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HSE Plan

Mar 08, 2016

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Syed Shiraz Ali

HSE Plan
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EQUIPMENT LIST OF PROCESS UNITS

Pakistan Petroleum Limited QHSE Guideline

Project

J33010Unit

00

Snamprogetti

Engineering BVSpecification No.

00-ZA-E-09502

Sheet/ofRev

90 / 1451233A

4

PROJECT HEALTH, SAFETY AND ENVIRONMENTAL

(HSE) PLAN

CONTENTS

PART 1 HSE PLAN - DESIGN ACTIVITIES

51.INTRODUCTION

2.REFERENCE DOCUMENTS83.ORGANISATION AND RESPONSIBILITIES94.HSE ACTIVITIES115.PROGRAMME286.HSE DOCUMENTATION30Part 2 HSE PLAN - CONSTRUCTION ACTIVITIES

1.INTRODUCTION322.APPLICABLE REGULATIONS, CODES AND STANDARDS323.HSE GOALS384.HSE PROCEDURES395.HSE functions, RESPONSIBILITIES AND COMPETENCY REQUIREMENTS396. HSE MEETINGS437. HSE AT WORK SITES498.ACCIDENT REPORTING AND INVESTIGATION529.HSE INSPECTION AND MONITORING5210. HSE RECORDING, MONITORING AND REPORTING5511.HAZARD IDENTIFICATION, ANALYSIS AND CONTROL5712. CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN5913.EMERGENCY PLANNING AND RESPONSE6414.SECURITY6815.HSE SCHEDULE6816.SAFETY COMMUNICATIONS AND PROMOTIONS6917.EDUCATION AND TRAINING REQUIREMENTS7118.CRITICAL SAFETY CONCERNS74

APPENDICES

AHazard Analysis and Control Programme Sheets

BEnvironmental Audit Procedure

CEnvironmental Requirements during Construction and Commissioning

DWaste Register

EWaste Log for Non Hazardous Waste

FWaste Log for Hazardous Waste

GWaste Consignment Note

PART 1 HSE PLAN DESIGN ACTIVITIES

1.INTRODUCTION

1.1GeneralThis document presents the Health, Safety and Environmental Plan for the design phase of the Bhit Gas Field Development Project for LASMO Oil Pakistan Limited (LOPL). The Plan is intended to provide direction and guidance to the Project Team on HSE issues during the detailed design phase and provide an interface to construction HSE activities.

1.2The Project

1.2.1LASMO Oil Pakistan Ltd is developing the field within the Kirthar region of the Sindh Province of Pakistan. The development of the site includes the erection of gas gathering and process plant facilities on and adjacent to the Bhit Mountain.

1.2.2The Bhit Field was discovered in early 1997 and is located approximately 180 kilometres north east of Karachi, within the Kirthar Concession Block. The field is estimated to contain 1.4tcf of hydrocarbon gas with the potential of producing at rates of up to 400mmscf/d. The gas is to be gathered from the various well locations and routed to the Bhit Process Plant. At the Bhit Process Plant produced water will be removed from the gas stream and treated. The gas will require CO2 removal and dehydration prior to passing to the Nitrogen Rejection Unit (NRU). Also significant gas compression will be required due to the low pressure of operation for the NRU. The complete scope of work will include flowlines, gathering lines, process plant and metering facilities. The gas will be exported via a new pipeline to be constructed by SSGC to tie-in with the existing SSGC (Sui Southern Gas Company) Indus Right Bank Line (IRBL) approximately 30 km from the plant (the existing pipeline supplies gas to Karachi).

1.2.3The field development facilities covered include:

Wellsites;

Interconnecting infield flowlines and pipelines;

Gas processing plant at the foot of the Bhit Mountain;

1.2.4The scope of work of Snamprogetti Engineering BV (SPBV) includes the wellsites (but not the wellheads themselves - LOPL scope), all infield pipelines and the main gas processing plant. The export pipeline, including the pig launcher within the main gas plant, is within the scope of SSGC.

1.3The HSE Plan1.3.1The Design HSE (Health, Safety and Environmental) Plan defines the studies and design reviews to be carried out during the detailed engineering and procurement of the Bhit Field Development Project in Pakistan. It also defines their purpose in relation to:

safety;

personnel health;

the environment;

the responsibilities of personnel within the project organisation; and

the approximate timing of the studies.

1.3.2The object of the plan is to provide an overview of the methods adopted by Snamprogetti Engineering BV (SPBV) to ensure that the project complies with contractual, statutory and SPBV requirements with respect to safety, personnel health and the environment. It also demonstrates how HSE activities are integrated with the development and verification of the design.

1.3.3The principal objectives of the plan are outlined below:

To identify and ensure compliance with the overall policies of the LOPL Project Management Team to prevent or minimise risks to operating personnel, the general public and inhabitants of site accommodation facilities.

To provide a framework of Safety Management to ensure that safety, health and environmental issues are addressed and documented fully during the design engineering and procurement phases including engineering design completed by Contractors. Also, to ensure that any outstanding issues are effectively communicated into the construction and operation of the plant.

To identify known safety, health and environmental activities and milestones including submissions to regulatory bodies, safety audits and safety assessments and to define the interfaces between these activities and between interested parties.

To provide and implement mechanisms whereby safety and safety management, health and environmental issues are continuously monitored throughout the life of the project and opportunities for improvement are identified, implemented and carried forward.

Identify and inform the design team and other interested parties of all known safety activities, findings and milestones and the implications of process design changes for process emissions and environmental impact.

Identify any regulatory standards and principles applicable (e.g. local Pakistani legislation) and ensure that they are complied with by the project.

Identify operations involving chemical handling in order that proper procedures, protection and minimisation of operator exposure are developed.

Ensure that all design decisions are based on sound safety reasoning and that the rationale for safety design choices is demonstrable, employing cost/benefit analysis where practicable to ensure a cost-effective design.

Ensure that hazards and risks are identified and quantified, as necessary, using appropriate information and approaches.

Ensure that all operational hazards and risks are minimised, brought under control or eliminated and that these considerations can be demonstrated objectively.

1.3.4The purpose of the HSE activities during the project is to ensure that all risks, not only to the workforce but also the general public who might be affected by the development, are identified and assessed and either eliminated, controlled or mitigated depending on their nature. Risks arise not only as a result of safety-related events but also through long term exposure to emissions and the general environmental impact of the development.

1.4DefinitionsCIV

Civil Discipline

CSOB

Construction Management Discipline

DCN

Design Change Notice

ELE

Electrical Discipline

HAZAN

Hazard Analysis

HAZOP

Hazard and Operability Study

HSE

Health, Safety and the Environment

LOPL

LASMO Oil Pakistan Ltd

MECH

Mechanical Discipline

NRU

Nitrogen Rejection Unit

PEM

Project Engineering Manager

PFD

Process Flow Diagram

PHA

Preliminary Hazard Assessment

P&ID

Piping and Instrumentation Diagram

PM

Project Manager

PRC

Process Discipline

PSL

Project Specialist Leader

QRA

Quantified Risk Assessment

SHE

Safety, Health and Environment

SERD

Safety Engineering Discipline

SIL

Safety Integrity Level Assessment

SPBV

Snamprogetti Engineering BV

2.REFERENCE DOCUMENTS

2.1Project Procedures and Specifications00-ZA-E-09003Project Procedure

00-ZA-E-09529Design HSE Philosophy

2.2SPBV Corporate Operating ProceduresOPR/ENDP/345Plot Plan Preparation and Review

OPR/ENDP/346Model Construction and Review

OPR/ENDP/347Hazardous Area Classification and Review

OPR/PSD/349P&ID Design and Engineering Reviews

OPR/QUAL/350Hazard and Operability Studies

OPR/PSD/421Project SHE Plan

OPR/QUAL/458Application of IEC 61508 - SIL Review

OPR/PSD/488SHE Reviews

OPR/PSD/489Initial Process Safety Review

OPR/QUAL/492Quantified Risk Assessment

2.3SPBV Corporate Design PracticesBDP/QUAL/1465Initial Hazard Identification and Analysis

BDP/QUAL/1468Hazard Assessment

BDP/PSD/1470Initial Process Safety Review Report

BDP/QUAL/1490Availability and Reliability

BDP/QUAL/1493Onshore Explosion Overpressure Assessment

2.4Local RegulationsPakistan Environmental Protection Ordinance (No. XXVII), February 1997

The Environmental Impact Assessment Guidelines for the Pakistan Energy Sector, November 1991

Guidelines for the Safety, Health and Environmental Management in Pakistan Petroleum Exploration and Production Sector

The Oil and Gas (Safety in Drilling and Production) Regulations, 1994

3.ORGANISATION AND RESPONSIBILITIES

3.1Organisation3.1.1HSE activities during the entire project, from detailed design through to construction and commissioning, will be controlled by an overall HSE process which will ensure that HSE-related activities are effectively monitored and organised. The first step in this process is the preparation of the Design HSE Plan (this document). The Design HSE Plan identifies and approximately schedules the HSE-related activities throughout the detailed design phase of the project and the interface to the subsequent construction and commissioning.

