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CORPORATE QUALITY, HEALTH, SAFETY & ENVIRONMENT

HSE MANAGEMENT SYSTEMS MANUAL

SKPB/LI/HSE/001

REV 0

14th August 2013

Document Custodian Document Owners

Ahmad Sharifuddin Abdul Kadir Dato’ Mokhzani Mahathir Tan Sri Dato’ Seri Shahril Shamsuddin
Vice President Executive Vice-Chairman President and Group CEO
Corporate QHSE

This document and its content is the property of SapuraKencana Petroleum Berhad. Any dissemination, distribution or copying of this document and
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DISTRIBUTION LIST

Copy Number Document Holder


Master
Document Control Centre (DCC), Corporate QHSE
(signed hardcopy)
Master (electronic) Cpnas Administrator
HARDCOPIES
001 President & Group CEO
002 Executive Vice-Chairman
003 Executive Vice President of Corporate Finance & Treasury
004 Executive Vice President of Fabrication/Hook Up & Commissioning
005 Senior Vice President of Offshore Construction & Subsea Services
006 Senior Vice President of Energy and JVs
007 Senior Vice President of GeoTech & Maintenance Services
008 Senior Vice President of SapuraKencana Drilling Pte. Ltd.
009 Senior Vice President of Corporate Strategy & Planning
010 Senior Vice President of Corporate Human Resources
011 Senior Vice President of Corporate Capital Management & IR
012 Vice President of Corporate Quality, Health, Safety & Environment
013 Chief Financial Officer, Corporate Account
014 Group Chief Risk Officer, Corporate Risk Management
015 Chief Internal Auditor, Corporate Internal Audit
016 Head of HSE Fabrication/Hook Up & Commissioning
017 Head of HSE Offshore Construction & Subsea Services
018 Head of HSE Energy and JVs
019 Head of HSE GeoTech. & Maintenance Services
020 Director of QHSE SapuraKencana Drilling Pte. Ltd.
021 Head of Group Corporate Legal
022 Head of Corporate Supply Chain
023 Head of Corporate Administration
024 Head of Group Security
025 Head of Corporate IT
026 Head of Corporate Communications
027 Head of Corporate Business Development

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REVISION RECORD

Rev. Page
Rev. Date Description Updated By
No No

A 28/3/2013 All Issue for Review RAW

B 5/4/2013 All Issue for Review RAW

C 18/4/2013 All Issue for Review by Op Co’s HSE RAW

D 31/5/2013 All Issue for Review RAW

E 1/8/2013 All Issue for Review by Group Corporate Legal RAW

0 14/8/2013 All Issue for Approval RAW

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CONTENTS

1.0 PREFACE 6

2.0 REFERENCES, DEFINITIONS & ABBREVIATIONS 7


I References
II Definitions & Abbreviations

3.0 INTRODUCTION 18
I Purpose
II Scope
III Company Profile

4.0 HSE MANAGEMENT SYSTEMS FRAMEWORK 20

4.1 General Requirement 20


4.1.1 The Plan-Do-Check-Act (PDCA) Model
4.1.2 HSE Management Systems
A. HSE Management Systems Model
Matrix of correspondence between the sections of SKPB HSE MS;
B.
and OHSAS 18001:2007 and ISO 14001:2004.
4.1.3 HSE Governance
4.1.4 Leadership & Commitment

4.2 HSE Policy 27


4.2.1 Content and Dissemination
4.2.2 SKPB HSE Policy and Supplementary Policies

4.3 Planning 28
4.3.1 Hazard & Effect and Aspect & Impact Management Process
4.3.2 Legal & Other Requirements and Standards
4.3.3 Strategic HSE Objectives, Plans, Programmes and Activities

4.4 Implementation & Operation 34


4.4.1 Organization, Resources, Roles, Responsibility, Accountability and
Authority
4.4.2 Competence, Awareness & Training
4.4.3 Communication, Participation and Consultation
4.4.4 Documentation
4.4.5 Control of Documents

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4.4.6 Operational Control Procedures
4.4.7 Contingency, Emergency Preparedness & Response and Crisis
Management.

4.5 Checking – Monitoring, Measurement & Reporting 48


4.5.1 Performance Monitoring
4.5.2 Evaluation of Compliance
4.5.3 Incident Reporting, Investigation and Follow-Up
4.5.4 Nonconformity, Corrective Action and Preventive Action
4.5.5 Control of Records
4.5.6 Assurance

4.6 Management Review 52

5.0 APPENDICES 54
Appendix 1 List of SKPB Divisions and Operating Companies
Appendix 2 Health, Safety & Environment Policy
Appendix 3 Drug, Alcohol & Prohibited Substances Policy
Appendix 4 Stop Work Policy
Appendix 5 SKPB 16 Life Saving Rules
Appendix 6 SKPB Organization Structure
Appendix 7 SKPB Group HSE Steering Committee Structure
Appendix 8 Examples of Performance Indicators

   

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1.0 PREFACE

Foreword

This Manual defines how HSE will be managed within SKPB and provides a clear understanding of the
principles of HSE management within the Company, as each and every one of us is directly charged with the
task of implementing its main principles.

Supported by policies, standards, business and operational controls, the Management of SapuraKencana
Petroleum Berhad (SKPB) continues to set targets for improvement, measure, and report performance in
order to achieve continual HSE performance improvement.

It is the responsibility of every employee of SKPB, and all of our subcontractors, to play a part in improving
our operations and the HSE MS manual is a key tool in this process.

Update and Review

The Custodian of this document is the Head of Corporate QHSE who should be consulted if further information
on the subject matter is required. The Custodian is also responsible for the accuracy of information contained
within this document.

The document is subject to periodical review (at least once in 3 years) and update, when document holders
have the opportunity to express opinions and suggest improvements.

Copyholder’s Responsibilities

It is the responsibility of the registered copyholder to maintain the accuracy of this document by ensuring
that all updates are promptly acknowledged, incorporated, and implemented.

The registered copyholder must at all times maintain custody of this document unless prior approval is given
by the relevant Technical Authority.

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2.0 REFERENCES, DEFINITIONS & ABBREVIATIONS

I- References

No Title Reference No
ISO 14001:2004 Environmental Management Systems –
1
Requirements with guidance for use.
OHSAS 18001:2007 Occupational Health and Safety
2
Management Systems Requirements
PETRONAS Procedures and Guidelines for Upstream Activities
3
(PPGUA), Rev.2 , 2008

II- Definitions & Abbreviations

Abbreviations

ACT Accident Control Technique


ALARP As Low As Reasonably Practicable
CHRA Chemical Health Risk Assessment
CRA Construction Risk Assessment
CIMAH Control of Industrial Major Accident Hazards
COO Chief Operating Officer
DOE Department of Environment
DOSH Department of Occupational Safety & Health
EAI Environmental Aspect & Impact Identification
EIA Environmental Impact Assessment
EVC Executive Vice-Chairman
HAZID Hazard Identification
HAZOP Hazard and Operability Studies
HEMP Hazard and Effect Management Process
HRA Health Risk Assessment
HSE Health, Safety & Environment
GHSESC SKPB Group Health, Safety & Environment Steering Committee
ISO International Organization for Standardization
ISO 14001 Environmental Management Systems - specification with guidance for use
ISPS International Safety & Port Security
JSA/JHA Job Safety Analysis/Job Hazard Analysis
JV SKPB Joint Venture Companies
MARPOL International Convention for the Prevention of Pollution From Ships
MFV Management Facilities Visit
MOC Management of Change
Op Co Operating Companies
OSHA Occupational Safety & Health Act

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PGCEO President and Group Chief Executive Officer
PPE Personal Protective Equipment
PPGUA PETRONAS Procedures and Guidelines for Upstream Activities
PTW Permit to Work
QRA Quantitative Risk Assessment
RAM Risk Assessment Matrix
SKPB SapuraKencana Petroleum Berhad
SARS Severe Acute Respiratory Syndrome
SOLAS International Convention for the Safety of Life at Sea
TRCF Total Reportable Case Frequency
TROIF Total Reportable Occupational Illness Frequency
UAUC Unsafe Act, Unsafe Condition
WHO World Health Organization

Key Definitions

No Key Word Definition


1 Accountability a) Answerable for specified health, safety and environmental responsibilities
particularly connected with tasks, objectives and targets within their area
of authority. Accountability cannot be delegated.
b) The ultimate responsibility for an area of authority defined by the
individual’s Job Description, and will include authority delegated to a
subordinate albeit temporary or permanent.
(OGP Report 6.52/244, 1999: Glossary of HSE Terms)
2 Activity Work to be carried out as part of a process characterised by a set of specific
inputs and tasks that produce a set of outputs to meet customer
requirements.
3 As Low As
 As Low As Reasonably Practicable
Reasonably
Practicable (ALARP) Means that the degree of risk in a particular activity or environment can be
balanced against the time, trouble, cost and physical difficulty of taking
measures to avoid the risk. If these are disproportionate to the risk that it
would be unreasonable for the persons concerned to have to incur them to
prevent it, they are not obliged to do so. The greater the risk, the more likely
it is that it is reasonable to go to very substantial expense, trouble and
invention to reduce it. But if the consequences and the extent of a risk are
small, insistence on great expense would not be considered reasonable. It
is important to remember that the judgment is an objective one and the size
or financial position of the employer is immaterial.

 As Low As Practicable
Embraces whatever is technically possible in the light of current knowledge,
which the person concerned had or ought to have had at that time. A stricter
standard than the previous and the cost, time and trouble involved are not
to be taken into account.

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 Best Practicable Means
Where the law prescribes that “best practicable means” should be
employed, it is usual for the regulating authority to indicate its view of what
is practicable in notes or even agreements with particular firms or industries.
Interpretation can vary depending on the context in which it is used.

 Definition as per Occupational Safety and Health Act, 1994


(Malaysia)
 The severity of the hazard or risk in question;
 The state of knowledge about the hazard or risk and any way of
removing or mitigating the hazard or risk;
 The availability and suitability of ways to remove or mitigate the hazard
or risk; and
 The cost of removing or mitigating the hazard or risk.
4 Assessment (or The process of analysing and evaluating hazards. It involves both causal and
Evaluation) consequence analysis and requires determination of likelihood and risk.
5 Asset Integrity Is the documented assurance that the equipment and structures remain
reliable for continued service thereby preventing the release of contents to
the environment and/or is guaranteed to function correctly on demand either
in an emergency or otherwise. Commonly referred to as the “Mechanical
Integrity” element in the Process Safety Management requirements.
6 Assurance/ Audit a) A systematic review to determine the extent to which “audit criteria” are
fulfilled and verify conformance with agreed standards (e.g. HSE
Management Systems and its associated procedures). Assurance
employs a well-defined review procedure to ensure consistency and to
allow the assessors to reach defensible conclusions.
b) A systematic, independent and documented evaluation process for
obtaining “audit evidence” to determine whether or not the health, safety
and environment Management Systems and its operation comply with
planned arrangements, and whether or not the system is implemented
effectively, and is suitable to fulfill the Company’s health, safety and
environmental policy and objectives.
c) The examinations of the whole system to assess how it has been used
over a period, and to make sure it has operated as intended.
Note: Independent does not necessarily mean external to the organization.
In many cases, particularly in smaller organizations, independence can be
demonstrated by the freedom from responsibility for the activity being
performed.
7 Audiometric An arrangement for determining an employee’s threshold of audibility
8 Awareness A perception of the task, job or work that provides an insight into possible
variances and their potential impact with the realisation of the appropriate
action.
9 Board A body of elected or appointed members who jointly oversee the activities of
a company or organization.
10 Company An organisation engaged, as principal or contractor, directly or indirectly, in
the work activities. For bodies or establishments with more than one site, a
single site may be defined as a company.

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11 Competence a) The necessary awareness, knowledge and skill to fulfill the requirements
of the job / position. Competence is therefore the level of performance
which a person must achieve to carry out specified tasks or work without
close supervision.
b) The ability to perform a particular job in compliance with performance
standards.
12 Contingency/ A pre-established plan to mitigate an unusual situation which has the
Emergency Plan potential for harm, which incorporates the best use of local as well as remote
facilities and resources.
13 Continual Year-on-year enhancement of overall health, safety and environmental
Improvement performance, not necessarily in all areas of activity, resulting from continuous
efforts to improve.
14 Contract A formal business agreement detailing the terms and conditions for the
supply of products or the provision of services.
15 Contract Holder Person (including department or section) within SKPB group who has the
budget, responsibility and management authority to execute the contract.
16 Contractor A firm which has entered into a legal contract to supply services or material
to SKPB group. Any reference to Contractors shall, unless otherwise stated,
be taken to include Consultants, Agents, and other Third Parties who has
entered into similar legal contract for the supply of services or material to
SKPB group.
17 HSE Plan A description of the means of achieving health, safety and environmental
objectives by Op Co/Project/ Worksite.

