Petroleum HSEC Controls

Transcription

BHP Billiton Petroleum HSEC Controls Accountabilities Table
Control
Control Owner
Reference #
Hazard & Risk
Safety and Risk Manager
Element #3
Community
Community Manager
Element # 6
Crisis & Emergency Management
Asset Protection Manager
Element #11
Security
Asset Protection Manager
Element #11
Health & Hygiene
Occupational Health & Hygiene Manager
Element #13
Aviation
Principal Aviation Specialist
Element #14
Marine
Principal Marine Specialist
Element #14
Fatal Risk
Safety & Risk Manager
Element #14
Road Going and Light Vehicles
FRC 1
Mobile Equipment
FRC 2
Explosives
FRC 3
Hazardous Materials
FRC 4
Isolation
FRC 5
Equipment Safeguarding
FRC 6
Working at Height
FRC 7
Lifting Operations
FRC 8
Dropped Objects
FRC 9
Working with Pressure
FRC 10
Presence of Hydrogen Sulphide (H2S)
FRC 11
Confined Space Entry (CSE)
FRC 12
Diving
FRC 13
Ground Disturbance & Ground Control
FRC 14
Application of Fatal Risk Controls
All FRCs
Site Traffic Management Plan
FRC 1 and 2
Environment
Environmental Engineering Manager
Element #15
HSEC Data Reporting
Element #16
Revision Number
Revision Date
URL
Comments
Contents
Introduction
Purpose
Scope
Application
Responsibility References
BHP Billiton Petroleum HSEC Portal
Marine Operations Controls
1
1
1
1
1
1
Hazard and Risk Management Controls
Control 1 – Risk Assessment
Control 2 – Risk Treatment
Control 3 – Governance and Compliance
11
12
13
Crisis and Emergency Management Controls
Control 2 – Emergency Response Structure
Control 3 – Plans
Control 4 – Provision of Resources
Control 5 – Training and Exercises
Control 6 – Business Continuity
Control 7 – Review
17
17
18
18
19
19
20
Security Controls
Control 1 – Accountabilities
Control 3 – Plans
Control 4 – Use of Public and Private Security Resources
Control 5 – Firearms and the Use of Force
Control 6 – Security Training and Awareness
Appendix A: Security and Emergency Management
Approvals Framework
23
23
24
24
25
25
26
Health and Hygiene Controls
Control 1 – Occupational Exposure
Control 2 – Fit for Work
Control 3 – Reporting and Management Review
Applicability Supplement
Associated Documentation
29
29
30
31
31
Aviation Controls
Control 1 – General Requirements
39
41
42
43
44
45
Fatal Risk Controls
5
6
7
Community Controls
Control 1 – Stakeholder Engagement
Control 2 – Community Development
Control 3 – Human Rights
Control 1 – Operations Management
Control 2 – Contracting of Vessels
Control 3 – Facility Safety Zones
Control 4 – Personnel Transfer
Control 5 – Transfer of Supplies
Control 6 – Off-Take Tanker Operations
35
Control 1 – Road Going and Light Vehicles
49
Control 2 – Mobile Equipment
50
Control 3 – Explosives
51
Control 4 – Hazardous Materials
52
Control 5 – Isolation and Permit to Work
53
Control 6 – Equipment Safeguarding
54
Control 7 – Working at Height
55
Control 8 – Lifting Operations
56
Control 9 – Dropped Objects
57
Control 10 – Working with Pressure
58
Control 11 – Presence of Hydrogen Sulphide (H2S)59
Control 12 – Confined Space Entry (CSE)
60
Control 13 – Diving
61
Control 14 – Ground Disturbance and Ground Control
62
Appendix B: Notes, Application and Inter-Relationship 63
of Fatal Risk Controls
Appendix C: Site Traffic Management Plan requirements
66
Appendix D: Transitional Requirements for Existing 66
Light Vehicles
Environment Controls
Control 1 – Land, Marine and Biodiversity Disturbances
Control 2 – Noise Disturbances
Control 3 – Hydrocarbon
Control 4 – Water Sourcing, Use and Discharge
Control 5 – Air Emissions
Control 6 – Energy Use and Greenhouse Gas Emissions
Control 7 – Waste
Control 8 – Drilling Muds and Drilled Cuttings
References
69
70
71
72
73
74
75
76
77
Data Reporting Controls
Control 1 – General Requirements
Control 2 – Reporting Requirements
Control 3 – Significant Events
81
82
84
B Health, Safety, Environment and Community Management System Framework
Introduction
Purpose
BHP Billiton Petroleum corporate mandatory HSEC requirements
as described in the HSEC related Group Level Documents (GLDs)
are met through implementation of the BHP Billiton Petroleum
HSEC Management System Framework, associated BHP Billiton
Petroleum HSEC Controls and related procedures.
Responsibility
Unless otherwise stated, managers responsible for BHP Billiton
Petroleum activities are accountable for the implementation of the
performance requirements outlined in this document. Personnel must
comply with the letter and spirit of the performance requirements in
the BHP Billiton Petroleum HSEC Controls including associated
documentation.
Scope
References
The BHP Billiton Petroleum HSEC Controls cover BHP Billiton
Petroleum activities that affect or have the potential to materially
affect, beneficially or adversely, the health, safety and security of
people, the physical environment and protection of assets.
• The HSEC Controls document must be used in conjunction with the
associated BHP Billiton Petroleum HSEC Controls Compliance
Workbook. Each workbook provides additional details associated
with each requirement (responsibilities, approvals, endorsements,
evidence of compliance, frequency of execution and supporting
documentation.
Application
The BHP Billiton Petroleum HSEC Controls apply to the entire
lifecycle of BHP Billiton Petroleum activities, processes and
products. Contractors must comply with relevant aspects of the
BHP Billiton Petroleum HSEC Controls. Partners and suppliers are
encouraged to adopt the intent and nature of the performance
requirements in this document.
Where there is a conflict between legislation and BHP Billiton
Petroleum requirements, the more stringent standard prevails
while ensuring legal compliance requirements are met. A
BHP Billiton Petroleum variance form must be completed and
submitted to BHP Billiton Petroleum HSE Systems Support where
applicable requirements cannot be met and are assessed as a
material gap. Where the gap is associated with a Group Level
Document (GLD), the purpose of the variance form will be to
ensure visibility of the issue at the appropriate level within
BHP Billiton Petroleum. For BHP Billiton Petroleum specific
requirements, the variance form will be reviewed and addressed
by the relevant functional owner.
• BHP Billiton Petroleum HSEC Glossary of Terms
• BHP Billiton Petroleum HSEC Management System Framework
BHP Billiton Petroleum HSEC Portal
Consistent with the principles of continuous improvement, the BHP
Billiton Petroleum HSEC Controls and other related documents will be
periodically updated therefore:
• The BHP Billiton Petroleum HSEC Portal must be used to access the
governing current version of this document.
• HSEC Control References in the electronic copy are italicized and
hyperlinked as appropriate within the HSEC Portal.
Controls 1
BHP Billiton Petroleum Controls
Hazard and Risk
Management
Hazard and Risk Control 1
Risk Assessment
Intent
Identify and assess HSEC Hazards associated with BHP Billiton Petroleum activities and manage HSEC Material Risks
Performance Requirements
1.1
1.2
1.3
1.4
1.5
1.6
Identify sources of hazards, possible causes and impacts as
a result of the risk.
Conduct Process Hazard Analysis (PHA) workshops across
all phases of the life cycle of a facility in accordance with
the PHA Management procedure to identify HSEC Hazards.
Involve appropriate technical and functional representation
in the Process Hazard Analysis (PHA) workshops.
Conduct Hazard and Operability (HAZOP) studies for all
new developments in accordance with the BHP Billiton
Petroleum HAZOP procedure.
Conduct a revalidation Process Hazard Analysis (PHA) for
operating sites in accordance with the frequencies as
defined in the PHA Management procedure.
Conduct a Risk Analysis to determine severity and
likelihood for each hazard event identified utilizing the
BHP Billiton Petroleum HSEC Risk Matrix.
1.7 Identify all HSEC Material Risks in accordance with
BHP Billiton Petroleum criteria, established by the Risk
Management Procedure.
1.8 Manage actions from Process Hazard Analysis (PHA)
workshops to completion in accordance with PHA
Management procedure.
1.9 Document HSEC Material Risks in a controlled Risk Register
in accordance with the Risk Management procedure.
1.10 Communicate HSEC Material Risks to personnel involved in
the activities.
1.11 Develop and make available Bowtie diagrams for all HSEC
Material Risks identified in accordance with the
Management of Critical Controls procedure.
1.12 Use Bowtie diagrams to describe credible causes,
consequences and Controls and ensure they form part of
the Safety Case.
1.13 Maintain Bowtie diagrams to ensure alignment with current
HSEC Material Risk Register.
.
Controls 5
Risk Treatment
Intent
Identify, establish and evaluate Critical Controls that are required to manage HSEC Material Risks and demonstrate to BHP Billiton
Petroleum stakeholders that facilities have been selected, designed, constructed, commissioned and can be operated in a manner such
that residual risk levels are ALARP
2.1 Identify Critical Controls for Material HSEC Risk in
accordance with the BHP Billiton Petroleum Management
of Critical Controls Procedure.
2.2 Identify Critical Equipment, required to satisfy the objective
of the Critical Controls, in accordance with the BHP Billiton
Petroleum Management of Critical Controls Procedure.
2.3 Develop and maintain a Critical Equipment Register.
2.4 Develop Performance Standards for each Critical Control
(Equipment and Non Equipment) in accordance with the
BHP Billiton Petroleum Management of Critical Controls
Procedure.
2.5 Manage Critical Controls that do not meet their
Performance Standard via the BHP Billiton Petroleum Case
to Operate Procedure.
2.6 Review Performance Standards as per the relevant
procedure and update in accordance with the Management
of Change Procedure.
2.7 Verify Critical Control effectiveness through Control Self
Assessment in accordance with the Risk Management
procedure.
6 Health, Safety, Environment and Community
2.8 Develop a Safety Case in accordance with the Development
Phase and/or operations lifecycle that includes all HSEC
Material Risks, Bowties, Critical Controls, Critical
Equipment and Performance Standards and verification
procedures to demonstrate how the facility manages risk.
2.9 Review and update Safety Case in accordance with the
Safety Case procedure. It shall be reviewed at least every 5
years, per local regulatory requirement or when there are
material changes that might change the facility/project risk
profile whichever is sooner.
2.10 Develop a Safety Case for Drilling Operations for activities
that extend beyond 180 days per year and /or for well
campaigns that present high risk e.g., HPHT wells.
2.11 Develop a bridging document to address a combined
Operations Safety Case and for the interaction of critical
controls when 2 or more facilities interact in combined
operations.
2.12 Involve appropriate technical and functional representation
endorsed by the HSEC function to review the Safety Case.
Governance and Compliance
Intent
Performance measurement and verification for BHP Billiton Petroleum activities and sites provides assurance that HSEC Hazard and Risk
Management is effective.
3.1 Provide assurance that risks are adequately managed by
subjecting the Operations Safety Case and Risk Register to
an Annual HSEC Material Risk Review in accordance with
the Risk Management procedure and BHP Billiton Petroleum
HSEC Assurance procedure.
3.2 Develop and report on Process Safety Key Performance
Indicators (KPIs) as part of the Project or Production Unit
annual KPIs.
3.3 Review associated actual or potential significant events
when evaluating Critical Control effectiveness.
3.4 Manage Bowtie and Critical Controls Health checks in
accordance with the BHP Billiton Petroleum Management of
Critical Controls Procedure.
3.5 Develop risk-based handover certification to ensure
assurance activities are conducted and satisfied prior to
start-up or continuation of operations after a major
shutdown.
Controls 7
Community
Figure 1 Community Requirements by BHP Billiton Petroleum Project Lifecycle
Pre-Development/
HSEC Screening/
Risk Assessment
HSEC
Screening/Risk
Assessment
Evaluate
Risk
Exploration and
Identification Phase
Development
Financial
Investment
Decision
Selection and
Definition Phases
Acquire
Lease
Stakeholder
Identification
Go
Stakeholder
Engagement
and
Documentation
HSEC Screening
includes sociopolitical
and human rights
Identify
Business
Opportunity
Stakeholder
Engagement
Management
Plan (if critical)
Social Impact
and
Opportunities
Assessment
Social Baseline
Study
Commence
Field
Work
Obtain
Broad-based
Community
Support
Complaints
and Grievances
Mechanism
Implement
Stakeholder
Engagement
Management
Plan
Stakeholder
Analysis
Human Rights
Impact
Assessment
Maplecroft
<6.25
Verify/Validate
HRIA
Human Rights
Impact
Assessment
Evaluate
Material Risk
Evaluate
Material Risk
Yes
Yes
Human Rights
Management
Plan
Yes
Human
Rights
Training
Decision to
Proceed to
Develop
Human Rights
Management
Plan
Verify/Validate
HRIA
Yes
Note: Dotted line indicates earlier timing of a requirement based on risk. Refer to Community Controls for details.
Execution
Phase
Operations
Design
Community
Development
Management
Plan
Implement
Community
Development
Programs
Evaluate
Effectiveness
Design
Local
Procurement
Plan
Implement
Local
Procurement
Plan
Evaluate
Targets
Initial
Community
Perception
Survey
Annual Review
Stakeholder
Engagement
Management
Plan
Community
Perception
Survey 3-yr.
Complaints
and Grievances
Mechanism
Complaints
and Grievances
Mechanism
Three-year
HRIA Review
Implement
Initial
Community
Projects
Human Rights
Training
Annual HRMP
Review
Community Control 1
Stakeholder Engagement
Intent
A Stakeholder Engagement Management Plan must be implemented and maintained to support regular and ongoing dialogue with
stakeholders who could have an impact on, or be impacted by BHP Billiton Petroleum activities.
The timing of the following Performance Requirements is based
upon the BHP Billiton Petroleum Project Lifecycle phase of a
BHP Billiton Petroleum activity indicated by Figure 1.
1.1 Identify those stakeholders who have an interest in the
project or operations and who could influence the outcome
of the project or operations. Refer to the Stakeholder
Engagement Procedure.
1.2 Prepare a Stakeholder Analysis to understand and consider
the concerns, interests and relationships of identified
stakeholders. Refer to the Stakeholder Engagement
Procedure.
1.3 Implement and document consultation activities specific to
each stakeholder. Refer to the Stakeholder Engagement
Procedure.
1.4 Prepare, implement and maintain a Stakeholder
Engagement Management Plan. Refer to the Stakeholder
1.5 Document all stakeholder engagement activities, responses
to concerns and complaints, outcomes, agreements and
commitments. Refer to the Stakeholder Engagement
Procedure.
1.6 Review and update the Stakeholder Engagement
Management Plan annually. Refer to the Stakeholder
1.7 Conduct a community perception survey to identify priority
areas for community development. Refer to the Stakeholder
1.8 Evaluate progress against the objectives documented in the
Stakeholder Engagement Management Plan every 3 years
based on a community perception survey that includes
indicators reflecting community concerns. Refer to the
Stakeholder Engagement Procedure.