3.1.2 HSE issues will be managed, on a day-to-day basis, by the Project [4]

HSE Supervisor. Overall responsibility for HSE issues on the Project remains with the Project Manager, however. The SPBV Project HSE Supervisor will liaise with LOPL HSE Supervisor to ensure that LOPL requirements are met. LOPL HSE Supervisor will liaise as necessary with Pakistani regulatory bodies, with support from SPBV as required contractually.

3.2ResponsibilitiesResponsibilities defined are in accordance with SPBV procedure OPR/PSD/421.

3.2.1Project ManagerThe Project Manager has overall responsibility for HSE issues on the Project and will act as the overall manager (the HSE Plan [4]

Supervisor) of the implementation of the Design HSE Plan. The HSE Plan Supervisor will be responsible for organising and chairing the periodic HSE reviews during the Project, in line with normal SPBV practice (see Section 4).

3.2.2HSE Supervisor

[4]The HSE Supervisor will manage, on a day-to-day basis, the HSE issues arising on the Project and the HSE activities detailed in this plan (see Section 4).

3.2.3Engineering ManagerThe Project Engineering Manager (PEM) is responsible for ensuring that the requirements of the HSE Design Philosophy are incorporated into the design. Queries regarding the design philosophy and derived documentation will be referred to the PEM for resolution.

3.2.4Project Specialist LeadersWithin each discipline, responsibility for safe design resides with the PSL. Each PSL is to ensure that the nominated reviews and studies (see Section 4) occur at the appropriate point in the Project.

3.3Management of HSE Activities3.3.1HSE activities are not discrete events but have feedback into the developing design, particularly in the early (conceptual and basic engineering) stages. It is therefore important to ensure that the findings of any safety reviews, specific studies or environmental impact assessments have been considered for incorporation into the design. In addition, it is necessary to ensure that studies and reviews are completed approximately to schedule in order that any findings which might have an impact on the design are incorporated at a time such that rework and cost impacts are minimised.

3.3.2At the end of detailed engineering, the status of all Project HSE activities shall be reviewed to ensure that all reports/studies are closed-out or that any outstanding issues have been identified and recorded so that, where appropriate, relevant responsibilities have been carried forward to CSOB and LOPL, as appropriate, in a formal manner (see Section 4 for details of management of HSE activities and close-out/transfer of information and responsibilities at the end of detailed engineering).

4.HSE ACTIVITIES4.1Project GoalsThe purpose of the HSE activities undertaken during the detailed design phase of the Project is to provide a sound and cost-effective basis for the process, infrastructure and other facilities in the development, whilst ensuring compliance with local safety and environmental standards and regulations. The combination of hazard assessments, risk assessments, design reviews and safety/environmental design philosophies is intended to fulfil the goals of:

ensuring and demonstrating the safety of the development;

providing an auditable trail of design decisions and justifications; and

identifying and minimising where possible the hazards associated with construction of the plant.

The principal activities constituting the Design HSE process are described in Sections 4.2 and 4.3 below.

4.2Project HSE Reviews4.2.1The HSE Plan (this document) defines the organisation, responsibilities and activities to be undertaken during the detailed design of the facilities and the manner in which HSE issues will follow through into construction. In order to identify the requirements for specific HSE activities and to monitor the progress and implementation of such, a series of structured Project HSE Reviews will be performed. The reviews also ensure that SPBV corporate HSE policy is applied to the Project. The reviews are management reviews, rather than technical. The review procedure is described below and is according to SPBV Procedure OPR/PSD/488.

4.2.2HSE reviews will be held at appropriate intervals during the course of the Project, in line with the main work phases. The reviews anticipated and their approximate relation to the ongoing design development are as follows:

Project Kick-Off (HSE-1)

The HSE activities for the Project are defined, based on a review of the process and its attendant hazards, summarised in the Initial Process Safety Review Report (see Section 4.3.1). Special features of the Project are identified and Project requirements with regard to risk assessment, HAZOP etc are specified, also principal HSE-related design philosophies. This then forms the basis for the Project HSE Plan (this document). The Project HSE activities are detailed in Section 4.3.

Engineering Design Phase (HSE-2)

At the midpoint of detailed engineering, studies identified for early completion in order to provide a firm design basis will be reviewed for completion and implementation. The status of design reviews and studies still to be completed will be established to ensure that schedule requirements are met and the impact of design changes is minimised according to the nature of the activity. The number of meetings during this period will be dependent on the status of activities.

End of Detailed Engineering/Precommissioning/Construction Planning (HSE-3)

Activities scheduled for the end of the design phase will be reviewed for completion and implementation and compliance of the design with established risk criteria and other identified safety goals. Precommissioning and commissioning requirements and preparations for the transfer to site of other relevant HSE-related information will also be reviewed.

Mechanical Completion (HSE-4)

Activities at site will be governed by the Construction HSE Plan. Implementation of the plan will be examined, together with operation of field change procedures, in order to effectively control modifications. Identified operation and/or maintenance problems will also be reviewed.

Review of HSE Documentation (HSE-5)

During the course of the Project, a quantity of HSE-related documentation will be prepared, both as output from identified activities, review and studies and also as correspondence and minutes. This will be assembled into an overall dossier (see Section 4.3) and reviewed for completeness, such that an auditable trail of design decisions is presented.

4.2.3The purpose of the reviews and their timing is to ensure that HSE-related activities are identified and executed at the appropriate point during the Project and the findings implemented as appropriate in order to achieve an inherently safer design and ensure that both SPBV and LOPL HSE requirements are met. Level of LOPL involvement in Project HSE reviews is to be established.

4.3Design HSE Activities

Design HSE requirements and activities are defined during the first HSE review meeting. The requirements for the Project will be influenced by the requirement to ensure that HSE actions arising from the Front-End Engineering Design (FEED) package are effectively reviewed for implementation in the detailed design, as well as the coordination with Associated Scope Managing Contractors. HSE activities and responsibilities are summarised in Table 4.1.

Management of change is an integral aspect of safety management, hence all material design changes during the detailed design phase will be reviewed for their impact on safety and environment (with regard to remaining within agreed emission limits). This will include Design Change Notices (DCN) as they are generated, which might require further HAZOP studies (see Section 4.3.7) during detailed design, or reassessment of fire and explosion loads, for example. The significance and purpose of selected activities is expanded upon below.

4.3.1Initial Process Safety Review ReportThe process is reviewed in order to identify, at a high level, the hazards associated with its operation and hence the precautions necessary in design and operation. The review report forms the basis for the HSE-2 meeting, all subsequent HSE activities are defined on the basis of this review. Preparation of the report is in accordance with OPR/PSD/489.

4.3.2Preparation of Principal Design PhilosophiesThe HSE Design Philosophy will be defined in a project specification, in order to ensure that HSE design criteria are effectively implemented. Philosophies covering:

fire and gas detection;

fire protection (active and passive);

noise control

emergency shutdown and isolation;

maintenance isolation;

flaring and venting

will expand upon the requirements of the HSE Design Philosophy. Principal philosophies to be prepared are detailed in Table 4.2.

4.3.3Review of FEED Documentation for Outstanding ActionsA number of HSE-related studies have been prepared as part of the FEED package, however not all recommendations and actions were incorporated into the final design package. In particular the:

Hazard Identification (HAZID) study;

Environmental Impact Mitigation Plan; and

Coarse HAZOP Study

will be reviewed to identify actions to be resolved in detailed design. Actions will be managed and closed via the Project Action Tracking Register (see Section 4.4).

4.3.4Preliminary Hazard AssessmentPreliminary hazard assessments (PHA) will be performed for each of the principal facilities main processing plant, wellheads and gathering systems of the development. The purpose of the studies is:

to evaluate hazard distances for major accident scenarios (fires, explosions, flammable (unignited) releases);

define the accidental loads on principal structures and equipment as a result of identified credible major accident scenarios;

to provide an input to the preparation of plot plans which can be established on a risk basis.

The results of PHA will be used to establish optimum sitings for control rooms and other vulnerable areas, also the requirement for, and assistance in the location of, fire and gas detection measures.

The assessment will be in accordance with BDP/QUAL/1468.

The export pipeline and associated facilities at the main processing plant are not in SPBV scope and will not be examined.

4.3.5Plot Plan ReviewOnce prepared, plot plans of the wellhead sites and main processing plant will be issued to the engineering disciplines for Inter-Disciplinary Check (IDC). Comments arising from the IDC will be discussed during the review meeting. Review and preparation of the overall plot plan will be according to SPBV Corporate Procedures OPR/ENDP/345 and BDP/ENDP/1304 respectively.

Plot plans for individual process and utility areas at each site will be developed during the detailed design. The development of all plot plans will take account of the results of the preliminary hazard assessments performed for each of the principal sites in the development.

4.3.6Hazardous Area ClassificationThe purpose of hazardous area classification is to define the extent and nature of zones in which flammable gas/air mixtures might occur, in order to establish the requirements for electrical and other equipment located within that area. The extent of hazardous zones will be defined in accordance with Institute of Petroleum Practices Part 15 as indicated in the HSE Design Philosophy, Project Specification No. 00-ZA-E-09529.

