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SGSO PRELIMINARY TRANSLATION 0.0 NOTE: This free translation has no legal effect for compliance or enforcement purposes. The original document can be obtained at http://www.anp.gov.br/petro/legis_seg_operacional.asp . NATIONAL PETROLEUM, NATURAL GAS AND BIOFUELS AGENCY RESOLUTION Nº 43 DATED 06 th DECEMBER, 2007. THE DIRECTOR-GENERAL of the NATIONAL PETROLEUM, NATURAL GAS AND BIOFUELS AGENCY – ANP, in the exercise of his legal attributions and based on the Directorate Decision nº 696, dated 29 th November, 2007. Considering the ANP purpose of promoting the regulation, hiring and monitoring of economic activities concerning the petroleum industry, in accordance with the provisions in the legislation, in the guidelines issued by the National Council for Energy Policy - CNPE and in accordance with the interests of the Country, as established in the art. 8 of Law 9.478, dated 06 th August, 1997 and in art. 2, Chapter I, Annex I of Decree n o 2.455, dated 14 th January, 1998; Considering the ANP principle of monitoring economic activities, with the purpose of educating and guiding the economic players of the sector, and also exercising preventive measures and enforcement acts regarding violations of the relevant legislation and of the provisions contained in contracts and authorizations, as established in sub-item VI of art. 3, Chapter I, Annex I of Decree n o 2.455, dated 14 th January, 1998; Considering the ANP duty of monitoring the marine installations regarding the activities of drilling and production of oil and natural gas, as established in sub-item V of art. 27, Chapter VI of Law 9.966, dated 28 th April, 2000; Considering the ANP competence to establish the technical economical and legal requirements to be accomplished by concessionaires at the drilling and production installations of oil and natural gas, and the design requirements regarding the environmental protection, the industrial safety and the populations involved; Considering the need to establish criteria to the concessionaires register the conditions of the Operational Safety in order to meet ANP requirements to monitor activities of drilling and production, and Considering the need to establish criteria for implementation and operation of an adequate Management System for Operational Safety at drilling and production facilities, new or for those already operational, hereby makes public the following act: OPERATIONAL SAFETY REGIMEN Art. 1º The Operational Safety Regimen for drilling and production facilities of oil and natural gas is hereby established. § 1º The Operational Safety Regimen is understood to mean the regulatory structure established by the ANP with the purpose of guaranteeing Operational safety, taking into account the responsibilities of the Concessionaire and the duties of the ANP in conducting the activities on marine installations for exploration and production of oil and natural gas. § 2º In the Operational Safety Regimen, the responsibilities of the Concessionaire are considered as being:

Transcript of Sgso full translation aug2010

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NATIONAL PETROLEUM, NATURAL GAS AND BIOFUELS AGENCY

RESOLUTION Nº 43 DATED 06th DECEMBER, 2007.

THE DIRECTOR-GENERAL of the NATIONAL PETROLEUM, NATURAL GAS AND BIOFUELS AGENCY – ANP, in the exercise of his legal attributions and based on the Directorate Decision nº 696, dated 29th November, 2007. Considering the ANP purpose of promoting the regulation, hiring and monitoring of economic activities concerning the petroleum industry, in accordance with the provisions in the legislation, in the guidelines issued by the National Council for Energy Policy - CNPE and in accordance with the interests of the Country, as established in the art. 8 of Law 9.478, dated 06th August, 1997 and in art. 2, Chapter I, Annex I of Decree no 2.455, dated 14th January, 1998;

Considering the ANP principle of monitoring economic activities, with the purpose of educating and guiding the economic players of the sector, and also exercising preventive measures and enforcement acts regarding violations of the relevant legislation and of the provisions contained in contracts and authorizations, as established in sub-item VI of art. 3, Chapter I, Annex I of Decree no 2.455, dated 14th January, 1998; Considering the ANP duty of monitoring the marine installations regarding the activities of drilling and production of oil and natural gas, as established in sub-item V of art. 27, Chapter VI of Law 9.966, dated 28th April, 2000; Considering the ANP competence to establish the technical economical and legal requirements to be accomplished by concessionaires at the drilling and production installations of oil and natural gas, and the design requirements regarding the environmental protection, the industrial safety and the populations involved; Considering the need to establish criteria to the concessionaires register the conditions of the Operational Safety in order to meet ANP requirements to monitor activities of drilling and production, and

Considering the need to establish criteria for implementation and operation of an adequate Management System for Operational Safety at drilling and production facilities, new or for those already operational, hereby makes public the following act:

OPERATIONAL SAFETY REGIMEN

Art. 1º The Operational Safety Regimen for drilling and production facilities of oil and natural gas is hereby established. § 1º The Operational Safety Regimen is understood to mean the regulatory structure established by the ANP with the purpose of guaranteeing Operational safety, taking into account the responsibilities of the Concessionaire and the duties of the ANP in conducting the activities on marine installations for exploration and production of oil and natural gas.

§ 2º In the Operational Safety Regimen, the responsibilities of the Concessionaire are considered as being:

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I. ascertain that the installation operator has a management system that meets the practices

of the Management System for Operational Safety (SGSO) established by ANP in the attached Technical Regulation;

II. ascertain that the installation operator will provide the verification of the critical elements for

operational safety and will audit the Operational Safety Management System as prescribed in the Technical Regulation attached;

III. submit to the ANP the documentation described in the 3rd article;

IV. provide free access to the Concession Area and to the operations, for inspections and auditing of the facilities giving transport, food, accommodation and other provisions needed to meet the requirements established in sub-item VI of art. 3, Chapter I, Annex I of Decree no 2.455, dated 14th January, 1998. The ANP will previously communicate the Concessionaire to ensure a minimum impact at the conduction of regular operations;

V. provide immediate and unrestricted access for accident investigation at the Concession

Area, giving transport, food, accommodation and other provisions needed to meet the requirements established in the ANP Administrative Rule nº 3, dated 10th January, 2003.

§ 3º In the Operational Safety Regimen, the following items are considered to be ANP duties:

I. Carry out the analysis of the documentation required in the 3rd Article;

II. Carry out audits at the installation to verify the performance of the Operational Safety

Management System, in order to comply with the requirements established in sub-item VI of art. 3, Chapter I, Annex I of Decree no 2.455, dated 14th January, 1998.

III. Carry out inspections of the critical elements for operational safety, in order to comply with

the requirements established in sub-item VI of art. 3, Chapter I, Annex I of Decree no 2.455, dated 14th January, 1998.

IV. Investigate accidents, in order to comply with the requirements established in sub-item V of

art. 27, Chapter VI of Law nº 9.966, dated 28th April, 2000, without detriment to the application of other administrative rules established in the provisions, and

V. Put into effect injunction actions when found non-conformities regarding the Technical

Regulation approved by this Resolution and other requirements contained at the applicable legislation, as established in the specific legislation about injunction procedures.

§ 4º The following installations are covered by Operational Safety Regimen:

I. Drilling Installations;

II. Production Installation; and

III. Storage and Offloading Installations;

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SGSO TECHNICAL REGULATION Art. 2º The attached Technical Regulation of the Management System for Operational Safety on Marine Installations for Drilling and Production of Oil and Natural Gas is hereby approved. Art. 3º The Concessionaire must submit to the ANP the Safety Operational Documentation (DSO) described at the Technical Regulation attached. § 1º For drilling installations, the DSO must be presented 90 (ninety) days prior to the date set for the start-up of the installation in Waters under National Jurisdiction. § 2º For production installations, the DSO must be presented 180 (one hundred and eighty) days prior to the date set for the date scheduled to the installation positioning at the permanent location. § 3º In special situations and when technically justified, the deadline for the documentation presentation may be modified, at the discretion of the ANP.