Controls 11
Community Control 2
Community Development
Intent
A Community Development Management Plan must be implemented, maintained and reviewed to assist BHP Billiton Petroleum to
contribute to the livelihoods of people in host communities and enhance BHP Billiton Petroleum’s license to operate.
2.1 Complete a social baseline study and social impact and
opportunity assessment, and select key quality-of-life
indicators. Refer to the Community Development
Procedure.
2.2 Develop a community development budget, and design,
implement, maintain, and annually review a Community
Development Management Plan, according to the
Community Development Procedure.
2.3 Identify, implement, and document the initial community
development projects that are linked to focus areas,
according to the Community Development Procedure.
2.4 Identify, implement, and document Community
Development Projects linked to the quality-of-life
indicators, according to the Community Development
Procedure.
2.5 Evaluate the effectiveness of the Community Development
Management Plan every three years, according to the
Community Development Procedure.
2.6 Design and implement a local procurement plan with
targets. Refer to the Community Development Procedure.
2.7 Complete and authorize the Community Development
Project or Donation Anti-Corruption Template for all
community development projects, donations, and
sponsorships. Refer to the Community Development
Project or Donation Anti-Corruption Procedure and
the Community Development Project or Donation
Anti-Corruption Template.
2.8 Complete and authorize the BHP Billiton Petroleum
Community Development Project Quality Assessment
Framework Template for community development projects
with a total value over US$1 million.
2.9 Implement and provide access to the Employee Matched
Giving program to all employees, in accordance with
protocols defined by Group HSEC.
Community Control 3
Human Rights
Intent
Activities must be undertaken so that people’s human rights are respected and BHP Billiton Petroleum’s human rights commitments
are met.
3.1 Prepare, verify, validate and annually review a Human
Rights Impact Assessment. Refer to Human Rights
3.2 Prepare a Human Rights Management Plan if the Human
Rights Impact Assessment identifies a material risk issue.
Refer to the Human Rights Management Procedure.
3.3 Where a Human Rights Management Plan is required, train
employees and contractors to facilitate compliance with
BHP Billiton Petroleum’s human rights commitments. Refer
to the Human Rights Management Procedure.
3.4 Obtain and document broad based community support
prior to seeking Execution approval, and document any
opposition to the project. Refer to the Human Rights
Management Procedure, and the Stakeholder Engagement
Procedure.
3.5 Investigate and resolve promptly all breaches to the United
Nations Declaration of Human Rights. Refer to the Human
Rights Management Procedure.
3.6 Implement a resettlement program (voluntary or
involuntary) for BHP Billiton Petroleum activities that
require physical or economic displacement, consistent with
the requirements of the IFC Performance Standard 5: Land
Acquisition and Involuntary Resettlement, excluding the
requirements to obtain Free Prior Informed Consent. Refer
to the Human Rights Management Procedure.
3.7 Develop and implement a complaints and grievances
mechanism commensurate with the country risk rating, and
document through the BHP Billiton Incident Reporting
System. Refer to the Human Rights Management Procedure
and the Claims Management Procedure.
Controls 13
Crisis and
Emergency
Management
Crisis and Emergency Management Control 1
Risk Assessment
Intent
Identify potential incidents that threaten the safety of people, environment, property and reputation.
1.1
Identify credible emergency scenarios based on evaluation
of material risks and most likely hazards associated with
BHP Billiton Petroleum activity.
1.2 Engage a cross-functional team inclusive of stakeholders to
define:
• Mitigation activities designed to reduce the impact(s)
arising from each identified emergency response
scenario.
• Preparedness activities associated with organizing and
mobilizing essential emergency response resources.
• Response strategies and actions to be followed during
the emergency.
• Recovery strategies and actions required postemergency for the re-establishment of normal state.
Emergency Response Structure
Intent
Ensure that an adequate organization is established, that roles and responsibilities are identified, then communicated and understood.
2.1 Put in place an emergency response organization in
alignment with BHP Billiton Petroleum CEM procedure as
follows:
• Establish a tiered response structure (FRT/IMT/EMT) to
direct, control, coordinate and escalate response and
recovery activities.
• Authorize competent personnel to respond to and
manage emergencies as follows:
-- Have plans, processes and procedures for the
activation, operation, coordination and
communication of the incident response;
-- Have resources available to support the plans,
processes and procedures to manage an incident; and
-- Communicate with stakeholders.
• Put in place adequate redundancy of personnel such that
successful emergency response is likely, even if key
individuals are not able to perform their assigned roles.
-- Confirm the nature and extent of an incident;
-- Trigger and activate an appropriate emergency
response at each tier level, commensurate with
severity of the emergency;
Controls 17
Plans
Intent
Ensure that plans identify routine and contingency actions for managing risks and incidents.
3.1 Develop Emergency Response plans that are scaled
according to the BHP Billiton Petroleum activities,
associated hazards, material risks and applicable regulatory
requirements. At a minimum plans must include:
• Critical information that is organized and prioritized for
quick access.
• Procedures for incident detection, notification, incident
severity thresholds at which each response level is
mobilized.
• Procedures to communicate and coordinate with all
persons involved in responding to or potentially affected
by the emergency.
• Clear roles and responsibilities of all responders.
• Identification of response organizations and descriptions
of command and control structures.
• Identification, description and methods of notifying and
mobilizing predetermined resources, required personnel,
equipment, and services.
• A communications plan to engage stakeholders including
coordination with Group Public Affairs, for incidents
with a maximum foreseeable loss.
3.2 Review Emergency Response plans annually, as well as
under the following circumstances:
• Change in nature of activity and associated risks.
• Change in availability or provision of response resources,
services or equipment.
• Inclusion of lessons identified through training exercises
or real events.
• Change in regulatory or Company requirements.
Provision of Resources
Intent
Identify, allocate and maintain necessary resources.
4.1 Put in place resource management arrangements to enable
timely and unimpeded access to identified resources which
prevent, mitigate, prepare for, respond to, or recover from
identified emergency scenarios; resource management
must include the following tasks:
• Establishing processes for describing, inventorying,
requesting, and tracking resources.
• Activating, dispatching and deactivating these processes
prior to and during an emergency.
• Contingency planning for shortfalls of resources
• Establishing alarm and warning systems to inform all
affected personnel an emergency condition exists and
what actions to take.
• Ensuring access to qualified medical resources.
4.2 Conduct an assessment to identify resource capability
shortfalls, constraints and the steps necessary to overcome
any shortfalls and constraints.
4.3 Establish formalized 3rd party contracts and agreements
with defined performance standards/criteria for the
provision of resources, services or equipment in support of
emergency response activities.
4.4 Define Mutual aid arrangements inclusive of each
participant’s commitment, as well as other agreed
responsibilities.
4.5 Establish and implement Inspection, testing and
maintenance procedures for emergency response
equipment.
Training and Exercises
Intent
Individuals are skilled in their knowledge and application of plans and that processes and resources are acceptable.
5.1 Train individuals assigned emergency response duties in
their roles and responsibilities prior to commencement of
duties or actively participating in an actual response.
5.2 Identify frequency and scope of training through training
needs analysis and comply with relevant regulatory
requirements.
5.3 Maintain training records and certification.
5.4 Develop exercises using realistic scenarios. Events should
be based on the relevant material risks.
5.5 Design exercises to test and evaluate individual essential
elements, interrelated elements, or the entire plan(s),
procedures, and capabilities.
5.6 Conduct post exercise and event reviews to assess the
achievement of the aims and objectives and provide a
written report that includes outcomes and required actions.
Business Continuity
Intent
A plan is established which defines the steps necessary to ensure the continuation of or re-establishment of business activities following
an emergency event.
6.1 Develop business continuity plans aligned with the
BHP Billiton Petroleum Business Continuity procedure, that
are scaled according to the BHP Billiton Petroleum
activities, associated hazards, material risks and applicable
critical activities.
6.2 Identify critical activities whose loss as the result of a
disruption beyond the emergency response phase that
would have the greatest impact in the shortest time and
which need to be recovered most rapidly.
6.4 Develop business continuity strategies and plan(s) which
set out prioritized objectives in terms of:
• Critical activities to be recovered.
• Timescales in which they are to be recovered.
• Resources including external needed for implementing
the recovery.
• Recovery levels needed for each critical activity.
• The situation in which the plan can be utilized.
6.3 Identify measures that:
• Reduce the likelihood of a disruption.
• Shorten the period of disruption.
• Limit the impact of a disruption on key products and
services.
Controls 19
Review
Intent
Ensure plans are current, people are trained and resources are allocated in a consistent manner.
7.1
Review Emergency Response arrangements including
response plans annually as part of the local HSEC assurance
review and update plan(s) and procedures as deemed
necessary.
Security
Security Control 1
Accountabilities
Intent
Personnel with security management responsibilities or duties are suitably experienced, or trained, to perform the function.
1.1
Appoint a Security Focal Point (SFP) and register the
appointment in a security plan.
1.2 Execute the SFP responsibilities as defined in the Site
Security & Asset Protection Performance procedure.
1.3 Attain the required SFP training and competence as defined
in the Site Security & Asset Protection Performance
procedure.
Security Control 2
Risk Assessment
Intent
Security risks are identified and mitigations or controls for vulnerabilities are evaluated.
2.1 Conduct an initial Security risk assessment
2.2 Utilize the Security Threat Management procedure to
evaluate security-specific threats
2.3 Document security risk assessments and associated
mitigations.
2.4 Record material risks in the appropriate risk register.
2.5 Update or review the initial Security risk assessment:
annually, prior to commencement of any new activity or
significant or material change to routine activities, or upon
a change in threat or threat level.
2.6 Brief the relevant Divisional President on all material risks.
2.7 Assess risks from Explosive Remnants of War where
appropriate and in accordance with the Threat
Management Plan procedure.
Controls 23
Security Control 3
Plans
Intent
Detailed responsibilities, operating procedures and controls to reduce and mitigate identified vulnerabilities or risks are captured within
an approved security plan.
3.1 Develop a Security Plan in accordance with Site Security &
Asset Protection Performance procedure.
3.2 Review Security Plans as part of the Security Risk
Assessment process and update accordingly.
3.3 Label Security Plans and contingencies as “CONFIDENTIAL”
and share on a need-to-know basis as approved in
accordance with Appendix A.
3.4 Make available for review Security Operating Procedures to
all company personnel assigned to the activity.
Security Control 4
Use of Public and Private Security Resources
Intent
Resources engaged to protect Company personnel and properties are effective and operate within a framework that upholds respect for
individual rights. Public or Private Security forces shall comply with Voluntary Principles of Security and Human Rights.
4.1 Review licensing and authority of Private and Public
Security Resources to be engaged.
4.2 Private security resources comply with all relevant Company
policies and applicable laws including, without limitation:
• The US Foreign and Corrupt Practices Act (FCPA) and all
other relevant anti-corruption laws.
• The Voluntary Principles on Security and Human Rights
(VPSHR).
• Written agreement to the International Code of Conduct
for Private Security providers.
4.3 Encourage Public Security resources to comply with all
relevant Company policies and applicable laws including,
without limitation:
• The US Foreign and Corrupt Practices Act (FCPA) and all
other relevant anti-corruption laws.
• The Voluntary Principles on Security and Human Rights
(VPSHR).
4.4 Receive approval from the Chief Executive BHP Billiton
Petroleum prior to engaging any public or private security
resource that may not adhere to the VPSHR.
4.5 The appointed SFP is to ensure compliance to all VPSHR GLD
requirements by following the Site Security & Asset
Protection Performance procedure.
Security Control 5
Firearms and the Use of Force
Intent
The use of firearms, weapons and the use of force by any security force shall be considered only when all other mitigation options have
been exhausted and there remains an intolerable risk of harm or loss of human life due to an adversarial threat.
5.1 Gain approval for the carriage, storage, or use of firearms
on BHP Billiton Petroleum business by the Chief Executive
BHP Billiton Petroleum. This includes use for both the
protection of human life and stewardship requirements
such as injured livestock management. This control does
not apply to the use of flare guns for emergency purposes.
5.2 Deploy armed security guards only when warranted by a
security risk assessment and approved by the Chief
Executive BHP Billiton Petroleum.
5.3 Comply with the International Association of Oil & Gas
Producers Firearms and Use of Force principles as well as
comply with, or meet the intent of, the Voluntary Principles
on Security & Human Rights as it relates to the
management of firearms, ammunition, and the rules of
engagement for firearms use.
5.4 Brief any responding armed law enforcement or emergency
response officials, legally acting within their appropriate
jurisdiction and official capacity, of associated hazards of
discharging firearms relative to the BHP Billiton Petroleum
activity.
Security Control 6
Security Training and Awareness
Intent
All personnel are appropriately aware of security risks and individual responsibilities are understood and individuals with security
responsibilities are competent to perform specific security duties.
6.1 Include a description of security risks and procedures
during HSEC inductions or orientations and specifically
address: any unique or local security risks; an overview of
security controls in place; individual responsibilities for
preservation of security and incident reporting.
6.2 Implement a process to support all personnel working at
marine facilities or vessels to receive specific maritime
security awareness training in alignment with ISPS Code.
6.3 Train personnel with security duties to perform their duties
as documented in security plans, standard operating
procedures and emergency response plans.
Controls 25
Appendix A
Security and Emergency Management
Approvals Framework1
CSG President
Division President
Head of Gp HSEC
Legal
VP HSE
Country/PU/Project
Mgr
Divisional HSE Mgr
Approve
Asset Protection
Inform
Country/PU/Project
HSE Mgr
Endorse
Country/PU/Project
Security Mgr
Recommend
Selection and appointment of Security employees or
contractors.
As required by BHP Billiton Petroleum HR Approvals
Framework.
Selection and appointment of security consultants or
service providers, including training.
2
Engagement of any security provider not compliant with
the Voluntary Principles on Security and Human Rights.
Design or modification of physical and technical site
security controls.
PU, Project or Country level security procedures and
plans.
PU, Project or Country level journey management
procedures.
Safe travel plans for travel in high, or extreme, risk areas
without established Production Units or Project Controls.
Security risk assessments, when conducted by an
external agency, consultants and non-Asset Protection
personnel.
Deployment of firearms in support of BHP Billiton
Petroleum operations.
1
2
3
These approvals are intended in addition to normal approvals required by the BHP Billiton Petroleum Approvals Framework.
Legal endorsement may be required for contracting of specific security services.
CSG President approval required for travel to destinations rated as Extreme risk.
3
Health and
Hygiene
Health and Hygiene Control 1
Occupational Exposure
Intent
To identify potential or actual health & hygiene exposures and implement measures to eliminate or minimize the risk of adverse health
effects.
1.1
Complete a Baseline Assessment to establish an
Occupational Health & Hygiene Exposure profile.
1.2 Communicate Baseline Assessment findings to the Senior
Manager; relevant Senior Manager direct reports; Central
HSEC team.
