BTC Construction Phase ESAP Annex D.6 Health and Safety Management Plan

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    Health and Safety Management Plan

    BTC Project

    Final

    BTC Pipeline Project

    Execute Phase

    Health and Safety Management Plan

    Final

    April 2003

    U01 March 2003 Issued for use Bethan Morgan Alan Jones David Winter

    Rev Date Reason for Issue Prepared by Checked by Project Approval

    Category Code Category Code Description

    Area Code 0000 General (Common)

    Document Type Code Procedure

    System Number - -

    Life Cycle Code x Transitory

    DOCUMENT NUMBER:

    AGT Project Core

    Team / IPMT Code

    Area Code Function

    Code

    Document

    Type

    Sequence

    Number

    Language Revision

    0000 HS A01

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    CONTENTS

    INTRODUCTION...........................................................................................................................5SCOPE..............................................................................................................................................5STRUCTURE OF THE DOCUMENT ...........................................................................................................5

    1 LEADERSHIP AND ACCOUNTABILITY.................................................................................81.1 INTRODUCTION ......................................................................................................................81.2 COMMUNICATIONS..................................................................................................................91.3 ORGANISATION......................................................................................................................9

    2 RISK ASSESSMENT AND MANAGEMENT..........................................................................112.1 GENERAL............................................................................................................................112.2 H&S RISK MANAGEMENT OVERVIEW .......................................................................................112.3 HEALTH SAFETY DURING CONSTRUCTION.................................................................................112.4 ENSURING HS SAFETY DURING OPERATION THROUGH THE DESIGN PROCESS ................................12

    3 PEOPLE, TRAINING AND BEHAVIOURS ......... ........ ......... ........ ......... ......... ........ ......... ....... 133.1 GENERAL............................................................................................................................133.2 BEHAVIOURAL CHANGE.........................................................................................................133.3 HEALTH ..............................................................................................................................143.4 DRUGS, ALCOHOL AND SMOKING ............................................................................................14

    4 WORKING WITH CONTRACTORS AND OTHERS ......... ........ ......... ........ ......... ........ ......... ...154.1 GENERAL............................................................................................................................154.2 PERFORMANCE MEASUREMENT..............................................................................................15

    5 FACILITIES DESIGN AND CONSTRUCTION ........ ......... ........ ......... ........ ......... ........ ......... ...165.1 GENERAL............................................................................................................................165.2

    CONTRACTOR MANAGEMENT .................................................................................................16

    6 OPERATIONS AND MAINTENANCE......... ........ ......... ........ ......... ........ ......... ........ ......... ...... 17

    6.1 GENERAL............................................................................................................................177 MANAGEMENT OF CHANGE..............................................................................................18

    7.1 GENERAL............................................................................................................................188 INFORMATION AND DOCUMENTATION.............................................................................19

    8.1 DOCUMENT CONTROL ...........................................................................................................198.2 APPLICABLE REGULATIONS, CODES, STANDARDS .....................................................................198.3 INFORMATION STORAGE AND RETRIEVAL..................................................................................198.4 PROJECT MANUAL................................................................................................................19

    9 CUSTOMERS AND PRODUCTS..........................................................................................2010 COMMUNITY AND STAKEHOLDER AWARENESS ........ ......... ........ ......... ........ ......... ........ ..21

    10.1 GENERAL............................................................................................................................2110.2 INTERNAL COMMUNICATIONS..................................................................................................2110.3 EXTERNAL COMMUNICATIONS ................................................................................................2210.4 COMPLAINTS .......................................................................................................................23

    11 CRISIS AND EMERGENCY MANAGEMENT........................................................................2411.1 EMERGENCY RESPONSE PLANS .............................................................................................2411.2 OIL SPILL RESPONSE............................................................................................................24

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    12 INCIDENTS ANALYSIS AND PREVENTION ......... ......... ........ ......... ........ ......... ........ ......... ...2512.1 GENERAL............................................................................................................................25