4.3.7P&ID Safety and Operability ReviewA review of Piping and Instrument Diagrams (P&ID) will be performed during the basic design once the principal control loops have been defined and tagged and valve sizes determined. The purpose of the review is to assess the process design with respect to the possibility of fire, explosion, unforeseen chemical reactions, excessive inventories, maloperation etc. It will address operability, process safety systems, emergency shutdown/blowdown facilities, materials of construction, any specific startup measures and will ensure that the basis of design is sound. The review will be performed according to SPBV Corporate Procedure OPR/PSD/349.

The P&ID Review is distinct from, and different to, the HAZOP study. The HAZOP is performed at a later stage of the design on IFD documentation and attempts to identify all potential hazard and operability problems by the use of logical queries. The P&ID Review attempts to ensure that the design incorporates protection appropriate to the generic hazards identified but does not attempt to identify those hazards (and their causes) in detail.

4.3.8Hazard and Operability Study (HAZOP)A HAZOP will be performed during the detailed design for all facilities within SPBV scope in accordance with SPBV Corporate Procedure OPR/QUAL/350. The chairman for the studies will be provided by LOPL.

The outputs from the HAZOP are a number of recommendations for improving the safety and operability of the design. A key aspect of the HAZOP process is the tracking of the responses to actions arising from the HAZOP, in terms of implementation, into the ongoing design, or otherwise, in order to ensure an auditable trail. The means by which actions will be tracked, and responsible persons, is detailed in the HAZOP procedure, as is the means by which the checks for implementation into the ongoing design will be tracked.

[4]

Package items including the Mole Sieve and Refrigeration Packages [4]will be examined during the main HAZOP studies at a level of detail commensurate with the detail available although at this stage there might be little beyond the process flow diagram and the principal control loops.

As well as the main process package items indicated above, there will be a number of utility packages, for example:

water demineralisation and chemical dosing;

waste water and produced water treatment and disposal;

sewage treatment;

production chemical injection;

instrument air; and

nitrogen generation.

All of these packages are considered to represent mature technology, in particular the water demineralisation and sewage treatment systems. Instrument air compressors and nitrogen generation are also widely used technologies. Whilst the chemical injection facilities and water treatment systems have some fire potential, these are considered to present a low risk.

The requirement for formal HAZOP of these systems beyond the initial examination (prior to availability of vendor information) is to be defined. A review of interfaces will always be performed.

As well as the production sites, the intrafield and product export pipelines will be subject to HAZOP review. The reviews will take account of the effects of such occurrences as the shutdown of import and export facilities on the operation of the pipeline systems. HAZOP of the export pipeline is outside SPBV scope of work, however, principal interfaces and interactions will be reviewed.

Any change to the process design following the HAZOP studies will be assessed for their impact on the HAZOP findings and the requirement for re-examination. Design Change Notices (DCN) will be reviewed for scope and impact when assessing the requirement for revisiting HAZOPs. Major process changes will, in principle, always be revisited.

4.3.9Environmental Impact AssessmentAll of the sites and facilities in the development (wellheads, infield pipelines, main processing plant) have the potential for environmental impact by some means, either during construction, commissioning or normal operation. For the wellheads, workover operations must also be considered. In the case of the production sites, gaseous and liquid discharges will occur both as a result of normal production (e.g. turbine exhausts, vents) and emergencies (flaring and high venting rates, albeit for a limited duration).

An environmental impact assessment has been performed on behalf of LOPL during the FEED phase and presents binding requirements with regard to emissions from the facilities in the development and waste management strategies. It will be necessary to ensure that emissions, in all forms, remain within these limits. An emissions summary will be prepared and maintained and the requirements of the FFED Environmental Impact Mitigation Plan implemented via the HSE Design Philosophy.

The purpose of the environmental impact assessment activities to be performed is therefore:

to provide an auditable trail of environment-related decision making by identifying the principal sources of emissions and documenting the technology employed to abate/mitigate them, as well as the reasons for their selection and alternatives considered;

To quantify emissions as far as possible, to ensure that project and statutory discharge limits are met (this will involve modelling of vents and flares to establish ground level concentrations, also noise);

to recommend, where appropriate, measures to improve the environmental performance of the plant;

to provide sufficient information for the development of a suitable waste management system.

Other environment-related activities during detailed design will be related to the design of waste water treatment systems (storm water, produced water, contaminated water from bunded areas) where it will need to be ensured that the performance of those systems, as a minimum, are such that emissions estimated for the acceptance of the initial Environmental Impact Assessment are not exceeded.

A quantity of contaminated water and other waste materials will be generated during construction and commissioning (commissioning of the pipelines and flowlines, for example, will result in a considerable volume of contaminated water), with the attendant potential problems of noise, dust and traffic. These issues are not considered in this document and will be considered in the specific Construction HSE Plan for these construction activities.

Issues raised during the FEED which require resolution during detailed design will be managed via the Action Tracking Register (see Section 4.4). This will apply also to issues relating to construction waste management.

4.3.10Definition of Risk Assessment RequirementsRisk assessment activities during the detailed design will be sufficient to satisfy all contractual and statutory obligations, whilst providing sufficient information to demonstrate that agreed identified safety goals have been met and assist in decision-making. Risk assessment activities will be based upon the preliminary hazard assessments performed during the basic design.

Risk assessments will be performed for the wellhead sites, gathering system and main processing plant. Risk criteria and acceptance criteria will be agreed with LOPL. Risks will be presented in terms of fatal risks only, both to the operations personnel and inhabitants of the site accommodation and industrial facilities adjacent to the main processing plant. Risks to drilling personnel during well workover operations will not be evaluated (not in SPBV scope).

4.3.11SIL Classification ReviewThe functional safety requirements of electrical, electronic and programmable electronic safety-related systems will be established in accordance with IEC 61508. The requirements will be expressed in terms of a Safety Integrity Level (SIL) for each system.

The objective is to provide a formal but qualitative risk based approach to the assessment of process hazards and the degree of risk reduction required to bring them to a tolerable level. The methodology employed will cover the complete loop from sensor to actuating device and will include techniques to validate that the required risk reduction has been achieved. The methodology to be employed is detailed in SPBV Corporate Procedure OPR/QUAL/458, however the chairman will be provided by LOPL.

The method may be used to optimise the design of protection systems against potential hazards based on a knowledge of the consequences of failure. It also provides a basis for implementing a testing strategy that achieves a minimum reliability target for the loop, that is dependent upon the associated hazards.

4.3.12Availability and ReliabilityAn availability assessment will be performed for the facilities in the development within SPBV scope of work. This will validate the sparing philosophy adopted for major equipment items such that the necessary plant availability is achieved. Vendors of major equipment items will be required to provide reliability data for their equipment in order that an accurate model is developed.

Availability and reliability assessments will be performed according to SPBV Corporate Procedure BDP/QUAL/1490.

4.3.133-D Model ReviewThe model of the plant will be reviewed in detail to confirm that the distances between equipment and the access for cranes and emergency vehicles have been provided. As this review takes place much later than the Plot Plan Reviews, the subsequent detailed design and piping layout can be checked to see that it has not encroached on the access routes previously specified.

The review will be performed according to SPBV Corporate Procedure OPR/ENDP/346.

4.4Management and Tracking of HSE Activities and Actions4.4.1The various studies and reviews described in the preceding sections will give rise to a number of recommendations, findings and actions. Some will require incorporation into the developing design, others will feed forward into construction and commissioning. HAZOP actions, for example, are monitored by the governing procedure, as resolution and tracking of actions is a normal part of the process. However, some recommendations and actions might relate to issues in the future (e.g. commissioning) or to documents yet to be prepared (.e.g operating manuals). In addition, there are a number of outstanding actions arising from the various reviews and studies performed during the FEED which will require identification, review and closing-out. A mechanism is required to permit close-out of the original studies (of all types) whilst ensuring that these final few actions remain live until they too can be closed-out. In order to achieve this, a tracking register will be maintained, to which study actions (from all sources) can be transferred if they cannot be promptly resolved.

4.4.2The purpose of the tracking register is to identify not only the outstanding actions but also the responsible discipline/organisation, the current status (open,closed) and a reference. The register will comprise two parts:

The register itself, which will act as a simple summary of actions and status; and

For each action, a response sheet will be prepared indicating the action, project response and confirmation by an identified responsible person that the action has either been fulfilled (incorporated into the design or design documentation) or that it has not, in which case the response shall indicate why. Confirmation of implementation shall mark the action as closed.

4.4.3The process is similar to that employed for HAZOP actions, which will form the majority of the items tracked, however it is intended to be sufficiently flexible to permit input from other studies where prompt resolution, for whatever reason, is not possible. The proforma register and action response sheet are presented as Figures 4.1a and 4.1b.

4.4.4It is possible that some actions will fall to LOPL or other outside bodies to resolve, for example, safety management or operational issues and the resolution of these might be outside the involvement of SPBV in the development. In this case, the ownership of the register will transfer from SPBV to LOPL at the end of SPBV involvement, however, all actions shall be closed by this time.