1.3 Develop Occupational Health & Hygiene monitoring
strategies associated with the Baseline Assessment.
1.4 Develop and implement Exposure Control Plan(s) to manage
issues highlighted in the Baseline Assessment.
1.5 Communicate findings and proposed plans to affected
personnel.
1.6 Provide targeted training to affected personnel.
1.7 Report on progress against the Exposure Control Plan(s).
1.8 Train persons with responsibilities for managing
Occupational Hygiene Exposures for role.
Fit for Work
Intent
To ensure all personnel are present fit-for-work upon employment and while performing duties assigned.
2.1 Comply with fit for work requirements in accordance with
BHP Billiton Petroleum Health and Hygiene procedures.
2.2 Undertake BHP Billiton Petroleum Medical assessments or
equivalent in accordance with BHP Billiton Petroleum
Health and Hygiene procedures.
2.3 Implement a drug and alcohol testing program in
accordance with the BHP Billiton Petroleum Drug and
Alcohol Procedure.
2.4 Implement a fatigue management program in accordance
with BHP Billiton Petroleum Fatigue Management
Procedure.
2.5 Manage injury and illness cases in accordance with the
BHP Billiton Petroleum Injury & Illness Case Management
Procedure.
2.6 Identify resources to implement systems to manage all
aspects of Fitness to Work.
2.7 Require Site Medical Professionals to be approved by the
BHP Billiton Petroleum Health & Hygiene Manager.
2.8 Require third party medical support to be approved by the
BHP Billiton Petroleum Health & Hygiene Manager.
Controls 29
Reporting and Management Review
Intent
To ensure compliance and quality assurance with Company requirements and regulatory agencies.
3.1 Make available the results of Occupational Exposure
monitoring and surveillance to participating individuals.
3.2 Conduct management reviews of all occupational health
and hygiene programs, incidents and opportunities for
improvement.
Health and Hygiene Controls
Applicability Supplement
Occupational Health
and Hygiene Aspect
Office
Baseline Assessment
Applicable1
Exposure Profile
Applicable
2
Exposure Control Plan
Short Term Projects
Long Term Projects
Production
*Applicable
*Applicable
*Applicable
N/A
*Applicable
*Applicable
*Applicable
*Applicable
N/A
Health and Hygiene
Exposure Reporting
N/A
*Applicable
Health Surveillance
Reporting
N/A
*Applicable
Management Review
Fitness for Work
*Applicable
*Applicable
*Applicable
*Applicable
Office
Short Term Projects
Long Term Projects
Production
*Applicable
*Applicable
*Applicable
*Applicable
Notes
*In accordance with procedure
Short Term Projects – A project with duration of less than or equal to 6 months. (includes Development & Exploration Projects)
Long Term Projects – A project with duration of greater than 6 months. (includes Development & Exploration Projects)
Production includes World Wide Drilling long term rigs
Qualitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure)
1
Quantitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure)
2
Associated Documentation
• Medical Assessment Procedure
• First Aid and Medical Equipment
• Occupational Exposure Management Procedure
(Occupational Hygiene)
• Pre-requisites for Site Medical Professionals
• Injury/Illness Case Management
• Drug and Alcohol
• Assessment for Determination of Occupational Health
Support
• Ergonomics
• Bloodborne Pathogens Questionnaire
• Fatigue Management
• Actions by Sites with a Site Medical Professional
• Medical Protocols for Site Medical Professionals
• Hearing Conservation
• Actions by Sites without a Site Medical Professional
• Respiratory Protection
• Audiometric Testing Process with Work-Relatedness
Determination Process
• Drug and Alcohol Procedure for Workers Regulated by
the DOT
• Travel Medical Kit – Use and Contents
• Health & Hygiene Control Compliance Assessment
Workbook
Controls 31
Aviation
Aviation Control 1
General Requirements
Intent
To manage aviation activities in order to identify, assess and eliminate or minimize aviation related risk.
Implement the following for BHP Billiton Petroleum activity:
1.1 Use aircraft operators approved by Head of Group HSEC
and the BHP Billiton Petroleum Principal Aviation Specialist
(no deviation allowed).
1.2 Conduct aircraft operations in accordance with the
BHP Billiton Petroleum Aircraft Charter Requirements which
includes compliance with the Flight Safety Foundation Basic
Aviation Risk Standard (BARS).
1.3 Have in place a written agreement (contract) with the
charter operator that includes the BHP Billiton Petroleum
Aircraft Charter Requirements and the BARS.
1.4 Require aircraft with two turbine engines and operated by
two qualified pilots for carrying of passengers.
1.5 Manage BHP Billiton Petroleum aviation activities in
accordance with the BHP Billiton Petroleum Aviation
1.6 Engage the BHP Billiton Petroleum Principal Aviation
Specialist prior to the start of any new operation or if there
are significant changes to existing operations.
1.7Conduct Aviation Self Assessments annually.
Controls 35
Marine
Operations
Marine Control 1
Operations Management
Intent
Marine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks
Documentation
1.1
Implement documentation for the management of marine
operations commensurate with activities and associated
risk. The documentation must cover:
• Compliance with the requirements in this Control and
local marine operations regulations (e.g., MOM for
USCG, Safety Case for NOPSA).
• Conformance to the Marine Operations Framework
Process.
• Conformance to the requirements of the BHP Billiton
Petroleum Marine Operations Documentation Procedure.
• Vessel specific types and operational work scope.
• Roles, responsibilities and training requirements for key
marine operations personnel.
• Site and/or field data required to support the execution
of the BHP Billiton Petroleum marine operations.
• Process for conducting risk assessments requirements
outlined in the Marine Operations Control document.
• Emergency response plans.
• Identified critical controls and established performance
standards.
• Processes for testing critical controls associated with
emergency response procedures prior to commencement
of activities and periodically thereafter against a
schedule of drills.
• Suitable procedures for storm avoidance and/or
emergency down-manning.
• Berthing and Terminal Handbook for off take operations
(see Marine Operations Control 6.4).
Marine Operations Risk Assessment
1.2 Evaluate marine operations HSEC risks in accordance with
the BHP Billiton Petroleum Hazard and Risk Management
Controls for:
• Use of a new build vessel or a vessel under construction
prior to engagement.
• Use of a vessel undergoing modification, or requiring
modification or conversion prior to commencement of
the modification works.
• Offshore and onshore personnel transfers.
• Changes to a routine marine operation.
• Changes to regulatory or other requirements.
• Changes to environmental and/or operational
conditions.
1.3 Engage responsible managers and other relevant personnel
to participate in Marine Operations risk assessments.
1.4 Obtain Principal Marine Specialist endorsement where
Marine Operations risk assessments identify material risks.
Emergency Response Plans
1.5 Implement an emergency response plan for management of
Marine Operations. The plan must take into account:
• The roles and responsibilities of emergency response
personnel from BHP Billiton Petroleum and third party
marine contractors such as vessels operators or off-take
tanker operators.
• Documented lines of communications between
BHP Billiton Petroleum and relevant marine third parties.
• Oil spill response plans based on nature of the product,
likely dispersion and available response resources. Oil
spill response plans must include coordination with
BHP Billiton Petroleum Marketing for transport of
petroleum products.
• Local emergency response capabilities.
• Methods for recovering people falling overboard and
contingency plans for recovery of people at imminent
significant risk during personnel offshore and onshore
personnel transfer.
• Hazards associated with the surrounding environment.
Controls 39
Marine Control 1
Operations Management (continued)
Intent
Marine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks.
1.6 Exercise the Emergency Response plan(s) annually and if
practicable within 30 days of a new operations start. Tests
and exercises should be designed to include:
• Worst case scenarios covering weather, hours of
darkness and availability of response resources.
• Effectiveness of bridging documentation between the
third party marine contractors, operators, other
emergency response resources (e.g., oil spill resources)
and BHP Billiton Petroleum.
Communication
1.7 Communicate relevant Marine Operations documentation
including the outcomes of the risk assessment to
stakeholders, including affected employees and
contractors.
Review
1.8 Update Marine Operations documentation including the
outcomes of the risk assessment to reflect temporary
changes to any critical controls or when there are events
such as brownfield projects, seismic campaigns and dive
support vessel activities.
1.9 Review Marine Operations documentation including
outcomes of the risk assessment annually. The review must
involve personnel from affected functions and the Principal
Marine Specialist. The review must consider as a minimum
the following:
• Changes in operational scope
• Procedural changes
• Changes in regulatory requirement
Variances
1.10 Obtain an approved BHP Billiton Petroleum HSEC Variance
Form in circumstances where the requirements of this
Controls document cannot be met prior to commencing
Marine Operations activity.
Variances to this procedure must be approved by:
• Principal Marine Specialist
• Contract Line Manager
• Project Manager
For Variance Requests where the Functional Specialist has
assessed the consequence as an actual or potential
significant event, additional approval is required from:
• Vice President HSEC
Marine Control 2
Contracting of Vessels
Intent
Marine vessels and marine operations suppliers are audited and verified as qualified to meet the requirements of the Marine Operations
Controls prior to use.
Selection, Approval and Engagement of Marine
Operations Suppliers
2.1 Obtain the endorsement from the Principal Marine
Specialist regarding the use of marine vessels and marine
operations contractors to ensure the appropriate
specification, terms and conditions and written agreements
are applied as follows:
• Tender process
• Contract award
2.2
2.3
2.4
2.5
2.6
2.7
2.8
• Changes to existing contracts
Include a copy of the Marine Operations Controls and the
BHP Billiton Petroleum Marine Audit Procedure in Tender
documentation relating to marine operations contracts.
Obtain approval from the Principal Marine Specialist for the
use of all contracted marine vessels prior to engagement.
Audit all marine vessels prior to contract award according
to the requirements of the BHP Billiton Petroleum Marine
Audit Procedure.
Complete all high level and HSEC critical audit findings, as
defined in the BHP Billiton Petroleum Marine Audit
Procedure, prior to contract execution (e.g.,
commencement of field activities or construction activities).
Variation from this requirement must be endorsed by the
Principal Marine Specialist or delegate.
Obtain endorsement from the Principal Marine Specialist
for the closure of high level and HSEC critical marine audit
findings.
Obtain endorsement from the Principal Marine Specialist
for the proposed modifications to marine vessels;
modifications to critical equipment must be approved by
the Divisional President.
Exempt vessels that have been independently audited
within the last 12 months from a BHP Billiton Petroleum
audit subject to a review of the findings and status of the
associated actions by the Principal Marine Specialist.
New Build Vessels and Vessel Modifications
2.9 Subject new build dynamically positioned vessels and
existing vessels with modified1 DP systems to a Failure
Mode and Effects Analysis (FMEA) together with
appropriate proving trials; the scope of sea trials and the
FMEA must be endorsed by the Principal Marine Specialist.
2.10 Subject new build vessels and vessels undergoing
modifications to the propulsion, steering or hull dynamics
to appropriate sea trials; the scope of sea trials and the
FMEA must be endorsed by the Principal Marine Specialist.
Bridging Documentation
2.11 Prepare bridging documentation in accordance with
Element 10 of the BHP Billiton Petroleum HSEC
Management System Framework.
2.12 Address in the bridging documentation differences and
interface processes between BHP Billiton Petroleum and the
marine contractor, including:
• Communication protocols that cover:
-- Normal activities
-- SIMOPS
-- Incident reporting
• Roles and responsibilities.
• Coordination of emergency response plan.
2.13 Communicate the bridging documentation to all affected
personnel.
Marine Operations
2.14 Comply with the Marine Operations Framework Process
when contracting vessels.
A modification means any substantial changes that would require
Classification Society approval.
1
Controls 41
Marine Control 3
Facility Safety Zones
Intent
Marine safety zones are established and managed at BHP Billiton Petroleum and contracted third party facilities (including MODUs).
Establishment of Safety Zones
3.1 Establish and maintain a Facility Safety Zone for Offshore
facilities as follows:
• A minimum distance of 500m or as required by
regulations.
• Define provisions for monitoring the safety zone.
• Define activities permitted within the safety zone.
• Define critical controls to manage activities in the safety
zone including the Facility Safety Zone Check Sheet.
• Define controls for SIMOPs in the safety zone.
• Communicate information concerning the safety zone to
relevant stakeholders, including affected employees,
contractors and contractor vessels.
Marine Operations within Safety Zone
3.2 Complete Part A of the Facility Safety Zone Check Sheet and
obtain approval from the Facility OIM prior to entering the
safety zone.
3.3 Complete Part B and Part C of the Facility Safety Zone
Check Sheet and obtain approval from the Facility OIM prior
to the following respective phases:
• Commencement of work within the safety zone (Part B).
• Departure from the Facility Safety zone (Part C).
3.4 Keep the Facility Safety Zone clear except for vessel
operations and activities approved by the Facility OIM.
3.5 Require vessels to keep clear or to depart the Facility Safety
Zone when unable to maintain position or are experiencing
degradation of station keeping capability.
Third Party Facilities
3.6 Establish Facility Safety Zones for third party contracted
operations such as drill rigs, heavy lift vessels or flotels in
accordance with this control and document relevant
aspects in the associated bridging documentation.
Marine Control 4
Personnel Transfer
Intent
Personnel transfer risks are controlled to ensure the safe transfer of personnel.
Offshore Personnel Transfers
4.1 Conduct a risk assessment prior to initial commencement of
offshore personnel transfer activities, to identify the most
appropriate means of transfer and relevant controls.
Personnel transfer methods include:
• By helicopter
• Basket transfers
• Boat to Boat Transfer
• Davit to Davit Transfer
• Swing Rope
4.2
4.3
4.4
4.5
4.6
4.7
4.8
• Temporary bridges
Consider helicopters as the preferred primary means of
personnel transfer to vessels and facilities with a certified
helideck. All helicopter operations must meet the
requirements of the Aviation Operations Controls.
Prohibit the use of collapsible personnel transfer baskets
(e.g., Billy Pugh X-800 series nets or similar) must not be
used.
Use only rigid personnel transfer baskets (e.g., Billy Pugh
X-904 and Reflex Marine FROG) or offshore personnel
transfers.
Conduct marine personnel transfers under a lift plan in
accordance with the BHP Billiton Petroleum Lifting
Equipment Control and Operations Procedure. Personnel
basket transfers must also comply with the BHP Billiton
Petroleum Personnel Transfer and Man-Riding Procedure.
Prohibit personnel basket transfers during the hours of
darkness with the exception of emergency situations.
Assign a designated person to supervise the transfer
operation at each of the landing zones.
Subject all lifting equipment utilized in basket transfer
operations to a visual inspection by a competent person
such as a certified rigger prior to use.
Offshore Temporary Bridge
4.9 Inspect and certify “fit for purpose” all temporary bridges,
landing platforms and securing arrangements.
4.10 Clearly mark and keep free of obstructions access and
egress to temporary bridges.
Dockside
4.11 Require use of a gangway or accommodation ladder for all
BHP Billiton Petroleum owned or contracted vessels
alongside docks.