A contractor’s HSE plan is a contractor’s proposal as to how he intends to


manage the risk associated with the company or contracted work as well as
implement the HSE requirements as outlined by SKPB. For the selected
Contractor, this becomes the plan on which the HSE terms in the contract
are based on.
18 Critical Activities Activities that have been identified by the Hazards and Effects Management
Process as vital to ensure asset integrity, prevent incidents, and/or mitigate
adverse HSE effects.
19 DOSH Acronym for Department of Occupational Safety and Health (Malaysia).
20 Effect The severity of the consequences of an event attributed to any HSE hazards,
normally expressed in terms of consequences to people, environment, asset
and reputation.
21 Employee Any individual who carries out duties or actions specified by an employer for
which the individual receives remuneration from the employer.

As defined by the Malaysia legislation i.e. Occupational Safety and Health Act,
1994 (OSHA 1994) - A person who is employed for wages under a contract
of service on or in connection with the work of an industry to which the OSHA
1994 applies and
 Who is directly employed by the principal employer on any work of, or
incidental or preliminary to or connected with the work of, the industry ,
whether such work is done by the employee at the place of work or
elsewhere;

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 Who is employed by or through an immediate employer at the place of
work of the industry or under the supervision of the principal employer or
his agent on work which is ordinarily part of the work of the industry or
which is preliminary to the work carried on in or incidental to the purpose
of the industry; or
 Whose services are temporarily lent or let on hire to the principal
employer by the person with whom the person whose services are so lent
or let on hire has entered into a contract of service.
22 Employer The immediate employer or the principal employer or both

Immediate employer
In relation to the employees employed by or through him, means a person
who has undertaken the execution at the place of work where the principal
employer is carrying on his trade, business, profession, vocation, occupation
or calling, under the supervision of the principal employer or his agent, of the
whole or any part of any work which is ordinarily part of the work of the
trade, business, profession, vocation, occupation or calling of the principal
employer or is preliminary to the work carried on in, or incidental to the
purpose of, any such trade, business, profession, vocation, occupation or
calling, and includes a person by whom the services of an employee who
has entered into a contract of service with him are temporarily lent or let on
hire to the principal employer.

Principal employer
The owner of an industry or the person with whom an employee has entered
into a contract of service and includes:-
 A manager, agent or person responsible for the payment of salary or
wages to an employee;
 The occupier of a place of work;
 The legal representative of a deceased owner or occupier; and
 Any government in Malaysia, department of any such government, local
authority or statutory body.
23 Environment The surroundings and conditions in which a company operates or which it
may affect, including air, water, land, natural resources, flora, fauna, humans
and their interrelation.
24 Environmental Element of an organization's activities or products or services that can
Aspect interact with the environment.

Note: A significant environmental aspect has or can have a significant


environmental impact.
25 Environmental Any change to the environment, whether adverse or beneficial, wholly or
Impact (Effect) partially resulting from an organization’s activities, products and services
interaction with the environment.

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26 Environmental a) Part of project management concerned with identifying through formal
Impact Assessment written technical evaluation the likely impact (positive and negative) of a
(EIA) proposed development or activity on the natural and man-made
environment. A process whereby the assessment is used in reaching a
consensus on acceptable levels of change, defining the means by which
agreed standards of operations and procedure will be achieved and
establishing management procedures to ensure these objectives are
achieved and maintained.
b) A formal, written, technical evaluation of potential effects on the
environment (atmosphere, water, land, plants and animals) of a particular
event or activity.
27 Ergonomics The science of studying people at work, and designing tasks, jobs, tools,
equipment, facilities, and the work environment, so that people can be safe,
healthy, effective, efficient, productive, and comfortable.
28 Greenhouse Gases Gases that alter the thermal properties of the atmosphere such as methane,
carbon dioxide, CFCs, halon, etc.
29 Guidelines Provide sound advice which should be followed to achieve acceptable HSE
results unless alternative practices or methods are proven to meet or exceed
the expected level of performance.
30 Hazard Source, situation or act with a potential to cause harm, including ill health
and injury, damage to property, products or the environment; production
losses or increased liabilities or a combination of these.
31 Hazardous Event The 'release' of a hazard. The undesired event at the end of the fault tree
and at the beginning of an event tree. The centre point in a Hazard 'Bow-
Tie.' Where one hazardous event is followed by others, then the 'Top Event'
is the first hazardous event. (see Top Event) Hazardous events include: Loss
of Containment, Structural Failure, Dropped Objects, Exceeding Occupational
Exposure Limit, Loss of Control, Falls to Same Level, Falls to Lower Level,
Oxygen Deficiency, Loss of Separation, Electrical Shock, and Explosion.
32 Hazard and Effect The structured hazard analysis methodology involving hazard Identification,
Management Assessment, Control and Recovery and comparison with screening and
Process (HEMP) performance criteria. To manage a hazard completely requires that all four
steps must be in place and recorded.
33 Hazards and Effects A hazard management communication document that demonstrates that
Register hazards have been identified, assessed, are being properly controlled and
that recovery preparedness measures are in place in the event control is ever
lost.
34 Health Effects, Acute Acute health effects are those which occur suddenly and in a short time
(seconds to hours) following exposure, generally to higher levels or
concentrations of a health hazard. An acute exposure runs a comparatively
short course.
35 Health Effects, Chronic health effects are those which occur gradually over a long period of
Chronic time following repeated or prolonged exposure to relatively low levels or
concentrations of a hazardous agent. In certain cases a short term exposure
may result in a chronic health effect.
36 Health Risk The likelihood that, under specified conditions of exposure, the health of a
certain population will be harmed. Individual risk is assessed on the basis of
group risk assessment.

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37 Health Risk The identification of health hazards in the work place and subsequent
Assessment evaluation of risk to health, taking account of existing control measures.
Where appropriate, the need for further measure to control exposure is
identified.
38 Health, Safety, and The company structure, responsibilities, practices, procedures, processes and
Environmental resources for implementing health, safety, and environmental management.
Management
Systems (HSE MS)
39 Hot Work Work involving electric or gas welding, cutting, brazing, or similar flame or
spark-producing operations.
40 Hour-worked The hours that an employee is present at the work location; for onshore
operations shall be the actual hours worked, for offshore workers at 12 hour
a day.
41 HSE Case A demonstration of how the Company HSE objectives are being met in a
methodical and assessable reference document. A completed HSE Case will
provide a reference document to all information relevant to the safety and
health of the operations personnel, environment and resources on an
installation
42 HSE-Critical Job (or Activities, personnel or measures that have been identified as vital to ensure
Activities) asset integrity, prevent incidents, and/or to mitigate adverse HSE effects.
43 HSE Focal Point Staff in line departments appointed to coordinate relevant HSE matters for
their respective Op Co/Division/Department/ Project/Worksite
44 HSE Policy It is a public statement of the intentions and principles of actions of a
company regarding health, safety and environmental effects, giving rise to
its strategic and detailed objectives.
45 HSE Standards SKPB HSE policy, local and/or international HSE Technical Standards
which SKPB subscribes to, strategic objectives, procedures, and guidelines
that make up the total SKPB HSE Management Systems.
46 HSE Targets Agreed plans and measurements used to assess SKPB group/Op
Cos/JVs/Projects performance against the strategic objectives.
47 Human Factors Environmental, organisational and job factors, and human and individual
characteristics which influence behaviour at work in a way which can affect
health and safety
48 Incident A work-related event or chain of events which has caused or could have
caused injury, illness and/or damage (loss) to assets, the environment,
reputation, or third parties (including near-miss, or dangerous occurrence).
An incident involves the release or near release of a hazard.

49 Injury Physical harm or damage to a person resulting from traumatic contact


between the body of the person and an outside agency, or from exposure to
environmental factors.
50 Interface/ Bridging A bridging document that define the agreed HSE MS, including specific
Document standards, procedures and guidelines, to be adopted for a stipulated project
or activities in cases where parties (e.g. Company and/or Contractors) to the
project or activities each have their respective HSE MS. Example - during
simultaneous operations.
51 ISM International Safety Management Code. Requirement under the Safety of life
at Sea (SOLAS) convention on a company’s minimum safety Management
Systems arrangement.

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52 ISO International Organization for Standardization, based in Geneva, Switzerland.
Produces certification standards series such as ISO 9000, ISO 14000, etc.
53 ISPS International Ship and Port Facility Security (ISPS) Code. Requirement under
the Safety of life at Sea (SOLAS) convention on a minimum security
arrangement for ships and ports.
54 Job Description A short document which sets out an employee’s authority and responsibilities
in the job, who he reports to, and who reports to him; what his duties are
and the qualifications necessary to perform those duties.
55 Joint Venture Joint Ventures in which SKPB has a:
a) Controlling interest; or
b) Non-controlling interest, and are
 Under operational control,
 Under joint operational control,
 Under other participant operational control, or
 Self-directed
56 Knowledge Understanding of the task, job or work through a learning experience or study
of the “process” and related subject matter.
57 Line Management Denotes the person, including department or section in the organization who
are involved in the day-to-day operation of the company.
58 LOTO Lockout-Tagout – a documented system of barriers and notices that prevents
the accidental or inadvertent operation of equipment whilst it is being
maintained or inspected.
59 Management of The management for planning and controlling any changes (i.e. permanent,
Change (MOC) temporary or emergency) including plant, process, people and procedures to
avoid adverse HSE consequences.
60 Management A person who, irrespective of other roles and responsibilities, shall have
Representative (MR) defined roles, responsibilities and authority to ensure that the HSE MS is
established, implemented and maintained and to report to top management
on the performance of the HSE MS. In OHSAS 18001, a management
representative shall be a member of an OPU top management
61 Management of Defines the limit of safe operation permitted for a particular asset if control
Permitted and/or mitigation measures are reduced and/or removed with the objective
Operations (MOPO) of maintaining a tolerable level of risk. Considers combinations of hazards
and hazardous events.
62 Material Safety Data A sheet issued by a manufacturer of chemical substances that sets out the
Sheet (MSDS)/ hazards likely to be encountered by those coming into contact with the
Chemical Safety substance. The sheet may also identify recovery procedures following
Data Sheet (CSDS) adverse exposure.
63 Mitigation Measures taken to reduce the consequences of a potential hazardous
event. Mitigation measures include:
 'Active' systems intended to detect and abate incidents (gas, fire,
and smoke alarms, shutdowns, deluge)
 'Passive' systems intended to guarantee the primary functions (fire and
blast walls, protective coatings, drain systems) and
 'Operational' systems intended for emergency management (contingency
plans, training, drills).

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64 Monitoring, Monitoring techniques focusing on assessing the effectiveness of the defence
Proactive system (risk control measures) are active monitoring techniques, and shall
be given due priority, in comparison with reactive monitoring technique.

Proactive monitoring provides information in the absence of any incident, ill-


health or damage to the receiving environment. It includes checking that the
HSE Management Systems requirement (e.g. Procedures) are being complied
with, and that objectives and performance criteria are met.
65 Monitoring, Reactive Monitoring techniques focusing on causes of incidents are reactive monitoring
techniques. Reactive monitoring relies on information on incidents (including
near-miss incidents, ill-health or environmental damage) that have occurred
to provide insights into the means of preventing recurrence of similar
incidents.
66 Occupational Illness An abnormal health condition or disorder (physical or mental) that is caused
or aggravated by exposure to environmental factors associated with
employment, including chemical, physical, biological, or ergonomic factors.
67 OHSAS 18001 Occupational Health and Safety Assessment Series, an international standard
on occupational health and safety management, published by a group of
National Standards bodies and Certification bodies
68 Performance Criteria Performance criteria describe the measurable standards set by company
management to which an activity or system element is to perform.
(Some companies may refer to performance criteria as goals or targets)
69 Performance Key HSE Performance Indicators, against which the targets can be set to
Indicator measure performance.
70 Permit to Work a) A control system that authorises specific tasks and procedures to be done
and formal permission and/or handover of safe plant / equipment for the
activities to be carried out.
b) A formal written system used to control certain types of work which are
identified as hazardous. It is also a means of communication between
site/installation management, plant supervisors and operators and those
who carry out the work.
71 Personal Protective Equipment and clothing which are intended to be worn or held by a person
Equipment (PPE) at work and which may afford protection against one or more risks to health
and safety.
72 Practicable Is defined under Malaysia’s Occupational Safety and Health Act 1994
meaning “practicable” having regards to:
 The severity of the hazard or risk in question;
 The state of knowledge about the hazard or risk and any way of removing
or mitigating the hazard or risk;
 The availability and suitability of ways to remove or mitigate the hazard
or risk; and
 The cost of removing or mitigating the hazard or risk.
73 Prevention Completely eliminating a threat, escalation factor or a hazard.
74 Preventive Maintenance carried out before the unit or system fails to ensure its
maintenance continued reliability and safe operation.
75 Procedure A procedure is a document that:
a) Provides series of steps to be carried out in a logical order for a defined
operation or in a given situation.
b) Describes how an activity is to be performed and by whom.