§ 4º When delivering the Operational Safety Documentation (DSO) to the ANP, the

Concessionaire shall assume entire responsibility for the content as well as for the compliance of

the installation operational safety conditions with the requirements of the Technical Regulation

attached.

§ 5° The operation start-up permission will be given after the analysis of the documentation

established by this Resolution, according to the following deadlines:

I. ANP will carry out the analysis up to a maximum of 30 days and will require modifications

or complementary information, or will allow the commencement of operations by the concessionaire demonstration to perform the activity.

II. Up to a maximum of 30 days after receiving the modifications or the complementary

information previously required, the ANP may require new modifications or information, or will allow the commencement of operations by the concessionaire demonstration to perform the activity.

§ 6º The absence of manifest by the ANP indicates express permission for the start of the activities.

INSTALLATIONS IN OPERATION

Art. 4º The installations covered by the Operational Safety Regimen that are operating when this Regulation came into force, must be aligned with the Technical Regulation within 2 (two) years.

§ 1º The Concessionaire must submit to the ANP, within 90 (ninety) days of this Resolution coming into force, a timetable for presenting the Operational Safety Documentation (DSO) and for the implementation of the Technical Regulation on each installation for drilling or production.

§ 2º The ANP will carry out the analysis and approval of the proposed timetables.

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§ 3º When technically justified by the concessionaire, the ANP may approve adjustments on the timetables. § 4º The two-year period cited at this Article may be extended when technically justified on the timetable submission, but never exceeding 4 (four) years.

INSTALLATIONS IN CONSTRUCTION

Art. 5º The installations covered by the Operational Safety Regimen that are under construction or that intends to operate within one year from the start of the validity of this resolution, shall submit a timetible for presenting the Operational Safety Documentation (DSO) and for the implementation of the Technical Regulation on each installation for drilling or production. § 1º The ANP will carry out the analysis and approval of the proposed timetables.

§ 2º When technically justified by the concessionaire, the ANP may approve adjustments at the timetables.

PENALTIES

Art. 6º Non-compliance with the provisions herein shall imply the application of the penalties defined at the applicable legislation.

Art. 7º The unforeseen cases will be analyzed at the discretion of the ANP.

Art. 8º This Resolution shall come into force on the publication date.

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TECHNICAL REGULATION OF THE MANAGEMENT SYSTEM FOR OPERATIONAL SAFETY ON MARINE INSTALLATIONS FOR DRILLING AND PRODUCTION OF OIL AND

NATURAL GAS

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INDEX

CHAPTER 1

GENERAL PROVISIONS

1 OBJECTIVE ................................................................................................................................................................... 1

2 DEFINITIONS ................................................................................................................................................................ 1

2.1 Corretive Action ....................................................................................................................1

2.2 Preventive Action ..................................................................................................................1

2.3 Fitness for Purpose ..............................................................................................................1

2.4 Decomissioning of Installation ..............................................................................................1

2.5 Critical Operational Safety Elements ....................................................................................1

2.6 Workforce .............................................................................................................................2

2.7 Installation Manager .............................................................................................................2

2.8 Incident .................................................................................................................................2

2.9 Installation ............................................................................................................................2

2.10 Correlation Matrix ...............................................................................................................2

2.11 Non-Conformity ..................................................................................................................2

2.12 Installation Operator ...........................................................................................................3

2.13 Emergency Plan .................................................................................................................3

2.14 Operational Safety ..............................................................................................................3

2.15 Hazardous or Noxious Substance.......................................................................................3

2.16 Visitor .................................................................................................................................3

3 COVERAGE................................................................................................................................................................... 3

3.1 Installations ..........................................................................................................................3

3.2 Activities ...............................................................................................................................3

3.3 Life Cycle of Installations ......................................................................................................3

3.4 Exclusions ............................................................................................................................4

4 MANAGEMENT PRACTICES ....................................................................................................................................... 4

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4.1 Management Practices related to Leadership, Personnel and Management, presented in the Chapter 2: .............................................................................................................................4

4.2 Management Practices related to the Installations and Technology, presented in Chapter 3:4

4.3 Management Practices related to the Operational Practices, presented in Chapter 4: ..........4

5 OPERATIONAL SAFETY DOCUMENTATION (DSO) .................................................................................................. 5

5.1 Presentation of the Operational Safety Documentation (DSO) ..............................................5

5.2 Updating and Revision ..........................................................................................................5

5.3 Correlation Matrix (MC) ........................................................................................................5

5.4 Marine Unit Description (DUM) .............................................................................................6

5.5 Concessionaire Information Report (RIC) .............................................................................7

CHAPTER 2

LEADERSHIP, PERSONNEL AND MANAGEMENT

MANAGEMENT PRACTICE No. 1: SAFETY CULTURE, COMMITMENTS AND MANAGERIAL RESPONSIBILITY ... 8

1.1 Objective ..............................................................................................................................8

1.2 Safety Values and Policy ......................................................................................................8

1.3 Organizational Structure and Managerial Responsibility .......................................................8

1.4 Means of Communication .....................................................................................................8

1.5 Resource Availability and Planning .......................................................................................8

MANAGEMENT PRACTICE No. 2: INVOLVEMENT OF PERSONNEL .......................................................................... 9

2.1 Objective ..............................................................................................................................9

2.2 Personnel Participation .........................................................................................................9

MANAGEMENT PRACTICE No. 3: QUALIFICATION, TRAINING AND PERSONNEL PERFORMANCE ..................... 9

3.1 Objective ..............................................................................................................................9

3.2 Organizational Structure .......................................................................................................9

3.3 Training ................................................................................................................................9

MANAGEMENT PRACTICE No. 4: WORK ENVIRONMENT AND HUMAN FACTORS ............................................... 10

4.1 Objective ............................................................................................................................ 10

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4.2 Work Environment and Human Factors .............................................................................. 10

MANAGEMENT PRACTICE No. 5: SELECTION, CONTROL AND MANAGEMENT OF CONTRACTED ................... 11

5.1 Objective ............................................................................................................................ 11

5.2 Selection and Evaluation of Contracted .............................................................................. 11

5.3 Operator Responsibilities .................................................................................................... 11

5.4 Training of Contracted ........................................................................................................ 11

MANAGEMENT PRACTICE No. 6: MONITORING AND CONTINUED IMPROVEMENT OF PERFORMANCE .......... 11

6.1 Objective ............................................................................................................................ 11

6.2 Safety Goals and Performance Indicators........................................................................... 11

6.3 Monitoring ........................................................................................................................... 12

MANAGEMENT PRACTICE No. 7: AUDITS.................................................................................................................. 12

7.1 Objective ............................................................................................................................ 12

7.2 Audit Planning .................................................................................................................... 12

7.3 Audit Execution................................................................................................................... 13

7.4 Audit Evaluation .................................................................................................................. 13

MANAGEMENT PRACTICE No. 8: INFORMATION AND DOCUMENTATION MANAGEMENT ................................. 14

8.1 Objective ............................................................................................................................ 14

8.2 Responsibilities in Information Management ....................................................................... 14

8.3 Information Access ............................................................................................................. 14

MANAGEMENT PRACTICE No. 9: INCIDENTS INVESTIGATION ............................................................................... 14

9.1 Objective ............................................................................................................................ 14

9.2 Procedures and Investigation Organization ........................................................................ 14