    13 ASSESSMENT, ASSURANCE AND IMPROVEMENT ......... ........ ......... ......... ........ ......... ....... 2613.1 GENERAL............................................................................................................................2613.2 BTC ACTIVITIES AND SAFETY INPUTS ......................................................................................2613.3 ASSURANCE OF CONTRACTORS ..............................................................................................2613.4 IMPROVEMENT .....................................................................................................................26

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    ABBREVIATIONS

    AGI Above Ground Installation

    ALARP As Low As Reasonably Practicable

    ASA Advanced Safety Audit

    BTC Baku-Tbilisi-Ceyhan

    CDM Construction, Design and Management (Regulations)

    COSHH Control Of Substances Hazardous to Health

    DAFWC Days Away From Work Cases

    ERP Emergency Response Plan

    ESIA Environmental and Social Impact Assessment

    GHSER Getting HSE Right

    HAZCON Construction Hazard Identification Workshop

    HAZID Hazard Identification Workshop

    HGA Host Government Agreement

    HSE Health, Safety and Environment

    HS&ES-MS Health, Safety and Environmental, Social Management System

    KPI Key Performance Indicator

    MOC Management Of Change

    NOK Next of Kin

    OSHA Occupational Safety and Health Administration

    PPE Personal Protective Equipment

    PTW Permit To Work

    QRA Quantitative Risk Analysis

    STOP Safety Training Observation Program

    TMP Transport Management Plan

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    INTRODUCTION

    Scope

    The scope of this document describes the way in which the management of Health and Safety

    (HS) is implemented across the BTC Pipeline Projects activities. It is consistent with BPs

    Corporate HSE Management system, Getting HSE Right (GHSER). The requirements of this

    document will be implemented in the three host countries, Turkey, Azerbaijan and Georgia by

    their own local management systems and plans, suitably tailored to the local requirements.

    Structure of the Document

    This document is structured in terms of the 13 elements of GHSER, so that the means of

    implementation of the expectations of each element are described for clarity and consistency. Itshould be noted that Element 9 Customers and Products is excluded from consideration in this

    document because it is not yet relevant.

    The overall framework of the HS&ES Management System and Plan is shown in Figures 1 and

    2.

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    POLI CY

    AGT PROJ ECT MANAGEMENT

    SYSTEMFRAMEWORK

    TURKEYBotas/ BTC I nterf ace

    LEVEL I : BP

    LEVEL I I : PROJECT

    LEVEL I I I : I N- COUNTRY

    LEVEL I V: CONTRACTOR

    Figure 1 AGT HS and ES MANAGEMENT SYSTEM COMPONENTS

    I N- COUNTRY MANAGEMENT SYSTEMS AND PLANS

    I N- COUNTRY CONTRACTORS OWN MANAGEMENT SYSTEMS PLANS

    PROCEDURES (APPROVED BY AGT)

    SUB- CONTRACTORS OWN MANAGEMENT SYSTEMS PLANS PROCEDURES (APPROVED BY

    BOTAS)

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    POLI CY

    AGT PROJECT MANAGEMENTSYSTEM

    FRAMEWORK

    LEVEL I : BP

    LEVEL I I : PROJ ECT

    Figure 2 AGT HS and ES MANAGEMENT SYSTEM PROJ ECT DOCUMENTS

    Pr oject wide

    GHSERElement s

    H&S- specif ic

    I mplement ationI ssues

    E&S I mplement ation I ssues

    (St r uct ur e that includesCont r actor Cont r ol Plans,Commit ment Regist ers etc.)

    GHSER

    Based H&S Plan

    E&S MSFramework

    DocumentAGT HS&ES PLAN- 2 Document s

    This document

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    Category Means of Implementation Targets

    Personal

    Development

    Attend management safety training 5 days per

    year

    minimum

    Contractor

    Engage key contractors towards the zero accidentculture

    Conduct project HS&ES workshops with groups ofcontractors

    Accident and

    Injury Free

    Programme

    Quarterly or

    as

    necessary

    Assurance &Control

    Review project HS&ES Performance at face to facemeetings

    Quarterly or

    as

    necessary

    1.2 Communications

    Leadership will engage in two-way communication with employees, contractors and others

    through a variety of means, including:

    Regular safety and progress meetings which include both contractors and management;

    An open door policy for the discussion of HS&ES issues; and

    Provision of notice boards for HS&ES issues, which will present information on H&S

    performance and also lessons learned.

