Integrated HSE Management

Systems and Permit to Work System

INTRODUCTION:

•Petroleum industry, by its nature is a hazardous industry.

•Processing, handling , storage and transportation of large

volumes of hazardous petroleum products and processing
chemicals present inherent risks of fires, explosions, toxic
releases and environmental pollution if adequate precautions
are not taken during the design and operation of petroleum
installations.
The petroleum operations have been constantly developing,
upgrading and improving their design and operating techniques
in terms of economy of scale, high quality products and energy
optimization to meet the stiff market competition.

All this has increased the potential of major risks.

Major accidents like Bhopal , Mexico city ,Seveso , Flexiobro

and others in the last two decades or so have shaken the
confidence of general public about the safety of the people,
property and environment.

In fact, some companies have been closed down on account of

poor safety and environmental performance.
After these major disastrous government authorities, human
activist groups and corporate houses in many countries
including India have taken a number of steps to evolve a
strategy to avert major mishaps in the installations which have
the potential to cause loss of human life, property and
environmental damage.

No doubt, health, safety and environment issues are very

critical in the petroleum operations in the current scenario.
 NEED FOR HSE MANAGEMENT

• Regulations alone are not enough to maintain a very high level

of safety in petroleum and allied industries, which have many
inherent hazards.
• In order to prevent major accidents and mishaps and to win
confidence of general public - management,leadership and
commitment is very essential.
• Even for implementing and compliance of regulatory
measures, a committed leadership is necessary.
• This can be achieved by establishing an effective and efficient
Health, Safety and Environment (HSE) Management System.
HSE Management Profile

There are certain characteristics of an integrated HSE management

system that should be in place to ensure that the system functions
most efficiently and effectively.

These characteristics are sufficiently generic to apply to any type of

petroleum installation-whether an offshore or onshore oil/ gas
exploration and production facility, a refinery or a petrochemical
complex, bulk or retail marketing outlet, etc.

Not all characteristics or features may be needed in every

installation; however, these have particular value as a profile of the
principal requirements of an effective HSE management system that
can be adopted to suit the particular needs of the installation.
Some important features of an effective and efficient HSE
management system are discussed below.

HSE Policy
• Every organization must have a written policy on health, safety and
environment signed by the Head of the organization with date.

• The copies of this policy should be displayed at prominent places in

the organization so that everybody is familiar with its
contents/intentions.

• Some organizations ensure that every employee receives a copy of

its HSE policy.

• HSE policy spells out the values, beliefs and commitment of the
organization towards health, safety of its employees, community and
at the macro level of the nation.
What does ‘HSE POLICY’ Contain?

•Health and safety of personnel, and protection of environment

overrides all production targets in our organization.

• Production and HSE are complementary to each other. Safety

and environment protection is everybody’s business in the
organization.

• All statutory requirements must be complied with at all times.

•All personnel must use approved safe working procedures

without making any risky short cuts
• All personnel–own or contractors–must be given relevant
training before assigning them work

• All plants, facilities and work procedures/ systems must be

audited periodically by in-house teams as well as external
agencies

• Plant and ambient environment as well as various effluents

must be monitored continuously to maintain a clean and safe
environment in and around the plants

• A very high standard of house keeping must be maintained at

all places of work–plants, offices and facilities

• Every employee must be subjected to a pre-employment,

periodic and any specific medical check-up for early
identification and treatment of any occupational health hazard
• All employees must keep abreast with the latest codes,
standards and practices on health, safety and environment

• All accidents, however small, must be investigated and

followed up. The lessons learnt from these accidents should be
disseminated to all levels of workforce

• No modifications in plant, facilities or procedures will be

done without proper scrutiny and approval by an authorized
person(s)

• No contractor will be engaged without ascertaining his safety

performance/record

• Non-compliance of this policy will attract severe disciplinary

action
 HSE Organization

• In order for the HSE management of an organization to be

efficient and effective, it is important that the Chief of HSE
should report to the Head of the organization.