9.3 Investigation Execution ....................................................................................................... 14

9.4 Corrective Actions .............................................................................................................. 15

9.5 Preventive Actions .............................................................................................................. 15

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CHAPTER 3 INSTALLATIONS AND TECHNOLOGY

MANAGEMENT PRACTICE No. 10: DESIGN, CONSTRUCTION, INSTALLATION AND DECOMISSIONING ........... 16

10.1 Objective .......................................................................................................................... 16

10.2 Management and Organization ......................................................................................... 16 10.3 Safety at the Design, Construction, Installation and Decomissioning Phases………….... 16

MANAGEMENT PRACTICE No. 11: CRITICAL OPERATIONAL SAFETY ELEMENTS .............................................. 16

11.1 Objective .......................................................................................................................... 16

11.2 Identification of Critical Operational Safety Elements ........................................................ 17

11.3 Critical Operational Safety Elements Management and Control ........................................ 17

MANAGEMENT PRACTICE No. 12: RISK IDENTIFICATION AND ANALYSIS ........................................................... 17

12.1 Objective .......................................................................................................................... 17

12.2 Types of Risks Analysis .................................................................................................... 17

12.3 Risks Identification and Analysis Methodology.................................................................. 17

12.4 Risk Analysis Execution .................................................................................................... 18

12.5 Preparation of the Risk Analysis Report............................................................................ 18

12.6 Results ............................................................................................................................. 18

MANAGEMENT PRACTICE No. 13: MECHANICAL INTEGRITY ................................................................................. 19

13.1 Objective .......................................................................................................................... 19

13.2 Inspection, Test, Maintenance and Procurement Planning ............................................... 19

13.3 Activities Control ............................................................................................................... 19

13.4 Monitoring and Results Evaluation .................................................................................... 19

MANAGEMENT PRACTICE No. 14: PLANNING AND MANAGEMENT OF MAJOR EMERGENCIES ....................... 20

14.1 Objective .......................................................................................................................... 20

14.2 Planning and Management of Emergencies ..................................................................... 20

14.3 Major Emergencies Response .......................................................................................... 20

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14.4 Response Resources Management .................................................................................. 21

14.5 Communication System .................................................................................................... 21

14.6 Simulated Exercises...........................................................................................................21

14.7 Emergency Plan Update ................................................................................................... 21

CHAPTER 4 OPERATIONAL PRACTICES

MANAGEMENT PRACTICE No. 15: OPERATIONAL PROCEDURES ......................................................................... 22

15.1 Objective .......................................................................................................................... 22

15.2 Preparation and Control of the Operational Procedures .................................................... 22

15.3 Procedures for Start-up and Decommissioning ................................................................. 22

15.4 Simultaneous Operations ................................................................................................. 22

MANAGEMENT PRACTICE No. 16: MANAGEMENT OF CHANGE ............................................................................ 23

16.1 Objective .......................................................................................................................... 23

16.2 Types of Changes ............................................................................................................ 23

16.3 Control Procedures ........................................................................................................... 23

MANAGEMENT PRACTICE No. 17: SAFE WORKING PRACTICES AND CONTROL PROCEDURES IN SPECIAL ACTIVITIES .................................................................................................................................................................... 23

17.1 Objective .......................................................................................................................... 23

17.2 Permit to Work .................................................................................................................. 23

17.3 Monitoring ......................................................................................................................... 24

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CHAPTER 1 GENERAL PROVISIONS

1 OBJECTIVE The Objective of this Technical Regulation is to establish requirements and directives for implementation and operation of a Management System for Operational Safety (SGSO), to guarantee the operational safety of marine installations for drilling and production of oil and natural gas, aiming at the protection of human life and environment, by the adoption of 17 management practices. 2 DEFINITIONS This Technical Regulation adopts the Definitions indicated in items 2.1 to 2.16. 2.1 Corretive Action Action to eliminate a detected Non-conformity or other undesirable situation. 2.2 Preventive Action Action to eliminate the cause of a pontential Non-conformity to prevent its occurrence. 2.3 Fitness for Purpose Condition needed for an Installation (or equipment) to be designed, maintained, inspected, tested and operated in a way that is appropriate for the purpose, performance, availability and effectiveness required. 2.4 Decomissioning of Installation Envolves the removal of production facilities, providing appropriate destination, and the environmental recovery of the areas where these facilities were located. 2.5 Critical Operational Safety Elements The Critical Operational Safety Elements are classified in three categories: 2.5.1 Critical Operational Safety Equipment Any equipment or structural element of the installation that could, in case of failure, cause or significantly contribute to a near accident or to an operational accident. 2.5.2 Critical Operational Safety System

Any engineering control system that has been designed to maintain the Installation within Operational Safety bounds, to completely or partially stop the installation or process in case of failure or to reduce human exposure to the consequences of failures. 2.5.3 Critical Operational Safety Procedure A procedure or criteria used to control operational risks.

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2.6 Workforce All the people involved in the operation of the Installation, employees of the operator or of the contracted. 2.7 Installation Manager Person designated by the operator for onboard responsibility of management and execution of all operations and activities. 2.8 Incident Incident means any occurrence arising from a fact or an intentional or accidental act involving:

a) risk of harm to the environment or to human health; b) harm to the environment or to human health; c) material damage to self-owned or third party properties; d) occurrence of fatalities or serious injuries to employees or contracted personnel; e) unexpected interruption of the Installation operations for more than 24 (twenty-four) hours.

Within this concept of an incident, near-accidents and accidents related to operational safety are defined as follows: 2.8.1 Near Accident Any unexpected event that has potential risk to operational safety, not harmful to human health or the environment. 2.8.2 Accident Any unexpected event that causes harm to the environment or to human health, material damage to operator or third parties, fatalities or serious injuries to employees or third parties, or interruption of the Installations operations for more than 24 (twenty-four) hours. 2.9 Installation A fixed or floating marine structure, used at drilling, production, storage or offloading of oil and natural gas. 2.10 Correlation Matrix Document prepared by the Installation Operator, establishing the correlation between the requirements contained in the management practices of SGSO and documents of its own management system. 2.11 Non-conformity Non-fulfillment of a requirement of this Technical Regulation.

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2.12 Installation Operator Concessionaire or company designated by the concessionaire to be responsible for the management and execution of all operations and activities of an Installation. 2.13 Emergency Plan A set of measures that determines and establishes the responsibilities and actions to be initiated immediately after an incident, as well as defining human resources, materials and adequate equipments for prevention, control and response to the Incident. 2.14 Operational Safety The prevention, mitigation and response to events that may cause accidents that can put human life or the environment at risk, in marine Installations for drilling and production of oil and natural gas, by the adoption of a Management System that ensures the integrity of Installations throughout its entire life cycle. 2.15 Hazardous or Noxious Substance Any substance that, if released to the atmosphere or into waters, is capable of generating risk or cause damage to human health, ecosystems, or to impair use of air, water and surroundings. 2.16 Visitor Any person that not belongs to the Workforce and may access the installations covered by the Technical Regulation for a limited period of time, not exceeding 3 (three) days. 3 COVERAGE 3.1 Installations The following Installations, authorized by the ANP for carrying out the activities listed at 3.2, are covered by this Technical Regulation:

a) Drilling Installations; b) Production Installations; and c) Storage and Offloading Installations.

3.2 Activities The Exploration and Production Activities covered by this Technical Regulation are:

a) well drilling; b) well completion and refurbishment; c) production of oil and natural gas; d) primary petroleum processing; e) oil storage and offloading; and f) natural gas compression and offloading.