    1.3 Organisation

    The following organisation chart shows the structure of the leadership team. The leadership

    team will ensure that appropriate resources are made available for the project in terms of

    competent individuals and HS&ES professionals to provide specific advice and expertise.

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    Figure 1.1 IPMT Organisation Chart showing key H,S & ES individuals

    David Winter

    Technical and H&S ComplianceManager

    Phil Allison

    Project DirectorSheila Spence

    Environmental and Social

    Compliance Manager

    Alan Jones

    H&S Manager

    Ed Johnson

    Georgia Project Manager

    Wayne Wheeler

    Azerbaijan Project Manager

    Ed Truett

    Turkey Project Manager

    Jaime Potes UK Project Manager

    (London)

    Ed Walker H&S Manager

    M. Zaunbrecher Construction E &S Compliance Manager

    M. Aycrigg Cultural & Community

    Investment Manager

    Ed Morgan H&S Manager

    Phil Middleton Env/SocialManager

    Ingemar Bryngelsson HS&S

    ManagerMartin Lednor LTO Manager

    Frank Smith Safety Engineer

    Craig Warrender Environmental

    Engineer

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    2 RISK ASSESSMENT AND MANAGEMENT

    2.1 General

    Risk assessment and management is a key process for the management of HS&ES and is

    central to meeting expectations and the projects goals in these areas. The approach focuses

    on identifying, assessing and managing HS&ES related risks in project activities.

    The rest of this section concentrates on the management of HS risks. ES risks are

    addressed comprehensively in each countrys ESIA (see

    www.caspiandevelopmentandexport.com) and supporting documents.

    2.2 H&S Risk Management Overview

    The approach taken by the project is one of systematic identification of hazards, recording of

    hazards, performing of risk assessments, and devising risk controls to eliminate or reduce

    risk to a tolerable and as low as reasonably practicable level (ALARP).

    Risk identification has been a continuous process from the Define stage when a study was

    commissioned by the project to identify significant ways of improving the safety performance

    (during construction) . This study was based on extensive consultation with industry. The

    recommendations have been used, together with other advice from BP (e.g. the Golden

    Rules Of Safety) and industry sources on best practice, to develop comprehensive HS

    requirements.

    The project has implemented a number of risk assessment and risk management activities

    prior to the Execute phase. These have included:

    HAZIDs,

    HAZOPs,

    QRAs,

    Layout reviews,

    Design and engineering reviews, and

    Constructability reviews.

    The project also commissioned an aviation risk assessment of charter aircraft and helicopter

    companies available to operate in-country.

    2.3 Health Safety during Construction

    The contractor(s) is required to continue the development of the above studies to ensure that

    risks are assessed and reduced to ALARP prior to operational acceptance. These are among

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    a very comprehensive group of requirements in the area of H&S described in the Invitation to

    Tender Document. See also Element 4.

    The contractor is also required to organise and facilitate a Construction Hazard IdentificationWorkshop (HAZCON) to brainstorm, identify, discuss and agree with the project the

    appropriate management controls for hazards arising during the execution of the work

    activities during this phase. A joint risk assessment between project personnel and the

    contractor will then be conducted and actions resolved prior to beginning work or mobilisation

    to site, underlining the need to determine levels of risk for all activities to impose appropriate

    management controls, in particular the need for an effective Permit to Work system.

    The contractor is required to develop risk assessments and method statements to manage all

    identified risks and hazards after break down of the work scope. The contract documents give

    a minimum but non-exhaustive list of these areas.