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76 Process A logical sequence of inter-related activities.
Also, any activity involving a highly hazardous chemical including any use,
storage, manufacturing, handling, or the on-site movement of such
chemicals, or combination of these activities. For purposes of this definition,
any group of vessels which are interconnected and separate vessels which
are located such that a highly hazardous chemical could be involved in a
potential release shall be considered a single process.
77 Procurement A term used to cover the whole cycle of activities which need to be performed
to acquire and deliver to a user an item of material or a service, from
conception of the need through design, purchasing, storage and delivery to
ultimate disposal.
78 Quality Assurance All those planned and systematic actions necessary to provide adequate
confidence that an item or component will meet SKPB Group/Op
Co/JVs/project performance requirements in service.
79 Quantitative Risk Quantitative evaluation of the risk imposed by a system design, whether
Assessment (QRA) those risks are from human, hardware or software failures, or environmental
events, or from combinations of such failures / events.
80 Recovery Measures All technical, operational and organizational measures that limit the chain of
consequences arising from the first hazardous event (or 'top event'). These
can:
i. Reduce the likelihood that the first hazardous event or 'top event' will
develop into further consequences and
ii. Provide lifesaving capabilities should the 'top event' develop further.
81 Resources The necessary personnel, time, equipment and infrastructure to carry out a
specified task.
82 Responsibility Obligated to undertake, or alternatively delegate to authorized and
competent persons, specified duties and tasks connected with their job and
position.
83 Risk Combination of the likelihood of an occurrence of a hazardous event or
exposure(s) and the severity of injury or ill health that can be caused by the
event or exposure(s) which this event may have upon people, environment,
asset and reputation.
84 Risk Assessment Process of evaluating the risk(s) arising from hazard(s), taking into account
the adequacy of any existing controls, and deciding whether or not the risk(s)
is acceptable.
85 Risk Management A process of evaluating the risks that is used to identify, assess, analyze the
Process HSE risks and implement proactive controls to manage the risks as well as
implementing recovery measures to contain & mitigate the consequences of
resulting from the release of hazards.
86 Risk Matrix The matrix portraying risk as the product of probability and consequence,
used as the basis for qualitative risk determination. Considerations for the
assessment of probability are shown in the horizontal axis. Considerations
are included: impact on people, assets, environment and reputation. Plotting
the intersection of the two considerations on the matrix provides an estimate
of the risk.
87 Safe / Safety A condition in which all hazards inherent in an operation have either been
eliminated or are controlled such that their associated risks are both below a
tolerable threshold and are reduced to a level which is as low as reasonably
practicable.

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88 Screening Criteria The values or standards against which the significance of the identified
hazard or effect can be judged. They should be based on sound scientific and
technical information and may be developed by the company and industry
bodies, or provided by the regulators.
89 Standards A prescribed set of rules, conditions or requirements Standard is an all-
inclusive term denoting specifications, recommended practices, procedures,
guidelines philosophies, and hand-books.
90 Statement of Fitness A documented affirmation by the asset holder that (HSE) conditions are
satisfactory to continue operation.
91 Strategic Objectives The broad goals, arising from the HSE policy, that a company sets itself to
achieve, and which should be quantified wherever practicable. In SKPB
terminology this means objectives. Goals which the organization wishes to
achieve over the long-term provides a basis for judging progress and
achievements. Strategies provide the framework for plans to achieve the
objectives used as a screen for possible plans.
92 Stress Any interference that disturbs a person’s healthy mental and physical well-
being.
93 Survey Operations Includes seismic survey, geological field survey, topographical survey and site
survey carried out to assess the safety of offshore or onshore locations.
94 Targets The measurable standards set by SKPB management committee to which an
activity or system element is to perform. Essentially, these are the agreed
plans and measurements used to assess SKPB group/ Op Cos/ JVs/ Project/
Department performance against the strategic objectives.
95 Threat A possible cause that will potentially release a hazard and produce an
incident. Threat classes include damage caused by: thermal (high
temperature), chemical (corrosion), biological (bacteria), radiation
(ultraviolet), kinetic (fatigue), electrical (high voltage), climatic condition
(poor visibility), uncertainty (unknowns) or human factors (competence).
96 Top Event The 'release' of a hazard. The undesired event at the end of the fault tree
and at the beginning of an event tree. The centre point in a 'Bow-Tie'
Diagram.
97 Toxic The characteristic of a chemical substance to produce injury or ill health once
it reaches a susceptible site in or on the body. The effects may be acute or
chronic, local or systemic.
98 Trade Secret Any confidential formula, pattern, process, device, information, or
compilation of information that is used in an employer's business, and that
gives the employer an opportunity to obtain an advantage over competitors
who do not know or use it.
99 Waste Any material (solid, liquid or gas) which is generated at the work location as
a product of the work, but which fulfill no further useful purpose at the
location. Scheduled Wastes are special types of waste defined by the
Environmental Quality (Scheduled Wastes) Regulations 2005.
100 Waste management A system to achieve reduction, re use, reclamation, recycling and responsible
disposal of materials.

   

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3.0 INTRODUCTION

I. Purpose

This Health, Safety & Environmental Management Systems (HSE MS) Manual describes the core
elements and the systematic approach in managing HSE risks for the protection of personnel and
environment, relevant to SKPB activities, processes and assets. It also describes the processes,
standards and documents used to ensure compliance with the legislation and to achieve continual
performance improvement. It is in line with the requirements of ISO 14001 “Environmental
Management Systems- Specification with Guidance for Use”, OHSAS 18001 “Occupational Health and
Safety Management Systems – Requirements” and PETRONAS Procedures and Guidelines for
Upstream Activities (PPGUA).

Implementation and compliance with this HSE MS is the direct responsibility of everyone in SKPB
Group of Companies within their individual sphere of responsibilities.

II. Scope

The scope of the HSE MS covers the following:


i) Provision for Integrated Offshore Engineering, Procurement, Construction,
Fabrication, Transportation, Installation, Hook-Up & Commissioning (EPCIC),
Marine & Subsea Services, Drilling, Geotech & Maintenance of Offshore Structure
including Operations Support Bases;
ii) Development & Production of Hydrocarbons;
iii) Maintenance Services for Downstream Petroleum Industry and General Industry;
and
iv) Corporate Support Functions

The sites within the above scope are:-

i. SapuraKencana Petroleum Berhad (Head Office) at Menara SapuraKencana Petroleum, Solaris


Dutamas.
ii. SapuraKencana Petroleum Berhad, Sapura @ Mines, Seri Kembangan. Providing support
services to all SKPB operational activities.
iii. Divisions and Operating Companies (Op Co) as listed in Appendix 1.

Note: Op Co(s) may supplement this HSE MS with an Op Co specific HSE MS.

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III. Company Profile

SapuraKencana Petroleum Berhad (SapuraKencana) is one of the world's largest integrated oil and
gas services and solutions provider. Refer to Appendix 6 for the SKPB Organization Structure.

SapuraKencana is steered by a team of qualified and experienced management team. Our talent pool
is made up of more than 9,000 people worldwide, which comprises nationals from 20 countries
ranging from Malaysia, Thailand, Australia, United States to Brazil.

The Group's principal business includes providing end-to-end solutions and services to the upstream
and downstream petroleum industry. Business segments of upstream activities comprise of
engineering, procurement, construction & commissioning (EPCC); installation of pipelines & facilities
(IPF); drilling; marine & subsea services; geotech & maintenance services; and development &
production and maintenance services for downstream petroleum industry.

   

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4.0 HSE MANAGEMENT SYSTEMS FRAMEWORK

4.1 GENERAL REQUIREMENT

The HSE MS is established to describe how the Health & Safety and Environmental policies,
procedures, work instructions, records and associated record management are implemented and
maintained throughout SKPB via the ‘Plan, Do, Check and Act’ (PDCA) model.

The management of health, safety & environmental concerns encompasses all critical activities both
offshore and onshore; that are within the control and influence of SKPB covering all personnel,
suppliers and subcontractors performing tasks that have significant health & safety risk and potential
to cause significant environmental impact.

Through an ongoing plan/ implement/ check/ review process and in accordance with its HSE Policies,
SKPB’s HSE MS shall provide the structure for achieving continual improvement, prevention of injury
& ill health and prevention of pollution.

4.1.1 The Plan-Do-Check-Act (PDCA) Model

The SKPB’s HSE MS is powered by the PDCA model whereby it is an on-going, iterative process, which
enables SKPB to establish, implement, review, maintain and achieve continual improvement. The top
management is committed to continually improve its HSE practices as reflected in its HSE Policies
which provide the frame work and action for setting HSE objectives and targets. The steps of this
ongoing process are:-

i) Plan (Framework)
An effective ongoing planning process is established to ensure continual success of the HSE MS.
This process involves: -

 Identification of environmental aspects & evaluation of significant aspects, identification


of hazards & risks assessment and determining risk control measures;
 Identification of applicable HSE legal requirements and other requirements relevant to the
operations;
 Setting HSE performance criteria; and
 Determining HSE objectives and targets and establishing programme(s) to achieve the set
objectives and targets.

ii) Do (Implementation and Operation)


For an effective implementation and operation, SKPB is committed to ensure availability of the
following support mechanisms to achieve its HSE Policies, objectives and targets. This involves
providing resources, capabilities and structures to:-

 Create management structures, assign roles and responsibilities with sufficient authority;
 Provide adequate resources;

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 Train persons working for or on behalf of the organization and ensure required level of
awareness and competence is achieved;
 Establish process for the participation, consultation and internal & external
communication;
 Establish and maintain documentation;
 Establish and implement document control;
 Establish and maintain operational control; and
 Ensure emergency preparedness and response.

iii) Check (Checking)


SKPB shall then proactively measure, monitor and evaluate its HSE performance via the following
process:-

 Conduct ongoing monitoring and measurement;


 Evaluate status of compliance;
 Identify actual & potential nonconformity and take corrective and preventive actions;
 Manage records to demonstrate compliance to HSE MS requirements; and
 Conduct periodic internal audits at planned interval.

iv) Act (Management Review and Continual Improvement)


SKPB shall review and continually improve its HSE Management Systems with the objective of
improving its overall HSE performance. This involves evaluating the HSE MS’s continuing
suitability, adequacy and effectiveness in line with SKPB activities within the scope of HSE MS,
via the following process:-

 Conduct management reviews of the HSE Management Systems at appropriate interval to


identify areas for continual improvement.
 Document, communicate and monitor all identified remedial actions until closure.

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4.1.2 HSE Management Systems

A. HSE Management Systems Model

HSE LEADERSHIP AND COMMITMENT

Policies, Manuals, Life Saving Rules


and Objectives

Risk Management (HS Risk, EIA, Legal


PLAN register, Standards)

Organizational, Responsibilities & Resources


(including competency & training)

DO

Operational and Process Control (HSE MS, Asset Integrity, Procedures &
Work Instructions, Management of Change, Contractor Management,
Consequence Management PTW, Emergency Planning)

Performance Monitoring & Reporting (Leading Corrective Actions and


& Lagging KPIs, Incident Reporting) Improvements

CHECK

Assurance (e.g. Audit) Corrective Actions and


Improvements

Management Review (SKPB Group HSE Corrective Actions and


ACT Steering Committee) Improvements

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B. Matrix of Correspondence between the sections of SKPB HSE MS; and OHSAS 18001:2007
and ISO 14001:2004.