4.12 Install gangways and ladders in accordance with the
manufacturer’s design and operating requirements.
4.13 Use an approved safety net as a supplement for gangways
and accommodation ladders.
4.14 Provide safe means of access for personnel transfer
between vessels rafted alongside each other.
4.15 Require the use of a designated person supervising transfer
operations between vessels rafted alongside each other.
4.16 Conduct a risk assessment to determine the requirements
for additional means of access/egress for vessels/facilities
in shipyards. (e.g., two gangways).
Familiarization and Orientation
4.17 Brief personnel undertaking offshore marine transfers prior
to commencing the initial transfer and then at ongoing
intervals, the frequency of which is determined based on:
• The assessed risk and nature of the transfer method.
• Applicable regulatory requirements.
• Helicopter transfers require safety briefing prior to each
flight, as per the BHP Billiton Petroleum Aviation
Operations Controls.
4.18 Include the following in the user briefing:
• An overview of the transfer method type
• Hazards and risk management controls
• Emergency procedures
• Communication protocols (if required)
Controls 43
Marine Control 5
Transfer of Supplies
Intent
Safe and environmentally responsible transfer of supplies (excluding petroleum products such as crude) to and from BHP Billiton
Petroleum facilities and/or to and from contracted third party vessels.
Cargo transferred by Crane
5.1 Manage crane cargo transfers in accordance with the
BHP Billiton Petroleum Lifting Equipment Control and
Operations Procedure.
Liquid Bulk Transfer
5.2 Comply with the Marine Containment Audit Check Sheet
when vessels are engaged in bulk transfer activities.
5.3 Manage bulk transfer activities under a permit-to-work.
5.4 Implement a process to support using dedicated bulk
transfer hoses for the transfer of a single substance “type”
only (e.g., diesel, potable water, brine). Bulk transfer hoses
must not be used for the transfer of other materials.
5.5 Maintain direct line of sight during cargo transfer activities
between the vessel’s master and the bulk hose(s).
5.6 Use bulk transfer hoses which have the capacity to remain
afloat at all times. Where the inherent buoyancy of the hose
is insufficient to support a particular product additional
flotation devices must be provided.
5.7 Provide adequate illumination where bulk cargo transfers
take place during hours of darkness. All hoses and the
support vessel must be illuminated prior to, and throughout
the transfer operation. Hoses should be fitted with
retro-reflective material when illumination cannot be
consistently maintained.
5.8 Use dry break couplings on hoses used for bulk transfer of
petroleum, petroleum based products, and brines (for
example Avery Hardoll or TODO couplings). Additionally,
there must be a weak link breakaway coupling (for example
a KLAW coupling) within the hose string.
5.9 Provide vessel Masters with a completed Dangerous Goods
Declaration and MSDS (material safety data sheet) prior to
commencement of loading or back-loading dangerous
goods.
5.10 Conduct a risk assessment prior to back-loading
contaminated supplies onto a vessel for transport onshore.
5.11 Obtain approval from the vessel master and the shore base
manager prior to back-loading contaminated supplies onto
a vessel for transport onshore.
Project Execution Plans
5.12 Conduct a risk assessment as part of the Project Execution
Plan for project related transfers, (e.g., pipe bundles, sub
sea lifts and heavy lifts).
Marine Control 6
Off-Take Tanker Operations
Intent
Tanker operations for petroleum products (including crude, condensate, LPG and LNG) to and/or from BHP Billiton Petroleum facilities
are conducted using safe and environmentally responsible methods.
Tanker Vetting & Inspection
6.1 Implement a formal Off-take tanker vetting arrangement
using an approved marine tanker vetting company.
6.2 Audit the approved marine tanker vetting company on an
annual basis to ensure compliance with industry vetting
standards.
6.3 Use tankers for the off-take of petroleum products which
have undergone a formal vetting and inspection process in
accordance with OCIMF and meet the BHP Billiton
Petroleum Vetting and Operating Standards.
Facility/Tanker Operations
6.4 Develop and maintain a Berthing and Terminal Handbook in
accordance with the Marine Operations Document
Procedure for the management of tanker off-take activities.
6.5 Include the following in the Berthing and Terminal
Handbook:
• Terminal/location details
• Communications plan (including applicable VHF
channels)
• A site specific lifting vessel questionnaire
• Relevant regulatory requirements
• Availability of bunkers, potable water and stores
• Any restrictions on crew transfers (except in case of
emergency)
• Roles, responsibilities and training requirements for
personnel associated with critical controls
• Operating limits/requirements at the facility/berth
(e.g., max deadweight tonnage and displacement, vapor
recovery, ballast)
• Environmental limitations
• Engine and steering gear tests required prior to the
commencement of approach
• Pilotage and pilot boarding controls
• Insurance requirements (Protection & Indemnity)
• Mooring procedures including inspection requirements
prior to mooring
• Pollution prevention and preparedness controls
including coordinated emergency response plans
• Hose connection and disconnection, including
emergency disconnect procedures
• Cargo operations
• Where the off-take tanker requires assistance by a vessel
on static tow during the off-take, a procedure is required
for the static tow
6.6 Communicate relevant aspects of the Berthing & Terminal
Handbook to stakeholders including Joint Venture Partners,
customers and vessel owner/operators.
6.7 Test critical controls associated with emergency response
procedures prior to commencement of off-take activities
and periodically thereafter against a schedule of drills.
Joint Interest Unit Operations
6.8 Assess management of off-take arrangements and any
other Terminal Controls against requirements of the
BHP Billiton Petroleum Marine Operations Off-Take Tanker
Controls.
6.9 Engage BHP Billiton Petroleum Principal Marine Specialist
where a material risk has been identified.
Controls 45
Fatal Risk
Fatal Risk Control 1
Road Going and Light Vehicles
Intent
Select, equip, operate and maintain Road Going & Light Vehicles to protect personnel (including pedestrians) from harm and prevent the
risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant
For new acquisitions of Road Going and Light Vehicles
1.1
Acquire new BHP Billiton owned or leased light vehicles
which have a 5 Star NCAP (USA- NHTSA or IIHS) safety
rating. This includes the safety features referenced in
Appendix B. See Appendix B for NCAP, NHTSA and IIHS
details.
Existing Road Going and Light Vehicle fleet
1.2 Implement a process to support all BHP Billiton owned or
leased light vehicles having a 5 Star NCAP or equivalent
safety rating by 1st January 2016. In the intervening period,
existing vehicles must have the safety features referenced
in Appendix D.
Support Equipment
1.3 Fit company owned or leased vehicles being used at site or
on direct company business with support equipment as
defined by location specific risk assessment (this does not
apply to personal vehicles used temporarily on business
travel). See Appendix B for examples of support equipment.
People
Competence Management
1.4 Use and manage competent drivers (employees and
contractors) as follows:
• Operate vehicles with certified, licensed drivers.
Procedures
Light vehicle management process.
1.5 Inspect and maintain vehicles as follows:
• Implement a formal inspection & preventative
maintenance system in keeping with manufacturer
guidance.
• Identify and manage high-risk road journeys.
• Implement emergency response arrangements to
mitigate consequences of accidents or break down risk.
• Comply with BHP Billiton Petroleum Management of
Change (MoC) Process with regard to vehicle
modifications (company owned & leased vehicles only).
• Prohibit installation of aftermarket equipment to 5 Star
NCAP vehicles (other than special purpose light vehicles
such as ambulances) except where necessary to meet the
requirements of visibility and communications
equipment.
1.6 Comply with Traffic Management Plan requirement for a
minimum safe distance to be maintained between light
vehicles and mobile equipment when light vehicles are used
within a facility.
Notes: See Appendix B for supplementary information regarding
Road Going and Light Vehicles.
• Comply with local regulatory certification requirements.
• Comply with company defined requirements inclusive of
training on defensive driving.
• Implement a process for identifying and managing
at-risk driving behaviours.
• Prohibit the use of mobile phones by drivers, including
hands-free applications, unless the vehicle is stopped at
a safe location.
Controls 49
Mobile Equipment
Intent
Select, equip, operate and maintain Mobile Equipment to protect the workforce and the public (including pedestrians) from harm and
prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant
Safety Features
2.1 Select mobile equipment appropriate for the function and
cargo to be carried or task to be performed. This includes
the safety features referenced in Appendix B.
Support Equipment
2.2 Fit mobile equipment with support equipment as defined by
risk assessment. See Appendix B for examples of support
equipment.
Access and Egress
2.3 Provide safe access and egress, including:
• Emergency egress, from mobile equipment.
• Safe systems of work for operation and maintenance of
components where there is a potential to fall two or
more meters, or where a fall could result in a significant
incident.
Equipment Management Risk Mitigation
2.4 Manage equipment operation and maintenance to:
• Prevent uncontrolled movement of vehicles and mobile
equipment during operation and repairs.
• Mitigate risks from towing and recovering mobile
equipment, loading and unloading of cargo to prevent
dropped objects, spillage or un-planned movement of
loads.
People
2.5 Use and manage competent people:
• Operate mobile equipment using certified, competent
drivers. This includes local regulatory and company
defined requirements.
• Identify and manage at-risk driving behaviours.
• Prohibit the use of mobile phones by drivers, including
hands-free applications, unless the vehicle is stopped at
a safe location.
Procedures
Mobile Equipment Management Process
2.6 Implement a defined process for management of mobile
equipment which includes the following:
• A documented formal inspection & preventative
maintenance system for mobile equipment and
registered heavy vehicles; inclusive of checks required
prior to operation and appropriate action to be taken if
defects are identified.
• Define requirements for the isolation of mobile
equipment in line with the BHP Billiton Petroleum Fatal
Risk Control - Isolation and Permit to Work.
• Require compliance with BHP Billiton Petroleum
Management of Change (MoC) Process with regard
to vehicle modifications (company owned & leased
vehicles only).
2.7 Develop a process for management of traffic which
includes:
• Use of an authorized traffic management plan (see
Appendix C).
• A process to identify and manage high-risk road
journeys.
• Emergency response arrangements to mitigate
consequences of accidents or break down risk.
Explosives
Intent
The transport, storage and usage of explosives and initiating components must only be performed by trained, competent and authorised
employees and contractors in strictly managed and controlled environments for the security of explosive materials and protection of
personnel.
Plant
Explosives Register
3.1 Define and document in a register the approved types
of explosives to be used for supporting BHP Billiton
Petroleum activities.
People
3.2 Engage third party specialists in the management and use
of explosives who are suitably qualified as per
manufacturers, regulatory and BHP Billiton Petroleum
requirements.
3.3 Educate impacted personnel about access control to
support effective management of blasting activity.
Procedures
Explosives Management Process
3.4 Develop and implement an Explosives Management
Procedure which includes the following:
• Defined processes for management of all stages of
operations involving the use, transportation, storage,
handling and disposal of explosives.
• Defined training and competency requirements for
transport, storage, handling and usage of explosives and
initiating components.
• Process for control access to areas of blasting activity,
including clearance zones for potentially affected areas.
• Process for mitigating the risks of equipment operating
in the vicinity of loaded holes or explosives remnants.
• Process for management of simultaneous operations
‘use of explosives’ is involved.
• Emergency Response arrangements when explosives are
involved.
• Process for managing the risk of misfires and the
destruction of old explosives.
• Process for identifying and managing the risks of
blasting in hot or reactive ground. See BHP Billiton
Glossary of Terms.
3.5 Supplementary Requirements
• Comply with all applicable local laws and regulations
controlling use of explosives.
• Comply with manufacturers, regulatory and BHP Billiton
Petroleum requirements as it relates to the packing of
explosives, inclusive of secondary boxes.
• Comply with manufacturers, regulatory and BHP Billiton
Petroleum requirements as it relates to support
documentation for explosives.
Explosives.
Controls 51
Hazardous Materials
Intent
Process, store, handle, produce, transport, recycle and dispose of hazardous materials to protect personnel from harm and prevent the
Plant
Hazardous Material Risk Mitigation
4.1 Implement the following arrangements:
• Locate vessels, containers, bulk stores and process areas
containing hazardous materials within areas of adequate
design and size to safely contain spills and allow for
effective response to spills.
• Identify vessels, containers or pipes containing
hazardous materials by appropriate signage or labels
and, where relevant, clearly indicate the direction of
flow.
• Equipment associated with hazardous materials must fail
to a safe condition in the event of interruption to
electric, hydraulic or pneumatic power supply.
• Segregate hazardous materials from incompatible
materials.
• Install detectors/monitoring appropriate to the hazard
where there is the potential for exposure to harmful
levels of flammable or toxic materials.
• Identify and make available Emergency Response
equipment associated with Hazardous Materials
operations.
People
4.3 Training, Access and Monitoring
• Provide personnel with information and training on the
nature of the hazards to which they may be exposed and
the means of assessing and controlling their exposure.
• Educate personnel about the importance of adhering to
access control requirements.
• Assess and monitor health of personnel involved in
hazardous materials management activities.
Procedures
Hazardous Materials Management
4.4 Conduct an initial risk assessment as follows:
• Conduct a ‘basis of design’ process hazard analysis
(PHA) for new, modified or temporary processes which
transports, produces, stores, uses or disposes of
hazardous materials.
• Update “As-built” design drawings based on findings
from PHA.
4.5 Manage Hazardous Materials as follows:
• Complete a PHA and define required controls before any
new hazardous materials are first used.
• Maintain a site register of hazardous materials.
• Maintain copies of all relevant design input and output
records including those from risk assessments
throughout the life of the plant.
• Maintain Material Safety Data Sheets (MSDS) for
hazardous materials and make them accessible for
involved personnel.
• Access control appropriate to the identified risk for the
process, storage and handling areas of hazardous
materials.
• Implement an appropriate maintenance system to
support the safe operation of equipment involved in
processing hazardous materials.
Management of Temporary Powered Equipment
4.2 Implement the following arrangements for the use of
Temporary Powered Equipment:
• Site Temporary Powered Equipment in an appropriate
zone that conforms with regulatory and BHP Billiton
Petroleum requirements to minimize potential negative
interaction with hazardous materials.
• Equip Temporary Powered Equipment with appropriate
protective devices for use in those defined zones which
include automatic shutdown devices, over-speed
protection, spark arrestors, protected exhaust
manifolds, non-flammable fuel lines, pneumatic starter
motors.
• Make available, relevant procedures, associated
documentation and records for the management of
Hazardous Materials.
• Address identified risk from Hazardous Materials in the
site Emergency Response Plan.
Isolation and Permit to Work
Intent
Plan and manage phases of work, tasks, locations, machinery, vehicles and mobile equipment requiring a permit-to-work, or isolation of
energy sources to safely perform work (including de-energisation of stored energy) to protect personnel from harm.
Plant
Purchasing and Design
5.1 Purchase equipment which meet the requirements of this
control (this includes hired and contracted temporary
equipment)
5.2 Identify any points of isolation.
5.3 Provide personnel performing the work with unique,
secure, control of the points of isolation prior to
commencing work.
People
Use and Manage Competent People
5.4 Authorization, Training, Accountabilities
• Specify who can authorize the issue of a permit-to-work.