    2.4 Ensuring HS Safety during Operation through the design process

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    3 A RISK BASED APPROACH HAS BEEN FULLY INTEGRATED INTO THE DESIGN. A

    SAFETY CASE HAS BEEN DEVELOPED WHICH SUMMARISES ALL THE

    RELEVANT PROJECT INFORMATION AND SAFETY STUDIES TO THE END OF THE

    DEFINE STAGE, AND DEMONSTRATES THAT THE DESIGN IS ALARP. A

    SEPARATE SAFETY CASE WILL BE PRODUCED FOR OPERATIONS, ENSURING

    THAT ALL ASSUMPTIONS REGARDING THE WAY THAT THE PIPELINES ARE TO

    BE OPERATED WILL BE EXPLICITLY IDENTIFIED SO THAT APPROPRIAT E

    PROCEDURES CAN BE DEVELOPED, AND THE IMPACT OF ANY CHANGE CAN

    BE READILY ASSESSED. PEOPLE, TRAINING AND BEHAVIOURS

    3.1 General

    The behaviour of people at all levels of the project is critical to its success and to the

    achievement of the HS&ES goals. It is therefore essential that all personnel are carefully

    selected and trained, and that their skills and competencies are regularly assessed. It is also

    essential that good HS&ES performance is encouraged and rewarded, in part through the

    KPIs that have been developed for the project.

    Line management will be responsible for providing the appropriate training and procedures

    necessary to ensure safe work. All personnel employed on the BTC Pipeline Project will be

    responsible for the safety of their work and the safety of others who may be affected by it.

    3.2 Behavioural Change

    There is a project commitment to achieving a substantial improvement in safety performance

    over current industry practice for the construction activity. HS&ES programmes and training

    have been implemented that engage managers, supervisors and personnel in behavioural

    change and improved safety performance such as:

    STOP (Safety Training Observation Program), with STOP cards submitted regularly

    ASA (Advanced Safety Auditing) to identify, recognise and eliminate unsafe acts and

    conditions

    Project Management have engaged contractors senior management and HS&ES

    Professionals in workshops to communicate the projects expectations.

    Personnel going to site will be required to carry a Safety Passport (with photograph), detailing

    the training that that employee has received.

    Training records will be documented in the passports and kept in the permanent training files.

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    3.3 Health

    The Azerbaijan Business Unit Health department supports the project on all health issues in-

    country. There are Doctors in the in-country offices and a health/medical services risk

    assessment has been carried out for each country.

    This risk assessment has been provided to contractors to assist them in determining their

    own level of medical support requirements, which they then provide themselves. The contract

    HS&ES requirements also specify minimum camp welfare standards for contractors

    personnel. Each Office Manager will ensure that workstation health risks and ergonomics are

    assessed.

    3.4 Drugs, Alcohol and Smoking

    It is the projects policy to maintain a work environment free from the influence of alcohol and

    other drug abuse. Accordingly, the project prohibits the consumption, use or influence of

    alcohol and/or illicit drugs during working hours. This includes to/from and during work or

    when conducting business on the projects behalf. Additionally, there are specific restrictions

    with respect to smoking.

    There is a programme for drug and alcohol abuse prevention and random testing that is

    consistent with the scope and objectives of the BP Drug and Alcohol Abuse Policy. There is

    a program for medical review and maintenance of records for drug and alcohol testing

    programs and other mandated compliance programs.

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    4 WORKING WITH CONTRACTORS AND OTHERS

    4.1 General

    The importance of successfully working with contractors to achieve a step-change in safety

    was identified in the Define stage. This led to:

    The development of comprehensive contractual requirements as part of the tendering

    process ;

    Pre-qualification of contractors with HS&ES issues contributing significantly to the scoring

    of bids;

    Requiring contractors to have certain HS&ES items as lump sum amounts and separate

    budget items in the lump sum amounts, for which payment would be against deliveringpromised programmes and performance.

    4.2 Performance Measurement

    Contractors must develop KPIs against which they will be audited and there is a documented

    approach to performance measurement.

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    5 FACILITIES DESIGN AND CONSTRUCTION

    5.1 General

    The project has and continues to undertake the activities necessary to meet the expectations

    for this element. For example:

    Baseline technical, environmental and health data have been collected and formed

    the basis of the ESIAs;

    Facilities have been designed using technology that balances HS&ES risks and

    financial benefits;

    Design, procurement and construction standards have been formally approved by the

    designated technical / engineering authority;

    Formal design review, verification and validation studies have been carried out based

    on risk assessment;

    Operational, maintenance and HS&ES expertise have been integrated early in the

    project / design stage. Experience from previous projects and current operations have

    been applied; and

    Risks have been assessed using appropriate risk assessment tools during the

    preceding project phases and will continue to be assessed (see Section 2). Risks will

    be mitigated and managed accordingly.