SKPB HSE MS Manual Sections OHSAS 18001:2007 ISO 14001:2004

4.1 General Requirement 4.1 General Requirement 4.1 General Requirement

4.1.1 Plan-Do-Check-Act
(PDCA) Model

4.1.2 A HSE MS Model

4.1.3 HSE Governance

4.1.4 Leadership and


Commitment

4.2 HSE Policy 4.2 OH & S Policy 4.2 Environmental Policy

4.3 Planning 4.3 Planning 4.3 Planning

4.3.1 Hazard & Effect and 4.3.1 Hazard identification, risk 4.3.1 Environmental Aspects
Aspect & Impact assessment and
Management Process determining controls

4.3.2 Legal & Other 4.3.2 Legal & Other 4.3.2 Legal & Other
Requirements and Requirements Requirements
Standards

4.3.3 Strategic HSE Objectives, 4.3.3 Objectives and 4.3.3 Objectives and
Plans, Programmes & programme(s) programme(s)
Activities

4.4 Implementation & 4.4 Implementation & 4.4 Implementation &


Operation Operation Operation

4.4.1 Organization, Resources, 4.4.1 Resources, Roles, 4.4.1 Resources, Roles,


Roles, Responsibility, Responsibility & Authority Responsibility,
Accountability & Accountability &
Authority Authority

4.4.2 Competence, Awareness 4.4.2 Competence, Training & 4.4.2 Competence, Training &
& Training Awareness Awareness

4.4.3 Communication, 4.4.3 Communication, 4.4.3 Communication


Participation & Participation &
Consultation Consultation

4.4.4 Documentation 4.4.4 Documentation 4.4.4 Documentation

4.4.5 Control of Documents 4.4.5 Control of Documents 4.4.5 Control of Documents

4.4.6 Operational Control 4.4.6 Operational Control 4.4.6 Operational Control


Procedures

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4.4.7 Contingency, Emergency, 4.4.7 Emergency Preparedness 4.4.7 Emergency Preparedness
Preparedness & & Response & Response
Response and Crisis
Management

4.5 Checking – 4.5 Checking 4.5 Checking


Monitoring,
Measurement &
Reporting

4.5.1 Performance Monitoring 4.5.1 Performance 4.5.1 Monitoring &


Measurement & Measurement
Monitoring

4.5.2 Evaluation of Compliance 4.5.2 Evaluation of Compliance 4.5.2 Evaluation of Compliance

4.5.3 Incident Reporting, 4.5.3.1 Incident Investigation - -


Investigation and Follow-
Up

4.5.4 Nonconformity, 4.5.3.2 Nonconformity, 4.5.3 Nonconformity,


Corrective Action and Corrective Action & Corrective Action &
Preventive Action Preventive Action Preventive Action

4.5.5 Control of Records 4.5.4 Control of Records 4.5.4 Control of Records

4.5.6 Assurance 4.5.5 Internal Audit 4.5.5 Internal Audit

4.6 Management Review 4.6 Management Review 4.6 Management Review

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4.1.3 HSE Governance

The management of HSE matters in SKPB is governed by the following principles:


 The SKPB Group HSE Steering committee is the final decision body on SKPB policy for all SKPB
HSE matters.
 The execution of work in accordance with the SKPB HSE policy, local and International legislation,
standards, procedures and guidelines is a line responsibility. Deviation shall be subject to the
approval of appropriate approving authorities in the Op Co/ functional management.
 The Corporate HSE functions develop, maintain and provide advisory support to management
on policy, strategy, business HSE plan, standards and procedural matters and reports on SKPB
HSE performance.
 The Corporate/ Division/ Op Co HSE functions advise the line on application of HSE tools and
techniques.
 The Division HSE function acts as the focal point to communicate and disseminate information
between Corporate HSE and the Division/ Op Co. The function also provide monitoring and
advisory support to Op Co HSE function on HSE matters.
 The line management shall oversee the HSE performance within their respective entities. The
line shall be responsible for the development and implementation of their respective HSE plans
in line with the SKPB HSE plan.
 In joint ventures where SKPB has no operational control of the activity, the designated person-
in-charge of the venture shall put in place a mechanism to enable the Board of joint ventures to
formally monitor HSE MS implementation and HSE performance in line with SKPB’s HSE MS.

4.1.4 Leadership & Commitment

SKPB believes that the foundation of an effective HSE management is derived from a good leadership
and commitment shown by all level of Management in promoting a sound HSE culture.

The SKPB Senior Management team, who are also represented in the SKPB Group HSE Steering
Committee meeting, demonstrates visible leadership and commitment, establishes the HSE policy and
framework for SKPB and promotes a corporate culture in which all employees share a commitment
to HSE.

The SKPB Senior Management team demonstrates a top-down commitment and a company culture
essential to be seen as providing a leading role towards constant improvement through leadership
and action planning involving:

a) Visibility

Top management of each Division, Op Co or worksite shall provide strong and visible leadership to
promote a culture in which all employees including subcontractors share a commitment to achieve
HSE policy and objectives by:
 Putting HSE matters high on the agenda of meetings, from Board downwards.
 Leading by example by intervening during day to day activities whenever HSE requirements may
not be met, including challenging business decision.

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 Insisting on compliance with applicable laws, regulations and HSE requirements; and take
appropriate action to correct deficiencies.
 Applying consistent consequence management for those who break rules and those who create
the conditions for rule breaking.
 Taking immediate and visible response and involvement in case of incidents or other
abnormal events related to HSE.
 Communicating the importance of HSE considerations in business decisions.
 Committing to implement an effective HSE MS and achieve internationally recognized certification
e.g. ISO 14001, OHSAS 18001, and ensuring that the necessary resources, milestones and
reviews are incorporated in the Business Plan.
 Communicating HSE expectations to employees by developing relevant HSE policies and setting
relevant HSE objectives.
 Promoting the sharing of HSE lessons learnt.
 Recognising achievements to improve HSE performance.

ii) Proactive in Target Setting

Top management shall be proactive in target setting by incorporating SKPB HSE targets in their
business operations.

Target shall be developed and discussed with managers, employees and contractors aimed at
achieving continual improvement including:
 Ensuring staff having HSE performance indicators targets in their individual appraisal.
 Participating in the review of both reactive and proactive HSE performance indicators.

iii) Informed Involvement

To exhibit leadership and commitment, top management and leaders shall demonstrate informed
involvement in HSE issues by:
 Reviewing the content and implementation of HSE MS and/ or Project HSE Case or Project HSE
Plan and be actively involved in HSE activities.
 Attending relevant HSE trainings.
 Being fully aware of the high priority areas for improvement identified in the HSE Management
Systems, particularly in relation to legal compliance and stakeholder issues, and the closure
status of the follow up actions.
 Being personally involved in improvement efforts arising from the formal senior
management ‘Review’ of the HSE Management Systems.

Leadership and commitment is further demonstrated by:

 Attending and chairing HSE meetings


 Receiving and acting on HSE reports
 Promoting HSE topics in company meetings (e.g. Board meeting) and in company publications
including HSE performance data, etc.
 Endorsing plans for achieving HSE objectives
 Participating in the execution and reviewing of HSE Plans
 Conducting HSE assurance or inspections personally

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 Participating in Management HSE visit/ walkabout
 Participating in incident investigation and review
 Communicating with contractors on HSE matters
 Attending HSE meetings / conferences outside the company
 Allocating experienced and competent personnel to develop and maintain the HSE MS system
 Setting specific HSE tasks and targets for individuals and departments for continual
HSE performance improvement
 Discussing and reviewing with employees, suppliers and contractors progress against meeting
specific HSE targets.
 Demonstrating active personal participation in HSE activities such as training, reward
and recognition schemes, industry/sub-contractor workshops, conferences and audits.
 Developing an open approach to external liaison with authorities and the general public.

4.2 HSE POLICY

The SKPB HSE Policy has been endorsed by the PGCEO and EVC. An Operating Company may have
its own written HSE Policy in line with the Group policy statement on Health, Safety and Environment.

The HSE policy, is being supplemented with related policies such as Drug, Alcohol and Prohibited
Substance policy, Stop Work Policy, etc.

In supporting the fulfilment of the policy objectives, SKPB has also established the SKPB 16 Life Saving
Rules, which set the behavioural expectations of all employees and contractor personnel.

4.2.1 Content and Dissemination

4.2.1.1 Content

 HSE and supplementary policies established at Op Co level shall:


a) Be consistent with the SKPB policy statement on Health, Safety and Environment
and include commitment to take reasonable and practicable steps to prevent and
eliminate the risk of injuries, occupational illnesses and damage to properties as
well as protection of the environment.
b) Be relevant and take into consideration the current and future nature and scale of
the activities, products and services of the Op Co(s).
c) Include a commitment to comply with applicable HSE legislation and other
requirements
d) Approved and signed by the SVP(s) or Head of the respective Op Co(s) and be kept
current.

 The SVP(s) or Head of Op Co(s) shall be the custodian of the HSE policy and be responsible
for its review.

 At least once a year the HSE policy shall be reviewed taking into account the continued
relevance of its intent, scope and adequacy as part of the formal HSE Management
Systems review.

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(Note: employees participation in policy review - Refer to section 4.4.3 Communication,
Participation and Consultation)

4.2.1.2 Dissemination

 The HSE Policy shall be communicated to all employees, all other persons working for &
on behalf of SKPB and key stakeholders e.g. visitor, supplier, etc. either by induction or
notice board or web homepage or contract documents.
 The HSE policy shall be readily available to the public and other interested parties upon
request in a language that is easily understood.
 All employees and contractors shall be informed of the HSE policies and their personal role
in meeting the requirements of the policies.
 Any changes in HSE Policy shall be communicated to all employees and subcontractors.

Means of communicating the HSE policies can be achieved via the following:

 All new staff shall be given an HSE induction by the HR function or their supervisor/
leader
 All visitors shall be given HSE briefing by their Sponsors.
 All contractor personnel shall be given an HSE induction by the Contract Holder or his/ her
representative. (Contractors shall be informed of the relevant HSE policies through
contract documents).

4.2.2 SKPB HSE Policy and Supplementary Policies

SKPB’s Policy on Health, Safety and Environment, supplementary policies and the 16 Life-Saving
Rules (Refer Appendix 2 to 5).

4.2.3 Other Related Documents


i. Consequence Management Procedure (SKPB/LII/ HSE/003)
ii. Drug, Alcohol & Substance Abuse Screening and Testing Procedure (SKPB/LII/HSE/005)
iii. Policies specific to Op Co(s)/ Worksite.

4.3 PLANNING

4.3.1 Hazard & Effect and Aspect & Impact Management Process (HEMP)

Hazard and Effect Management Process describes the identification of HSE hazards and evaluation
of HSE risks, for all activities, products and services, and development of control and recovery
measures to reduce HSE risks to as low as reasonably practicable (ALARP).

SKPB expects that the HEMP process be applied to its critical operations/ activities which include:
• An inventory of health and safety hazards and environmental aspects of all activities,
products and services,
• An assessment of the related risks, implementation of measures to control these risks and
to recover in case of failure control.

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There are 4 steps in the HEMP process namely: ‘identify’, ‘assess’, ‘control’ and ‘recover’. The effective
application of the HEMP process within the business is a process that requires participation at all
levels in the Organization.

4.3.1.1 Identification
 The systematic identification of the health, safety and environmental ‘hazards, effects
and aspects, impact’ that may either affect, or arise from, the activities and services of
the Op Cos/projects/worksites shall utilize techniques such as CHRA, QRA, CIMAH report,
Safety Report, Fire Risk Assessment, HAZOP, HAZID, Bow Tie, CRA, HRA, JHA/JSA, EAI,
EIA, UAUC, ACT, etc.

 The identification shall cover:


a) Planning, construction, commissioning and decommissioning of facilities e.g. asset
acquisition, design & development, merger of business entities, divestment,
abandonment, operations, improvement activities, etc.;
b) Routine and non-routine operating conditions, including shut-down, maintenance
and start-up;
c) Whole lifecycle of an activity (e.g. from inception through to decommissioning and
disposal).
d) Relevant environmental aspects in all phases of its activities, products and services
that it can control and over which it can be expected to have an influence on, in
order to determine which have or can have (actual and potential) significant impacts
on the environment.
e) Incident and potential emergency situations, including those arising from: -
i. Product and/or material containment failures.
ii. Structural failure.
iii. Climatic, geophysical and other external nature events.
iv. Sabotage and breaches of security.
v. Potential hazards and effects associated with past activities

 The process for updating the hazard, effects, environmental aspect/impact,


inventories/registers as a result of operational/facility changes, process, local factors &
circumstances, the balance of cost & benefits and technology changes/availability or
findings from e.g. job hazard analyses, inspections or incident analyses and completion of
corrective action undertaken to address the risks shall be linked to the Management of
Change procedure.

 A comprehensive inventory or register of HSE hazards and environmental aspects


shall be maintained in Op Cos/Projects/Installation/Worksites. A complete review of the
generic assessments (hazard register and aspect tables/registers) shall be conducted
at least once every three (3) years.

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4.3.1.2 Assessment

All hazards, effects and aspects/impacts identified in the HEMP process shall be assessed and
ranked by a team comprising of competent personnel and the personnel directly involved with
the risk.

For Environmental Aspect & Impact refer to section 4.3.1.6.

A qualitative assessment of risk is adequate for most situations but when the risk level is
intolerable a quantitative risk assessment (QRA) may be required.

4.3.1.3 Control Measures


 Hierarchy of controls (elimination, substitution, isolation, engineering, administrative &
Personal Protective Equipment) shall be applied to reduce the risk level.