• HSE should be an advisory function reporting to the top

management and the various line managers should be directly
responsible for Health, Safety and Environment activities
pertaining to their respective departments.
• If HSE Chief occupies a junior position in the organizational
hierarchy, he cannot work without fear or clash of interest
with other functional managers.
• He should have authority and important say in the
decision making process.
• Even some regulatory agencies also recommend HSE Chief
reporting directly to the Head of the organization.

• HSE Chief should be a qualified engineer with long

experience in various functions.

• He should have a team of qualified professionals to advise

on safety, occupational health, fire protection and
environment.
• The number of professionals in HSE will depend on the size
and diversity of the organization, but it is recommended to
have a leaner set-up.

• HSE organization should be fully integrated with various

safety and health committees.
Custodianship/Ownership

Health, Safety and Environmental management is a teamwork.

Every member of the team contributes in maintaining a high level of

safety in his area of work.

In order to manage HSE effectively in a petroleum installation or

complex which is usually a large entity it is important and desirable
to demarcate each area of the installation/complex and assign the
ownership/custodianship to a senior member of the concerned area.
These areas are commonly called safety districts.

A big petroleum complex may have 10-15 safety districts.

These districts should be shown on the layout drawing of the complex

with all the boundaries clearly identified and marked.
The objective of safety districts is to decentralize the HSE
responsibility to the functional owner/ custodian of the area
who is fully responsible and accountable for all management
functions in his district with specific reference to
control/management of health, safety and environment.

HSE department acts as a catalyst.

Plans and procedures
• Plans and procedures is the heart of a good HSE management
system.
• They are the basis of setting up an effective and efficient
management system.
• A large number of industrial accidents and mishaps have
occurred all over the world due to human errors and the main
cause of these errors has been the lack of written procedures
and/or non- compliance of the same.
• In some cases, courts have penalized the organizations
because victims of the accident did not have written
procedures to be followed by them.
• It is essential that a well written and approved operating
procedures of all important activities are in place and the
same are strictly followed .
• The various HSE procedures should be developed broadly
based on process safety management (PSM), which is a well
known frame work of HSE management all over the world .
• All these procedures should be complied in the form of HSE
bible .
The various procedures documented should address the following
main elements of PSM:

•Process Technology Information

•Process Hazard Analysis
•Operating Procedures
•Work Permit System
•Management of Change
•Training and Validation
•Contractor Safety
•Incident Investigation and Communication
•Safety and Environment Auditing
• Quality Assurance
• Mechanical Integrity
• Pre Start-up Safety Reviews
• Emergency Planning and Response
• Following is a broad list of typical procedures on health ,
safety and fire protection and environment functions
applicable for most petroleum operations.
• The procedures relevant to particular installations should be
identified and documented clearly in simple language so that
everybody working in these installations understand them.
• Procedure should be easily accessible to all concerned
• Procedure should be revised and update periodically to reflect
changes that might take place over time
 Safety related procedure
Basic Safety Related procedure for Employees, Contractors and
Visitors-------
• Safe Work Permit System
• Mechanical Isolation
• Pre Start-up Safety Review
• Entering and Working in Confined Spaces
• Working at Height
• Safe Scaffolding and Ladders
• Safe Excavation
• Safe Handling of Hazardous Substances
• Safe Handling of Hydrogen Sulfide, Chlorine, Ammonia, etc.
• Safe Use of Hoses
• Contractor Safety
• Ionization Radiation Safety
• Traffic Safety Inside and Outside the Installation
• Safe Use of Cranes, Hoists and other Mechanical Devices
• Safety in Manual Handling of Material
• Accident /Incident Reporting and Investigation
• Selection and Safe Use of Personal Protective Equipment
(PPE)
• Safe Transportation of Hazardous Materials by Road, Water
and Rail
• Management of Plant Changes and Procedures
• Safety Audits
• Personnel Movement and Transportation by Road , Cranes,
Basket, Boats and Helicopters
• Grinding, Welding and Cutting
• Safety Signage’s, Labelling and Posters
• On-site Emergency and Disaster Management
 Environment Related Procedures