    5.2 Contractor Management

    Contractor documentation will be reviewed and approved by appropriate project personnel.

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    6 OPERATIONS AND MAINTENANCE

    6.1 General

    The key activities relating to this element for this stage are related to ensuring:

    Integrity assurance of as-built facilities with design intent;

    Readiness for handover to operations including pre-start up reviews and

    documentation, and acceptance by Operations;

    Commissioning procedures oversight; and

    Lessons learned handover, e.g., due to local geographical or other risks encountered

    during construction.

    HS&ES impacts associated with waste, emissions, noise, biodiversity and energy use during

    construction are addressed in contractual requirements documentation and in the ESIAs.

    Decommissioning, remediation and restoration plans will also be developed prior to handover

    to operations.

    Simultaneous construction and operation, e.g., adjacent pipelines will be addressed in the

    field by the contractors Permit to Work systems.

    Simultaneous construction and operation at Ceyhan Terminal and Jetty will be addressed

    initially through risk assessment, with activity matrices being used to identify prohibited

    concurrent activities, and where additional control procedures may be necessary. This will

    then provide input to the PTW procedures.

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    7 MANAGEMENT OF CHANGE

    7.1 General

    A suite of documented procedures address Management of Change across the project.

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    8 INFORMATION AND DOCUMENTATION

    8.1 Document Control

    A system is in place to securely manage drawings, design data and other

    documentation, including definition of responsibilities for maintaining this information.

    The information requirements for operations have been identified and described.

    A project wide action tracking system has been set up.

    A system has been set up for tracking all the different sections of pipe to ensure that they are

    deployed as intended in the field.

    8.2 Applicable Regulations, Codes, Standards

    Applicable regulations, permits, codes, standards and practices have been identified and

    have been included in the contractual documents and HGAs.

    8.3 Information Storage and Retrieval

    All general project information is retained by DCC.

    Confidential medical records will be kept by the HR department for London based staff and by

    the relevant in-country teams for personnel working in-country.

    8.4 Project Manual

    A manual of essential project-wide information, plans and procedures has been compiled and

    is structured by GHSER element.

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    9 CUSTOMERS AND PRODUCTS

    Not relevant at this stage.

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    10 COMMUNITY AND STAKEHOLDER AWARENESS

    10.1 General

    The BTC Project has and as a whole has and will continue to expend significant effort on

    developing open communication with communities, regulators and other project stakeholders.

    The project will communicate openly to its customers, employees, neighbours, public interest

    groups and contractors regarding significant HS&ES aspects of the project. The method for

    communicating H&S aspects both internally and externally is discussed in the following

    subsections.

    10.2 Internal Communications

    By effective internal communication of the relevant HS&ES aspects, project employees willbe made aware of the Projects HS&ES requirements, expectations and performance.

    10.2.1 Responsibilities

    10.2.1.1 Project Manager

    The Project Director has the ultimate responsibility as to what information will be shared with

    Project employees and representatives.

    10.2.1.2 HS&ES Managers

    The HS & Technical Compliance Manager, the ES Manager and the HS Manager have the

    responsibility to ensure that the personnel, resources and procedures exist that provide for

    the widest dissemination of HS&ES information.

    10.2.1.3 Project Management and Supervisors

    Project In-Country Managers will be responsible for ensuring that those personnel under their

    supervision or responsibility are aware of and understand the applicable HS&ES project

    requirements, goals, and objectives.

    10.2.1.4 Project Employees

    Project employees will be responsible for the information provided to them by their direct line

    management. When there is uncertainty as to what the requirements, goals and/or objectives

    are, the employee will be responsible for initiating the clarification process (i.e., ask the

    question).