 Control measures identified through risk assessment shall be implemented to bring the
risk level to ALARP. This shall be maintained to ensure its integrity and continual
improvement to further lower the risk.

 The control measures established shall commensurate with the risks, the
responsibilities and accountabilities for their implementation are clearly defined.

 Performance against each control’s indicator must be monitored and measured


routinely. The results must be analysed, trended and reviewed.

 Control measures shall be reviewed and updated whenever there are changes or
in light of incidents and industry best practice.

4.3.1.4 Recovery Measures


 Recovery measures such as early warning system, medical response, emergency response,
oil spill response, fire-fighting equipment shall be evaluated and applied to minimise the
consequence of the event.

 In the operations phase, established recovery measures must be maintained to ensure its
integrity and continual improvement to further lower the risk.

 The recovery measures established shall commensurate with the risks, the responsibilities
and accountabilities for their implementation are clearly defined.

 Performance against each recovery measure’s indicator shall be monitored and measured
routinely. The results shall be trended and reviewed.
 
 Recovery measures shall be reviewed and updated whenever there are changes or in light
of incidents, post mortem of drills/exercises and industry best practices should be included
in HSE Plans.

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4.3.1.5 Statutory HSE Risk Assessment Requirement

 The Op Cos/worksites shall identify Statutory Risk Assessment requirements and


document those critical operations and installations, which require a fully documented
demonstration that risks have been reduced to a level as low as reasonably practicable
(ALARP), hence complying with relevant regulatory requirements e.g. noise exposure, HSE
Case, CIMAH report, CHRA, EIA, approval letters, etc.

 The Statutory Risk Assessment record should also accurately reflect controls in place and
current practice at the location or site and be reviewed as per regulatory requirements.

 The Statutory Risk Assessment record shall also specify detail activities that must be
discontinued or restricted in given circumstances. These circumstances might be when
HSE critical equipment is not available, during adverse weather or when particular non-
routine hazardous activities are being carried out. The Statutory Risk Assessment record
shall be endorsed by the Asset or Process Owner and by those managing the asset or
operation. It shall be retained as per retention time stated specifically by the relevant
authority/ legislation.

4.3.1.6 Environmental Aspect & Impact

The process of identifying significant environmental aspects are generically carried out as
described in the procedure to identify environmental aspects – Environmental Aspect Impact
Procedure.

4.3.1.7 Other Related Documents


i. Environmental Aspect Impact Identification and Assessment Procedure
(SKPB/LII/HSE/007)
ii. HSE Risk Assessment Procedure (SKPB/LII/HSE/010)
iii. Legal Register (SKPB/LIV/HSE/001)
iv. Procedures specific to Division/Op Co/ Project/Worksites procedures

4.3.2 Legal & Other Requirements and Standards

4.3.2.1 It is the objective of SKPB to ensure compliance with applicable Malaysian HSE legislations,
International convention and protocol ratified by the Malaysian government.

4.3.2.2 Each specific Op Co/ facility/ location is responsible to maintain a site-specific register on legal
compliance to demonstrate commitment to comply with the relevant local legislation,
international convention and protocol, and other requirements.

4.3.2.3 For SKPB international operations, the respective country’s HSE legislation, as well as
international convention and protocols ratified by the country shall be complied with.

4.3.2.4 Compliance to Technical Standards and Process Standards are equally important in managing
HSE risks during the planning stage.
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4.3.2.5 The Op Co/ facility/ location shall identify the relevant Legal & Other Requirements and Standards
applicable for their operations. This includes tracking on new requirements, changes and
deviation, and monitoring of compliance.

4.3.2.6 All action plans identified to meet new, changes and deviation to the Legal & Other Requirements
and Standards shall be endorsed by the Top Management or his designate.

4.3.2.7 The list/register (actual text or summary, where appropriate) shall be kept and maintained to
demonstrate compliance.

4.3.2.8 Communication process shall be established to disseminate the information and changes to
employees, contractors and relevant third parties.

4.3.2.9 Other Related Documents


i. Legal & Other Requirements Compliance Procedure (SKPB/LII/HSE/006)
ii. Legal Register (SKPB/LIV/HSE/001)
iii. Other Requirements Register (SKPB/LIV/HSE/002)
iv. Procedures specific to Division/Op Co/ Project/Worksites procedures

4.3.3 Strategic HSE Objectives, Plans, Programmes and Activities

SKPB is committed to pursue the goal of no harm to people and environment, to have a HSE
performance that we can be proud off, to earn the confidence of our employees, customers,
stakeholders and society at large based on the HSE MS framework, life-saving rules, principles of
sustainable development and compliance to relevant legislations.

In setting strategic objectives and developing HSE Plan, Division or Op Co(s) management shall
consider the overall risk levels of its business activities within the economic, environmental, social
and legal context of its operating environment.

4.3.3.1 Strategic HSE Objectives

 Each Division and Op Co shall establish and maintain documented health, safety and
environmental objectives, at each relevant function and level within the company.

 Strategic objectives shall be in line with the SKPB policy statement on Health, Safety &
Environment and business activities taking into consideration the legal requirements,
technological change, emerging issues and key stakeholders expectations.

 The strategic objectives shall provide a framework for setting and reviewing HSE Plan and
targets to ensure continual improvement.

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4.3.3.2 HSE Plan

 Within its Business Planning Cycle, the Company reviews and revises the SKPB HSE plan
which provides a 1 year and/or a 3 year plan and detail out the activities for the current
year for implementation with emphasis on continual improvement and setting pro-active
targets. The plan shall be in line with its HSE policy and strategic objectives.

 HSE Plans shall cover all activities such as new developments, existing operations,
modifications, acquisitions, abandonment, product development, etc.

 HSE Plans shall take into account present and anticipated future legislative requirements,
HSE risks, technological options, financial, operational and business requirements,
expectations of stakeholders and address deficiencies identified during HSESC meeting
and management review.

 The plans shall have annual HSE targets, SMART activity programs/ actions, including
suitable performance indicators for monitoring progress, clearly identified parties and
target completion dates and shall be communicated to employees.

 Each Op Co/ facility/ asset/ worksite/ project is required to prepare its specific annual/
project HSE plan for the management of its operations/ activities.
(Note: A Project HSE Plan shall be prepared specifically to cater for a project-type activity
as HSE planning tools including identification of risk controls and recovery measures for
implementation. It is submitted to clients as part of the contract bids and forms an
important component in the contractual obligations).

 The Hierarchy of SKPB’s HSE Plan is shown below.

SKPB Annual Business HSE Plan

Op Co HSE Plan

Asset/ Location/ Worksite/


Project HSE Plan
Office HSE Plan
 

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4.3.3.3 HSE Programmes and Activities

 Detailed HSE programmes and activities shall be developed to support the annual HSE
Plans. The programmes shall establish clear milestone and schedule with respective
accountable parties assigned. HSE programmes shall be developed to support the
mitigation measures arising from the risk assessment.

 Key Performance Indicators (KPI) shall be established for all HSE programs.

 KPI shall be monitored, tracked, analysed and reported periodically to ensure effective
and timely implementation of the programmes.

 All HSE programmes and activities shall be cascaded to relevant departments,


communicated and promoted through various platforms to engage all staff and
subcontractors in enhancing HSE culture.
Note: Where necessary, the objectives/ programmes may be amended to address changes
in business needs, activities, operating conditions and legal & other requirements to
maintain their suitability and effectiveness.

4.3.3.4 Other related document

i. Corporate HSE objectives, plan and programmes.


ii. HSE objectives, programmes and plans specific to Op Co/ facility/ asset/ worksite/
project

4.4 IMPLEMENTATION AND OPERATION

4.4.1 Organization, Resources, Roles, Responsibility, Accountability And Authority

In SKPB, HSE is a line responsibility. Each function/location is responsible for its HSE
implementation and performance.

HSE roles and responsibilities as described within their own Job Description shall be made available
for all employees. Line management is responsible to prepare and communicate the roles and
responsibilities.

The Corporate HSE team provides first line day-to-day HSE support and services to the line and
advises management on the overall implementation strategy and framework of the HSE MS in the
Company. Section 4.1.3 defines the HSE Governance for SKPB.

4.4.1.1 SKPB is committed to the provision of adequate HSE organization and resources (technically
competent personnel, infrastructure, technology and budget) for implementation, maintenance
and improvement of the HSE Management Systems and effective management of risks. Examples
of these are as follows:

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 Prompt rectification of HSE related deficiencies identified by the company or regulators.
 Facilities, plant and equipment to meet regulatory requirements.
 Personnel, equipment and infrastructure to reduce and mitigate risks associated with its
operations.
 Formation of a pool of competent HSE personnel to provide advice and support to
management and the line.
 Allocation of personnel for on-going verification that HSE Critical systems is functioning in
accordance with the design intent and objectives.
 Allocation of funds for HSE activities, including HSE training to maintain and enhance
competencies, to be incorporated in the annual HSE budget.
 Resources for emergency response.

4.4.1.2 Line Management is responsible to ensure resource are sufficient to meet HSE requirements and
will not drop to a level that will compromise the controls to reduce risks. Resources level shall
be regularly reviewed (at least annually during the annual Business planning process) to ensure
that any changes in resource level do not increase HSE risk. These shall include staffing
requirements for both long term and short term such as staff succession planning, and leave
rotations & sickness absence. (Refer to Section 4.4.6.3 Management of Change).

The SKPB Organisation structure is as illustrated in Appendix 6.

4.4.1.3 The SKPB Group HSE Steering Committee

The SKPB Group HSE Steering committee is the ultimate decision making body pertaining to HSE
matters. These decisions are guided by advice from the Corporate HSE team and divisional HSE
teams. The sharing of HSE information across the group and alignment of practices and
procedures at operational level is affected through the “Corporate HSE-Divisions HSE Heads”
engagement forum, held monthly.

Refer to appendix 7 for SKPB Group HSE Steering Committee Structure

4.4.1.4 Board of Risk Committee (BRC)

The Board of Directors of SapuraKencana Petroleum Berhad (the “Board”) assumes the ultimate
responsibility over the effectiveness of the Group’s Risk Management and HSE practices. The
principal objective of the Board of Risk Committee is to assist the “Board” in discharging its roles
and responsibilities, amongst which is to oversee the assessment of processes relating to
Company’s risks and controls. The BRC shall determine that Management has implemented
policies in ensuring that the Group’s risk including HSE risk are identified and evaluated and that
the control measures which are in place are adequate and properly functioning in addressing the
risk.

4.4.1.5 Management Representative (MR)

 The management representative for the company is the Head of Corporate QHSE or his
authorised designate. The primary role of the MR is to provide HSE advice and is
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responsible for the establishment, implementation and maintenance of the HSE MS on
behalf of the PGCEO.
 He/ She should have sufficient knowledge of the company and its activities, and of HSE
issues, with sufficient authority to undertake the role effectively.
 The MR periodically reports on the effectiveness of the HSE MS to senior management for
review both at Board Risk Committee (BRC) level and SKPB Group HSESC level for
continuous improvement of the HSE MS.
 The application of the HSE MS to a local operation, installation, facility or worksite shall be
the responsibility of the local line management.
Note: The appointment of MR should not reduce the responsibility of Division Heads, Op
Co Heads, and individual Line Managers to implement the HSE MS in their spheres of
operation.

4.4.1.6 Division Head

 Has the Overall HSE responsibility for Division in his/her capacity as the Head of Division.
 Ensures the management of HSE in accordance to the SKPB’s HSE Policy and HSE MS
manual, and ensures compliance.
 Demonstrates visible HSE leadership and commitment towards compliance to HSE
requirements.
 Approves and issues the Division annual HSE Plan
 Owns the Division HSE MS Manual (if any) and ensures compliance
 Is responsible to ensure total closure of all corrective action and preventive action arising
from (but not limited to) incident investigation, audit findings, inspection findings, etc.
 Escalates Division’s specific HSE issues to the SKPB Group HSESC for sharing/ learning/
seeking direction as necessary.
 Is responsible to chair the Tier 2 ECC Management.
 Communicates HSE policies to Op Co Heads.

4.4.1.7 Op Co Head

 Has the Overall HSE responsibility for the Op Co in his capacity as the Op Co Heads.
 Ensures HSE matters are managed in accordance with SKPB HSE Policies and HSE MS
manual, and ensures compliance.
 Demonstrates visible HSE leadership and commitment towards compliance to HSE
requirements.
 Approves and issues the Op Co annual HSE Plan.
 Owns the Op Co HSE MS Manual and ensures compliance.
 Is responsible to ensure total closure of all corrective action and preventive action arising
from (but not limited to) incident investigation, audit findings, inspection findings, etc.
 Chairs the Op Co HSEC meeting for sharing/ learning/ setting direction as necessary.
 Endorses the Incident Owner/Responsible Senior Manager for Significant and High Risk
incident investigation.
 Is responsible to declare/activate Op Co Tier 2 ECC management.
 Communicates HSE policies to Op Co Line Managers.