4.4.5Operation of the register is illustrated in Figure 4.2. Periodically, registered actions will be reviewed to establish whether the situation is now such that the action can be followed-up and closed-out. Responses shall be prepared on the Action Response Sheet attached (Figure 4.1b). The person preparing shall sign and where actions involve SPBV, the response shall be approved by the SPBV Engineering Manager. Completed action response sheets will be returned to the HSE Supervisor who will own the register and maintain related records. Prior to the action being closed out on the register, it shall be confirmed that the action has been performed as indicated in the response by the person implementing it.

4.4.6The Action Tracking Register is intended not only to manage long-term HAZOP actions but any safety-related issues which might arise during the project for which positive confirmation of close-out is required. The register will be available to assist in the management of these issues but some discretion will be required to ensure that a large number of minor issues are not accumulated.

4.4.7HAZOP and other actions/recommendations shall be uniquely numbered for maintenance of the action register. Originating references (e.g. HAZOP action numbers) shall be indicated for cross-reference. Action numbers shall be sequential, according to facility involved. The register is intended to act as a simple summary of action status; the action response sheet is considered to be the key document and this shall be employed to collate all signatory approvals.

4.5Construction and Commissioning4.5.1The Project HSE Plan describes the overall safety management system to be employed on the project during both the detailed design and during construction and hence how performance at the construction site will be reviewed in a structured manner (see Section 4.2). Specific construction HSE issues will be covered in the separate Construction HSE Plan. This will detail the management measures necessary during construction, i.e. procedures covering the welfare, health, sanitation and safety of employees:

HSE inspection and monitoring;

Accident reporting and investigation;

Hazard management and job risk analysis;

Emergency planning and response;

Environmental management

4.5.2In order to effectively manage the construction activities, a number of procedures covering safe working practices, environmental requirements and security will be prepared.

4.5.3It is possible that there will be issues arising from design reviews and other activities from both FEED and detailed design which will directly affect the construction and commissioning phases, the latter particularly during the initial startup. These issues, which might be recommendations from HAZOPs or model reviews, for example, will be fed forward into the documentation for later work such as:

operating manuals;

precommissioning instructions;

commissioning instructions; and

startup instructions

Incorporation of such recommendations and requirements will be according to the procedure governing the originating study, together with follow-up and close-out.

Table 4.1 HSE Activities A3 format

Philosophy/Basis of Design

OwnerOutput

(Document)Comments

HSE Design BasisSERD00-ZA-E-09529General document covering wellheads and main plant. Requirements for layout, fire protection etc

Equipment Noise LevelsMECH00-MA-E-30009Requirements for noise and noise control of equipment

Emergency Shutdown PRC00-ZA-E-04009Definition of shutdown levels, systems and interactions

Relief and BlowdownPRC00-ZA-E-04005Flare/relief design basis for all field facilities

Valving & IsolationPRC00-ZA-E-04002

Process Control & OperatingPRC00-ZA-E-04007

Explosion ProtectionSERDN/ARequirements for protection by layout detailed in HSE Design Philosophy. Blast loads defined by Hazard Assessment studies

Table 4.2 Principal HSE Design Philosophies

Figure 4.1a action tracking register A3 format

BHIT FIELD DEVELOPMENT PROJECT

ACTION RESPONSE SHEET

Action Reference No. _______Sheet 1 of ___________

Action/Recommendation:

Date Raised: __________

Reference (Meeting/Drawing No./Document/Study*):

* including originating action reference, if any

Response Required From (Discipline) _______________ By (Date): __________

Response Completed By:

Name: ___________________ Signature: ____________________ Date: __________

Response/Action Proposed:

Action

Agreed as above/Rejected/Other*

(* delete as applicable)

Action AgreedSPBV PEM (if applic.) : ____________________Date: _______

LOPL : _________________________________

Date: ________

Action Implemented:Signature __________________________Date: ________

Reference (Document, etc):

Figure 4.1 - Action Response Sheet

Figure 4.2 - Operation of Action Tracking Register

5.PROGRAMME5.1HSE activities during detailed engineering are detailed as part of the Project Overall Contract Programme, Document 00-ZB-09011. During engineering, HSE activities will be an integral part of the scope of work and scheduled to provide the necessary flow of information and review findings at the earliest stage into the ongoing design.

5.2The relationship between HSE activities during detailed engineering design and into construction is shown in Figure 5.1. The flow of information and findings, with feedback into the ongoing design, assumes a largely frozen design and prompt resolution of outstanding issues. Late design changes have the potential for further feedback points in the design cycle, which might warrant reopening and repeating studies previously completed.

Figure 5.1 flowchart of HSE activities

6.HSE DOCUMENTATION6.1Principal HSE-related documentation produced during the detailed design, construction and commissioning phases of the project will include:

Design & Construction HSE Plans;

Initial Process Safety Review Report;

Hazard Assessment Study;

Plot Plan Review (minutes of meeting);

Area Classification Review (minutes of meeting);

P&ID Design Review (minutes of meeting);

Hazard and Operability Study Report;

Environmental Impact Assessment (mitigation plan and emissions summary);

Quantified Risk Assessment;

SIL Review Study;

3D Model Review (minutes of meeting);

HSE Management Reviews (minutes of meeting);

Action Trading Register and Close-out Report;

6.2 The many HSE activities performed during detailed engineering and during construction will be drawn together in an overall Project HSE Dossier. The Project HSE Supervisor will be responsible for the assembly of the HSE Dossier.

PART 2 HSE PLAN CONSTRUCTION ACTIVITIES

1.INTRODUCTION

This Health, Safety and Environmental (HSE) Plan is designed to give direction and guidance to the Managing Contractor Project Management Team of Aquater during Construction and Commissioning phases of the Lasmo (referred to as the Company), Bhit Gas Field Development project.

In addition to this HSE Plan, each contractor shall prepare and submit his own project specific HSE Plan for approval by the Managing Contractor/Company.

LASMO Oil Pakistan Ltd is developing the field within the Kirthar region of the Sindh Province of Pakistan. The development of the site includes the erection of gas gathering and process plant facilities on and adjacent to the Bhit Mountain. The object of the plan is to provide an overview of the methods adopted by the company to ensure that the project complies with statutory, contractual and company requirements with respect to safety, personnel health and the environment. It also demonstrates how HSE activities are integrated with the development and verification of the design.

The Bhit field was discovered in early 1997 and is located approximately 180 kilometres north east of Karachi, within the Kirthar Concession Block. The field is estimated to contain 1.4tcf of hydrocarbon gas with the potential of producing at rates of up to 400mmscf/d. The gas is to be gathered from the various well locations and routed to the Bhit Process Plant. At the Bhit Process Plant produced water will be removed from the gas stream and treated. The gas will require CO2 removal and dehydration prior to passing to the Nitrogen Rejection Unit (NRU). Also significant gas compression will be required due to the low pressure of operation for the NRU. The complete scope of work will include flowlines, gathering lines, process plant, export pipelines and metering facilities. The gas will be exported to tie in with the existing SSGC (Sui Southern Gas Company) Indus Right Bank Line (IRBL) approximately 30 Km from the plant (the existing pipeline supplies gas to Karachi).

The field development facilities covered include:

Wellsites;

Interconnecting flowlines and pipelines;

Gas processing plant at the foot of the Bhit Mountain.

2.APPLICABLE REGULATIONS, CODES AND STANDARDS

Environmental CodesInternational

Basle Convention 1989 - Convention on the Control of Transboundary Movements of Hazardous Waste and their Disposal

Montreal Protocol 1987/1990 - Substances that Deplete the Ozone Layer

Pakistan National RegulationsPakistan Environmental Protection Ordinance (1983). The provisions established National Environmental Quality Standards (NEQSs) gazetted as Statutory Notification Aug 29th 1993.

Pakistan Environmental Protection Ordinance (No. XXVII) February 1997.

The Pakistan Penal Code.

The West Pakistan Regulation and Control of Loudspeakers and Amplifiers Ordinance 1965

The Factories Act 1934 (Section 14 - Waste Disposal))

The Sind Local Government Ordinance 1979

The Explosives Act 1884

The Environmental Impact Assessment Guidelines for the Pakistan Energy Section (Nov 1991)

Guidelines for the Safety, Health and Environmental Management in Pakistan

Petroleum Exploration and Production Sector

The Regulation of Mines and Oilfields and Mineral Development (Govt Control) Act 1948

The Oil and Gas (Safety in Drilling and Production) Regulations 1994

Wild Birds and Animals Protection Act 1992

West Pakistan Wildlife Protection Ordinance 1959

Wildlife Protection Rules 1960

Forest Act (No. XVI) 1927. The Forest Act (several notifications fall under this heading) Protection, regulation of exploitation, includes protected forests

Land UseThe Easement Act (No. V) 1882, Law Easements and Licences

Transfer of Property Act 1882

The Land Acquisition Act 1894

Government Grants Act 1895

West Pakistan Land Reform Rules 1959

West Pakistan Land Reform Regulations 1959, MLR No. 64

Consolidations of Holdings Ordnance (No. VI) 1960

West Pakistan Land Reforms (Ejectment of Tenants to provide for Buildings) Rules 1969

Land Revenue Act 1967, Rules 1966 Assessment Rules 1968

West Pakistan Land Revenue (Conferment of Rights of Ownership) Rules 1969

Land Reform Regulations 1972 (Repeals 1959 Regulation)