• Air Pollution Control and Monitoring

• Effluent Monitoring

• Industrial Wastes Management

• Biodegradable and Office Wastes Management

• Fugitive Emission Monitoring

• Ground Water Monitoring

• Environment Inspection and Audit

 Occupational Health Related Procedures

• Health Care System

• Medical Management of Obnoxious Substances

• Hygiene and Sanitation

• First-aid

• Health Risk Assessment

• Pre-employment and Regular Medical Checks

• Wellness and Fitness Programme for Employees and families

• Emergency Medical Care

•
 Basic safety rules

Because of inherent hazards in a petroleum installation, it is absolutely necessary that

all employees, contractors, visitors, vendors and other third parties must be fully
aware of some basic safety requirements to be followed inside the installation.
Management should document these basic rules/requirements and anybody entering
the premises must be made familiar with the same.

This document should address following items related to the health, safety and
environment aspects of the installation:
•Access/Entry to the premises
• Prohibition of smoking, alcohol and drugs
• Restriction on naked lights, sparks, use of cameras and mobile phones
• Traffic control
• Use of Personnel Protective Equipment, PPE
• Safe Work Permit System
• Accident/Incident reporting
• Maintaining good house keeping standard
• Basic color codes of piping/equipment, etc.
• Safety signage’s
• Electrical safety
• Hand and portable power tools
• Hazards of flammable products and chemicals
• Emergency alarms and communication and what to do in such situations
• Some general dos and don’ts
• Other specific rules
Basic Rules for Visitors

As a bare minimum requirement, every visitor to the premises must be given a

safety briefing before giving him an entry pass.

As an illustration, a safety briefing developed by petroleum refinery is given

below.

Every installation should make a similar briefing relevant to its operations and local
conditions.
Access /Entry to the Premises

•Visitors should report to security gate for entry pass

•Every person must display a valid identification badge issued by the security

•Visitor should visit the designated area only for which he has obtained the
entry pass

•He should be accompanied by a company employee

• It is forbidden to take children inside the premises

Tobacco /Alcohol Restrictions

•The entire.-refinery is a tobacco free zone

•Tobacco in any form-cigarettes, biddies, gutka, etc. , is prohibited
•Use of alcohol and drugs is prohibited

Regulations on Naked Lights and Sparks

•Matchboxes, lighters, flashlights and cameras are not allowed inside the premises

•Only intrinsically safe mobile phones are allow inside

•No shoes with nails in the soles to be worn inside premises

•Use of 100% nylon or synthetic clothes inside the premises is prohibited

General

•Visitor shall be responsible for his own safety

•Photography inside is prohibited

•Never go to the site in case of any fire or other emergency

•Visitor is not allowed to touch any equipment interfere with the plant activities

• All persons must wear safety helmets and safe shoes in process areas.
Requirement of any other personal protective equipment will be advised by
plant personnel

•Use following telephone nos. in case required: Fire l00 Security 101, Medical
102
Accident Reporting and Investigation

In spite of good systems in place and people taking precautions while doing their work, the
possibility of, accident can not be ruled out.

It is necessary that each organization should have a good accident reporting and
investigating system in place.

Many people, at times, tend to look at accident investigation as an exercise to collect some
facts for the sole objective of putting blame or hanging someone for his errors and
omissions to set an example.

For this, accident investigation should be a learning process to prevent accidents and for
many other purposes.
The magnitude of accidents sometimes makes them appear to be beyond practical
solution, but a systematic investigation makes it possible to identify all the possible
circumstances and causes leading to the accident.

Like peeling the onion, it enables us to look at the underlying causes of an accident, which
may not be so obvious.

A proper investigation helps to identify the root cause (s) of an accident enabling the
management to take appropriate corrective action.
Some of the several objectives of an accident investigation are listed below, the rationale
of each being self-explanatory:
•Define the root cause (s) of the accident to take appropriate corrective measures
•Define management errors
•Satisfy company rules and identify violations of company procedures
•Satisfy insurance requirements
•Prevent further accidents
•Define operating errors
•Satisfy regulatory requirements
•Provide protection against litigation
•Comply with workers' compensation rules
•Provide answers to address anticipated public concerns
•Satisfy news media
•Research purposes

Thorough investigation of an accident is an essential step toward the prevention of

accidental losses of our precious resources including the people, property and
environment.

