within the
SR. The action plan shall be no longer than 3 calendar months and shall be incorporated into the
annual action plan described in section 4.1 of this document.
(iv) The SR shall update NEOM-LP&FS on the progress of implementation on a monthly basis through
formal meetings. The meeting shall be recorded.
(d) NEOM-LP&FS shall provide NEOM with an annual report on the overall performance of all SR’s,
including benchmarking of performance.

5.1 Withdrawal of Appointment

(a) As the competent authority for OSH and the NEOM-OSH-GF in NEOM, NEOM-LP&FS has the right to
recommend to NEOM withdrawal of appointment as an SR.

(b) Recommending withdrawal of appointment as an SR shall be based upon:

(i) Performance issues (as per section 5 of this document);

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 (ii) Changes in policies, laws, direction of NEOM; and
(iii) Change of NEOM-OSH Policy / Direction.
(c) Prior to recommending the withdrawal of appointment of the SR role, NEOM-LP&FS shall meet with the
SR to review and agree the following:

(i) Redeployment of SR OSH resources;

(ii) OSH Budgets;

(iii) Handover plan; and
(iv) On-going issues.
(d) NEOM-LP&FS’s recommendation of withdrawal to NEOM shall cover the issues identified in clause 5.1(c).

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 Reference List

Title Reference Section in

NEOM-OSH-GF – MSU 1 – Roles and Responsibilities. Various

NEOM-OSH-GF – SOP 2.0 – Incident Notification, Investigation and Reporting; 2.2

NEOM-NPR-SOP 06.0 – Performance Monitoring and Reporting. 2.2 – 4.2

NEOM-NPR-SOP 07.0–Organisation, OSH Practitioner Registration and Appointment

2.3
of Principal Contractor

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