Land Reforms (Amendment) Act 1973

Land Reforms (Amendment) Act 1974

Procedure for Ejectment Suits Rules 1974

Land Reforms (Amendment) Act 1975

Board of Revenue instructions about colonisation operation (Standing Order No. 67 date uncertain)

Labour Laws (Amendment) Ordinance 1972

API 5LSpecification for Linepipe

API RP 1102Steel Pipelines crossing Railroads and Highways

ASME B31.8Gas Transmission and Distribution Pipeline Systems

IP Part 6Model Code of Safe Practice in the Petroleum Industry Pipeline Safety Code

Civil Codes and StandardsBS 1722Fences - Anti-intruder fences in chain link and welded mesh

Part 10

BS 1722Fences - Steel palisade fences

Part 12

BS 5228Noise and vibration control on construction and open sites

Mechanical Codes and StandardsBS 3923Methods for ultrasonic examination of welds

BS 4515Specification for welding of steel pipelines on land and offshore

ASME B31.3Process Piping

ASME IXWelding and Brazing Qualifications

API 6FAFire Test for Valves

API RP 520Sizing, Selection and Installation of Pressure Relieving Devices in Refineries

API RP 521Guide for Pressure Relieving and Depressuring Systems

API 1104Welding of Pipelines and Related Facilities

MSS SP 44Steel Pipeline Flanges

MSS SP 75High Test Wrought Butt Welding Fittings

NACE MR 0175Sulfide Stress Cracking

Instrument/Electrical/Cathodic Protection CodesBS 1133Packaging code

Section 6Protection of metal surfaces against corrosion during transport and storage

BS 1710Specification for identification of pipelines and services

BS 3900Methods of test for paints

BS 4652Specification for zinc-rich priming paint (organic media)

BS 4800Schedule of paint colours for building purposes

BS 5345Selection, Installation and Maintenance of electrical apparatus for use in potentially explosive atmospheres

BS 5378Safety signs and colours

BS 5493Code of practice for protective coating of iron and steel structures against corrosion

BS 5501Electrical apparatus for potentially explosive atmospheres

BS 5750Quality systems

BS 6651Code of Practice for protection of structures against lightning

BS 7079Preparation of steel substrates before application of paints and related products

BS 7361Cathodic protection

BS 7430Code of practice for earthing

BS 7671Requirements for electrical installation. IEE Wiring Regulations 16th edition

BS EN 60529Degrees of protection provided by enclosures (IP Code)

IP Part 1Model Code of Safe Practice in the Petroleum Industry Electrical safety code

IP Part 15Model Code of Safe Practice in the Petroleum Industry Area classification code for petroleum installations

IEC 60331Fire-resisting characteristics of electric cables

IEC 60332-3Tests on electrical cables under fire conditions

ASTM B418Specification for Cast and Wrought Galvanic Zinc Anodes

ASTM G42Test Method for Cathodic Disbonding of Pipeline Coatings subjected to Elevated Temperatures

DIN 30670Polyethylene Sheathing of Steel Tubes and of Steel shapes and Fittings

ISO 8501Preparation of steel substrates before application of paints and related products - Visual assessment of surface cleanliness

ISO 8502Preparation of steel substrates before application of paints and related products - Tests for the assessment of surface cleanliness

US MIL-A-18001KAnodes, Corrosion Preventive, Zinc, Slab, Disc and Rod Shaped

Safety Codes - Statutes and RegulationsBS 3481Flat lifting slings

BS 5228Noise and vibration control on construction and open sites

BS 5306Fire extinguishing installations and equipment on premises

BS 5378Safety signs and colours

BS 5499Fire safety signs, notices and graphic symbols

BS 5607Code of practice for the safe use of explosives in the construction industry

BS 5930Code of practice for site investigations

BS 6164Code of practice for safety in tunnelling in the construction industry

Health & Safety at Work Act - 1974

Management of Health & Safety at Work Regulations - 1992

The Provision and Use of Work Equipment Regulations - 1992

The Factories Act - 1961

Abrasive Wheels Regulations - 1970

The Lifting Plant & Equipment (Records of Test & Examination etc) Regulations - 1992

Electricity at Work Regulations - 1989

Health & Safety (Display Screen Equipment) Regulations - 1992

Personal Protective Equipment Regulations - 1992

Power Press Regulations - 1965

Pressure Systems & Transportable Gas Containers Regulations - 1989

Woodworking Machines Regulations - 1974

Workplace Health, Safety & Welfare Regulations - 1992

Construction, Design & Management Regulations

MiscellaneousCIRIA Report 97Trenching Practice

Safety Supervisors Booklet (RoSPA)

BS EN ISO 9001Quality systems. Model for quality assurance in design, development production, installation and servicing

3.HSE GOALS

The Managing Contractor (Aquater) and subcontractors employed on this project shall adhere to all the applicable rules, regulations and guidelines issued by the Pakistan Government (Workers Safety, Health and Welfare laws contained in Mines Act 1923) and UK Government (Referenced in Snamprogetti Safety, Health and Environment procedure POL/QUAL/102).

The objective is to complete the Gas Field Development project fully embracing its zero accident tolerance philosophy and achieving its target of zero injury or illness cases, lost time or not, zero fatalities and zero incidents of a nature that damage the environment, property or equipment. The target will be to strive to achieve 100% of the project job hours being accident or incident free.

The performance toward the achievement of the target of zero will be tracked using the following indicators:

Cumulative safe hours (safe hours are hours worked without an accident or incident)

Number of lost time injury-free workhours

Number of lost time injuries

Lost time injury frequency

Number of incidents (non-injury, no-material damage)

Basic and immediate cause

4.HSE PROCEDURES

Relevant Snamprogetti procedures are:-

POL/QUAL/102Safety, Health and Environment

OPR/SRD/351Safety Audit

OPR/CSOB/373Construction SHE

OPR/HRF/466Office Safety, Health and Environment

COP/CSOB/2713Site Safety

Project specific HSE Procedures are detailed in Section 7.

5.HSE functions, RESPONSIBILITIES AND COMPETENCY REQUIREMENTS5.1

Individual and Group ResponsibilitiesManaging Contractor Manager

Carries the responsibility and overall accountability for Managing Contractor HSE Programme execution

Leads the Managing Contractors Project Team as it meets the overall objectives of the HSE Programme

Contributes details as necessary to the Programme

Ensures all subordinates including line management and supervision maintain ownership of elements of the HSE Programme and safety performance

Ensures that Managing Contractor manual and non-manual individual employee performance appraisal includes significant evaluation of the employees commitment and performance contribution to the Zero Accident Tolerance and overall to the HSE Programme.

Managing Contractor Site Representative

Is responsible for all construction activities including overall health, safety and environmental quality and performance.

Assumes the leadership role in the HSE process.

Sets the prime example of executing the work with full dedication to Zero Accident Tolerance

Ensures that all Managing Contractor line management and supervision conduct their duties in a manner which supports the Zero Accident Tolerance philosophy

HSE Manager (Head Office)

Provides professional direction and guidance to the Site HSE Supervisor/Managing Contractor Site Representative.

Ensures necessary reviews, and updating of the HSE Plan

Ensures that the project receives the HSE services that it requires, and maintains awareness of the project management's and Company evaluation of that service

Verifies that HSE personnel assigned to the project are suitably qualified by education, training and experience in the type of work involved in this project (as defined by the Company), and experienced in Managing Contractor HSE management systems

Ensures that the site is furnished with project-specific HSE procedures

Inspects, audits and reports on the project HSE programme to senior Managing Contractor and Company project management

Managing Contractor HSE Supervisor

He reports directly to the Managing Contractor Site Representative. He is responsible for the correct application and updating of the health, safety and environmental management procedures.

With his staff he conducts regular inspections of the infrastructure, and of the site in all construction areas, this is to verify that the working and living conditions conform to required standards.

He verifies that safety regulations are in force and that safety equipment is constantly kept in order and properly used. He ensures the day by day HSE education of Managing Contractor and Contractors personnel, and provides for the initial HSE induction. He promotes the co-operation of all staff, supervision and labour personnel involved in construction for incidents prevention.

He manages and supervises the HSE training programmes of Managing Contractor and Contractors. He advises the Managing Contractor Site Representative of required actions to upgrade any substantial working and living conditions. He maintains contacts with local authorities in charge of health and environmental matters.