3.3 Life Cycle of Installations

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This Technical Regulation is applicable to the entire Life Cycle of drilling and production Installations, including the phases of:

a) design; b) construction; c) installation; d) operation; and e) Decomissioning.

3.4 Exclusions This Technical Regulation does not apply to:

a) Marine Installations for drilling and production that are in transit or installations that are not executing authorized operations;

b) Onshore Installations for drilling and production; c) Pipelines.

4 MANAGEMENT PRACTICES The 17 Management Practices contained in this Technical Regulation are divided into 3 major groups: 4.1 Management Practices related to Leadership, Personnel and Management, presented in the Chapter 2:

a) Management Practices nº 1: Culture of Safety, Commitment and Managerial Responsibility;

b) Management Practices nº 2: Involviment of Personnel; c) Management Practices nº 3: Qualification, Training and Personnel Performance; d) Management Practices nº 4: Work Environment and Human Factors; e) Management Practices nº 5: Selection, Control and Management of Contracted; f) Management Practices nº 6: Monitoring and Continuous Improvement of Performance; g) Management Practices nº 7: Audits; h) Management Practices nº 8: Information and Documentation Management; and i) Management Practices nº 9: Incident Investigation.

4.2 Management Practices related to the Installations and Technology, presented in Chapter 3:

a) Management Practices nº 10: Design, Construction, Installation and Decomissioning; b) Management Practices nº 11: Critical Operational Safety Elements; c) Management Practices nº 12: Risk Identification and Analysis; d) Management Practices nº 13: Mechanical Integrity; and e) Management Practices nº 14: Planning and Management of Major Emergencies.

4.3 Management Practices related to the Operational Practices, presented in Chapter 4:

a) Management Practices nº 15: Operational Procedures; b) Management Practices nº 16: Management of Change; and c) Management Practices nº 17: Safe Working Practices and Control Procedures in Special

Activities.

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5 OPERATIONAL SAFETY DOCUMENTATION (DSO) The Concessionaire subject to the Technical Regulation should prepare three documents for submission to the ANP. The collection of documents listed below will be referred as Operational Safety Documentation (DSO):

a) Correlation Matrix (MC) b) Marine Unit Description (DUM); and c) Concessionaire Information Report (RIC).

5.1 Presentation of the Operational Safety Documentation (DSO) 5.1.1 For marine drilling Installations, DSO should be submitted 90 (ninety) days prior to the date scheduled for the beginning of the Installation operation in Brazilian Waters. 5.1.2 For marine production Installations, DSO should be submitted with 180 (one hundred and eighty) days prior to the date scheduled for the Installation positioning at the permanent location. 5.1.3 The Correlation Matrix (MC) and the Marine Unit Description (DUM) should integrate administrative processes when submitted to ANP. The documents that may serve to more than one DSO will be kept as independent administrative processes. 5.1.4 If the Correlation Matrix (MC) and the Marine Unit Description (DUM) had been submitted to ANP by another Concessionaire, they will be dismissed from re-submission, as described at the Concessionaire Information Report (RIC) 5.1.5 Will be allowed a unique management system, presented as a Correlation Matrix (MC), for a particular Installation Operator, concessionarie or not, that operates in one or more concessions, contiguous or not. 5.1.6 The Marine Unit Description should be presented for each Installation referred at this Regulation. 5.1.7 Marine uninhabited Installations operating under the supervision of a central should be included in the DSO of the set of Installations. 5.2 Updating and Revision 5.2.1 The MC, DUM and RIC should be sent to the ANP when modified. 5.2.2 For Production Installations, the Concessionaire should annually endorse that the information contained in the documents MC, DUM and RIC remains unchanged. The endorsement should be submitted together with the Annual Work Program and Budget (PAT). 5.3 Correlation Matrix (MC) 5.3.1 The Installation Operator must have a management system for operational safety and must develop a matrix establishing the correlation between the requirements contained in SGSO and his own management system. 5.3.2 Structure of the Correlation Matrix

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The Correlation Matrix (MC) should consider all the elements described in the 17 management practices and must refer to each item of SGSO. 5.4 Marine Unit Description (DUM) The installation Operator must prepare the Marine Unit Description (DUM), describing the items related to the Installation Safety. 5.4.1 Content of the Marine Unit Description 5.4.1.1 The content of the DUM should be presented as described at the Annexes 1 and 2 of this Technical Regulation. 5.4.1.2 The risks to health or the environment related to hazardous or noxious substances produced or used in the installation must be described in the chemical products information sheets that should be available on the Installation. 5.4.2 Plans and Documents 5.4.2.1 The general plans and documents listed below are part of the DSO, and must be sent together with the forms of Annexes 1 and 2.

a) Installation General Arrangement; and b) Process Flow Diagram, which must contain the process overview and the identification of

major equipment and pipes. 5.4.2.2 The certificates, plans and documents that details the design and operation of the installation does not need to be submitted to the ANP, but must be available onboard:

a) Certificates listed in the International Conventions and in the Maritime Authority Standards

(NORMAM); b) Statement for the Operation of Platforms, as established in the Maritime Authority

Standards (NORMAM); c) Drawings, plans and detailed diagrams with their structural systems, naval, drilling,

production and process, such as: - Stability systems, ballast, dynamic positioning, mooring, anchoring, among others; - List of installation equipment and pipelines; - Power and control systems; - Risers and receiving, processing and offloading systems for oil and gas production; - Pressurization and depressurization systems, including safety valves for pressure relief of flares and ventilation; - Escape, evacuation and rescue areas and equipments, including temporary shelters, lifeboats, rescue and stand-by vessels;

- Artificial lift equipments; - Fire and explosion barriers, including the fire-protection project for temporary shelters; - Cargo handling equipment such as cranes, winches, lifeboat davits; and - Accommodations.

d) Classification of Locations for Electrical Installations e) Oil Book, approved under terms of the MARPOL 73/78 Convention, as established in

article 10 of Law nº 9966/2000.

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5.5 Concessionaire Information Report (RIC) 5.5.1 The Concessionaire must prepare the RIC containing information related to the project, as described at the Annexes 3 and 4 of this Technical Regulation. 5.5.2 For Marine Drilling Installations, the Concessionaire shall submit, in addition to the requirements of Annex 3, a document that establishes the correlation between his own management system and the Safety Management System of the Installation Operator, to be used during the operation.

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CHAPTER 2 LEADERSHIP, AND PERSONNEL MANAGEMENT

MANAGEMENT PRACTICE No. 1: SAFETY CULTURE, COMMITMENTS AND MANAGERIAL RESPONSIBILITY 1.1 Objective The operator of the installation will define the Operational Safety values and politics, will implement an organizational structure defining the responsibilities and duties of the personnel involved, as well as establishing means of communication of values, policies and goals and will be committed to the availability of resources for the implementation and operation of the Operational Safety Management System. 1.2 Safety Values and Policy The Installation Operator must establish and disseminate the safety values and policy for the personnel involved in the installation activities. 1.3 Organizational Structure and Managerial Responsibility The Installation Operator will be responsible for: 1.3.1 Establishing the organizational structure for management of the Installation regarding to the Operational Safety. 1.3.2 Ensuring the effective participation of Installation Managers in the activities related the Operational Safety. 1.3.3 Define the duties and responsibilities of the entire workforce in the Operational Safety, including the installation Managers, other operators’ employees and personnel of contracted companies. 1.4 Means of Communication The Installation Operator will define the communication system for the workforce. The communication system will be established to: 1.4.1 Inform the Workforce about the policy, values, goals and plans to achieve the performance established for the Operational Safety. 1.4.2 Establish mechanisms for mutual and continuing communication between the managers and the workforce aimed at the improvement for operational safety. 1.5 Resource Availability and Planning The Installation Operator must plan and provide the necessary resources for the implementation and operation of the Safety Operational Management System and to comply with all requirements established in this Technical Regulation.

