CP-122 HSE Code of Practice - PDO

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HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual always reread the entire document before having it issued to detect overused words as well as errors that may have been unintentionally made. Sequence of suggestions: The author should attempt to present and layout the document in a logical way which will facilitate their implementation. Use of standard PDO templates facilitates this process, and these can be accessed in the PDO CMF. Providing instruction on the conduct of worksite tasks can take many forms, depending on the complexity of the task, the competence of the people performing it, the inherent hazards and risks associated with it, and the effects that it might have on other aspects of the operation or facility. Thus, verbal instructions will need to be supported with, or replaced by, written procedures or work instructions wherever the absence of written material could threaten proper HSE performance. Written work instructions will outline the work scope and reference any particular direction that is to be followed; similar considerations to those for system procedures also apply t o their development. Monitoring and other HSE requirements, such as applicable rules and personal protective equipment, can be specified in these documents as well. For example, in a production facility where hydrocarbons are stored and/or produced, stringent controls are required and most work is conducted under a 'Permit-to-Work' system. Within this, the work is defined, the precautions specified, other parties whose activities may be affected are notified, and the permit signed off properly by all parties involved. However, supplementary documentation is also often required in the form of job safety / hazard analyses, procedures, and/or work instructions for the task(s) itself. 5.3.2 Issuing Procedures / Work Instructions Procedures and/or work instructions define the manner of conducting tasks at the work-site level, whether conducted by the company's own employees or by contractors acting on its behalf. In the case of HSE Critical Tasks, which have the potential for adverse HSE consequences if incorrectly performed, these procedures and/or work instructions should be documented, communicated to relevant personnel, and be subject to the requirements of PDO‟s document and records control system. Use of standard PDO templates facilitates this process, and these can be accessed in the PDO CMF. The activities which can be described as 'HSE Critical' must have procedures and/or work instructions. An HSE Critical activity is any activity that is undertaken to provide or maintain controls for RAM 3+ consequences. For more information on the PDO RAM, see PR-1418. In situations such as projects and/or major contracts where PDO is the overall accountable party, HSE Critical activities will also be identified as such areas where documented procedures are particularly necessary (as opposed to an absence of documented procedures) in order to cover interfaces between different groups or disciplines and where coordination is vital to achieve successful HSE outcomes. This often requires the use of a „bridging document.‟ For example, one or more parties may be using their existing procedures, either from PDO or the Contractor‟s organisation to carry out a work activity, yet these procedures do not completely cover the identified risks and contingencies in the work activity. In such a case, another document is often required to „bridge‟ the gaps so as to cover what is needed to be done to completely cover all risks and contingencies in the work activity. In addition to the points made above, procedures and/or work instructions should be: Subject to a regular and formalized system of review, update, approval, and re-issue. Dated and traceable to the activity involved. Identified with a custodian. Accessible to all relevant personnel (not just physically evident but user-friendly and well indexed, either in soft- or hardcopy). 5.3.3 Accountability and Responsibility for Operational Control Asset Directors have single point accountability for the day-to-day management, performance, and development of all assets. This accountability includes controlling operations in a way that manages the HSE risks associated with each asset. The Asset Director Mandate describes the assets over which each Asset Director holds single point accountability. An asset may be passed between different Asset Directors during its life cycle. July 2011 Page 42
HEALTH, SAFETY AND ENVIRONMENT CODE OF PRACTICE (CP-122) PDO HSE Management System Manual Service Level Agreements (SLA) specify the nature, scope, roles, responsibilities, and accountabilities for the essential services to be provided by and for each party under the SLA. These also define the boundaries of operational control for each party / Asset Director. Contract Holders are accountable for specifying the applicable procedures and work instructions for Contractor activities, and for ensuring that they are complied with. Refer to PR 1171 Contract HSE Management for details about controlling and monitoring Contractor activities. Operational control documents (written procedures, work instructions, and/or specifications) within PDO are generally authored along Functional lines. When authored, the various roles, responsibilities, and accountabilities should also be clearly stated in the document, with use of the RASCI approach to ensure clarity. It is the accountability of individual Asset Directors to implement these documents within their Directorate Teams. 5.3.4 DCAF To further assist and improve planning processes, PDO also implements the Discipline Controls and Assurance Framework, or „DCAF.” This framework helps to standardize Quality Control (QC) and Quality Assurance (QA) across all disciplines. Both Controls and Assurance are covered in DCAF and its associated documentation. DCAF consists of three elements: 1. Discipline Standards: Standards (global and local) that lists all discipline deliverables that need sign-off by an authorized individual. Note that DCAF does not set the standards, the relevant Disciplines do. 2. Discipline Authority Manual: A list of individuals with their respective authority-levels. 3. Project / Asset Controls and Assurance Plan: A plan, listing what needs to be controlled or assured per the Opportunity Realization Process (ORP) phase. Controls are routine, risk-based (refer to Process 4, HEMP), internal steps to confirm the effectiveness of a prescribed process or activity. Assurance is an objective and independent review (refer to Process 7, Assurance) to ensure goals, objectives, and targets are met, and policies, procedures, and processes are adhered to. DCAF provides clarity; which decisions and deliverables must be quality controlled / assured and who is authorized to do so. It recognizes both the „Line of Sight‟ and the „Matrix‟ as sign-off occurs in the line of the Business, while Disciplines are responsible for providing standards and authorized and expert staff. In PDO, the Disciplines set the standards; DCAF does not. More access to DCAF can be found in the following link: http://sww.shell.com/ep/dcaf 5.3.5 Management of Change (MOC) PDO‟s requirements for initiating, planning, controlling, and closing out changes within its operations (both temporary and permanent), in people, plant, processes, and procedures, are addressed mainly through the Technical Integrity system and its associated procedures, operations procedures, as well as variance control procedures for projects. The purpose of Management of Change in PDO is to manage the HSE risks resulting from unforeseen consequences of changes. This applies to all employees and contractors in PDO, but is led by Managers and Management of Change process owners. In PDO, management of change applies to process changes (hardware, process control and process condition changes), procedural changes, and organisational changes (both PDO and contractors). Management of Change includes the following activities: Appointment by PDO leadership of a management of change “Process Owner(s).” The MOC Process Owner should be responsible for implementation of the following: Ensure that all HSE Critical Roles / Positions know how to recognize changes covered by this manual. Know how to initiate the management of change process, based on the type of change involved (procedural, engineering, organisational, or combination thereof). July 2011 Page 43
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CP-122 HSE Code of Practice - PDO

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