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4.4.1.8 General Managers, Senior Managers, Managers & Team Leaders

 Has the overall HSE responsibility within the team.


 Chair HSE meetings and HSE sub-committees, where applicable.
 Implementation of HSE MS, and wherever applicable HSE Case, within the team.
 Review the effectiveness of HSE MS implementation within the team.
 Demonstrate leadership and commitment.
 Ensure that contractor HSE is managed in line with this HSE MS.
 Comply and promotes the Life-Saving rules.
 Conduct investigations and ensure closure of all HSE incidents.
 Ensure closure of all audit findings arising from 1st party, 2nd party & 3rd party audit.
 Communicates HSE policies to employees.

4.4.1.9 Site/ facility/ installation (overall in-charge) Manager (Plant Manager, Base Manager, Barge
Superintendent, Marine Captain, etc.)

 Has the overall HSE responsibility within the facility, site, rigs, barges or vessel.
 Chairs location HSE meeting.
 Implement HSE MS, HSE Case and Site Specific Procedures at their respective location.
 Ensure compliance to Permit to Work (PTW) requirement.
 Ensure compliance to Management of Change (MOC) requirement.
 Ensure appropriate application of HEMP/ RA tools on all activities.
 Overall in-charge of the safe evacuation of site personnel in an emergency.
 Responsible for obtaining approvals for all deviations in their activities from established
procedures.
 Demonstrate visible leadership and commitment.
 Comply with and promotes the Life-Saving Rules.
 Initiate preliminary investigation and complete all HSE incidents investigations.
 Ensure closure of all audit findings arising from 1st party, 2nd party & 3rd party audit.

4.4.1.10 Specific/specialized Job Supervisors

 Overall in charge of specific activities or tasks.


 Conduct Job Hazard Analysis (JHA) and toolbox talk.
 Ensure adequate planning prior to start of work.
 Ensure the execution of work is in accordance with the PTW system.
 Attend HSE meetings.
 Report all HSE incidents to the overall in-charge supervisor.
 Ensure closure of all audit findings within their individual sphere of responsibility.
 Comply with and promote the Life-Saving rules.

4.4.1.11 All personnel

 Responsible for personal HSE compliance and that of his/her team mates (e.g. use of
PPE).

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 Observe HSE policies and comply with systems, procedures and guidelines, such as PTW
system, MOC procedure and good working practice.
 Report all HSE incidents to the Job Supervisor.
 Attend HSE meetings.
 Participate in HEMP (e.g. JHA/JSA, toolbox talk, etc.)
 Attend and keep up-to-date mandatory HSE training and other relevant HSE training.
 Comply with the Life-Saving rules.

4.4.1.12 Other Related Document


i. Board of Risk Committee Terms of Reference (Approval dated 21st May 2013)
ii. Specific Op Co/Location/Project/ Worksite documentation

4.4.2 Competence, Awareness and Training

4.4.2.1 All personnel who perform HSE critical activities are HSE critical staff and require appropriate
experience, qualifications and training to ensure they are competent to undertake important risk
control measures including:
 The HSE consequences, actual or potential, of their work activities, their work activities,
their behaviour, and the HSE benefits of improved personal performance;
 Their roles and responsibilities, and the importance of achieving conformity to the HSE
policy and procedures and to the requirements of HSE Management Systems, including
emergency preparedness and response requirements;
 The potential consequences of departure from specified procedures.

4.4.2.2 Recruitment, selection and placement processes shall be established to ensure that personnel
are qualified, competent, and physically & mentally fit for their assigned tasks.

4.4.2.3 An HSE competence assurance process (following structured competency assessment and
training systems) shall be in place for all HSE critical employees (company and subcontractor).
This process shall be documented and the record of competencies is to be maintained

4.4.2.4 The competency requirements of all HSE critical activities shall be periodically reviewed
and improved. The competence of employees shall be reassessed and shortfalls addressed.

4.4.2.5 All Op Cos including Corporate support functions shall define the necessary HSE competence
requirements to ensure all personnel are competent to carry out the HSE aspects of their duties
and responsibilities. The process involves the following:
 Identify HSE critical roles
 Specify HSE competency requirements
 Assessment of competency
 Identify gap
 Provide HSE trainings.

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4.4.2.6 Subcontractors HSE Management and Competency

4.4.2.6.1 Contractors and subcontractors play a substantial role in SKPB’s business activities.
Therefore, it is crucial for SKPB to ensure that its subcontractors operate within their HSE
Management Systems which shall be parallel with SKPB’s HSE Management Systems.

4.4.2.6.2 SKPB strives to work together with contractors to continually improve HSE performance
by implementing HSE management controls that are appropriate for the level of the
contract HSE risk and capabilities of the contractor to manage HSE within the scope of the
contract. Thus, the overall strategy in managing Contractors’ HSE is as follows:

 Where SKPB has the full influence in respect of Contractors working for the
Company, the Contractor shall be required to conform to the requirements of
Company’s HSE Management Systems as well as other associated policies,
procedures and guidelines.
Note: Full influence: - the Contractor provides people and tools for the execution of
work under the supervision, instruction and HSE MS of the company, and the
contractor has a Management Systems to provide assurance that the personnel for
whom he is responsible are qualified and healthy for the job and that the tools and
machinery he is providing are properly maintained and suitable for the job.

 Where SKPB has limited influence for Contractors working for the Company, the
contractor may elect to use their own standards, provided these are compatible with
SKPB’s standards. A bridging document should be developed.
Note: Limited influence: - the contractor executes all aspects of the job under its
own HSE Management Systems, provides the necessary instructions and
supervisions and verifies the proper functioning of its HSE Management Systems.
The company is responsible for verifying the overall effectiveness of the HSE
management controls put in place by the Contractor, and assuring that both the
Company’s and the Contractor’s HSE Management Systems are appropriately
compatible.

 In certain situations, where SKPB and Contractor have equal influence i.e. Joint
Operating in a contracts, both organisation shall agree how HSE to be managed
prior to contract signing. A bridging document shall be developed.

4.4.2.6.3 A person within the Op Co / project shall be identified for every contract as being
responsible for all activities in the contracting process and the execution of the contract.
 Contractor mobilisation shall be conditional upon receipt of an acceptable HSE Plan
based on the level of HSE risk and suitable interface arrangements, to ensure
compliance with the company HSE MS. All high-risk contracts shall have a
documented demonstration as to how the risks from hazards and effects are
reduced to ALARP. This can be in the form of a HSE Case (for major contracts) or
an HSE Plan.

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 Contracts shall specify an inspection / audit timetable, action to be taken in
case of non-compliance with standards, terms and conditions, defining
reward or penalties for HSE performance and the requirement. At least an
annual formal review of the HSE MS shall be performed for contracts/and or projects
running for long periods (>1 year).

 Evaluation of Contractor HSE performance shall be conducted after the


completion of the contract as part of project close out requirement.

4.4.2.7 Other Related Document


i. Competence, Training and Awareness Procedure (SKPB/LII/HSE/014)
ii. Contractor HSE Management – HSE Criteria For Bidding Process, HSE Performance
Evaluation & Audit Procedure (SKPB/LII/HSE/019)
iii. Specific Op Co/ Project/ worksite procedures

4.4.3 Communication, Participation and Consultation

4.4.3.1 Internal communication

The effective communication of HSE information is essential in achieving effective


implementation of HSE MS. The framework of HSE meetings and committee structure are the
primary means of risk communication.

All employees and contractors shall be made aware of their HSE responsibilities, the HSE
risks applicable to their place of work and work activities, importance of compliance to HSE
policies, standards and procedures, processes for raising concerns about unsafe acts and
conditions during their HSE induction and toolbox. Records of the tool box and HSE induction
process shall be maintained.

Methods put in place by company to motivate staff to be more aware of HSE controls, risk
mitigation measures, target & performance and to develop a good HSE culture can include:

 HSE information web / home page.


 The direct and personal interest shown by a supervisor in his subordinate’s work through
immediate recognition or criticism. This remains the most powerful motivational and
behaviour modification technique in HSE matters.
 HSE performance boards situated in prominent locations with regular update that
provide focus to the HSE effort.
 Issuance of HSE alerts and hazard identification packs to cascade lessons learnt.
 Cascading of information through HSE campaigns, workshops, engagements.
 Cascading/ role out of key HSE procedures such as Life-saving rules, PTW, Incident
management, Management of Change, etc.
 HSE weeks
 HSE induction program for mobilization of drilling rigs, barges, etc.

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 Counselling services and initiation of Behavioural Based Safety program for SKPB and
subsidiaries including HSE Consequence Management, monitoring return-to-work program
and HSE motivational & promotional programs to support/fulfill project & operational
activities/requirements by the Corporate HSE Counsellors team.

4.4.3.2 External Communications.


These shall address:-
 HSE issues raised by stakeholders
 The registration and attending to public complaints including HSE hazards/ aspects
communication.

4.4.3.3 Participation and Consultation


The SKPB Group Health, Safety & Environment Steering Committee (HSESC) is the highest
hierarchy of HSE meetings in SKPB. Each Op Co/ Projects/ Sites/ Installations shall establish their
own HSE Committee Meeting depending on their scale of operations addressing the following:
 Composition of HSE committee at Op Co shall comply with the regulatory requirements to
ensure provision for participation and representation of workers in HSE matters, HSE
committee shall be established at Op Co levels.
 HSE Committee shall focus on relevant HSE issues and provide a framework for
communication on the management of HSE matters.

4.4.3.4 Other Related Documents


i. Internal and External Communication, Participation & Consultation Procedure
(SKPB/LII/HSE/015)
ii. Managing SKPB HSE Committee Procedure (SKPB/LII/HSE/022)
iii. Specific Op Co/ Project/ Worksite procedures

4.4.4 Documentation

It is essential that the HSE MS and the associated documents are thoroughly and clearly documented.
This is necessary to ensure consistent application throughout the Company. It also allows efficient
review and auditing of the system and its components by either internal or external parties.

All HSE documents shall have an Owner who is accountable for all aspects of managing document
throughout its lifecycle, including business value, integrity of its content, retention and review
requirements and a document custodian or technical authority who is responsible for creation and
update of document content at least once in 3 years or when there is any change.

Documents shall be updated and upgraded in line with relevant requirements for continual
improvement.

All HSE information is documented in hardcopies or electronic formats accessible to employees that
consist of:
 The HSE policies, objectives, targets and programmes.
 Description of the scope of the HSE MS.

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 A manual that describes the core elements of the HSE MS and their interaction and reference to
related documents including processes, standards, legislation and other requirements used to
manage HSE and assist employees and contractors in understanding how the company will meet
the objectives of the HSE Policy.

SKPB HSE documentation hierarchy:

4.4.5 Control of Documents

All the documents required for the implementation and maintenance of HSE MS shall be identified
and control to ensure relevancy.

Op Cos/Projects/ worksites shall put in place a mechanism for the management and control of
documents in paper and/or electronic format including formal administration, custodianship, review
frequency requirement for technical correctness and to ensure:
 They are periodically reviewed, revised as necessary and approved/ re-approved for adequacy
by authorized person;
 Changes and the current revision status of documents are identified;

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 Relevant versions of applicable documents and data essential to the effectiveness functioning of
the HSE system are available at points of use;
 Obsolete documents and data are promptly removed from all points of issue and points of use
or otherwise assured against unintended use;
 Documents remain legible and readily identifiable;
 External origin documents are identified and distribution controlled; and
 Archival/ retention of obsolete documents and data for legal or knowledge preservation purposes
are suitably identified and prevented from unintended use.

4.4.5.1 Other Related Procedures


i. Control of HSE Documents Procedure (SKPB/LII/HSE/013)
ii. Control of HSE Records Procedure (SKPB/LII/HSE/017)
iii. Specific Op Co/ Project/ Worksite procedures.

4.4.6 Operational Control Procedures

Company systems, procedures and guidelines are developed for use across the SKPB Group of
companies as it is desirable to maintain a common standard across all operating companies. Where
the use of common systems, procedures and guidelines is not and overriding factor, each Op Co may
maintain its own specific procedures and work instructions as long as it is at par or more stringent
than the SKPB procedures. It is the responsibilities of each Op Co/ project/ worksite to ensure that
the systems, procedures and guidelines are appropriate for the activities or task to be carried out.