A good and systematic investigation is therefore an important HSE management tool.

Methodology

The first step is to have a proper accident reporting system.

In this direction, every petroleum installation should make a standard procedure for
notification and reporting of any accident to the concerned officials of the installation and
outside agencies.
This procedure should list the contact telephone numbers of key people.

In case of any accident, the personnel on duty should inform the concerned people as per
this procedure.

These numbers should be displayed at prominent locations in the installation.

Whenever an accident takes place howsoever small, it must be investigated.

Depending upon the nature of accident, an investigation team should be set up which
should go into all details-plant data, log sheets, strip charts, historian, interviews with
personnel, photographs, videos of effected area and equipment, etc.

If required, external help of a professional accident investigator can be taken

Effects and consequence models are available which can be very helpful in the
investigation of process type of accidents.
The team should make an honest report so that right decisions can be taken.

Many a times investigations done by internal teams are not very objective.

They tend to blame only the hardware and design of the facilities.

They are not comfortable in bringing out the human factors and fixing accountability.

If we have to learn from an accident and take proper corrective actions to avoid recurrence,
the investigation report must be frank and unbiased.

There should be a system to follow up the investigation report.

Management should establish a system to determine and document the response to each
finding of the report to ensure agreed upon actions are completed in a time frame.
The lessons learnt from the accidents should be disseminated to all the concerned
personnel in the complex.

In case of multi Unit Company, the conclusions of the investigation report should go
to all the units of the company.

In some cases, the information could also be shared with the other industry.
Training and its Validation

Training is an essential part of any HSE Management programme especially

in the petroleum industry.

It must be recognized that imparting relevant training and strict validation

of personnel after training is an absolute requirement for safe operation of
any petroleum installation.

The training on health, safety and environment is given to all employees–

new and those already working, contractors, third parties and visitors.

This training is in addition to the individual crafts and job training.

The extent of training depends on the target groups.

The training received by the new employees and contractors is called the initial
training, which includes comprehensive classroom and practical training in the
various HSE procedures applicable in the installation.

Everybody working in a petroleum installation must receive at least a basic fire

fighting training before he is assigned any work.

Those already working should also receive periodic HSE refresher training to keep
them updated with any changes or developments..
Training through video films can also, to some extent, minimize the
language problem.

To ensure that a candidate has understood the instructions, some

validation is a must.

This can be an objective type of test at the end of the session. If a

candidate has not performed satisfactorily in the test, he should go
through the session once again.

Records of training and validation should be maintained.

Third parties like truck drivers carrying products in /out of the installation and
various vendors should also be given minimum HSE training so that they
understand the basic safety rules to be followed in the installation.

Similarly, visitors should be given a safety brief before entry into the installation
so that they don’t do something unknowingly that may put themselves or others
into danger.

Many good companies issue entry passes/ID cards to those entering the
premises only after they have received the required HSE training
Methodology

HSE training should be a mix of theoretical classroom lectures and practical

training in the use of various fire and safety equipment and appliances.

Extensive use of audiovisual aids is used for effective training.

Care should be taken to select the right language(s) to meet the requirement
of multilingual workforce.

Some companies have produced video films, which are shown to the
newcomers, especially contractors, third parties and visitors to give them basic
HSE training with minimum requirement of faculty.
 Health, Safety and Environmental
Audits
• Statistics show that the root cause of many major accidents and mishaps
all over the world is human error.
• And the main cause of human errors has been the lack of written
procedures and/or non-compliance of the same.
• New plants/ facilities get normalized over a period after meeting the
initial challenges of commissioning and stabilization.
• Thereafter people tend to start relaxing and the systems/
procedures/facilities are not followed as in the earlier times.
• Many a times systems/procedures are not followed and hardware is not
maintained, inspected and tested as intended.
• Sometimes they are bypassed because of negligence, over-confidence and
complacency.
• Various health, safety and environment programmes including their
management systems require thorough auditing to exercise proper
control and ensure that the systems are working effectively.