Through the Managing Contractor Doctor he organises and manages the medical and first aid service and maintains contacts with local hospitals and the relevant medical and local authorities

Prioritises and produces a plan of work for implementing the HSE elements of the HSE Plan

Reports progress monthly, against the implementation schedule, to the HSE Manager (Head Office)

Reports to the Managing Contractor Site Representative on actual implementation progress compared with the schedule on a monthly basis

Establishes and maintains a professional relationship with the Company's HSE personnel and promotes the 'Zero Accident Tolerance' philosophy

Establishes and maintains a professional relationship with Managing Contractor's HSE personnel. Directs, manages and trains the safety staff as necessary to attain HSE management standards demanded by the Managing Contractors HSE programme

Trains local hire HSE personnel and Company's HSE personnel as directed

Receives professional guidance from the HSE Manager (Head Office)

Carries out professional safety and occupational health duties as required by the Site HSE Supervisor

Provide the professional oversight, guidance and resources to line management and supervision to ensure Managing Contractor achieves safety objectives and target of Zero Accidents/Incidents

Contractors, Vendors (on site)

Shall demonstrate satisfactory knowledge of Managing Contractors and Companys HSE requirements

Shall comply with all requirements of Managing Contractors and Companys HSE programme appropriate to their contract

Shall co-operate fully with Site HSE Supervisor and supervisors

Shall provide the Site HSE Supervisor with required information for the Managing Contractor Safety Statistics Monthly Return

5.2Individual and Group Qualifications5.2.1Safety Supervisor QualificationsThe Safety Supervisor shall:

Be knowledgeable in the specific relevant safety techniques for the areas of his specific job assignment

Possess the ability to communicate readily with supervisors and the workforce

Demonstrate a minimum of 5 years work experience in his stated field which shall be related to the activities carried out under this work

Demonstrate the ability to communicate in written and spoken English at the Company supervisor level

Provide evidence of the ability to conduct safety audits

Provide evidence of a proven training ability in accident prevention

Provide evidence of ability in conducting hazard assessment and analysis and leading line management and supervision in such processes

Preferably holds one or more certifications as an HSE professional (e.g., IOSH, DIPSM, RSP, CSP, CIH, CHMM, etc.)

5.2.2Company Requirements for HSE Department Staff

Managing Contractor shall submit curriculum vitaes of all HSE Department positions to the Company for acceptability.

Managing Contractor shall maintain and provide to the Company means of contact during and outside working hours for the Site HSE Supervisor, Safety Supervisor and medical staff.

5.3

Liaison with the Company5.3.1 Managing Contractor HSE Supervisor

Site HSE Supervisor shall:

promptly and comprehensively respond to all reasonable HSE requests by the Company

immediately notify the Company of any safety- or health-related off-normal incident involving personnel, equipment, property, environment, cost or schedule

as a minimum, supply a written HSE programme and monthly reports on the programme's progress, all information on incidents, investigations and analyses generated on-project.

5.3.2Managing Contractor Site Representative shall invite involvement of the Company in the HSE incentive awards programme and the HSE milestones award programme

6.

HSE MEETINGS6.1Responsibilities6.1.1Managing Contractor Manager Shall, with the HSE Manager (Head Office), ensure the Managing Contractor Site Representative commits schedule and resources for safety meetings as required in this plan or otherwise deemed necessary by the Contract Manager

Shall ensure that HSE elements be a regular agenda item at senior project management meetings

6.1.2Managing Contractor Site Representative Shall, in concert with the Site HSE Supervisor, ensure the line management and supervisors commit schedule, personnel and resources for safety meetings as required in this plan or otherwise deemed necessary by the HSE Manager (Head Office) Shall participate and contribute actively in site as well as project management safety meetings Shall ensure that line management and supervisors participate, contribute actively and exercise leadership in their respective individual and collective project safety meetings Shall ensure that HSE elements be a regular agenda item at site management meetings

Shall ensure that the scheduled safety meeting occur

6.1.3Site Line Management and Supervision Shall ensure that the workforce under their direction attend, participate and contribute actively to their respective safety meetings Shall ensure that all scheduled safety meetings under their purview occur Shall conduct unscheduled safety meetings as necessary at their own discretion or as directed by the Site HSE Supervisor.6.1.4Site HSE Supervisor Shall audit to ensure specific dedicated meetings e.g. Foremans HSE Training Meetings and Tool Box Meetings are conducted and shall review for content, participation and effectiveness

Shall support supervisors and foremen with specific meeting format and content as necessary

Shall generate a monthly log of meetings scheduled, meetings held, topics and attendance and submit the log to the HSE Manager (Head Office) , Managing Contractor Site Representative and the Company

6.2 Schedule of Safety Meetings

Safety meetings shall be conducted, at a minimum, according to the following schedule.

Safety Meeting TypeFrequency*Attendance

Company Managing Contractor KickOff Safety Meeting1Company, Contract Manager, HSE Manager (Head Office), Contractor Site Rep, Construction Manager, Site HSE Supervisor

Pre-Mobilisation Safety Meeting1Company, Contractor Site Rep, Construction Manager, Site HSE Supervisor.

Pre-Construction Safety Meeting1Company, Contractor Site Rep, Construction Manager, Site HSE Supervisor.

Managing Contractor Contractor** Pre-Bid SM1Procurement Manager, Site HSE Supervisor/Supervisor, Contractor HSE Supervisor.

Managing Contractor Management Safety MeetingQuarterlyCompany, HSE Manager (Head Office), Contractor Site Rep, Construction Manager, Site HSE Supervisor.

Managing Contractor Steering CommitteeMonthlyCompany, Managing Contractor Site Rep, Construction Manager, Site HSE Supervisor, Contractors.

Foremans Safety MeetingsMonthlySite HSE Supevisor and Foremen

Site Management Safety MeetingsWeeklyManaging Contractor Site Rep, Managers, Superintendents, Engineers and Co-ordinators

Workforce Tool Box Safety MeetingsWeeklySite HSE Supervisor/Supervisor and Workforce

Task/Craft-Specific TalksTask Start***Site HSE Supervisor/Supervisor and Taskforce

*Scheduled minimum frequency

**Includes Vendors and Suppliers on site

***Or as frequently as necessary

6.3

Managing Contractor-Contractor Pre-Bid Safety MeetingsManaging Contractor procurement will conduct a pre-bid meeting with all prospective Contractors, vendors or suppliers to ensure their understanding of the HSE programme requirements on the project.

Based on the complexity or potential hazard, the Site HSE Supervisor (or the Safety Supervisor) as well as the Managing Contractor Site Representative (or designated superintendents) may be elected to attend.More than one pre-bid meeting may be conducted as necessary for a given service or product.

The agenda shall include:

Review of Managing Contractor HSE programme

Chain of command for HSE issues

HSE requirements of the Contractor, vendor or supplier

Contractor, vendor or supplier questions

Managing Contractor-generated issues

In addition, the following points should be covered: Environmental considerations

Climotological and seasonal considerations

Local health hazards

Technical and safety training program

6.4Managing Contractor Management Safety MeetingsThese Meetings shall be initiated by the Managing Contractor Site Representative and the HSE Manager (Head Office) and occur quarterly. They shall include site and non-site Project level representatives of the Managing Contractor and the Company and include construction as well as HSE representation.

The agenda shall include:

Answers obtained to questions unanswered at the last meeting

Accident narrative reports, statistics and analyses

Review of HSE programme developments and on-going items

Company-generated issues

Managing Contractor-generated issues

Meeting minutes and an attendance roster shall be generated

6.5Foremens HSE Safety MeetingsRegular monthly meetings shall be held to brief foremen on the HSE programme and include their involvement in it. The meetings shall provide a mechanism for foremen to make their contribution to the HSE policy and programme. Special meetings shall be held as required.

The Site HSE Supervisor shall organise the meetings. He shall prepare an agenda and a written summary of each meeting highlighting the major discussion items, and unresolved issues.Standing items will be:

Answers obtained to questions unanswered at the last meeting

Accident narrative reports, statistics and analyses

Review of HSE programme developments and on-going items

Foremen's questions, point of view

Planned safety and health topic relevant to current work

Ensure those present sign to record their attendance

Arrange for special meetings to be held as necessary, for example to brief foreman on significant programme developments

6.6

Managing Contractors Steering CommitteeManaging Contractor shall initiate and maintain a steering committee on site with the primary function and mandate for HSE Programme implementation quality assessment. The steering committee shall be chaired by a member of the senior management.

The Managing Contractor Site Representative shall appoint a member of the site construction management team to co-chair the Managing Contractors Steering Committee.

Representatives shall be selected from a cross section of the workforce and job sites.

The committee shall meet on a monthly basis.

Primary meeting agenda is the quality assurance assessment of site safety activities with a special emphasis on the safety meeting and hazard identification and analysis activities.

Recommendations from the committee shall be provided to the Managing Contractor Site Representative and HSE Manager (Head Office).

6.7Site Management Safety MeetingsManaging Contractor Site Representative sponsors and co-ordinates this meeting.

Managing Contractor Site Representative, Companys Representative, Site HSE Supervisor, other line management including all Superintendents will attend the meetings. Medical staff should also attend.

The meeting is conducted weekly.

Standing items will be:

Answers obtained to questions unanswered at the last meeting

Accident narrative reports, statistics and analyses

Review of HSE programme developments and on-going items

Staff questions, point of view

Planned safety and health topic relevant to current work

6.8

Workforce Tool Box TalksThese talks will be topical and weekly.

The Site HSE Supervisor shall ensure that supervisors and their foremen are:

Conducting Tool Box Talks with their crew each week using their own and/or material furnished by the Site HSE Supervisor.

Providing employees with the opportunity to ask questions regarding HSE issues and providing responses to these in a timely fashion

Having all attendees sign the HSE meeting report form during the meeting

Submitting a completed Tool Box report form to the general foreman or lead supervisor/manager for review and action, then to the superintendent for review and action if required, and finally to the Site HSE Supervisor.