4.4.6.1 Procedures and Work Instructions

 All HSE Critical Activities arising from risk assessment and the supporting tasks (meeting
the requirements of section 4.3.1) shall have written procedures or work instructions
where the absence of such written procedures could result in infringement of the HSE
policy, or breaches of legal, regulatory, and/or other requirements, or performance
criteria. Where appropriate, procedures and instructions shall indicate performance
standards and criteria to be satisfied,

 The appropriate standards and procedures shall be readily accessible to employees,


suppliers and contractors and be written in a way that users will understand. Op Co
/Facility/ Worksite owner shall ensure that relevant HSE procedures and requirements for
their areas are communicated to suppliers and contractors.

 Relevant standards and procedures shall be consistently applied and any deviation shall
be assessed, reviewed and approved by the management according to Management of
Change procedure.

 Op Co shall integrate those relevant operational controls into its overall HSE MS which
shall include the following:

a) Controls related to purchased goods, equipment and services.


b) Controls related to contractors and other visitors at the workplace.
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c) Procedures to cover situations where their absence could lead to deviations from
HSE policy and objectives.
d) Operating criteria where their absence could lead to deviations from HSE policy and
objectives.

4.4.6.2 Permit To Work

The Op Co shall maintain a formal documented process of Permit to Work system (PTW) for
every worksite to manage work tasks where high potential hazards have been identified. The
PTW is designed to control work of elevated risk and ensure that any risk mitigation measures
are clearly communicated.

4.4.6.3 Management of Change

While SKPB recognizes the importance of maintaining standards through a set of formal written
arrangements, there are circumstances which necessitate changes or deviations from established
arrangements, thus:-

 The Op Co shall maintain written procedures for planning and implementing all changes
(i.e. facilities, equipment, design, process, procedures, organizational and people), both
permanent and temporary, to assess HSE impact and avoid adverse HSE consequences.
 The Management of Change procedures shall document the assessment, review and
approval processes, and define the responsibilities and competencies of those involved.
 Assessment and documentation of the HSE impact for implementing the change shall be
defined in the Management of Change procedure.

4.4.6.4 Contractor Management

SKPB is committed to work together with subcontractors to continually improve HSE performance
by implementing HSE management controls that are appropriate for the level of the contract HSE
risk. Managing contractor HSE is executed in accordance with the Contractor Management
Procedure.

4.4.6.5 Asset Integrity

SKPB recognizes the importance of establishing a good framework for describing how the
integrity of asset is assured through its lifecycle.

4.4.6.5.1 The Op Co shall establish and maintain procedures which ensure: -

 There is a clearly defined responsibility for asset ownership

 There is a signed statement of fitness to demonstrate that existing operating


facilities, new facilities and modifications to existing facilities are designed
constructed and commissioned in accordance with company and external standards,
codes and regulations such as:-
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a) Certificate of fitness for DOSH registered machineries, equipment and
pressure vessels (for Malaysia) shall be obtained and maintained.
b) Written approval from DOE
c) Fire Certificate from Fire Department
d) License to Occupy from Local Council
e) ISPS and Classification for offshore facilities

Note: Similar requirement shall be applied to overseas operations if there is such


regulatory requirement.

 The documentation necessary (including the HSE Case/CIMAH report) to support


operation, maintenance and inspection is complete prior to facilities start-up.

 Those activities and equipment critical in the safeguarding of asset integrity shall
be identified and documented in the HSE MS (e.g. typically in the HSE Case/CIMAH
report, Operating Manual and Maintenance Plan).

 The technical and operational integrity of asset (facilities and equipment


critical in the safeguarding of asset integrity during the life cycle) shall be
maintained, performance tested, and inspected.

 A clear maintenance and inspection philosophy and strategy shall be established


in order to develop a comprehensive plan covering both reactive and preventive
maintenance.

 That the design of new facilities shall be in line with the Hazard and Effects
Management Process. (Refer section 4.3.1 Hazards & Effects Management Process)

 Human factors consideration shall be taken into account during the design,
construction, operations, maintenance and decommissioning of any facilities and
plants including modification works.

 Human factors implementation at different sites shall be driven by the needs of each
site and shall be tailored to each site.

 Human factor performance data shall be analysed to identify the human


factors issues with appropriate intervention plans developed, covering the use
of different human factors tools.

4.4.6.6 Other Related Document


i. Permit to Work Framework (SKPB/LII/HSE/026)
ii. SKPB Contractor HSE Management - HSE Criteria for Bidding Process, HSE Performance
Evaluation & Audit Procedure (SKPB/LII/HSE/019)
iii. Management of Change Procedure (SKPB/LII/HSE/004)
iv. Specific Op Co/ Project / Worksite Procedures
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4.4.7 Contingency, Emergency Preparedness & Response, and Crisis Management

4.4.7.1 It is the objective of SKPB that all incidents are avoided through comprehensive program of
integrating HSE in the business and executed in accordance with prescribed standards. However,
in the unlikely event of an incident, it is necessary to mitigate associated adverse HSE
consequences of such incident by means of appropriate emergency preparedness and response
procedures at SKPB level, Op Co level and at the specific location.

 Op Co/ location shall document and maintain effective plans for responding to
abnormal situations and potential emergencies.

 A process shall be in place to identify and document credible incident action plan scenarios
including medical (e.g. avian flu, haze, SARS), operational, environmental emergencies
(e.g. facility abandonment & evacuation, oil spill), security risk and natural disaster (e.g.
flood, landslide, tsunami, hurricane, haze, drought) that can have impact on business
and HSE. Contingency and emergency response procedures shall be developed and
maintained to identify responses to incidents and emergency situations and for preventing
and mitigating the HSE impacts that may be associated with them.

 There shall be a comprehensive tiered Emergency Response Plan, Group Crisis


Management Plan and external agencies as appropriate. The plan shall include:

a) Organisation and responsibilities: identification of the incident command structure


(command and control personnel).
b) Systems and measures for minimising potential HSE effects e.g. through
mobilisation of support, evacuation procedures.
c) Communications to command and control personnel, emergency services,
authorities, employees and contractors who may be affected, others likely to be
impacted, e.g. local communities.
d) Requirements for training, emergency drills and assessment.

 There shall be a process for addressing the management of crisis in the company. It shall
be referenced to the group crisis management framework and strategy. A crisis in this
context is a relatively infrequent event that covers any significant disruption to the normal
business routine and requires an immediate response from senior management and
corporate communication department.

 Emergency Response Plans (Tier-2) (including medical, operational and environmental


emergencies) shall be periodically and regularly tested. Each Op co shall be responsible
for ER preparedness within their operation.

 A Business Continuity Plan shall be established to ensure minimum interruption to


business operation.

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4.4.7.2 In responding to a Tier 3 emergency, a fully manned SKPB Crisis Management Centre (CMC)
shall be established and manned by the Crisis Management Team (CMT).

4.4.7.3 In the event of escalation into a crisis, these arrangements are complemented by the SKPB Crisis
Management Procedure.

4.4.7.4 Other Related Document


i. Crisis Management Framework, Strategy and Plan (SKPB/LI/HSE /009)
ii. Emergency Response & Preparedness Framework (SKPB/LII/HSE/012)
iii. Specific Op Co/ Project/ Worksite Procedures

3-Tier Model Hierarchy of Emergency/Crisis Response Levels

Incident
LOCATION (Site Damage Control Team PRIORITY
(DCT))

Manage the Incident


Tier 1 Site Emergency Response
Incident Site/Facility Stabilize and manage fully
Team (SERT) led by Site
within the vicinity of incident
Emergency Commander
(Highest Authority on site)

Manage business impact of


Onshore Incident the incident on associated
Management Team (IMT) led business
by designated authority (EC) Cannot be managed at Op Co
level and requires additional
Tier 2 support outside Op Co Incident
Op Co or Client Emergency Management Team resources
Control Centre (ECC) either from division, group, or
third party e.g. oil spill
Business Support Team (BST) response, barge capsize,
led by Division Head blowout, etc.

Manage the impact of the


Crisis Management Team incident at SKPB level
Tier 3 Crisis Management Center (CMT) led by COO/PGCEO Major incidents which have a
(CMC) at Mines
potential impact on SKPB
Group

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4.5 CHECKING - MONITORING, MEASUREMENT AND REPORTING

As part of the Company objectives to pursue continual improvement, SKPB Corporate HSE regularly
monitors the implementation of the HSE MS, plan and performance to ensure targets are met and the
HSE MS remains current. These are being reported to PGCEO on a monthly basis and BRC on quarterly
basis.

Where targets are not met and gaps exist, the responsible parties at each level of the organization
shall determine appropriate remedial actions to bring back the performance back to the original
targets.

In principle:
 HSE performance objectives & targets shall be set to ensure progression towards the long-term
goals of no harm to people, asset, reputation and protection of the environment.

 Performance indicators shall be established, monitored and results reported in a way that can be
verified. Traditional reactive indicators shall be complemented with proactive indicators to
effectively manage HSE performance for continual improvement (Refer to Appendix 8).

 All HSE incidents including near misses shall be reported, thoroughly investigated and shared for
awareness and learnings.

4.5.1 Performance Monitoring

4.5.1.1 The management of the company shall ensure that there are systems in place to verify that the
tasks and activities are carried out in accordance with procedures & work instructions and
provide guidance for:
 Monitoring of the extent to which HSE objectives have been met
 Monitoring on the effectiveness of controls
 Proactive measures of performance that gauge the implementation and conformance
to the HSE MS such as ‘unsafe act auditing', 'site inspections', 'self-assessments', etc.
 Reactive measures of performance that monitor ill health, incidents and other historical
evidence of deficient HSE performance.
 Calibration and maintenance of monitoring equipment

4.5.1.2 Op Co/ Project/ worksite shall regularly measure, record, track and report HSE performance
against objectives & targets set in their HSE Plan and performance monitoring procedure.

4.5.1.3 Where monitoring equipment is required for performance measurement and monitoring,
the company shall establish and maintain procedures and retain records for the calibration and
maintenance of such equipment; this also include monitoring done by third party.

4.5.1.4 Management shall ensure that HSE performance of individual employee at all levels are measured
against HSE Objectives and targets, and review periodically.

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4.5.1.5 Other Related Documents
i. Performance Measurement and Monitoring Procedure (SKPB/LII/HSE/009)
ii. Specific Op Co/ Project/ Worksite Procedures

4.5.2 Evaluation Of Compliance

Full compliance with local and international legislation & other requirements is part of SKPB HSE
policy.

In the absence of legislation or relevant industry standards, SKPB shall adopt industry best practices.

4.5.2.1 SKPB/ Op Co/ Project/ Worksite shall establish, implement and maintain procedures for
periodical evaluation of compliance to applicable HSE legal requirements and to other
requirements specific to their sphere of operations/ activities:-
 Actions shall be taken for any non-compliance to ensure full compliance status; and
 Result of the annual evaluation shall be kept.

4.5.2.2 Other Related Document


i. Legal & Other Requirements Compliance Procedure (SKPB/LII/HSE/006)
ii. Legal Register (SKPB/LIV/HSE/001)
iii. Other Requirements Register (SKPB/LIV/HSE/002)
iv. Procedures specific to Division/Op Co/ Project/Worksites procedures

4.5.3 Incident Reporting, Investigation and Follow-Up

4.5.3.1 Occurrence of incident gives an indication that the HSE MS has failed or has proven to be
inadequate in one or more particular areas. For this reason it is essential that all incidents are
thoroughly investigated, to determine where that inadequacy or deficiency exists.

4.5.3.2 SKPB has established a procedure complying with the regulatory, Company policies and
procedures and applicable international standards for notifying, classifying, reporting, recording,
investigating, closing out of recommendations and analysing all incidents in a timely manner in
order to:
a) Determine underlying HSE deficiencies and other factors that might be causing or
contributing to the occurrence of incidents;
b) Identify the need for corrective action;
c) Identify opportunities for preventive action and for continual improvement; and
d) Document and communicate the results of such investigations.

4.5.3.3 SKPB/ Op Co/ Project/ Worksite shall foster a culture of openness in reporting all incidents
including near misses with accountabilities assigned, and progress on recommended actions
monitored until close out.

4.5.3.4 Employee shall be aware of the near miss and incident reporting procedures and participate in
incident investigations.

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4.5.3.5 Training shall be provided in incident investigation to appropriate staff throughout the company.

4.5.3.6 Any corrective or preventative action taken to eliminate the causes of potential incidents shall be
appropriate to the magnitude of problems and commensurate with the HSE risks encountered.

4.5.3.7 Any changes to the HSE MS documentation (e.g. work procedures) arising from such corrective
and preventive action shall be implemented and documented.

4.5.3.8 HSE Hazard and Effect Register shall be reviewed following the incident findings
and recommendations.

4.5.3.9 Lessons learnt from accidents and incidents shall be disseminated to relevant personnel and
contractors.

4.5.3.10 The personal involvement of Op Co Head and Op Co Senior management in the investigation
and close out process is a key signal of management commitment to HSE and is not normally to
be delegated.