• Such audits are conducted periodically on the systems, procedures and

operational aspects to ensure that a desired level of health, safety and
environmental standards are maintained as per the requirements of
company policy and statutory requirements.
• A management tool comprising a systematic ,documented ,periodic and
objective evaluation of the performance of the
organization ,management system and processes designed to protect
environment with the aim of facilitating management control practice s
which may have impact on environment and assessing compliance with
environmental policies
 Major objectives of audits are:
• Ensure that all statutory requirements are met fully.
• Ensure that set procedures are complete, up to date and compliant with
applicable standards, codes, company policies, good engineering and
process safety practices.
• Ensure that the management systems in place are effective.
• Identify opportunities where the systems and procedures can be
strengthened.
• To check on the training and preparedness of personnel to handle
emergency situations.
• Cater to public opinion and concern for safe environment.
 Types of audits

• Internal audits

or

• External audits.
 Internal audits
• Internal audits can be periodic detailed audits of one or more
plants/facilities of an installation conducted by a multidisciplinary team
drawn from various departments of the installation.
• In a company having more than one site, intersite audits by combined
teams drawn from various sites can also be a good method of conducting
internal audits.
• An internal audit may take 3-4 days by a team of 4-5 professionals from
different disciplines.
• The audit team reviews the systems, procedures and facilities for
complete and updated documentation and their compliance.
• Each plant/facility of an installation should be audited every two to three
years.
• Besides detail or comprehensive internal audits, there are mini audits.

• A mini safety audit is of short duration (typically 2-3 hours) conducted by

a two-men team using checklists to ensure the compliance of a particular
procedure at a time.

• Such audits are done more frequently to cover various procedures

relevant to the installation.

• This is a very useful and quick method of finding the weaknesses/

deficiencies in the system.

• Another type of internal audits is called BSC audits. These are self-audits
based on British Safety Council’s standard checklists.

• Each plant/department maintains these checklists for various systems

pertaining to its activities.
 External Audits
• The external audits are done by outside agencies or third parties
approved by statutory authorities to meet requirements under various
statutory rules and regulations

• In leading companies, external audits are done not only to meet statutory
requirements but also to bring in a fresh approach and additional
objectivity through a third eye.

• It must be understood that external audits are supplementary to the

internal audits.

• External audits are generally more global covering the entire

premises/installation.
• Typical external audit agencies approved by various statutory authorities
include:
• Oil Industry Safety Directorate, OISD
• British Safety Council (5-star audit)
• National Environmental Engineering Research Institute, NEERI
• Central Labour Research Institute, CRI
• Loss Prevention Association, LPA
• National Safety Council, NSC
• Engineers India Limited, EIL
• Lloyds Register of Shipping
• Det Norske Veritas
• Comet Consultancy Services
• Netal Chromatographs
• KLG/TNO
• SGS India Limited
• Others as approved from case to case
Methodology of Audits

Composition/Selection of Audit Team

Conducting the Audit

Audit Report

Follow-up
Composition/Selection of Audit Team

The team for a comprehensive internal audit comprises a member each from
• Operation
• Engineering/Maintenance,
• Technical services/Technology,
• HSE and any other specific discipline if required.
The chief of the installation through an office order nominates the team.

• The Chief of HSE nominates the team for a mini audit in consultation with
individual departments. The team comprises of two members–one from
the area/department to be audited and the other from HSE.

• The programme of such audits is published by HSE through procedures

audit schedule published by him every month.
Conducting the Audit
• To start with, the team gets organized and holds a kick-off meeting to
discuss the plan of action.
• They try to collect all relevant data of the area/plant/department they are
going to audit.
• The team visits the area and talks to various personnel there to get
feedback about their plant/area.
• The team checks the various systems/procedures and records.
• The safety aspects of the plant are checked using checklists.
These checklists could be standard lists made as part of a
written audit procedure and supplemented by specific
checklists made for special systems/equipment by each team
before starting the audit.
• Checklists are very useful as they save a lot of time and
also to ensure that all aspects or subsystems have been looked
into and not missed inadvertently.
• In case of mini audits, the two-men team goes to the area
where audit is to be done.
• The team ensures the compliance of the procedure under audit by using
a standard checklist made for the particular procedure

• They check the level of compliance to each checklist item by talking to

the plant personnel and seeing the situation in the field and rate the item
on a 1-5 scale (1 is least compliant, 5 full compliance).