• Establish the training and competency requirements for
permit issuers, permit holders and persons performing
isolations inclusive of lock-out/tag-out.
• Define the responsibilities and accountabilities of the
permit issuer, individual permit holders and persons
performing isolations.
Procedures
Isolations and Permit to Work (PTW) Management
5.5 Implement an Isolations and PTW procedure(s) which
include the following processes:
• Identify and document all sources of stored energy
which could impact the planned activity.
• Identify and document the hazards.
• Identify, document and implement appropriate
prevention and mitigation controls to manage the
hazards associated with the planned activity.
• Identify and document isolation points.
• Safe management of identified isolations.
• Safe management of breaking of containment.
• Permit to Work management.
• Defined controls which apply to personnel accessing
machinery that may start and stop automatically or by
instruction from a remote location.
• Control and approval of software overrides, hard-wire
bridging or interlock bypassing.
• Control of isolations and permits-to-work which span
one or more shift handovers.
• Definition of how a competent person will prove safe
isolation is achieved before commencing work.
• Determination and description of actions required if
there is any doubt safe isolation was achieved.
• Management of permits-to-work and isolations for
interacting with simultaneous activities.
• Work authorization by a responsible person.
• Verification that all personnel undertaking work
requiring a permit understand the hazards being
controlled by the permit, the permit conditions to be
met, isolation standards to be achieved and the control
of simultaneous operations (SIMOPS) activities.
• Authorization of changes which may affect the scope of
the permit-to-work and/or the isolation standard(s)
required, including a re-assessment of the hazards,
potential impact on other operations, changes to
planned tasks and the action to be taken by the
permit-holder in response to an emergency.
• Verification that isolated equipment/plant is returned to
a safe operating condition before equipment/plant is
brought back into service.
Isolation and Permit to Work.
Controls 53
Equipment Safeguarding
Intent
Manage the interaction between personnel and moving parts of plant and equipment to protect personnel from harm and prevent the
Plant
Design, Modifications and Controls
6.1 Design plant and equipment as follows:
• Eliminate the need for guarding where practicable in
new, temporary or modified plant and equipment. All
energy sources must be considered. Safeguarding must
be in place where other potential mitigation measures
do not adequately protect personnel.
• Design and construct plant and equipment safeguards to
comply with applicable law, standards, codes of practice
and relevant recognized industry practices and
considering maintainability and operability.
• Install fail-to-safe switches or devices on all manually
operated rotating plant, rotating equipment and power
hand tools (e.g., saws, lathes, drill presses, etc.).
• Retain and control all documentation related to the
risk-based process for the selection of safeguarding
requirements.
People
Separate People from Moving Parts
6.2 Control and monitor access to plant and equipment where
safeguarding and interlock systems are assessed as
insufficient to protect people.
Procedure
Equipment Safeguarding Management Process
6.3 Implement the following via procedure:
• Do not modify or alter guarding except through the
application of the BHP Billiton Petroleum Management
of Change (MoC) process.
• Retain and control all documentation related to the
risk-based process for the modification of safeguarding
requirements.
• Use the BHP Billiton Petroleum Management of Change
(MoC) process to ensure the integrity of safeguarding is
addressed when change occurs.
• Conduct a Process Hazard Analysis (PHA) to identify
where safeguarding and interlocks are required on plant
and equipment.
• Implement a formal inspection and maintenance system
to ensure the integrity of plant and equipment
safeguarding.
• Remove guards for maintenance and repair only after
plant and equipment has been isolated, and verified as
isolated (proved isolated) in line with the BHP Billiton
Petroleum Fatal Risk Control - Isolation and Permit to
Work.
• Where the temporary removal of safeguards is necessary
on operating plant and equipment, for the purposes of
fault finding, testing and commissioning, a PHA must be
conducted.
• Guards must be re-instated prior to plant and equipment
being put back into operation.
Working at Height
Intent
Manage Work at height activities where there is a potential to fall two meters or more, where a fall could result in a significant incident,
or where there is the danger of dropped objects from the work being performed.
Plant
Design and Controls
7.1
Design new plant and equipment and plan tasks to
minimize the need to work at height where a fall could
result in a significant incident, or where there is the danger
of dropped objects from the work being performed.
7.2 Provide a secure working area of suitable design and
strength where work at height is unavoidable. This working
area must include:
• Flooring securely fastened in place so it cannot be
accidentally dislodged.
• Mesh, railings or solid barriers to prevent a person
falling.
• Toe-boards or similar means to prevent tools and
materials falling off the edge of the platform.
7.3 Provide a fall arrest or fall restraint system if a fixed ladder
is used and a work at height risk exists.
7.4 Require fall arrest and fall restraint systems to:
• Have lanyards and snap-hooks with a secondary locking
mechanism.
• Be used in a manner which ensures the user is able to
achieve 100% tie-off 100% of the time.
• Incorporate a shock absorber when using a fall arrest
system.
7.5 Protect personnel from objects dropped or dislodged by
personnel working at height by using barricades, warning
signs and tool lanyards.
Procedure
Work at Height Management Process.
7.9 Prohibit the use of portable ladders unless provision of a
secure working area is not reasonably practicable.
7.10 Prohibit the use of portable ladders for tasks at heights
exceeding 9 meters.
7.11 Require personnel to use a fall arrest or fall restraint system
where provision of a secure working area is not reasonably
practicable. The system must incorporate a full body
harness attached to anchor points and or safety lines
designed to withstand the maximum dynamic load from all
persons attached to the anchor point and/or safety line.
7.12 Require personnel working in Mobile Elevated Work
Platforms (includes cherry pickers, scissor lifts and
vehicle-mounted booms) or suspended work baskets to
wear a fall restraint system attached to an anchor point in
the basket, which is designed to withstand the maximum
dynamic load from all persons attached.
7.13 Inspect work at height equipment prior to use and clearly
show compliance with periodic inspection with marks or
tags.
7.14 Prohibit personnel from working alone when using a fall
arrest system.
7.15 Develop a plan for immediate response to a person
suspended in a harness within a time to prevent suspension
trauma.
People
7.6 Engage third parties who are suitably qualified to execute
specialist Working at Height activity.
7.7 Educate people about their required role to support
effective management of Work at Height activity.
7.8 Personnel who work at height must have no Fit to Work at
Height restriction.
Controls 55
Lifting Operations
Intent
Manage lifting operations to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton
Plant
Positioning, Illumination and Protection
8.1 Use lift equipment appropriate to the activity.
• Install and correctly position lifting equipment to
eliminate the risk of the equipment or a load striking a
person.
• Illuminate lifting operations appropriately.
• Provide cranes with electrical/mechanical overload
protection and, except for automated cranes, calibrated
load cells with a display clearly visible to the operator.
• Provide load moment indicators on cranes, other than
electric overhead travelling cranes, portal cranes or
automated stacker cranes.
People
Training and Competence
8.2 Plan and execute lifts safely.
• The level of planning will be appropriate to the
complexity of the lift.
• Plan and execute lifts using trained, certified, competent
and authorized personnel.
Procedure
Lifting Operations Management Process
8.3 Operate, maintain, inspect, test and certify cranes and
lifting equipment using approved standards, systems and
procedures.
• Define and manage the operational area to prevent the
risk of injury from the equipment or the load.
• Mark all lifting equipment to show the safe working
load.
• Undertake defined periodic examination and testing of
cranes and lifting equipment using a competent person.
• Mark lifting equipment clearly to confirm compliance
with the periodic examination requirements.
• Implement a process to clearly identify and quarantine
damaged or out-of-certification lifting equipment.
• Implement a process to identify and manage the risk of
sling roll-out from the hook.
• Develop clear criteria for what constitutes a complex lift
and require such lifts to have a lift plan.
• Implement a process to verify the ground is suitable for
safe operation of cranes and, where they are fitted,
deploy outriggers.
• Provide operating manuals and load charts in a language
understandable to the crane operator.
• Certify cranes and any associated equipment used for
lifting personnel.
Dropped Objects
Intent
Manage potential dropped objects to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP
Billiton Petroleum activities.
Plant
Secure Potential Dropped Objects
9.1 Identify and manage potential dropped objects
• Assess permanently installed equipment suspended
more than 2 meters above ground to determine the
requirement for primary and secondary securing
mechanisms in order to prevent dropped objects.
• Implement an in-built secondary securing device
(e.g., nuts with split pin or securing wire) on the primary
securing mechanism; where an external secondary
securing mechanism is deemed unnecessary or
impractical.
9.2 Comply with relevant approved design standards,
manufacturers specifications and local regulations for the
following:
• permanent structures
• temporary structures
• plant and equipment
• portable elevated work platforms
• movable elevated work platforms
• suspended work baskets
• scaffold structures
People
9.3 Engage third party specialists who are suitably qualified to
identify potential dropped objects to conduct scheduled
Dropped Object assessment inspections.
9.4 Educate personnel about the risks of potential dropped
objects and their role in supporting the process.
Procedure
Dropped Objects Management Process
9.5 Implement a dropped object management system. The
system must include the following provisions:
• A register of all structural objects that have the potential
to drop.
• Control strategies for managing these objects.
• Assessment of the impact of weather on these potential
dropped objects or work associated with these objects.
• Associated maintenance arrangements inclusive of
inspections.
• A process which manages temporary tools and
equipment being taken aloft, inclusive of a return to a
safe location at the end of work activity.
• A process to ensure contractor-owned and contractoroperated equipment, third-party equipment, and
equipment hired or contracted directly for BHP Billiton
Petroleum activity complies with this Fatal Risk Control
before usage.
Dropped Objects.
Controls 57
Working with Pressure
Intent
Manage pressurized equipment to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to
BHP Billiton Petroleum activities.
Plant
Design
10.1 Design, construct, test, inspect, place into service and
maintain pressure equipment, regardless of pressure rating,
in accordance with appropriate internationally recognized
industry standards.
10.2 Design and install storage and racking systems with
positive latching retaining bars that prevent pressurized
bottles/containers from tilting out of the rack.
10.3 Mark with a unique identifier and verified maximum
working pressure, all new and refurbished/repaired
pressure vessels as defined by API codes.
10.4 Label pressure containing equipment to identify contents
and pressure. This must include all buried pipelines/
flow-lines and associated rights-of-ways.
10.5 Provide a means of safe isolation for all instrument
connections on pressure containing systems.
10.6 Use pipe-work in the following order of preference:
1.Fixed pipe-work (temporary or permanent)
2.Flexible type steel piping (temporary or permanent)
3.Temporary pipes connected with swivel joints
10.7 Provide permanent piping systems with properly
engineered and installed piping clamps and restraints;
design must factor in vibration and thermal effects on the
piping and restraints.
People
10.8 Use persons who are trained in: Job Risk Assessment,
Isolations and Permit to Work; Emergency Response; Lock
Out/Tag Out; Safe pressure testing practices. These
personnel must wear appropriate PPE during pressure
testing.
Procedure
Working with Pressure Management
10.9 Implement a maintenance program which includes the
following:
• Verification of ratings and currency of pressure testing
equipment prior to usage.
• Inclusion of pressure containing equipment in the
planned maintenance system.
• Verification of performance standards and certifications
where pressure equipment classed as “Critical”.
• Clamp or restrain flexible hoses and temporary piping to
prevent whipping in the event of a connection failure.
10.10Implement procedure(s) to cover the following:
• Visual inspection for transit and other damage; thread
and sealing surfaces integrity; flanges and bolts being fit
for purpose.
• Use a documented “handover procedure” to transfer
responsibility to the testing authority. This procedure
must include verification of torque requirements/
methodology and system isolation points/methods.
• Incorporation of an exclusion zone for pressure testing;
pressure testing with gases must be approved; pressure
testing with volatile/flammable fluids is not permitted;
pressure testing must be conducted in accordance with a
written procedure and supporting Job Risk Assessment.
Presence of Hydrogen Sulphide (H2S)
Intent
Manage exposure to hydrogen sulphide (H2S) to protect personnel from harm and prevent the risk of fatalities, injuries and incidents
related to BHP Billiton Petroleum activities.
Plant
Design
11.1 Design, construct, and maintain equipment that is required
for H2S service using materials suitable for H2S service
(e.g., NACE Standard MR 0175-96, Standard Material
Requirements: Sulphide Stress Cracking Resistant - Metallic
Materials for Oilfield Equipment).
11.2 Label systems and piping that contain H2S.
11.3 Secure potential exposure points from public access
through the use of fences, locked gates and warning signs.
11.4 Identify and make available Emergency Response
equipment associated with H2S operations.
People
Procedure
H2S Management
11.7 Assess the likelihood of encountering H2S each time a new
hydrocarbon source is introduced; an existing source is
being worked upon or reservoir analysis indicates the
requirement for such a review.
11.8 Define and implement an appropriate H2S Management
System inclusive of controls and mitigations. This includes
the use of fixed, portable, personal detection systems;
breathing air and associated equipment for normal work
activity; emergency escape; emergency rescue; emergency
drills; muster points; use of aids such as wind socks;
associated maintenance systems.
11.9 Assess the potential impact of H2S exposure to the public
and implement relevant controls as part of the Emergency
Response Plan.
11.5 Train persons involved in BHP Billiton Petroleum activity
with potential for exposure to H2S; visitors must receive
adequate training to support safe operations for the
duration of their stay.
11.6 Require persons involved in H2S Emergency response are
clean shaven to minimize exposure to H2S while effecting
their duties; additionally they must be subject to a face-fit
testing for breathing air apparatus; Site Medical
professionals supporting operations must receive training
in the physiological effects of H2S toxicity and its treatment.
Controls 59
Confined Space Entry (CSE)
Intent
Manage entry into and work within confined spaces to protect personnel from harm and prevent the risk of fatalities, injuries and
incidents related to BHP Billiton Petroleum activities.
Plant
Confined Spaces
12.1 Identify confined spaces and maintain a confined space
register. Use the register to inform all work planned on such
confined spaces; the register must include permanent
equipment and any permanent or temporary third-party
service contractor equipment used in support of
BHP Billiton Petroleum activity.
12.2 Label all known confined spaces to prevent inadvertent or
unauthorized access to those spaces by personnel.
12.3 Assess equipment and spaces that undergo a modification
(permanent or temporary) to determine whether the
modification has created a confined space.
equipment associated with Confined Space Entry
operations.
People
Roles and Responsibilities
12.5 Define and document the roles and responsibilities for all
personnel working in and supervising work in confined
spaces.
12.6 Use people who are trained, deemed competent and
assessed as fit to work in confined spaces.
12.7 Require personnel who work in confined spaces to be
appropriately trained in Permit to Work and Job Risk
Assessment processes.
Procedure
Confined Space Entry Management Process
12.8 Conduct confined space entry only after other alternatives
have been evaluated and deemed unsuitable.
12.9 Identify and implement limits for exposure to dangerous
gases or other occupational exposures.
12.10Conduct a documented risk assessment prior to actual entry
into a confined space.