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MANAGEMENT PRACTICE No. 2: INVOLVEMENT OF PERSONNEL 2.1 Objective The Installation Operator must carry out the management practice in order to promote the involvement, the awareness and the participation of the workforce in the execution of the Operational Safety Management System. 2.2 Personnel Participation The Installation Operator will be responsible for: 2.2.1 Setting conditions for workforce participation in the development, implementation and periodic evaluation of the Operational Safety Management System. 2.2.2 Promoting awareness and information activities related to operational safety, as well as providing participation opportunities for the entire workforce. MANAGEMENT PRACTICE No. 3: QUALIFICATION, TRAINING AND PERSONNEL PERFORMANCE 3.1 Objective The Installation Operator must carry out the management practice in order to ensure that the workforce perform their functions in a safe manner, according to the organizational structure and responsibilities established at the Operational Safety Management System. 3.2 Organizational Structure 3.2.1 The operator will define the organizational structure of the Installation, establishing the function classification and the duties related to the function assigned. 3.2.2 Based on the function classification, the Operator will identify the training, competence, skills and knowledge levels required to each function, which qualifies the employee to perform the duties related to the function assigned. The functions and duties considered hazardous or that can produce impact on Operational Safety or Operational Safety Critical Elements should be emphasized. 3.3 Training The Installation Operator will be responsible for: 3.3.1 Establishing the training requirements in order to qualify the employee to perform the duties related to the function assigned. 3.3.2 Dimensioning the training program in accordance with the function classification and the duties related to the function assigned. 3.3.3 Ensuring that contracted companies establish the training requirements and programs as defined on items 3.3.1 and 3.3.2. 3.3.4 Establishing the qualification and training required to carry out the activities considered at the operational procedures.

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3.3.5 The following training types should be considered: 3.3.5.1 Awareness Training Necessary for all workforce, as well as visitors, whenever boarding installations covered by this Technical Regulation. 3.3.5.2 General Training Necessary for the workforce assigned to routinely perform operations, inspections, maintenance and engineering activities. This training should be conducted as part of the Operational Safety Management System implementation and must be periodically reviewed. 3.3.5.3 Specialized Training Necessary for the workforce assigned to perform specific activities related to this Technical Regulation. This training should be conducted as part of the Operational Safety Management System implementation and must be periodically reviewed. 3.3.6 Training Registration and Verification The operator must be able to provide evidence that the workforce has received the training associated to the functions assigned, and must create means to periodically check the compliance with this requirement. MANAGEMENT PRACTICE No. 4: WORK ENVIRONMENT AND HUMAN FACTORS 4.1 Objective The Installation Operator must carry out the management practice in order to encourage an adequate work environment and to consider the human factors during the whole Installation lifecycle. 4.2 Work Environment and Human Factors The Installation Operator will be responsible for: 4.2.1 Analyzing the aspects of the work environment in order to consider the human factors during the whole lifecycle of the installation and their systems, structures and equipments. 4.2.1.1 The codes and standards related to the work environment and human factors should be identified and considered in the phases of design, construction, installation and decommissioning. 4.2.1.2 During the operation, should be promoted the awareness of the workforce involved in the operation and maintenance, related to situations and conditions that may cause incidents.

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MANAGEMENT PRACTICE No. 5: SELECTION, CONTROL AND MANAGEMENT OF CONTRACTED 5.1 Objective The Installation Operator must carry out the management practice in order to establish requirements for selection and evaluation of contracted, considering the aspects of operational safety in all activities covered by this Technical Regulation. 5.2 Selection and Evaluation of Contracted The Installation Operator should establish requirements concerning the aspects of operational safety for selection and evaluation of contracted, according to the risk of undertaken activities. 5.3 Operator Responsibilities The Installation Operator will be responsible for: 5.3.1 Establishing the responsibilities of contracted, concerning the Operational Safety. 5.3.2 Ensuring that all contracted companies that provide services to the Installation:

a) Have trained employees on the safe work practices of the Installation; b) Have periodically instructed employees about the hazards related to the activities

performed, including fires, explosions and release of noxious substances; c) Have qualified employees to execute their responsibilities regarding the Installation

Emergency Plan; and d) Notify any risk identified to the Installation Operator.

5.4 Training of Contracted 5.4.1 Should be kept evidence that contracted employees have received adequate training in order to perform their functions in a safe manner. MANAGEMENT PRACTICE No. 6: MONITORING AND CONTINUED IMPROVEMENT OF PERFORMANCE 6.1 Objective The Installation Operator must carry out the management practice in order to establish performance indicators and goals to evaluate the effectiveness of the operational safety and to promote continuous improvement of the Installation safety conditions. 6.2 Safety Goals and Performance Indicators The Installation Operator will be responsible for: 6.2.1 Establishing the Operational Safety objectives to carry out the performance verification. 6.2.2 Defining a set of pro-active (to evaluate the conditions that may start or contribute to the occurrence of accidents) and reactive performance indicators. 6.2.3 Establishing the Operational Safety goals.

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6.2.4 Establishing regular reviews of the performance established for the Operational Safety. 6.2.5 Establishing a system of preventive and corrective actions when identified insufficient performance. 6.3 Monitoring The operator of the installation will be responsible for: 6.3.1 Establishing and maintaining documented procedures to regularly monitor and measure the main characteristics of the operations and activities that may cause incidents. Such procedures must include: the register of information to track the relevant operational controls, the performance and the compliance with the safety goals. 6.3.2 Establishing means for periodic evaluation of the compliance with applicable safety legislation and standards. MANAGEMENT PRACTICE No. 7: AUDITS 7.1 Objective 7.1.1 The objective of this management practice is to create and apply mechanisms for evaluating the effectiveness of the implementation and operation of the SGSO, looking for conformity with the requirements contained in this Technical Regulation, by means of audits. 7.1.2 For compliance with this practice, the audits can be internal or third party, considering all the requirements of the SGSO at the end of one audit cycle.

7.1.3 The audit team should be able to carry out the audit impartially and objectively, no matter if the auditing process is conducted by internal employees or third party. 7.2 Audit Planning 7.2.1 The Installation Operator will be responsible for the preparation of the auditing plans, applicable to the specific natures of the various phases of Installations’ Life Cycle and will define the audit teams. 7.2.2 The audit plans must be developed in order to consider the management practices applicable to the actual stage of the Installation Life Cycle, during a particular audit. 7.2.3 The audit plan should present the areas and activities to be audited, and might consider the execution in only part of the Installation, since all the facilities of the operator have been considered by the end of the auditing cycle. 7.2.4 Information on previous audits, performance assessments, accidents investigations and the accident risks will be considered in the preparation of the audit plans and might be used in the audits cycle definition. 7.2.5 The composition of the audit team will be specified considering:

a) The Audit Plan; b) The size and complexity of the installation; c) The Operational Safety Critical Elements;