• The overall compliance level is indicated in percentage.

 Audit Report
• After completing an audit, the team prepares a draft report, which is
presented to the custodian/manager of the area and his team.

• After discussion, the final report with action plan for implementing the
agreed recommendations is issued by the leader of the audit team to the
concerned action parties with copies to top management team.

• In case of mini audits, the audited checklist is itself the report. This is
issued to the concerned custodian/manager of the area immediately on
the same day after the audit is done.
 Follow-up
• The effectiveness of the audit lies in the degree of implementation of the
agreed recommendation.

• Therefore, it is essential to monitor the implementation programme.

• HSE plays a pivotal role in monitoring the recommendations of various

audits and presenting the implementation status to the top management.

• Record of an audit report is maintained with the custodian and HSE till
all the recommendations agreed to be implemented are liquidated.
 PERMIT TO WORK SYSTEM
• There are numerous cases where people worked without proper isolation of
equipment, cutting off electrical supply, proper personnel protective equipment,
etc.

• Every petroleum installation must have an approved Permit to Work System in

place.

• The permit is an official record of safe working conditions agreed upon by the
issuer and acceptor of the permit for carrying out any maintenance, repair,
inspection or modification work.
 Types of Permits
Various permits applicable in a petroleum installation are listed below:

• Cold Work Permit

• Hot Work Permit
• Confined Space Entry/Work Permit
• Excavation Permit
• Permit to Work on Electrical Equipment
• Electrical Isolation/Restoration Permit
• Permit for Closure of Roads
• Permit for using a Radioactive Source
• Permit for Working Over/Under Water
• Vehicle/Crane Entry Permit
• Permit for Photography
• Permit for Isolation of Fire Water System
• Mine/Rock Blasting Operations

Depending upon the nature of activities, some or all of the above permits may
applicable in a petroleum installation.
 Elements of a Typical Work Permit
•Every installation should design work permit formats as per its
requirement and nature of activities.
•Oil Industry Safety Directorate (OISD )and National Safety
Council (NSC) give guidelines for designing work permit formats.
Some important elements of a typical work permit are as below:
• Type of permit
• Date, time of issue and validity
• Description of location where work is to be carried out
• Brief description of the work
• Detailed safety precautions to be taken
• Name and signatures of person(s) issuing the permit
• Name and signature of the person receiving the permit
• Authorisation by senior management personnel depending
on seriousness of the hazard
• Declaration of completion of job by the receiver withdate
and time
 Permit Procedure
• Work permit is generally issued by an operating supervisor, called issuer
of the permit to the maintenance supervisor or a contractor, called the
acceptor of the permit after ensuring all the necessary precautions.
• The nature and location of work to be done must be clearly specified in
the permit by the issuer who should explain and show the same to the
acceptor in the field.
• The issuer and the acceptor of the permit must be clear regarding the
precautions to be followed for doing the work safely.
• The work can proceed only when both the parties have signed the
permit after taking the necessary precautions.
• The agreed precautions and conditions mentioned in the permit must be
maintained during the tenure of the work.
.
• After the work is completed, both the parties must sign the permit to
certify that the work has been completed as intended, the area has been
cleared of all personnel, tools, oil, grease, debris, etc.
• This check is necessary before restarting the equipment.

Following is a list of some precautions required to be taken for giving

different work permits.

• Inspection of area /location of work

• Isolating/blinding/spading the line/equipment
• Draining, depressurizing and making the equipment free of hydrocarbons
and other hazardous materials
• Cleaning/washing the equipment
• Testing the atmosphere for explosive and toxic gases
• Electrical isolation
• Isolation of other energy sources
• Isolation of radioactive sources
• Putting proper tags, notices/warnings, etc.
• Covering drains and manholes
• Providing proper illumination and ventilation
• Barricading the area
• Providing proper scaffolding and ladders for working at height
• Providing necessary Personnel Protective Equipment
• Cleaning surrounding area of any combustible material, debris and other
obstructions.