12.11Require a Permit to Work for Confined Space activity.
12.12Isolate piping, equipment and spaces connected with or
adjacent to the confined space in accordance with Fatal
Risk Control 5 – Isolation and Permit to Work.
12.13Assess the atmosphere of any confined space prior to entry.
Continue ongoing monitoring while work is being
performed to ensure it remains safe. Minimum atmospheric
monitoring includes: Oxygen content; Lower Explosive
Limit; Toxicity of atmosphere.
12.14Provide adequate ventilation to ensure a safe atmosphere
at all times, from initial entry until the work is completed
and the space is evacuated.
12.15Do not introduce pure oxygen into an oxygen deficient
space.
12.16Do not use combustion engine driven or nitrogen driven
mobile tools and equipment in confined spaces.
12.17Locate gas cylinders used for the purposes of cutting or
welding outside the confined space.
12.18Isolate sources of gases when cutting or welding work is
paused or stopped. Effective communication is required
between those conducting the work and those controlling
the gas shut-off outside the space.
Confined Space Entry.
Diving
Intent
Manage diving activity to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton
Plant
Diving Equipment and Support Vessels
13.1 Use marine equipment and vessels to support diving
operations, including support vessels which comply with
the specifications in the BHP Billiton Petroleum Marine
equipment associated with Diving Operations.
13.3 Do not use “band-masks” or recreational SCUBA
equipment; re-breather apparatus other than where used in
rescue or emergency operations.
People
13.4 Use trained, certified, experienced and competent
personnel for diving operations including personnel
inspecting and maintaining diving equipment.
13.5 Do not use uncertified or recreationally certified diving
personnel.
Procedure
Diving Management Process
13.6 Conduct diving operations only where the use of remotely
operated vessels (ROV) is not practicable.
13.7Implement BHP Billiton Petroleum Diving Operations
Procedure for all diving activities.
13.8 Conduct Diving Operations in accordance with a written
Dive Plan; plan must include specific emergency action
plans aligned with the diving risk assessment.
13.9 Prohibit the following diving and subsea activities:
• Diving operations of any type at working depth in excess
of 1,000 feet sea water (or 304 meters sea water).
• Diving in environments assessed by risk assessment as
heavily contaminated.
Diving.
Controls 61
Ground Disturbance and Ground Control
Intent
Manage work involving a man-made cut, cavity, trench or depression in the earth’s surface formed by earth removal to protect
personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities. This includes
falls of ground at stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations.
Plant
Design and Use Appropriate Equipment
14.1 Source and use equipment appropriate for Ground
Disturbance and Ground Control activity.
14.2 Source or define standards for the design and quality of
ground support materials.
equipment associated with Ground Disturbance or Ground
Control rescue and recovery as deemed necessary.
People
14.4 Use personnel who are suitably experienced and have been
trained and certified to conduct Ground disturbance and
Ground Control activity including personnel responsible for
inspections and maintenance.
Procedure
Ground Disturbance and Ground Control Management
Process
14.5 Develop and maintain an approved Ground Disturbance and
Ground Control procedure prepared by a competent person.
The procedure must address the following requirements as
applicable:
• Mark excavations with a unique name or identification
number at sufficient intervals to accurately identify the
location.
• Process for contacting relevant stakeholders prior to
disturbing the ground.
• Process for identification and management of overground and under-ground hazards inclusive of buried
pipelines, electrical cables, water lines.
• Methods for management of traffic.
• Methods to separate and protect personnel from
unsecured ground inclusive of barriers, barricades, other
access restrictions especially when powered equipment
is in use or when Confined Space Entry permits are
required.
• Methods to assess hazardous atmospheres based on
risk.
• Methods for controlled disturbance of ground, inclusive
of standards for the measuring, monitoring and analysis
of ground condition data, classifying soil and aligning
equipment selection, work methodology and emergency
response protocols.
• Methods of securing disturbed ground inclusive of
shoring, shielding, sloping and benching and assessment
of excavation stability and the effectiveness of ground
support (20 feet and deeper require engineered
protective systems).
• Methods for management of stockpiles of disturbed
ground.
• Methods for management of naturally occurring water in
disturbed ground.
• A process for management of planned and unplanned
changes to ground conditions inclusive of the impact of
weather.
• Process for effective communications to affected
personnel.
• Means for assuring the integrity of the installation of
ground support materials, including frequency of
examination and methods for repair.
• Identification and use of appropriate PPE.
• Emergency Response arrangements inclusive of rescue
from cave-in.
14.6 Undertake an annual review of the Ground Disturbance and
Ground Control procedure.
Ground Disturbance and Ground Control.
Appendix B
Notes, Application and inter-relationship of Fatal Risk
Controls
Control
Application
1 Road Going and Light Vehicles
This Control applies to BHP Billiton Petroleum owned, contracted (lease or hire) or operated road going
and light vehicles used for work related activity. It also applies to all BHP Billiton Petroleum personnel
using road going and light vehicles used for work related activities.
Road Going Vehicles includes all surface light vehicles, trucks and buses that are designed for public road
use. Examples include pick-ups trucks, four wheel and all-wheel drive vehicles, rigid and articulated trucks
(including associated trailers) and buses of all sizes.
Light Vehicles are a class of Road Going Vehicle which:
• Have four or more wheels, seat a maximum of 12 adults (including the driver),
• Are vehicles that, where registered, could be legally driven on a public roadway by a driver issued with
an approved driver’s license
• Do not exceed 4.5 tonnes gross vehicle mass (GVM), which is the maximum loaded mass of the motor
vehicle as specified by:
-- the vehicle’s manufacturer; or
-- an approved and accredited automotive engineer, if the vehicle has been modified to the extent that
the manufacturer’s specification is no longer appropriate.
• Light Vehicles may include the following categories of vehicles being used for work related activities:
-- BHP Billiton owned or leased vehicles;
-- Hired rental vehicles
-- Contractor or supplier vehicles operating on company property;
-- Private vehicles used for work related activity.
The requirements of this Control do not apply in the following situations:
• Vehicles being driven “on site” to the employee or visitor car park area, or for delivery drop off in
“non-hazardous” areas (e.g., warehouse deliveries).
• Private vehicles being used on an occasional basis to undertake a low risk work related trip, such as
visits to Contractor offices etc, where approved by the Line Manager or equivalent.
• Employees traveling between their fixed or temporary residence and their fixed or temporary work
place in either Company provided transport, public transport or personal transport.
• Situations where the employee departs from a reasonably direct route of work related travel for
personal reasons, e.g., a side trip to visit a place of interest.
Support equipment includes:
• Fire extinguisher
• High-visibility vest
• Signage appropriate for the location
• First aid kit
• Emergency roadside triangles or beacons
• Survival or emergency equipment suitable for the operating environment
• Signage appropriate for the location.
• Two-way radio.
• Method to move portable equipment while maintaining three points of contact.
Road Going & Light Vehicle Safety Equipment includes:
• Air-bags for all occupants.
• Anti-lock braking system (ABS).
• 3-point inertia reel seat belt for all occupants.
• Systems for control of cargo and segregation of cargo from occupants.
• Roll-over protection based on 5 Star NCAP or equivalent rating and/or have installed an electronic
stability control (ESC) system.
Off-road
• Road which has no engineering design.
• Natural tracks, river beds, gullies, naturally occurring land.
New Car Assessment Programmes (NCAP)
New Car Assessment Programmes are active in the following countries or regions: Australia (ANCAP);
Japan (JNCAP); S.E. Asia (ASEAN NCAP); Korea (KNCAP); Latin America (Latin NCAP); Europe (EuroNCAP);
USA (NHTSA and IIHS). Until the NHTSA 5 star rating programme matures, and the available range of
compliant vehicles increases, purchasers of USA-supplied vehicles can use IIHS ‘Good’ ratings as evidence
of NCAP equivalency (for instance, ‘Good’ ratings in both frontal and side impact tests).
2 Mobile Equipment
This Control applies to the use of all mobile equipment over and above those vehicles covered under Fatal
Risk Control 1 – Road Going and Light Vehicles. Includes, but is not limited to, mobile elevating work
platforms, self-propelled surface, tracked and rubber tyred equipment such as trucks, graders, tractors,
excavators, drills, draglines and similar plant.
It excludes relocatable plant such as crushers and stacking conveyors.
Controls 63
Appendix B
Notes, Application and Inter-Relationship of
Fatal Risk Controls continued
Control
Application
2 Mobile Equipment (continued)
Mobile Equipment safety features
• Seat belt.
• Fall-on and roll-over protection.
• Adequate lighting for safe execution of tasks.
• Reversing alarms, horn, effective windscreen wipers, guarding on moving parts.
Support equipment includes:
• Fire extinguisher
• High -visibility vest
• Signage appropriate for the location
• First aid kit
• Emergency roadside triangles or beacons
• Survival or emergency equipment suitable for the operating environment
• Signage appropriate for the location.
• Two-way radio.
• Method to move portable equipment while maintaining three points of contact.
3 Explosives
For WWD activity only - this Control must be used in conjunction with the World-Wide Drilling (WWD)
Explosives Management Guidelines contained within the Drilling Safety Guidelines Document No
WWD015.
DOT, OSHA, ATF or Local authorities requirements for shipping, handling and storing explosives must be
complied with.
4 Hazardous Materials
This Control applies to activities related to hazardous materials management. It includes management of
hydrocarbon processing facilities and operations and includes hazards associated with the extraction,
production, processing and transport of hydrocarbons and associated products. These controls must be
used in conjunction with the process hazard analysis (PHA) as defined in the Hazard and Risk Management
Controls. This Control does not cover handling of explosives (covered in Fatal Risk Control 3 – Explosives).
5 Isolation and Permit to Work
This Control applies to the isolation of all sources of energy (electrical, mechanical, hydraulic, chemical,
gravitational, pneumatic, kinetic, stored energy etc.). The requirements detailed in this Control must be
used in conjunction with the BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton
Petroleum Lock Out Tag Out Procedure.
6 Equipment Safeguarding
This Control applies to safeguarding of people from moving parts of plant, mobile machines, equipment
and power tools, including moving equipment, high pressure equipment and applications, electrical, and
other energy sources with the potential to move, and objects falling or projected from moving parts. This
includes the integrity of such equipment.
7 Working At Height
This Control applies wherever there is potential for any person to fall 2 meters or more, or to gain access
to within 2 meters of an open edge from where there is the potential to fall 2 meters or more, including
working from various forms of portable and moveable elevated work platforms, workbaskets, ladders,
scaffolding, or where a risk assessment has identified high potential fall hazards when working at heights
of less than 2 meters.
It also applies where a significant injury could result from a fall. (Note: if local applicable law requires
more stringent controls, then those controls must be implemented.) This Control does not apply to rope
rescue situations and abseiling that are regarded as specialist functions.
8 Lifting Operations
This Control applies wherever lifting operations are undertaken. These controls must be used in
conjunction with the BHP Billiton Petroleum Lifting Operations Procedure.
9 Dropped Objects
This Control applies to all work conducted on BHP Billiton Petroleum sites and to facility equipment, third
party equipment, and all equipment hired or contracted direct by BHP Billiton Petroleum. It includes:
• Objects falling or dropped from plant/equipment or a rig/derrick.
• Objects falling or dropped from crane booms, flare booms and other permanently or temporarily
installed structures and buildings.
• Objects falling or dropped from elevated decks, platforms, scaffolding and any other workspace where
equipment is mounted or secured overhead.
• Tools, equipment, and other objects falling or dropped while working from portable and moveable
elevated work platforms and while persons are working at heights using a work harness or working in
cages.
64 Health, Safety, Environment and Community Management System Framework
Appendix B
Notes, Application and Inter-Relationship of
Fatal Risk Controls continued
Control
Application
9 Dropped Objects (continued)
This Control should be used in conjunction with the requirements of Fatal Risk Control 7 – Working at
Height and Fatal Risk Control 8 – Lifting Operations.
This Control excludes:
• Loads falling from cranes during lifting procedures – these occurrences are covered under Lifting
• Tubulars (drill strings, BHA’s, test strings, casing and tubing, etc.) suspended from or in the rotary table
that drop down the well – these occurrences are covered by Drilling procedures.
10 Working with Pressure
This Control applies to all activities and operations where pressure-containing equipment is used. These
controls must be used in conjunction with Fatal Risk Control 5 – Isolation, BHP Billiton Petroleum Permit to
Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure.
11 Hydrogen Sulphide
This Control applies to all BHP Billiton Petroleum activities where H2S may be encountered.
12 Confined Space Entry
This Control applies to all BHP Billiton Petroleum activities involving confined space entry. These controls
must be used in conjunction with Fatal Risk Control 5 – Isolation and the BHP Billiton Petroleum Permit to
Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure.
The definition of a confined space must reflect local applicable law. The Australian Standard AS2865
defines confines space as, any space which:
• Is at atmospheric pressure during occupancy;
• Is not intended or designed primarily as a place of work;
• May have restricted means for entry and exit; and may:
-- Have an atmosphere which contains potentially harmful levels of contaminants;
-- Not have a safe oxygen level; or
-- Cause engulfment.
13 Diving
This Control applies to all diving activities including:
• Surface-supplied air diving.
• Surface supplied mixed gas diving.
• Saturation diving.
• Remotely Operated Vessels (ROV) interventions during diving operations.
This Control does not apply to the use of non-diving related ROV’s or manned submersibles.
14. Ground Distrubance and
Ground Control
This control applies to all BHP Billiton Petroleum activities involving ground disturbance. It requires the
identification of situations which could create dangers to personnel due to movement of ground at
stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations.
See OSHA 29 CFR 1926.650, .651, .652
OSHA defines an excavation as any man-made cut, cavity, trench, or depression in the earth’s surface as
formed by earth removal.
A trench refers to a narrow excavation made below the surface of the ground in which the depth is greater
than the width-and the width does not exceed 15 feet.
Trenching is common in utility work, where underground piping or cables are being installed or repaired.
If an excavation is more than 4 feet in depth or if there is a potential for engulfment, there must be a
protective system in place while workers are present in the excavation.
Excavations more than 4 feet in depth must have a way to get in and out, usually a ladder, for every 25
feet of horizontal travel.
Shoring , whether the traditional timber shores or the modern hydraulic shores, brace against and hold up
the walls of an excavation, preventing cave-ins. (never work outside of the shored area)
Shielding devices, commonly called trench boxes, shields, or coffins, are not designed to prevent a trench
wall from collapsing, but rather serves as a “shield” to the workers within the structure
should a cave-in occur. With both shoring and shielding, the workers are only protected as long as they
stay within the protective confines of the systems. (never work outside of the shored area)
Sloping refers to the cutting back of the trench walls at such an angle that there is little chance for
collapse.
Spoil piles shall be no closer than 2 ft from the edge of the excavation to the nearest point of the spoils.
Controls 65
Appendix C
Traffic Management Plan Requirements
Develop and implement a Traffic Management Plan which
establishes site road engineering and vehicle operating standards
for surface and underground Operations. The Traffic Management
Plan must establish criteria for:
• Minimizing the risk for all site road users with site road
network, traffic flow, intersection design and vehicle
selection.