The Tool Box Meeting Format shall be:

Answers to questions raised at the last meeting

HSE programme developments

Significant accidents or near misses

Topic/work for the day

Questions

Specific Hazard Identification

Specific Hazard Analysis

6.9

Craft-Specific Safety Meetings and Task Team TalksThese talks will be task specific and take place before each safety critical task.

Site HSE Supervisor shall assist the Superintendents and line management with the Task- and Craft-specific meetings.

Task Team talks will be held by the Supervisor in charge of the work before each new task is started.

These meetings shall focus on:

Specific Hazard Identification

Specific Hazard Analysis

Specific procedures for work at hand

Specific instructions unique to work at hand

Hazard Control and Analysis sheets referenced in Section 11 and presented in Appendix A of this HSE Plan shall be used as the main subject for the meeting.

Any questions generated pertaining to the hazard analysis shall be answered prior close of meeting.

Attendees shall sign the training form.

6.10Tool Box Attendance and Meeting Participation Quality MeasurementIn addition to the management system assessment tools in the Managing Contractors HSE Manual, the following assessment shall be carried out by the Managing Contractors Steering Committee :

Review meeting minutes and attendance of the previous fortnights safety meetings.

Review any new Hazard Control and Analysis sheets prepared since the last meeting.

Interview randomly selected workforce members regarding efficacy and applicability of the safety meetings they have attended. In particular they shall note:

-Responses where an employee had an unanswered question from a safety meeting

-Minimal participation by individuals in the safety meeting process

-Cases of poor attendance

-Any other issues noted

Prepare a list of concerns and recommended actions and submit to the Managing Contractor Site Representative and Site HSE Supervisor for action.

7.

HSE AT WORK SITES7.1

GeneralA complete set of HSE procedures has been prepared for site-based activities to complement the Company safety procedures and in particular have been developed to include the following requirements:

Adherence to local safety and environmental protection legislation and company policies.

Adherence to the safety rules and procedures included within Company Safety Manual, Operators Safety manuals and other Company procedures and regulations.

Provision of a safe working environment for all personnel engaged on the project construction sites.

Preparation by the Managing Contractor of procedures which will ensure the safe performance of hazardous jobs by requiring the issue of appropriate work permits, the briefing of personnel involved in any activity with regard to the identification and avoidance of potential hazards and by providing adequate supervision for the work.

Details of the Managing Contractors safety organisation structure detailing responsibility of the Managing Contractors and associated scope Managing Contractors line management and safety personnel with respect to safety, health, loss control, security and environmental protection.

Project safety induction and orientation will be carried out by Company for all personnel prior to commencing work on site. Ongoing training will take place as required by the contract and to meet the particular needs and safety performance of the project.

The project HSE plan will provide for co-ordination with Company in all related issues including emergency procedures, plant warning systems, assembly points and the reporting of accident and incidents including near misses.

Adherence to Company permit to work system and the use of Company standard forms for project work inside plant areas and near pipelines. Audits will be regularly conducted by Company on the permit to work system in operation.

Routine inspection of first aid services provided for Managing Contractor and associated scope Managing Contractor personnel.

Routine checking of fire fighting and safety equipment to ensure its correct functioning.

Measures to ensure that all personnel wear proper site clothing and apparel. Personal Protective Equipment (PPE) will be of a standard acceptable to Company.

An accident/incident investigation and reporting procedure to ensure that necessary measures to prevent the re-occurrence of similar incidents are implemented.

The provision of assistance to Company in handling claims for accidents sustained by employees of third parties working on the project.

Enforcing safety regulations.

Maintaining safety records.

Reporting to Company upon the planning and implementation of measures to be taken to ensure safe construction on the site.

The complete listing of procedures is as follows:

00-ZA-E-09500Heavy Lifts and Equipment Erection Specification

00-ZA-E-09501Lifting Equipment Specification

00-ZA-E-09504Lifting Operations

00-ZA-E-09505Fire Prevention

00-ZA-E-09506Housekeeping

00-ZA-E-09507Warning Signs and Barriers

00-ZA-E-09508Control and Use of Plant and Equipment

00-ZA-E-09509Personal Protective Equipment

00-ZA-E-09510Road and Traffic Safety

00-ZA-E-09511Disciplinary Procedures

00-ZA-E-09512Emergency Response

00-ZA-E-09513Waste Management

00-ZA-E-09514Hazardous Material

00-ZA-E-09515Working at Height

00-ZA-E-09516Temporary Electrics

00-ZA-E-09517Excavation

00-ZA-E-09518Noise

00-ZA-E-09519Heat Stress

00-ZA-E-09520Night Working

00-ZA-E-09521Welding Operations

00-ZA-E-09522Scaffolding

00-ZA-E-09523Permit to Work

00-ZA-E-09524Accident Investigations, Follow-Up Procedure

00-ZA-E-09525Hazard Analysis and Control Programme

00-ZA-E-09526Impact Assessment Tool

00-ZA-E-09542Radiation

00-ZA-E-09221Site Security7.2Health and Welfare7.2.1Health and Fitness

Managing contractor and contractor personnel shall ensure (as far as is reasonably practicable) that employees engaged in the work are medically fit and healthy. If necessary the nominated medical officer may approve the employment, on medical grounds, of personnel. The managing contractor and contractors should be able to demonstrate valid vaccination/immunisation records against contagious and epidemic diseases for its employees.

7.2.2Medical Welfare

[4]

Managing contractor, contractor and their subcontractors shall be responsible for the medical welfare of its employees and shall take care of periodical medical examinations, arrangements for medical attendance, treatment or hospitalisation and where appropriate will arrange suitable insurance cover for such contingencies. Company may provide the necessary emergency arrangements to transport any casualties from site to Karachi, from there the responsibility for the casulaty reverts to the Managing Contractor. Where suitable medical arrangements will be made available by the Managing Contractor and Contractors.

7.2.3Hygiene

Personnel, including contractors and subcontractors shall maintain high standards of hygiene in connection with the performance of the work.

7.2.4Camp Standards

Accomodation will be constructed in such a manner as to provide protection against wind, rain and extreme temperatures, and will be adequately screened against insects. A minimum sleeping space of 4m per employee is recommended.

A covered area with an easily cleanable floor covering and capable of accomodating at least half the relevant employee category at any one time will be provided as a prayer area.

8.ACCIDENT REPORTING AND INVESTIGATIONThis is addressed in full in a separate Construction HSE Procedure 00-ZA-E-09524, Accident Investigations, Follow-Up Procedure.

9.HSE INSPECTION AND MONITORINGThe Site HSE Supervisor shall:

Monitor project activities, inspect facilities to ensure that the HSE rules established within the HSE programme are being complied with

Identify hazards inadequately addressed by established procedures and ensure that safe work procedures are developed to deal with them

Report both positive and negative aspects of items revealed by inspection, promptly, in writing and ensure follow-up action

Devise and implement project management 'HSE walks', jointly with purchasers' representatives and Managing Contractors as necessary

Accompany Company HSE inspectors and promptly respond to their reasonable requests

The Contract Site Representative shall promptly action matters arising from the inspections

Contractors shall promptly action matters arising from the inspections and institute their own programme of inspection and monitoring.

9.1

Hierarchy of Inspections and AuditsScheduled inspections and audits shall be conducted by the HSE Department, medical personnel and site construction senior and line management according to the following hierarchy:

Imminently dangerous or hazardous conditions

Accident, incident or near miss follow-up

Company request

Scheduled inspection/audit event

9.2

Joint Company/Managing Contractor AuditsInspections and audit events will be made known to the Company representative. Company personnel shall be encouraged to accompany any inspection or audit event. Joint inspections and audits initiated by the Managing Contractor shall be scheduled for assurance of Company presence. These will be indicated on the schedule prepared by the Site HSE Supervisor to be submitted to Company.

9.3

Managing Contractor Internal AuditsThe Contract Manager shall sponsor periodic (6 to 9 month intervals) internal HSE audits which may be performed by off-project Managing Contractor personnel.

9.4

Programme of Safety Inspections by the Safety SupervisorRoutine daily safety inspections shall be a core component of the Safety Supervisors duties. The scope and areas of inspection shall be dictated by the current work activities. The Site HSE Supervisor shall plan the emphasis of these inspections on a weekly, or more frequent, basis as necessary.

Inspection logs shall be maintained and submitted to the Site HSE Supervisor on a weekly basis. Distribution of the inspection log shall include the Managing Contractor Site Representative and appropriate Contractors, supervisors and foremen.

Follow-up inspections shall be conducted on the appropriate time basis whenever the inspection results in required action items.

9.5

Programme of Safety Inspections by Discipline SupervisionRoutine daily safety inspections shall be a core responsibility of discipline supervision. The scope and areas of inspection shall be dictated by the current work activities. The Site HSE Supervisor and staff shall assist in the planning of these inspections on a weekly basis.

Inspection logs shall be maintained and submitted to the Site HSE Supervisor on a weekly basis. Distribution of the inspection log shall include the Managing Contractor Site Representative and appropriate Contractors, supervisors and foremen.

Follow-up inspections shall be conducted on the appropriate time basis whenever the inspection results in required action items.