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    10.2.2 HS & ES MS Availability

    The HS&ES key documents will be referenced within the Project Management Manual and

    will be available for review by all project employees. A copy of the manual will be available in

    project offices and electronically in Infoworks.

    10.2.3 Monthly Reporting

    At a minimum, monthly H&S reporting will include the number of (unless otherwise specified)

    occurrences during the reporting period.

    Health:

    recordable illnesses; and

    days away from work due to illnesses.

    Safety:

    fatalities;

    road accidents;

    total kilometres driven;

    recordable injuries;

    days away from work due to injuries; and

    hours worked.

    10.2.3.1 Emergencies

    Emergency communications are addressed in the Projects Emergency Preparedness and

    Response Plans see Section 11.

    10.3 External Communications

    External communications regarding significant Project HS&ES aspects must receive prior

    approval from the Project Director. There are circumstances where HS&ES aspects will be

    considered strictly confidential, until the circumstances are completely known and/orotherwise notified by the Project Manager. These include (but are not limited to) any event

    that:

    involves one or more fatalities;

    may receive national or international recognition;

    is a consequence of a major failure to the pipeline or its facilities;

    has implications to the Project Partners or Companys reputation;

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    Information regarding the items listed above may be communicated externally, but not until

    they have been fully investigated, appropriate persons notified, and the full details of the

    events known.

    10.4 Complaints

    As a result of project activities, complaints may be received either internally or externally that

    have HS&ES aspects. Complaints will typically be managed on a case-by-case basis. All

    complaints shall be included in the HS&ES monthly reports.

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    11 CRISIS AND EMERGENCY MANAGEMENT

    11.1 Emergency Response Plans

    An overall Emergency Response Plan is in place for the BTC Project, which provides

    an overall framework for emergency response.

    In-country plans address eventualities at the work site including, for example, fire, explosion,

    collapse of structures, serious injuries, medivac, spillage of chemicals and exposure to toxic

    substances. The plans also address response to natural occurrences such as lightning,

    storms and floods and other important security issues such as civil unrest or terrorist activity.

    The plans dovetail into the Azerbaijan Business Unit Incident Management System.

    The plans detail

    emergency organisation,

    resources and equipment,

    identification and testing of equipment and facilities,

    the responsibilities of key personnel,

    communications to be made,

    from where assistance should be sought,

    site evacuation, and

    rescue of persons.

    The plans include a medical emergency plan for dealing with injuries. Where appropriate, the

    in-country plans have been developed in consultation and co-operation with the local

    authorities and emergency services.

    Contractors own plans will be integrated with the in-country plans and include Emergency

    Response Plan (ERP) Bridging Documents.

    11.2 Oil Spill Response

    Specific oil spill response plans will be in place for operations.

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    12 INCIDENTS ANALYSIS AND PREVENTION

    12.1 General

    Injuries, illnesses, accidents, near misses and hazards will be reported, investigated and

    documented according to the BTC procedures .

    Contractors will have their own equivalent procedures.

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    13 ASSESSMENT, ASSURANCE AND IMPROVEMENT

    13.1 General

    HS&ES assessment and assurance through audits and inspections will carried out in

    accordance with control and assurance procedures:

    In addition each country has developed its own audit activity schedules.

    13.2 BTC Activities and Safety Inputs

    There are monthly targets for the numbers of ASAs, STOPs and H&S training hours and

    these will be recorded and reported. This information will be collected and analysed by the

    relevant H&S Manager at each level. Contractors will be expected to deliver similar inputs.

    13.3 Assurance of Contractors

    Contractors must develop KPIs against which their H&S performance will be measured (see

    Section 4). Contractors will also develop an incentive scheme for its staff and sub-

    contractors, which involves an assessment of the effectiveness of HS&ES procedures and

    how well they are implemented.

    Monitoring the activities of the Contractor, collaborating and assisting where required, and

    providing feedback on performance, are key activities to be undertaken.

    13.4 Improvement

    Findings from learning processes (e.g., audits, incident investigations, near misses,

    HAZOPS, etc.) will be prioritised and tracked using the Project wide Action Tracking system

    (ATS) and used to systematically improve the H&S processes.