• Mitigating risks to personnel from the hazards of remotecontrolled mobile equipment.
• Providing adequate visibility along company roads and at
intersections.
• Implementing traffic safety procedures that at least include:
-- right of way rules at site intersections.
• Keeping the number of light vehicles on site as low as
practicable.
-- site overtaking and vehicle interaction protocols.
• Minimizing interactions between pedestrians and vehicles,
and heavy and light vehicles, with physical separation
provided wherever practicable, including safe parking area
design and parking protocols.
-- the minimum safe distance to be maintained between site
vehicles and mobile equipment.
• Coloring, marking and equipping vehicles and mobile
equipment for adequate visibility and easy identification at a
safe distance by other vehicles, mobile equipment and
pedestrians.
• Building roads with adequate delineation and protection from
roadside and overhead hazards.
• Managing road maintenance, including hazards arising from
dust and over-watering.
• Selecting road traffic signs and road markings consistent with
the standards set by the national or state authorities in the
country of operation. Where such standards do not exist, or
are not suitable, the site must select an appropriate standard
from the European Union, North America, Australia, South
Africa or Chile.
-- site speed limits and how they will be enforced.
-- control of access to, and egress from, restricted areas,
including a process for ensuring the number of light
vehicles in a restricted area is kept to the absolute
minimum needed for effective Operations.
-- communication equipment requirements and
communication protocols.
-- work-related use of company-provided vehicles off site,
including the identification and management of high-risk
road journeys.
• Providing training and competency requirements for:
-- road safety awareness including defensive driving
techniques.
-- permits to operate/drive including site drivers’ licences
based on specific site rules, vehicle type, operating
standards and risks.
-- employees and contractors performing design and
engineering of road networks, traffic flow and traffic
engineering.
Appendix D
Transitional Requirements for Existing Light Vehicles
• Driver side air-bag.
• 3-point inertia reel seat belts (2-point inertia reel seat belts
where 3-point seat belts are not available).
• Systems for control of cargo and segregation of cargo from
occupants.
• Vehicle design to mitigate risks to occupants from toppling or
rollover.
66 Health, Safety, Environment and Community Management System Framework
Environment
Enviroment Control 1
Land and Marine Management
Land and Marine Disturbances
Intent
Land and marine disturbances must be managed to minimize environmental impact.
Control Framework
Where land activities or marine use may impact the environment:
• Assess the baseline biodiversity, land use, contaminated sites and environmental liability for areas potentially impacted. Identify
and map the owned, leased or managed land, freshwater and marine areas, designated protected areas and areas of high
conservation value.
• Assess actual and potential impacts to biodiversity, land use, contaminated sites and environmental liability.
• Quantify the acceptable level of impact taking into account regulatory requirements and stakeholder expectations.
• Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of
impact to biodiversity and land use.
• Implement a monitoring and review program to evaluate the effectiveness of control measures.
Mandatory Controls
1.1Obtain approval (i.e., internal and/or regulatory approval)
to disturb land, freshwater, and marine areas that
addresses regulatory requirements. This may be covered by
the site closure plan, Environmental Management Plan, or
regulatory submittal.
1.2 Design vessels, vehicles, plant or equipment that may cause
ground or seabed disturbance to ensure minimal
disturbance while meeting operational requirements and
allowing safe operation.
1.3 Do not explore, drill, develop or extract within the
boundaries of World Heritage listed properties.
1.4 Identify any local International Union for Conservation of
Nature (IUCN) Red List Threatened Species and do not
operate where the direct impact will result in their
extinction in the wild.
1.5 Onshore, rehabilitate disturbed land as soon as practicable
and consistent with the pre-disturbance land use or
alternate land uses developed in consultation and/or
agreement with stakeholders, regulators and land owners.
1.6 Offshore, conduct hydrodynamic modelling to predict the
extent of impacts to offshore habitat for any physical
disturbance that may impact shoreline, near shore areas or
areas protected for the purposes of conservation. Conduct
baseline benthic monitoring to predict the extent of
impacts to habitat.
Risk-Based Controls
Based on the level of impact identified in a risk assessment
process, the following must be implemented:
1.7Implement compensatory actions where actual or potential
residual impacts, after preventative and mitigating controls
have been implemented, exceed the quantified acceptable
level of impact to biodiversity, land use, watersheds and/or
water resources.
1.8 Do not conduct exploration, drilling and/or development in
the following instances:
• Adjacent to World Heritage listed properties unless the
proposed activity is compatible with the outstanding
universal values.
• Within the boundaries of the IUCN Protected Areas
Categories I-IV, unless a Biodiversity Action Plan is
implemented that delivers measurable benefits to
biodiversity commensurate with the level of expected
biodiversity impact and meets regulatory requirements
and authorizations.
1.9 Onshore, obtain authorizations before the implementation
of any material land conservation project.
Controls 69
Environment Control 2
Land and Marine Management
Noise Disturbances
Intent
Noise must be managed to minimize impact to fauna and communities.
Control Framework
Where noise may impact fauna or the community:
• Assess actual and potential impacts to fauna and communities.
• Quantify the acceptable level of noise impact taking into account regulatory requirements and stakeholder expectations.
impact to fauna and the community.
Mandatory Controls
2.1 Offshore, build sound power intensity of seismic shots
gradually (”soft-start”) following Joint Nature Conservation
Committee (JNCC) guidelines (4) to allow marine mammals
time to leave the area. In areas where cetaceans are not
expected and in the absence of passive acoustic monitoring
(PAM) systems, judgement must be used to ensure the area
is free from cetaceans prior to the soft start.
2.2 Offshore, continually watch for marine mammals during the
pre-shooting search and soft-start, and while airguns are
firing, in regions with known (regulated, designated or
otherwise indicated) marine mammal migratory pathways.
Seismic source vessels must carry at least one competent
Marine Mammal Observer (MMO) in accordance with JNCC
guidelines (5).
2.3 Offshore, for seismic operations, where stricter guidelines
do not apply:
• Delay the soft-start if marine mammals are seen within
500 meters of the center of the array during the
pre-shooting search. However, if marine mammals are
detected within 500 meters of the center of the airgun
array while the airguns are firing, either during the
soft-start or while at full power, there is no requirement
to stop firing the airguns (5).
• Conduct the pre-shooting search and soft start
procedure after shut down of the seismic source, or if
all airguns have stopped and not restarted for at least
10 minutes.
• Begin seismic activities at least 500 meters from the
platform where marine mammals are congregating
around a drilling or production platform, or other
structures.
Risk-Based Controls
2.4 Onshore, conduct a baseline noise survey to determine
representative “background noise” and perform noise
modelling to ensure acceptable environmental noise
targets are met off-site.
2.5 Onshore, incorporate efforts to manage noise using good
industry practices.
2.6 Offshore, consider the use of PAM for all offshore source
vessels involved in seismic acquisition; particularly for use
in areas where marine mammals are likely to inhabit the
proposed survey location.
Hydrocarbon Management
Hydrocarbon
Intent
Liquid hydrocarbon storage, pipelines and flowlines, must be managed to minimize the risk of land and water contamination.
Control Framework
Where hydrocarbon storage and pipelines may impact the environment:
• Assess actual and potential impacts to biodiversity, water, air or community.
impact to biodiversity, water, air or community.
Mandatory Controls
3.1 Identify, map and manage liquid hydrocarbon storage and
pipelines.
3.2 Conduct and maintain a risk assessment for all existing
below-ground or subaqueous liquid hydrocarbon storage
tanks (including vessels) and associated pipelines to
determine the likelihood of containment failure and
implement any required control measures.
Risk-Based Controls
3.3 Implement a risk-based integrity management program for
BHP Billiton Petroleum facilities and pipelines.
3.4 Construct new storage facilities and pipelines to comply
with local regulatory requirements and accepted petroleum
industry standards.
Controls 71
Water Management
Water Sourcing, Use and Discharge
Intent
Water sourcing, use and discharge, including disposal, must be managed to minimize impact to water resources, biodiversity
and communities.
Control Framework
Where water sourcing, use or discharge may impact the environment:
• Assess the baseline quantity and quality of water potentially impacted.
• Assess potential impacts on water quality and quantity.
• Quantify the acceptable level of impact to water taking into account regulatory requirements and stakeholder expectations.
impact to water (including quantity and quality criteria limits for water supply sources and discharges).
• Implement a monitoring and review program to verify the effectiveness of control measures.
Mandatory Controls
Risk-Based Controls
4.1 Maintain records of water sources, water use and
wastewater generation.
4.6 Conduct an accounting of water use.
4.7 Evaluate water recycling and reuse.
4.8 Onshore, ensure surface casing strings are cemented back
to surface to provide adequate isolation of all freshwater
zones penetrated. If cement is unable to be circulated back
to surface, run diagnostic logs to evaluate top of cement
and perform remedial cementing operations if necessary, to
provide adequate isolation.
4.9 Onshore, conduct groundwater monitoring to detect potential
impacts from losses of containment at permanent facilities.
4.10 Onshore, preferably store waste water in tanks rather than
pits/ponds.
4.11 Onshore, design and construct pits/ponds in a manner to
prevent leaching and unauthorized access.
4.12 Onshore, install leak detection systems on permanent
wastewater storage pits or ponds.
4.13 Offshore, use inline oil-in-water analysers with shut-downs/
auto-bypasses or manual sampling and testing for all PFW
overboard discharges.
4.14 Offshore, manage ballast water in compliance with
MARPOL 73/78 Annex I(7), International Maritime
Organization (IMO) Ballast Water Management
Convention(8) and BHP Billiton Petroleum Marine Operations
Controls (9).
4.2Where high quality water use exceeds or is anticipated to
exceed 3,000 megaliters per annum for an Operation or
project, or where water management is anticipated to be a
material risk issue, the Operation or project must:
• Maintain a quantitative water balance model.
• Maintain a 5-year forecast for high quality water use.
• Establish targets and implement and maintain projects
to reduce impacts to water resources in the regions
where the Operation or project is located. These targets
and projects must be included in the Asset 5-year plan.
• Maintain a high quality water use reduction cost curve
that identifies potential projects to reduce all high
quality water usage.
• Identify and assess water requirements, supply options
and supply risks for the life of the Operation.
• Implement, monitor and review controls designed to
deliver water supply requirements for the life of the
Operation.
4.3 Evaluate chemicals used for water treatment to minimize
potential environmental impacts.
4.4 Design, drill, complete, produce and abandon wells (oil,
gas, water abstraction and water disposal), to meet local
regulatory requirements and accepted industry standards
for the protection of groundwater and surface water.
4.5 Offshore, do not exceed a 24-hour average oil and grease
concentration of 30 mg/l for discharges of produced
formation water (PFW) (6).
Air Management
Air Emissions
Intent
Air emissions (excluding greenhouse gases) must be managed to minimize impact to the atmosphere and subsequent impacts on water,
land, biodiversity and communities.
Control Framework
Where air emissions may impact sensitive receptors:
• Assess the baseline air quality at sensitive receptors and maintain an inventory of air emissions.
• Assess potential air quality impacts on sensitive receptors.
• Quantify the acceptable level of impact to sensitive receptor’s air quality, taking into account regulatory requirements and
stakeholder expectations.
impact to sensitive receptor’s air quality (including air emissions criteria limits).
Mandatory Controls
Risk-Based Controls
5.1 Use natural gas as the preferred fuel at production facilities
where it is available.
5.2 Use low-sulphur diesel (containing sulphur equal to or less
than 500 ppm) as the fuel source where it is available.
5.3 Assess suitability of SO2 controls, where low sulphur
diesel is unavailable, for continuously operated major
emissions sources.
5.4 Utilize high-efficiency flare equipment on new facilities.
5.5 Measure (preferably) or estimate (using accepted industry
estimation methodology), record and report internally
air emissions.
5.6 Avoid cold venting of natural gas where practicable.
5.7 Offshore, comply with emission guidelines for PM, SO2 and
NOx as indicated by International Finance Corporation,
World Bank Group guidelines for air emissions and ambient
air quality (10) for engines and turbines (permanent and
temporary) owned or operated by BHP Billiton Petroleum.
5.8 Offshore, comply with the requirements of MARPOL 73/78
Annex VI (11) for emissions from combustion sources on
controlled marine vessels.
5.9 Evaluate the use of the following designs for new facilities
or at opportunistic retrofit:
• Clean/lean burn technology for use on BHP Billitonowned equipment for control of NOx, CO and volatile
organic compounds.
• Smokeless flare or high efficiency flare equipment.
• Vapour-recovery equipment for all planned or steady
state venting sources.
• Low or no-bleed pneumatic devices to regulate pressure
and control valves to minimize releases to a flare system.
• Electronic igniters as a means of lighting flares in lieu of
permanent pilots.
• Flare gas recovery systems.
• Flash gas and vent gas for fuel or sale.
• Compressed air instead of natural gas for powering
instruments and controllers.
• Bypass or closed-loop systems to eliminate excessive
flaring associated with commissioning and start-up
activities.
Controls 73
Energy and Greenhouse Gas Management
Energy Use and Greenhouse Gas Emissions
Intent
Energy use and greenhouse gas (GHG) emissions must be managed to reduce GHG emissions where emissions exceed or are anticipated
to exceed 50,000 tonnes CO2-e (equivalent) per annum for an Operation or project.
Control Framework
Where emissions exceed 50,000 tonnes CO2-e per annum for an Operation or project:
• Identify, evaluate and implement energy and GHG reduction projects based on current and forecasted energy use and GHG emissions.
• Develop a management plan and implement a monitoring and review program to verify the effectiveness of energy reduction and
GHG reduction projects.
Mandatory Controls
6.1 Maintain a GHG emission 5 year forecast.
6.2 Where emissions exceed or are anticipated to exceed
1,000,000 tonnes CO2-e per annum for an Operation or
project:
• Maintain an energy mass balance;
• Maintain a GHG reduction cost-curve that identifies
potential projects to reduce all GHG emissions;
• Establish targets and implement and maintain projects
to reduce greenhouse gas emissions consistent with the
reduction quantums committed to from the GHG
reduction cost curve. These targets and projects must be
included in the 5-year plan.
6.3 Measure (preferably) or estimate (using accepted industry
estimation methodology), record and report internally
GHG emissions.
6.4 Utilize waste heat recovery for new facilities or
opportunistic retrofit if emissions are greater than
50,000 tonnes per year of CO2 equivalent (CO2-e).
6.5 Apply the BHP Billiton Carbon Pricing Protocol during
project selection for applicable capital decisions (12).
6.6 Establish energy efficiency improvement goals and action
plans to reduce emission levels. Goals should be on a
normalized year-by-year basis and included in the
management plan.
6.7 Assess energy efficiency during the selection of new or
replacement equipment for fixed or permanent
installations. Energy efficiency evaluations are case-specific
for the selection of the required parameters to conduct a
lifecycle analysis.