4.5.3.11 Other Related Procedures


i. Incident Notification, Reporting & Investigation Procedure (SKPB/LII/HSE/001)
ii. Incident Investigation & Root Cause Analysis Team Member Handbook
(SKPB/LII/HSE/018)
iii. Online incident management (Incident Management Portal).
iv. Specific Op Co/ Project/ Worksite Procedures

4.5.4 Nonconformity, Corrective action and Preventive Action.

4.5.4.1 Any non-compliance and corrective/ preventive actions from various implementations of the HSE
MS such as audits, inspections, incident investigations, etc. need to be evaluated and tracked to
demonstrate stringent evaluations of the actions raised, resulting in effective close out of the
action items.

4.5.4.2 Op Co shall establish and maintain a procedure for handling actual or potential nonconformity
including defining the responsibility and authority for:
 Identifying and correcting nonconformity(s) and taking action(s) to mitigate their HSE
consequences;
 Investigating nonconformity(s), determining their cause(s) and taking action(s) in order
to avoid their recurrence;
 the initiation and completion of corrective and preventative actions
 confirmation of the effectiveness of corrective and preventative action taken
 Recording and communicating the results of corrective action(s) and preventive action(s)
taken.

4.5.4.3 All proposed corrective and preventive actions to address the nonconformity shall be taken
through a risk assessment prior to implementation. The actions taken shall be appropriate to the
magnitude of the problem, commensurate with the HSE risks encountered.
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4.5.4.4 Any changes to the HSE MS documentation (e.g. work procedures) arising from such corrective
and preventive action shall be implemented and documented.

4.5.4.5 Other Related Procedures


i. Nonconformity, Corrective & Preventive Action Procedure (SKPB/LII/HSE/016)
ii. Specific Op Co/ Project/ Worksite Procedures

4.5.5 Control of Records

4.5.5.1 HSE records pertinent to HSE shall be effectively managed. They shall be legible, identifiable and
traceable to the activities involved with retention times defined. They shall be stored and
maintained to prevent loss and unintended use. Where there are contractual, legislative and
regulatory requirements for record keeping, such requirements, including those relating to
duration for the records to be retained, shall be complied with.

4.5.5.2 Records supporting the performance data provided periodically to the SKPB Group shall be kept
in an auditable form.

4.5.5.3 Records shall be maintained, as appropriate to demonstrate conformance to the HSE


Management System, Group requirements and international standards and are used in HSE
improvement planning. Retention period of the records stated shall be adhered to.

4.5.5.4 Op Cos/Projects/ Worksites shall establish and maintain procedures/ mechanisms for the
identification, maintenance and disposition of HSE records.

4.5.5.5 Other Related Procedures


i. Control of HSE Records Procedure (SKPB/LII/HSE/018)
ii. Specific Op Co/ Project/ Worksite procedures.

4.5.6 Assurance

4.5.6.1 Assurance Plan


SKPB/ Op Co/ Project/ Worksite shall conduct HSE audit at planned intervals to review and
verify effectiveness of the HSE Management Systems. It is a documented activity performed in
accordance with written procedures aimed at verifying that the HSE MS:-
 Conforms to planned HSE arrangements, including the requirements of acceptable HSE
Standards and legislation.
 has been properly implemented and is maintained;
 Is effective in meeting the organization’s policy and objective.
 Providing information on the results of audits to management.

4.5.6.2 SKPB/ Op Co shall maintain a register of trained and competent auditors to ensure there is always
a sufficient pool of auditors to undertake the HSE audit programs. Selection of auditors and
conduct of audits shall ensure objectivity and the impartiality of the audit process. Personnel
from different functions, /departments of the Op Co shall form part of the HSE Audit Team.

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4.5.6.3 SKPB/Op Co shall establish and maintain an annual assurance plan covering all business activities
including operations and projects that have been contracted out.

4.5.6.4 Audit programme(s) shall be planned, established, implemented and maintained by the
organization, based on the risk associated with the activity or the operation (including
contractors’ activities), and the results of previous audits.

4.5.6.5 Assurance programmes shall include:


i. Internal audit ( Level 1 audit and Level 2 audit)
ii. External audits such as certification to ISO 14001 / OHSAS 18001, recognition/award
audits, regulatory compliance audits (where appropriate), supplier or subcontractor audit.
iii. Specific audits (e.g. Pre-start up safety review, project independent review, pre-execution
audit, etc.).

4.5.6.6 Regular, major contractors are required to establish their own schedules of audit and inspections.
The Contract Holder is responsible for monitoring contractor audit and inspection performances
are in line with Contractor HSE Management procedure. Audit programme (s) shall be in place
for monitoring the effective implementation of the Contractor HSE MS and interfaces between
the Company and Contractor.

4.5.6.7 All action items from HSE audits shall be monitored by the line. The auditee shall identify the
appropriate action party(s) and target date(s) for close-out (within 1 year from date of audit
report at the maximum) and drive the close-out of these action items.

4.5.6.8 Action items that are not closed-out after 6 months shall be escalated to the Op Co Head, Division
Head and PGCEO.

4.5.6.9 If the action items are still not closed at the agreed date after the initial close-out date, the
outstanding issue shall be escalated to the Board Risk Committee.

4.5.6.10 The status of effective close-out of these action items shall be monitored by the line.

4.5.6.11 Other Related Procedures


i. HSE Assurance Procedure (SKPB/LII/HSE/002)
ii. Specific Op Co/ Project/ Worksite Procedures

4.6 MANAGEMENT REVIEW

The successful implementation of the HSE MS involves regular review of the Management Systems to
ascertain its suitability, effectiveness and performance of the HSE Management Systems. The review
shall be carried out annually or as and when the need arises. The timing shall be linked to the Business
planning cycle to ensure recommendations are timely incorporated into the annual HSE plan.

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4.6.1 The Review shall address but not limited to:
i. The findings and status of previous reviews;
ii. HSE performance trending and analysis;
iii. The need to change HSE policies and strategic objectives;
iv. The impact of significant organisational, location or activity changes;
v. The HSE concerns of employees (including concerns from HSE committee meetings) ,
contractors and external stakeholders (including complaints);
vi. The provision of adequate resources and competent personnel to achieve HSE targets
objectives and strategies;
vii. Verification of closure of corrective actions resulting from HSE reviews, risk assessments,
audits, self- assessments, non-conformances, inspections and incident investigations
(including lessons learnt);
viii. Review of legal compliance;
ix. Recommendations for improvement of the HSE MS

4.6.2 Each Op Co/ Project/ worksite shall review the effectiveness of the HSE MS implementation within
their unit and where gap exist, these shall be rectified or brought to the attention of the relevant HSE
committees for resolution.

4.6.3 Results of Management Reviews and identified remedial actions shall be documented, communicated
and monitored until conclusion.

4.6.4 Other Related Procedures


i. HSE Management Review Procedure (SKPB/LII/HSE/008)
ii. Specific Op Co/ Project/ Worksite Procedures

   

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D APPENDICES

Appendix 1 List of SKPB Divisions and Operating Companies


Appendix 2 Health, Safety & Environmental Policy
Appendix 3 Drug, Alcohol & Prohibited Substances Policy
Appendix 4 Stop Work Policy
Appendix 5 SKPB 16 Life Saving Rules
Appendix 6 SKPB Organization Structure
Appendix 7 SKPB Group HSE Steering Committee Structure
Appendix 8 Examples of Performance Indicators

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Appendix 1: List of SKPB Divisions and Operating Companies

Division Investment Holding / Operating Company

TL Offshore Sdn. Bhd.

Allied Marine & Equipment Sdn. Bhd.

Total Marine Technology Pty. Ltd. – 94%

SapuraCrest Dana SPV Pte. Ltd.

SapuraCrest Deepwater Pte. Ltd.


Momentum Energy Sdn. Bhd. (Investment Holding)
(SapuraClough Offshore Pty. Ltd.)
(SapuraClough USA Investment Holding)
Offshore Construction &
Subsea Services Geomark Sdn. Bhd. (Investment Holding)

Sapura Petroleum Sdn. Bhd. (Investment Holding)


Nautical Essence Sdn. Bhd (Investment Holding)
(SapuraAcergy Sdn. Bhd. – 50%)
Seabras Sapura HoldCo. Ltd. (Investment Holding) – 50%
(TL Offshore PLSV1 Ltd – Incorporated in Bermuda – 50%)
(TL Offshore PLSV2 Ltd – Incorporated in Bermuda – 50%)

Seabras Sapura ParticipaçÕes S.A


(Investment Holding) -50%

TL Oilserve Sdn. Bhd.


Sapura Energy Sdn. Bhd.
(Sapura Power Services Sdn. Bhd. – 94.4%)
(Malaysian Advanced Refurbishment Services Sdn. Bhd.)
(Crest Marine Engineering Sdn. Bhd.)
(SE Projects Sdn. Bhd.)
Geotech & Maintenance (Sapura Retail Solutions Sdn. Bhd.)
Services
(Sapura Petroleum Technologies Sdn. Bhd. – 99.7%)
(Sapura Diving Services Sdn. Bhd.)
TL GeoSciences Sdn. Bhd.
(TL Geotechnics Sdn. Bhd.)
(TL Geohydrographics Sdn. Bhd.)

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Kencana HL Sdn. Bhd.

Kencana Bestwide Sdn. Bhd.

Kencana Pinewell Sdn. Bhd.

Kencana Nautilius Sdn. Bhd.

Kencana Torsco Sdn. Bhd.


Fabrication/HUC
Sarku Vessels Pte. Ltd.
Energy Unlimited Sdn. Bhd. (Investment Holding)
(Sarku Engineering Services Sdn. Bhd.)
(Sarku Engineering Services (Offshore) Sdn. Bhd.)
(Sarku Marine Sdn. Bhd.)
(Prominent Energy Sdn. Bhd.)

Sapura Energy Ventures Sdn. Bhd.

Kencana Energy Sdn. Bhd.


SapuraCrest Ventures Sdn. Bhd. (Investment Holding)
(Labuan Shipyard & Engineering Sdn. Bhd – 50%)

Petcon (Malaysia) Sdn. Bhd.


Probadi Sdn. Bhd. (Investment Holding)
Energy and JVs
(Uzmal Oil Inc – 50%)

Peritus International Limited – 51%

Peritus International Pty Ltd – 51%

Ocean Flow International LLC – 70%

Peritus International Inc – 51%

SapuraKencana Drilling Pte. Ltd. (incorporated in Singapore)


SapuraKencana Drilling
SapuraKencana Drilling Pte. Ltd. (incorporated in Labuan)
Pte. Ltd.
SapuraKencana Drilling (Bermuda) Ltd.
(Formerly known as Seadrill Tender Rig Ltd)

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Appendix 2: Health, Safety & Environment Policy

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Appendix 3: Drug, Alcohol & Prohibited Substances Policy

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Appendix 4: Stop Work Policy

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Appendix 5: SKPB 16 Life Saving Rules

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Appendix 6: SKPB Organization Structure

Board of Directors

Corporate
Secretarial

Corporate Internal
Audit
President & Group CEO Executive Vice Chairman

Tan Sri Dato’ Seri Shahril


Dato’ Mokhzani Mahathir
Shamsuddin

Business Divisions Support Divisions Support Divisions

Corporate Strategy and Corporate Risk


Drilling
Business Planning Management

Corporate Business Corporate


Fabrication/ HUC
Development Communications

Offshore Construction
Group Corporate Legal Corporate IT
& Subsea Services

Energy & JVs Corporate ERP

Geotech, Maintenance
Corporate Security
Services and Onshore

Support Divisions
Corporate Finance
Corporate Human & Treasury
Resources

Corporate Accounts Corporate Admin

Corporate Supply Chain

Corporate Quality
Health, Safety &
Environment

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Appendix 7: SKPB Group HSE Steering Committee Structure

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Appendix 8: Examples of Performance Indicators

Subject Proactive Reactive

Medical check-ups Sickness Absence Rate


First aiders Work related illness
Health Medical questionnaires Exposure to chemicals hazardous
OH Awareness Sessions to health
Healthy Lifestyle Campaigns TROIF
Unsafe Act Unsafe Condition (via U-See-U-
Act Programme)
Management Site Visit (MSV)
Audits
LTIF
Safety Safety campaigns, workshops
TRCF
Near miss investigations
Emergency Response/Crisis Preparedness
Exercise
Learning from Incident
Effluent
Spills
Environmental Impact Assessment (EIA)
Environment Ship Energy Efficiency
Audit follow up
Venting/Flaring/GHG
Waste

HSE Legal Compliance HSSE Regulatory Compliance Register Record of Fines paid

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