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d) The appointment of a leader that must be independent from the purpose of the audit. 7.3 Audit Execution The Installation Operator will be responsible for carrying out the audits, using appropriate methods (onboard documents evaluation, checklists, field observations and interviews), considering the audit schedule and the mandatory information that should appear in the reports to be prepared by the auditing team. 7.3.1 All information necessary for the audit execution must be available to the Audit team. 7.3.2 The Installation Operator must define the audit cycle, considering a maximum period of 2 (two) years. In extraordinary situations, when technically justified and at the discretion of ANP the time limit may be extended, but never exceeding 3 (three) years. 7.3.2.1 The first audit in the management practice Nº 11 - Operational Safety Critical Elements must be performed before the operation beginning. 7.3.2.2 The first audit of the management system should be performed at the limit of one year after the operation beginning, excepting item 7.3.2.4. 7.3.2.3 For production facilities, the requirements established in the management practice Nº 10 - Design, Construction, Installation and Decomissioning will be audited after the design detailing, but before the operation beginning. 7.3.2.4 The practice Nº 4 – Work Environment and Human Factors - must be audited at the design phase and periodically checked during the operation. 7.3.3 The Installation Operator should maintain the audit reports concerning the requirements of the Operational Safety Management System (SGSO). 7.4 Audit Evaluation 7.4.1 The Installation Operator should prepare the action plan for the treatment of non-conformities described in the audit report, containing the Corrective and Preventive Actions, as well as the time limits and the divisions or employees responsible for the implementation. The measures and respective time limits should be compatible with the risks involved. 7.4.2 The Installation Operator will be responsible for the implementation and monitoring of the measures described at the action plan, and should communicate the actions in progress to the Workforce involved in the activity or management practice audited.

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MANAGEMENT PRACTICE No. 8: INFORMATION AND DOCUMENTATION MANAGEMENT 8.1 Objective The Installation Operator will define in the Management System control and access procedures to documents related to the operational safety. 8.2 Responsibilities in Information Management The Installation Operator will develop a documentation control system that considers the development, updating, distribution, control and integrity of the information and the entire documentation required by this Technical Regulation. 8.3 Information Access The Installation Operator will be responsible for guaranteeing adequate access of personnel to the information and documentation related to this Technical Regulation, considering the work activities and the training requirements. MANAGEMENT PRACTICE No. 9: INCIDENTS INVESTIGATION 9.1 Objective The objective of this management practice is to describe the requirements that must be considered for conducting the investigation of each incident related to the Operational Safety. 9.2 Procedures and Investigation Organization The Installation Operator shall establish a procedure for conducting the investigation of incidents with undesirable consequences for Operational Safety. 9.2.1 The investigation procedures must include:

a) Sizing and definition of the investigation team, and b) Criteria for conducting the site investigation, considering the preservation of the physical

evidences, the schedule and execution of interviews and the collection and identification of documents, further data and appropriate records.

9.2.2 The incident investigation should be conducted with strict observance of legal impositions. 9.3 Investigation Execution The Installation Operator will be responsible for carrying out the incident investigations, according to the procedures established as described above, promptly mobilizing the team, establishing the work methodology and assuming the responsibility for the content of the report to be issued by the investigation team. 9.3.1 The investigation team will begin the investigation as soon as possible, but never later than 48 hours after the end of the incident in order to preserve evidence, except by an unpredicted event.

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9.3.2 The investigation team must prepare the investigation report that should contain, in addition to the required in the applicable legislation, all information considered relevant to subsequent implementation of actions that intend to avoid or minimize the reoccurrence possibility. 9.3.3 The incidents investigation report must be stored and available for ANP at any time. 9.3.4 An annual report will be submitted to ANP consolidating all Installation incidents, containing at least the following information:

a) Incidents Date; b) Classified and categorized types of Incidents; c) Related installations, processes, equipment and activities; d) Consequences for Operational Safety; e) The identified causes; f) Factors that contributed to the Incidents occurrence; g) Corrective Actions implemented to minimize the immediate consequences of the incidents; h) Preventive Actions implemented to prevent reoccurrence; and i) The assessment of non-conformities trends and recommendations appointed in the

investigation reports. 9.4 Corrective Actions The Installation Operator will be responsible for establishing, registering and implementing the necessary Corrective Actions, based on the measures appointed in the investigation report. The time limits for the implementation must be suitable to the actions complexity and risks involved. 9.5 Preventive Actions The Installation Operator will be responsible for establishing, registering and implementing the necessary Preventive Actions, based on the measures appointed in the investigation report. The time limits for the implementation must be suitable to the actions complexity and risks involved.

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CHAPTER 3 INSTALLATIONS AND TECHNOLOGY

MANAGEMENT PRACTICE No. 10: DESIGN, CONSTRUCTION, INSTALLATION AND DECOMISSIONING 10.1 Objective The objective of this management practice is to describe the requirements that must be considered by the Operational Safety Management System to promote safety at the design, construction, installation and decommissioning phases. 10.2 Management and Organization The operator of the installation must: 10.2.1 Observe the design criteria and consider the codes, industry standards and good engineering practices when planning the design, construction, installation and decommissioning. 10.2.2 Identify codes, standards and good engineering practices related to Operational Safety during the design, construction, installation and decommissioning phases. 10.2.3 Consider the codes, standards and good engineering practices related to Operational Safety during the installation items and equipments procurement process. 10.2.4 Consider in the design phase the human exposure reduction to the consequences of any equipment or system failure. 10.3 Safety at the Design, Construction, Installation and Decommissioning Phases The operator of the installation must establish a system that:

a) All aspects that may introduce risks to Operational Safety are properly considered in the installation design and in the subsequent updates at design, construction, installation and decommissioning phases;

b) Work environment and human factors are considered in the installation design and in the subsequent updates at design, construction, installation and decommissioning phases; and

c) Means of design modification are established when identified aspects that may introduce risks to the Operational Safety, during the construction and installation phases.

MANAGEMENT PRACTICE No. 11: CRITICAL OPERATIONAL SAFETY ELEMENTS 11.1 Objective The objective of this management practice is to describe the requirements that must be considered by the management system to identify the Critical Operational Safety Elements of the Installation and to establish systems of management and control.

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11.2 Identification of Critical Operational Safety Elements 11.2.1 The Installation Operator will identify and describe the essential characteristics and functions of Critical Operational Safety Elements, which are classified into three categories:

a) Critical Operational Safety Equipments; b) Critical Operational Safety Systems; and c) Critical Operational Safety Procedures.

The elements are considered critical when essential for the prevention or mitigation or, in case of failure, may cause an operational accident. 11.3 Critical Operational Safety Elements Management and Control 11.3.1 The Installation Operator will establish contingency procedures and will define a system for approval and control, to be used when Critical Operational Safety Equipment or System are degraded or out of operation. 11.3.2 Such procedures shall establish temporary measures that could supplement the absence of a Critical Operational Safety Equipment or System due to failure, degradation or shut down. Such measures must include when applicable:

a) Implementation of alternative equivalent controls; b) Production reduction or limitation, and c) Isolation and shut down of equipment, systems, installations.

11.3.3 The operator of the installation will establish the time period in which the temporary procedures will be permitted, until corrective measures are taken. MANAGEMENT PRACTICE No. 12: RISK IDENTIFICATION AND ANALYSIS 12.1 Objective The objective of this management practice is to establish requirements for identification and analysis of risks that can result in incidents, to be conducted at different stages of the Installation Life Cycle, through the use of recognized tools with results properly documented. 12.2 Types of Risks Analysis The operator of the installation will be responsible for the identification and for the conduction of quantitative or qualitative risk analysis as applicable, aiming at the recommendation of actions to control and reduce Incidents that may affect the Operacional Safety. 12.3 Risk Identification and Analysis Methodology The Risk Identification and analysis methodology must:

a) Be defined in the scope; b) Consider the Critical Operational Safety Elements; c) Consider previous risk analysis performed at the Installation or at similar facilities; d) Consider the historical analysis of incidents occurred at the Installation or at similar

facilities; e) Consider the layout, human factors and external causes, when applicable;

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f) Classify the identified risks; and g) Identify the necessary actions for mitigation and risk prevention.