6.8 Avoid cold venting of natural gas where practicable.
Waste Management
Waste
Intent
Wastes, excluding drilling muds and drilled cuttings, must be managed to minimize the environmental impacts resulting from the
production, storage, handling, transport, recycling and disposal.
Control Framework
Where hazardous, non-hazardous and general wastes are generated:
• Assess potential environmental impacts of wastes and determine if any wastes can be eliminated, reduced, recycled or reused in lieu
of disposal.
impact (including the tracking of waste from source to disposal).
Mandatory Controls
7.1
7.2
7.3
7.4
7.5
7.6
Maintain records of waste type, source and quantities of
wastes, and the storage and disposal locations.
Manage, store, transport, and dispose or treat hazardous
materials and hazardous wastes in accordance with
regulatory requirements or industry best practice. Where
hazardous wastes are generated and there are no
regulatory requirements, utilize the United Nations
Environment Programme “Basel Convention on the Control
of Transboundary Movements on Hazardous Wastes and
Their Disposal” (13) as a guide.
Conduct audits or assessments at least every two years on
waste management contractors to ensure their operating
practices are appropriate and in compliance with
regulations.
Evaluate chemicals, materials and products for
environmental impacts to achieve waste minimization.
Onshore, dispose of hydrostatic test water according to
regulations. Where regulations are not available, utilize
best practices such as requirements of the International
Finance Corporation (World Bank Group) (14).
Offshore, manage sewage and grey water in compliance
with MARPOL 73/78 Annex IV (15), and MARPOL 73/78 Annex
V (16), respectively, or other applicable permits prior to
discharge. Utilize a marine sanitation unit where installed.
Risk-Based Controls
7.7
Conduct risk-based HSEC evaluation on waste management
contractors prior to final contractual arrangements.
Controls 75
Waste Management
Drilling Muds and Drilled Cuttings
Intent
The use, storage and discharge of drilling muds and cuttings must be managed to minimize adverse environmental impacts.
Control Framework
Where drilling muds and drilled cuttings are generated:
• Assess drilling muds and drill cuttings for recycling or reuse.
• Quantify the acceptable level of impact from discharges taking into account regulatory requirements and stakeholder expectations.
impact.
Mandatory Controls
8.1 Assess the environmental impacts when selecting drilling
muds and completion fluids, including chemicals and
additives.
8.2 Onshore, construct pits used for drilling and completion
operations to prevent unauthorized access and to prevent
leaching, leakage or unauthorized discharge of pit contents
into the surrounding environment. Construct pits to ensure
that overflow associated with rainfall will not occur.
8.3 Onshore, avoid use of oil or saltwater-based muds when
drilling through groundwater and freshwater strata.
8.4 Offshore, do not discharge oil based mud (OBM) or
OBM-contaminated cuttings into the environment (10).
8.5 Offshore, where a synthetic based mud (SBM) or OBM
system is used, utilize separation equipment that is capable
of ensuring the volume of SBM or OBM retained on drilled
cuttings is no more than 10 percent by dry weight.
8.6 Offshore, conduct ecotoxicity testing (acute, sub-lethal
and/or chronic) on fluids to be discharged. This may be a
prior test conducted on a generic mud composition for the
well, or it may be a test on the actual mud in use or
discharged during the drilling operation.
Risk-Based Controls
8.7 Evaluate use of low toxicity water based muds (WBM) for
all drilling activities except for hole sections where SBM or
OBM is justified for technical reasons.
8.8 Onshore, consider closed-loop drilling systems.
Environment Controls
References
1.
BHP Billiton. BHP Billiton Petroleum HSEC Management System Framework.
2.
BHP Billiton. BHP Billiton Petroleum Health, Safety, Environment and Community (HSEC) Policy
3.
BHP Billiton. Management Plan Preparation Document.
4.
BHP Billiton. BHP Billiton Petroleum Investment Process Manual. (PM-PR-IM-01)
5.
Joint Nature Conservation Committee (JNCC). 2010. ANNEX A- JNCC guidelines for minimising the risk of disturbance
and injury to marine mammals from seismic surveys. August 2010
http://jncc.defra.gov.uk/pdf/JNCC_Guidelines_Seismic%20Guidelines_Aug%202010.pdf
6.
Oslo and Paris Commission (OSPAR). 2006. OSPAR Convention for the Protection of the Marine Environment of the
North-East Atlantic. OSPAR Recommendation 2001/1 adopted by OSPAR 2001 (OSPAR 01/18/1, Annex 5), Amended by
OSPAR Recommendation 2006/4 (OSPAR 06/23/1, Annex). OSPAR Recommendation 2001/1 for the Management of
Produced Water from Offshore Installations. http://www.ospar.org/v_measures/browse.asp?me
nu=00520417000000_000000_000000
7.
International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships
(MARPOL). MARPOL Annex I: Regulations for the Prevention of Pollution by Oil. London: IMO, consolidation edition,
2006.
8.
International Maritime Organization Ballast Water Management Convention. 2009
9.
BHP Billiton. BHP Billiton Petroleum Marine Operational Controls.
10. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Offshore Oil and Gas
Development. World Bank Group, April 30, 2007.
http://www1.ifc.org/wps/wcm/connect/bfc6f4004886590bb80afa6a6515bb18/offshoreoil.pdf?MOD=AJPERES&CACHEI
D=bfc6f4004886590bb80afa6a6515bb18
11.
International Maritime Organization (IMO). 2009. International Convention for the Prevention of Pollution from Ships
(MARPOL). Revised MARPOL Annex VI and NOx Technical Code 2008: Regulations for the Prevention of Air Pollution
from Ships. London: IMO, 2009 Edition.
12. BHP Billiton. Carbon Price Protocol. Updated quarterly. Information pertaining to the protocol can be obtained from
relevant BHP Billiton Petroleum Planning or Economics analysts.
13. United Nations Environment Programme. 1992. Basel Convention on the Control of Transboundary Movements of
Hazardous Wastes and Their Disposal. http://www.basel.int/Portals/4/Basel%20Convention/docs/text/con-e-rev.pdf.
14. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Onshore Oil and Gas
Development. World Bank Group, April 30, 2007. http://www1.ifc.org/wps/wcm/connect/4504dd0048855253ab44fb6a
6515bb18/Final%2B-%2BOnshore%2BOil%2Band%2BGas%2BDevelopment.pdf?MOD=AJPERES&id=1323153172270
15. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships
(MARPOL). MARPOL Annex IV: Regulations for the Prevention of Pollution by Sewage from Ships. London: IMO,
consolidation edition, 2006.
16. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships
(MARPOL). MARPOL Annex V: Regulations for the Prevention of Pollution by Garbage from Ships. London: IMO,
consolidation edition, 2006
Controls 77
Data
Reporting
Data Reporting Control 1
General Requirements
Intent
BHP Billiton Petroleum Exploration, Development and Production groups must define applicable reporting obligations and submit data
to Group HSEC to allow monitoring of HSEC performance in accordance with Table 1 (Scope) and Table 2 (Authorities).
Table 1 – Scope
Notes
Reporting Requirements
Entity
H&S
Hyg
Env
Comm
Fines
CSG1 (BHP Billiton Petroleum Level including Marketing)
Y
N
Y
Y
Y
Asset (Production Units, Joint Interest Units)
Y
N
Y
Y
Y
Operation (Minerva, LBA, BlackHawk, Atlantis)
Y
Y
Y
Y
Y
Closed Operation (Development/Production)
Y
N
4
Y
Y
Y
Project in Study Phase2 (Development)
Y
N
Y
Y
Y
Project in Execution Phase (Devlopment/Production)
Y
N
Y
Y
Y
Exploration
Y
N
Y
Y
Y
Y
N
Y
Y
Y
2
Other Function or Group Function3
Includes WWD, Supply, IM, HSEC at CSG or Asset
level as relevant
H&S - Health & Safety data
Hyg - Hygiene data
Env - Environmental data
Comm - Community data
Fines - Regulatory data
1
ctivities undertaken by a Customer Sector
A
Group that are not covered by an Operation.
2
ajor capital project in any phase of the
M
group investment process.
3
ata for Group Functions (GFs) must be
D
reported through Facilities and Services, not
individual GF.
4
Through Asset or direct.
Table 2 – Authorities
Endorse
Approve
Inform
Data parameters to meet internal and external reporting obligations
Head of HSEC (Asset)
ü
Senior Manager (Operation)
ü
HSEC data reported to Group HSEC
Senior Manager (Operation) or Project Director (if Project)
or President CSG
Implement the following for Exploration, Development and
Production controlled activity in accordance with the BHP Billiton
Petroleum HSEC Data Reporting procedure:
1.1Determine data reporting entities (e.g., Douglas, CR Luigs,
Macedon, GGO Project X).
1.2 Define and document reporting boundaries including
classification of activities as controlled or monitored.
1.3Determine HSEC data reporting obligations in the areas of
Safety, Occupational Health & Hygiene, Environment and
Community.
1.4 Collect, review, verify, authorize and submit applicable
HSEC data listed in Control 2 (Reporting Requirements).
1.5 Submit HSEC data to Group HSEC by 7th calendar day of the
month; submit data adjustments by the 15th working day.
ü
1.6 Comply with the following for each applicable data stream:
• Document measurement methods for each data point
including calculations or estimations.
• Define how reconciliation or adjustment of data is managed.
• Identify data sources (e.g., invoice, meter).
• Define relevant calibration and maintenance processes
and records (e.g., 1SAP records).
• Define how review, authorization and verification of
data will occur.
• Define process for changing, correcting and authorizing
changes to previously reported or recorded data.
• Define process for documenting data variations from
one reporting period to another (+/- ≥20%).
• Maintain a documented audit trail to support submitted data.
• Follow data collection framework defined in Table 3.
.
Controls 81
Reporting Requirements
Intent
BHP Billiton Petroleum groups collect, track and manage applicable HSEC data as defined in the HSEC Data Reporting procedure to meet internal
and external reporting obligations. Data must be reported as per Table 3 (HSEC Data collection framework) using HSEC data interpretations
found in the BHP Billiton Petroleum HSEC Glossary.
• Energy use
2.1 Health (hygiene)
• Audiometric assessments
• Waste
• Exposures to defined agents >OEL
• Exposures to noise greater than 85dB(A)
2.2 Health (illnesses)
• New cases of cancers, tumors or neoplasms
• Poisoning and toxic effects
• Water input and output
• Land use
• Unplanned and planned liquid releases
• Biodiversity data
2.5Community
• Community perception survey(s)
• Noise induced hearing loss
• Cultural Awareness training
• Dermatitis or eczema
• Human Rights training
• Infectious and parasitic diseases
• Number of security personnel
• Musculoskeletal occupational illness
• Community complaints – dust, noise, odor and
other related
• Silicosis
• Chronic Obstructive Pulmonary Disease, Asthma,
Pneumoconiosis, other respiratory system and other
diseases and disorders
2.3Safety
• Fatalities
• Lost time cases
• Value of in-kind and direct contributions
• Value of community programs.
• Information applicable to indigenous peoples
• Significant disputes associated with land use and
customary rights
• Restricted work cases
• Information applicable to artisanal mining on or near
owned land inclusive of risks and plans
• Medical treatment cases
• Information applicable to resettlement activities
• Restricted work days per injury/illness
• Details of stakeholder consultation
• Lost days per injury/illness
• Exposure hours
• Number and value of safety related fines
2.4Environment
• Number and value of environment related fines.
• Emissions – Greenhouse Gas (GHG), Ozone depleting
substances, fluoride, Nitrogen Dioxide (NOx), Sulphur
Oxide (SOx), and mercury.
• Sustainability Report metrics by 7th calendar day of July
2.6 Other BHP Billiton Petroleum HSEC Data Requirements
• Comply with other BHP Billiton Petroleum data reporting
requirements as defined in the BHP Billiton Petroleum
HSEC Controls (e.g., Process Safety, MOC).
Table 3 - HSEC Data Collection Framework
Discipline
Framework
HSEC Data Examples
Safety and Health
Title 29 Code of Federal Regulations Part
1904 Occupational Safety and Health
Administration (OSHA)
Injury and illness
Environment
Global Reporting Initiative Reporting
Framework (GRI) and GRI Mining and
Metals Sector Supplement.
•
•
•
•
• E nergy content, greenhouse emission
factors and calculation methods (in
order of preference):
• Energy
• Greenhouse gas emissions
Air pollutants (NOx, SOx)
Ozone depleting substances
Waste
Land
1. Local regulatory frameworks,
if applicable
2. 2006 IPCC Guidelines for National
Greenhouse Gas Inventories
• E mission factors for calculating
greenhouse gas emissions (electricity):
-- M
inerals Council of Australia Water
Accounting Framework:
See BHP Billiton Petroleum HSEC
Glossary for data interpretations
Community
Minerals Council of Australia Water
Accounting Framework.
See BHP Billiton Petroleum HSEC Glossary
for data interpretations
Water inputs, outputs and quality
Global Reporting Initiative Reporting
Framework (GRI) and GRI Mining and
Metals Sector Supplement
• Community complaints
• Stakeholder consultation
• Human rights issues and breaches
Controls 83
Significant Events
Intent
BHP Billiton Petroleum Exploration, Development and Production groups actual and potential significant events must be reported,
investigated and action taken to prevent recurrence in accordance with the BHP Billiton Petroleum Event Management procedure.
3.1 Implement the following for all BHP Billiton Petroleum
actual significant events associated with controlled
activity:
• Notify authorities in accordance with Table 4.
• Seek legal advice and apply legal professional
privilege.
Table 4 – Significant Event Notifications
Occurrence of an actual significant event (controlled activities)
Individual informing
Individual informed
President CSG or Head of Group
Function or Division President
•
•
•
•
• Record the event within 48 hours of occurrence.
Head of Group HSEC
Vice President Media Relations
Head of Group Investor Relations
Vice President Corporate
Communications
• Complete an event investigation appropriate to the
severity within 28 calendar days of occurrence.
Completed Investigation Report for actual significant events
(controlled activities)
• Distribute a copy of the completed investigation
report in accordance with Table 4.
Individual informed
Head of Group HSEC
potential significant events associated with controlled
activity:
• Record the event within 48 hours of occurrence.
• Complete an event Investigation appropriate to the
severity within 28 calendar days of occurrence.
actual significant events and aviation-related potential
significant events associated with monitored activities:
• Notify authorities in accordance with Table 4
within 24 hours of the event being reported to
BHP Billiton Petroleum.
Occurrence of actual significant events and aviation-related potential
significant events (monitored activities)
Individual informed
• G
roup Management Committee
(GMC) Owner
• Head of Group HSEC
8038_072012_150SWPP

Petroleum HSEC Controls

Transcription

Similar documents

bayu intan - EMAS Offshore Limited

Well-deserved Award for Sister Betty

Peer pricing - BHP Billiton

Exxon Mobil STS - Fendercare Marine Ltd

Geology – Micaela Weeks, BPXA - Alaska Oil and Gas Association

We`re Driven by Our Values