[4]9.6

Line Management Inspection/Audit Involvement

[4]Foremen, superintendents and any other discipline supervisors shall, in addition to conduction their required daily safety inspections, participate on a scheduled basis as dictated by the Site HSE Supervisor Inspection and Audit Time Table. Cross disciplinary utilisation of personnel will be emphasised.

9.7

Lessons Learned From Inspection and Audit Results

[4]

Any time the results of an inspection or audit generate information which would enhance the effectiveness of the HSE Programme, such information shall be disseminated via safety meetings and the various communications programmes available under this HSE Plan.

9.8Inspection Time Table

[4]

Being prepared at site.

10.

HSE RECORDING, MONITORING AND REPORTINGThe Site HSE Supervisor shall complete and provide the Company Site Representative the Health & Safety Statistics Monthly Return.

GAS DEVELOPMENT FIELD HEALTH & SAFETY STATISTICS MONTHLY RETURN

To : Company Contract Holder

CONTRACT NUMBER:

NAME of COMPANY

MONTH OF

TOTAL NUMBER of EMPLOYEES

TOTAL NUMBER of MAN HOURS (include. OT)

TOTAL NUMBER of LOST TIME INJURES (LTI) IN MONTH

TOTAL NUMBER of RESTRICTED WORK CASES (RWC) IN MONTH

TOTAL NUMBER of MEDICAL TREATMENT CASES (MTC) IN MONTH

TOTAL NUMBER of MEDICAL FIRST AID CASES (FAC) IN MONTH

TOTAL NUMBER of OCCUPATIONAL ILLNESS (TOI) IN MONTH

TOTAL NUMBER of NON INJURIOUS CAT 1 + 2 INCIDENTS IN MONTH WHICH ARE NOT REPORTED AS ROAD TRAFFIC INCIDENTS

TOTAL NUMBER of NEAR MISSES (NM) IN MONTH

TOTAL NUMBER of ROAD TRAFFIC INCIDENTS (RTA) IN MONTH

NUMBER OF ALL JOURNEYS MANAGED BY A JOURNEY MANAGER

PROPORTION OF JOURNEY PLANS CHECKED BY AN AUTHORISING PERSON

PROPORTION OF NON-COMPLIANCES ON JOURNEY PLANS DISCOVERED

NUMBER OF TIMES A JOURNEY MANAGER HAS NEEDED TO PHONE A LOCATION TO DISCOVER THE WHEREABOUTS OF A DRIVER

MONTHLY DRIVING STATISTICSNO. OF VEHICLESKM DRIVEN

VEHICLES ABOVE 3500 Kg GVW

OTHER VEHICLES

NAMES OF EMPLOYEES WITH LOST TIME INJURIES/RESTRICTED WORK CASES IN MONTH

(NAME)(DATE)

WAS CERTIFIED UNFIT ON

WAS CERTIFIED UNFIT ON

WAS CERTIFIED UNFIT ON

NAMES OF EMPLOYEES CERTIFIED FIT FOR DUTY DURING MONTH FOLLOWING LWC OR RESTRICTED WORK CASE ABSENCE

(NAME)(DATE)

RETURNED TO WORK ON

RETURNED TO WORK ON

RETURNED TO WORK ON

SIGNED

POSITION

DATE

10.1Health & Safety Statistics Monthly Return Notes All returns should relate to the previous calendar month only

The average may be taken as the total number of employees when fluctuations occur

In cases of doubt clarification should be sought from the Company HSE Department

10.2Health & Safety Statistics Monthly Return DefinitionsCategory 1 Fatalities / Permanent Total Disability, damage is in excess of US$ 150,000 (inclusive) or massive environmental impact.

Category 2 Permanent Partial Disabilities, Lost Workday Cases, damage more than US$ 15,000 (inclusive) or major environmental impact.

Fatality (FTL) A fatality is a death resulting from a Work Injury, regardless of the time intervening between injury and death.

First Aid Case (FAC) Any one-time treatment and subsequent observation of minor scratches, cuts, burns, splinters, and so forth, which does not ordinarily require medical care. Such treatment and observation are considered first aid even though provided by a physician or other medical staff.

Lost Time Injuries (LTI)Lost Time Injuries are the sum of Facilities, Permanent Total Disabilities, Permanent Partial Disabilities, and Lost Workday Cases. N.B. If, in a single Incident 20 people receive lost time injuries, then it is accounted for corporate reporting purposes as 20 LTIs (not 1 LTI).

Lost Work day Case (LWC)A Lost Work day Case is any Work Injury/Illness other than a Permanent Partial Disability which renders the injured person temporarily unable to perform any Regular Job or Restricted Work on any day after the day on which the injury / illness was incurred.

Medical Treatment Case (MTC)A Medical Treatment Case is any Work Injury that involves neither Lost Workdays nor Restricted Workdays but which requires treatment by, or under the specific orders of, a physician or could be considered as being in the province of a physician.

Near MissA Near Miss is an Incident which resulted in no injury, illness, damage or product loss. It can have any Potential Severity Rating.

Occupational IllnessOccupational Illness is any work related abnormal condition or disorder other than one resulting from a Work Injury, caused by or mainly caused by exposure at work

Permanent Partial Disability (PPD)Permanent Partial Disability is any Work Injury which results in the complete loss, or permanent impairment, of functions of parts of the body, regardless of any pre-existing disability of the injured member or impaired body function. It is a Lost Time Injury.

Permanent Total Disability (PTD)Permanent Total Disability is any Work Injury which incapacitates an Employee permanently and results in termination of Employment. It is a Lost Time Injury.

Restricted Work Case (RWC)A Restricted Work Case is any Work Injury which results in a work assignment, after the day the Incident occurred, that does not include all the normal duties of the persons Regular Job. The restricted work assignment must be meaningful and pre-established or a substantial part of a Regular Job.

Road Traffic Incidents (RTA)A Road Traffic Incident (Accident) is any Incident involving one or more moving vehicles which results in injuries, and/or damage to property, vehicle(s), or loads being moved or carried by vehicles. For the purpose of Companys Incident Reporting procedures, windscreen damage caused by thrown up road debris e.g. stone chips shall not be statistically reportable unless more serious damage or personal injuries occur as a result.

11.HAZARD IDENTIFICATION, ANALYSIS AND CONTROLThe Managing Contractor Site Representative, Site HSE Supervisor, line management and supervision shall ensure that every work activity performed by the Managing Contractor and its Contractors, vendors and suppliers is executed in a safe and controlled manner. To accomplish this, a hazard identification, analysis and control system has been instituted for every basic activity or type of work conducted. The identification, analysis and control procedures are detailed in Project Procedure 00-ZA-E-09525.

The following basic hazard categories have been identified :

Refined Hydrocarbons Hot surfaces

Other flammable materials in general Hot fluids

Explosives Electricity

Pressure Hazards Electromagnetic radiation

Differences in elevation Radioactive sources in general

Objects under induced stress Non-breathable conditions

Dynamic situations Toxic liquid

Nature Biological hazards

Ergonomic conditions Job/incumbent matching

Starting from this basis a hazard analysis has been performed and relevant control measures identified to reduce the risk as low as reasonably practicable.

Hazard Analysis and Control Programme sheets are provided in Appendix A of this Plan for the following hazard categories in order to :

determine what measures are needed to eliminate, reduce or minimise the likelihood of the release of the hazard identified

identify technical, operational or organisational measures that will limit the consequences of the hazard if released

Prior to use on site, the specific supervisors and foremen to perform the work encompassing the given hazard shall verify that the control measures specified are in place and confirm that there are no specific additional hazards that apply to the particular activity.

The Hazard Analysis and Control Programme sheets are listed below.

A-1Civil WorksExcavation

A-2Civil WorksConcreting and Shuttering

A-3GeneralTransportation of Gas Cylinders

A-4GeneralGas Cutting

A-5GeneralGrinding

A-6GeneralWelding

A-7GeneralDiesel Engines

A-8Mechanical InstallationRadiography

A-9Mechanical/CommissioningPressure Testing

A-10Electrical InstallationCable Drum Handling

A-11Electrical InstallationCable Pulling

A-12Electrical InstallationCable Laying/Cable Termination

A-13GeneralMaterial Handling

A-14GeneralHandling of Steel

A-15GeneralHandling of Timber

A-16CivilsConcrete Pours

A-17CivilsSteel Fixing

A-18CivilsBackfilling of Excavations

A-19Mechanical InstallationTransportation/Lifting of Heavy Equipment

A-20Temporary WorksErection of Scaffolding

A-21Temporary WorksProvision & Maintenance of Safe Scaffolding

A-22Temporary WorksDismantling of Scaffolding

A-23GeneralUse of Hazardous Substances

A-24Civil WorksErection of Fencing

A-25Civil WorksFabrication of Gates

A-26Civil WorksErection of Gates

A-27GeneralRemoval of Waste Material

A-28MechanicalErection of Steel Work

A-29MechanicalInstallation of Pipeline and Valve Fittings

A-30ElectricalElectrical Work

A-31Civil WorksRock Drilling

A-32Civil WorksRock Blasting

A-33Site PreparationEarthworks

A-34GeneralSite Transport

12.

CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN12.1Scope and ObjectivesThe Construction Environmental Management Plan (CEMP) des