12.4 Risk Analysis Execution 12.4.1 The risk identification and analysis must be performed by a multidisciplinary team. 12.4.2 The number of people involved and the experience characteristics must be determined by the dimension and complexity of the activity, installation, operation or enterprise to be analyzed. 12.4.3 The risk analysis must be approved by the Installation Manager or by a designated person of the company or organization legally responsible for the installation. 12.5 Preparation of the Risk Analysis Report 12.5.1 The Installation Operator will be responsible for preparing the identification and risk analysis reports to be held in the installation. 12.5.2 The risk identification and analysis report must address the following points at least:

a) Team components Identification; b) Objective and scope of the analysis; c) Description of the Installation, part of the installation, system or equipment that will be

submitted to the analysis; d) Methodology justification; e) Methodology description; f) Risk Identification and analysis; g) Risks classification; and h) Recommendations and conclusions.

12.5.3 The risk identification and analysis reports must be available during the conduction of audits, inspections or installation verifications. 12.6 Results 12.6.1 The Installation Operator will be responsible for the implementation of Corrective Actions related to the recommendations contained in the risk analysis. 12.6.2 The results should indicate the need for updating the Critical Operational Safety Elements list, when applicable. 12.6.3 The Installation Operator will be responsible for documenting the implementation of Corrective Actions. The alteration or refusal of any action must be justified and registered. 12.6.4 The Installation Operator must keep evidence that the risks were systematically evaluated during the design, construction, commissioning and operation phases, as well as before the decommissioning.

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MANAGEMENT PRACTICE No. 13: MECHANICAL INTEGRITY 13.1 Objective The objective of this management practice is to describe the requirements that must be considered by the Operatioanal Safety Management System to ensure that the installation, its systems, structures and equipments will undergo the necessary inspections, tests and maintenance, in a planned and controlled manner, in order to guarantee mechanical integrity and Fitness for Purpose. 13.2 Inspection, Test, Maintenance and Procurement Planning The Installation Operator will be responsible for: 13.2.1 Establishing plans and procedures for inspection, testing and maintenance, in order to ensure the integrity of its mechanical systems, structures, and Critical Operational Safety Equipments and Systems. This documentation must be aligned with the manufacturers’ recommendations, codes, standards and good engineering practices. 13.2.2 Establishing procedures for inspection, testing and maintenance containing clear instructions for safe conduction of this activities. 13.3 Activities Control The operator of the installation will be responsible for: 13.3.1 Registering all activities related to mechanical integrity carried onboard. 13.3.2 Ensuring that the operating procedures, manuals or any other document related to the installation, its systems, structures and equipment are available to the maintenance staff (own employees or contracted) when applicable. 13.3.3 Establishing requirements for quality assurance in the execution of the procedures. 13.3.4 Ensuring that all Critical Operational Safety Equipments and Systems are covered by inspection, testing and maintenance plans. 13.3.5 Any deviation from the design specifications must be ruled by the requirements of the Management Practice Nº 16 - Management of Change. 13.4 Monitoring and Results Evaluation The Installation Operator will be responsible for monitoring and evaluating the results of the inspections and tests.

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MANAGEMENT PRACTICE No. 14: PLANNING AND MANAGEMENT OF MAJOR EMERGENCIES 14.1 Objective The Installation Operator must carry out the management practice in order to ensure the appropriate planning and management of major emergencies that might occur during the installation operation. 14.2 Planning and Management of Emergencies 14.2.1 The Installation Operator must define the team responsible for the production of the Emergency Plans. 14.2.2 The qualification and experience of the item 14.2.1 team must be determined by the dimension of the scenario considered and by the complexity of the activity, installation, operation or enterprise to be examined. 14.2.3 The Installation Operator will be responsible for:

a) Identifying, under terms of Management Practice nº 12 (Identification and Risk Analysis),

the major emergencies and describe the associated accident scenarios; b) Evaluating the response capacity to each accidental scenario; c) Providing effective actions for emergencies response.

14.3 Major Emergencies Response The Installation Operator will be responsible for: 14.3.1 Preparing, documenting and establishing the Installation Emergency Plan containing the procedures for planning and response to emergencies. 14.3.1.1 The Installation Emergency Plan can be complemented with resources and supplementary response structure available in other location. The plan should indicate how structures and shared resources will be triggered, in spite of belonging to the own operator or third party. 14.3.2 Establishing a training program that considers the members of the emergency response team. Other people exposed to accident scenarios must be trained at the procedures for alarm and evacuation at least. The requirements of international codes and standards for emergency response must be considered, as well as the practices adopted by other applicable regulations in Brazil. 14.3.3 The Plan must also include:

a) installation identification and legal responsible; b) description of the Installation accesses; c) accidental scenarios; d) alarm systems; e) accident communication; f) organizational response structure; g) procedures for emergency response; h) equipment and response materials, and

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i) supplementary resources and response structures trigger procedure, when applicable. 14.3.3.1 - Accidental scenarios resulting from the accidental hypothesis "oil spill" can be considered in a particular emergency plan, such as "SOPEP - Shipboard Oil Pollution Emergency Plan" and / or other Emergency Plan defined by other specific regulation. 14.4 Response Resources Management The Installation Operator will be responsible for identifying all the response resources, including the emergency systems and equipments, as well as all support services-providing contracted companies, ensuring their suitability and availability. 14.5 Communication System The Installation Operator must establish reliable and effective alarm and communication systems, as well as the internal and external communication procedures, including regulatory agencies and other appropriate government authorities. 14.6 Simulated Exercises The Installation Operator will be responsible for: 14.6.1 Conducting periodic simulated exercises considering all the scenarios covered by the Emergency Plan. 14.6.2 The simulated exercises must be:

a) coordinated with all organizations and regulatory authorities, when applicable; b) analyzed in order to evaluate the need for updating the Emergency Plan; c) accurately documented; and d) scheduled to consider all the scenarios covered by the Installation Emergency Plan.

14.7 Emergency Plan Update The Emergency Plan must be updated in the following situations:

a) when indicated by a risk analysis; b) when indicated by the Emergency Plan performance evaluation, after an incident or

simulated exercise; c) when physical, operational or organizational changes affect the installation procedures or

the response capacity; or d) other situations at the ANP discretion.

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CHAPTER 4 OPERATING PRACTICES

MANAGEMENT PRACTICE No. 15: OPERATIONAL PROCEDURES 15.1 Objective The objective of this management practice is to describe the requirements that must be considered by the Operational Safety Management System (SGSO) when establishing procedures, to ensure a safe operation at the installation. 15.2 Preparation and Control of the Operational Procedures The Installation Operator will be responsible for: 15.2.1 Preparing, documenting and controlling the operational procedures for the operations that are conducted at the Installation, with clear and specific instructions for the safe execution of activities, considering the operational particularities and the activities complexity. 15.2.2 Ensuring that the operating procedures are updated and available onboard, for all personnel involved. 15.3 Procedures for Start-up and Decommissioning The Installation Operator will establish and implement procedures for start-up and decommissioning operations. Mechanisms for updating the information regarding the pre-operation should be provided, when applicable. 15.4 Simultaneous Operations 15.4.1 The Installation Operator will identify the various categories and types of Simultaneous Operations when existing significant operational interfaces and particularly when the Simultaneous Operations:

a) introduce new hazards that were not specifically considered at the risk analysis; b) require special logistics, support measures or safe working procedures that were not

specifically considered in other Management Practices of this Technical Regulation; and c) affect the availability / functionality of Operational Safety Critical Elements.

15.4.2 The Installation Operator will establish and implement procedures to manage Simultaneous Operations. 15.4.3 The control procedures must cover the following aspects:

a) The identification of the new risks introduced by Simultaneous Operations and the verification of appropriate preventive and/or mitigation measures for the risks identified;

b) Responsibilities definition, to ensure an adequate coordination among all organizations involved, including the emergency response.

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MANAGEMENT PRACTICE No. 16: MANAGEMENT OF CHANGE 16.1 Objective The objective of this management practice is to describe the requirements that must be considered by the Operational Safety Management System to ensure that permanent or temporary changes to be conducted at the installation will meet the requirements established in this Technical Regulation and in the applicable legislation. 16.2 Types of Changes Changes in operations, procedures, standards, installations or personnel must be evaluated and managed in order to ensure that the risks remain at acceptable levels. 16.3 Control Procedures The Installation Operator will establish and implement a procedure to manage changes that may affect the Operational Safety. This procedure must consider: 16.3.1 The description of the proposed change, including the justification for the change and the design specification, when applicable. 16.3.2 The hazards assessment and the impact on global activities, before the implementation of changes. 16.3.3 The updating of procedures and documentation affected by the changes. 16.3.4 The training and communication for all staff affected by the changes. 16.3.5 The authorization for the proposed change should be issued by appropriate management level. 16.3.6 The possibility of updating the authorization, when the planned period for temporary changes needs to be extended. 16.3.7 The process of Management of Change should be documented, stored and available for onboard consultation for 2 (two) years at least. After that period, the documentation generated by the process of Management of Change should be kept for a minimum period of 5 (five) years, in a place defined by the operator. MANAGEMENT PRACTICE No. 17: SAFE WORKING PRACTICES AND CONTROL PROCEDURES IN SPECIAL ACTIVITIES 17.1 Objective The objective of this management practice is to describe the requirements that must be considered by the Operational Safety Management System to control and manage the risks during the execution of special activities, not covered by other management practices. 17.2 Permit to Work 17.2.1 The Installation Operator must establish a work permission system and other means of control to manage activities in risk areas. The system must consider:

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17.2.1.1 The establishment of the activities that may involve risks to the Operational Safety and must require a Permit to Work. 17.2.1.2 The Permit to Work must include additional measures of precaution and mitigation that may be required to safely perform the activity. 17.2.1.3 The previous analysis of the safety conditions for the activities execution, as well as the hazards in the workplace. 17.2.2 The Installation Operator must ensure that the Permit to Work system:

a) Will be documented and will contain clear and concise instructions and authorization forms; and

b) Establishes controls and permissions approved by an appropriate managing or supervision level.

17.3 Monitoring The Installation Operator will be responsible for: 17.3.1 Monitoring the performance of activities in accordance with the requirements established in approved procedures, in the Permit to Work and in the associated information and documentation. 17.3.2 Ensure that the Permit to Work and further controls are used until the end of the activity.

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ANNEX 1

DRILLING MARINE UNIT DESCRIPTION (DUM)

(Identification Number)

1. ACTIVITY IDENTIFICATION

1.1. Concessionaire Operator Identification

Description

1.1. Drilling Installation Identification

Description

1.2. Drilling Installation Location

Description

2. INSTALLATION DESCRIPTION

2.1. Unit Main Characteristics

Description

2.2. Utilities and Ballast System

Description

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2.3. Storage System

Description

2.4. Salvage System

Description

2.5. Mooring or Positioning System

Description

2.6. Security, Detection and Firefighting System

Description

2.7. Cargo Handling and Personnel Transportation Systems

Description

2.8. Communication System

Description

2.9. Power System

Description

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3. DRILLING PROCESS DESCRIPTION

3.1 Drilling System

Description

3.2.Well Control System

Description

3.3 Automation, Control and Emergency-Stop System

Description

4. GLOSSARY

Description

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ANNEX 2

PRODUCTION DESCRIPTION OF UNIT MARINE (DUM) (Identification Number)

1. ACTIVITY IDENTIFICATION

1.1. Identification Operator Concessionaire

Description

1.2. Production Installation Identification

Description

1.3. Production Installation Location

Description

2. INSTALLATION DESCRIPTION

2.1. Unit Main Characteristics

Description

2.2. Utilities and Ballast System

Description

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2.3. Storage System

Description

2.4. Salvage System

Description

2.5. Mooring or Positioning System

Description

2.6. Security, Detection and Firefighting System

Description

2.7. Cargo Handling and Personnel Transportation Systems

Description

2.8. Communication System

Description

2.9. Power System

Description

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3. PRODUCTION PROCESS DESCRIPTION

3.1. Production System

Description

3.2. Oil Processing System

Description

3.3. Gas Processing System

Description

3.4. Offloading System

Description

3.5. Fuel Gas System

Description

3.6. Automation, Control and Sttopped of the Emergency System

Description

4. DESCRIPTION OF THE SUBSEA FLOWLINE SYSTEM AND CONNECTIONS TO OTHER INSTALLATIONS

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Description

5. GLOSSARY

Description

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ANNEX 3

CONCESSIONAIRE INFORMATION REPORT (RIC) (Identification Number)

1 – DRILLING PROJECT OF IDENTIFICATION

BLOCK OR FIELD

BASIN

CONTRACT NUMBER

MARINE UNIT

OPERATOR

2 – INSTALLATION LOCATION

ITEM INFORMATIONS

Geographic Coordinates

Geological Data

Oceangraphic Data

• Water Depth

• Winds predominant

• Predominant Current

• Wave Data (Significant wave heighs and significant wave periods)

3 – PRELIMINARY WELL DRILLING PROGRAM

ITEM INFORMATIONS

Well data

• Location

• Categoria/finalidade do poço

• Category / purpose

Program

4 – ENDORSEMENT

The Concessionaire _____________ endorses that the information forwarded to the ANP in the "Marine Unit Description (DUM) nº - xxx”, submitted by the Administrative Procedure nº __________ , of dd-mm-aaaa, remains valid for this drilling project. In addiction, the Concessionaire ________________________ endorses that the information forwarded to the ANP in the document "Correlation Matrix (MC) nº YYY” remains valid for this drilling project.

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ANNEX 4

CONCESSIONAIRE INFORMATION REPORT (RIC) (Identification Number)

1 –PRODUCTION PROJECT IDENTIFICATION

FIELD

BASIN

CONTRACT NUMBER

MARINE UNIT

2 – INSTALLATION LOCATION

ITEM INFORMATIONS

Geographic coordinates

Geological data

Oceangraphic data

• Water Depth

• Predominant Winds

• Predominant Current

• Wave data (Significant wave Heighs and significant wave periods)

3 - DIAGRAM OF FLOW

ITEM INFORMATIONS

Process flow diagram

4 – PROCESS DESCRIPTION

ITEM INFORMATIONS

5 – ENDORSEMENT

The Concessionaire _____________ endorses that the information forwarded to the ANP in the "Marine Unit Description (DUM) nº - xxx”, submitted by the Administrative Procedure nº __________ , of dd-mm-aaaa, remains valid for this production project. In addiction, the Concessionaire ________________________ endorses that the information forwarded to the ANP in the document "Correlation Matrix (MC) nº YYY” remains valid for this production project.