QPR - RHT - REG - 001

Health Safety and Revision 01

Environment Regulations Date 28.04.2008
Page I

Document Change History

Doc. No. Rev Rev Revision Description Page Approved
No. Date No. by
QPR-RHT- 01 28.04. New document All DL
REG-001 2008

Remarks: None
 QPR - RHT - REG - 001
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Environment Regulations Date 28.04.2008
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Contents

1.0 OBJECTIVES ................................................................................................ 1

2.0 SCOPE .......................................................................................................... 1
3.0 DEFINITIONS and ABBREVIATIONS ......................................................... 1
3.1 Definitions .................................................................................................. 1
3.2 Abbreviations ............................................................................................. 3
4.0 RESPONSIBILITIES and STANDARDS ...................................................... 6
4.1 Responsibilities .......................................................................................... 6
4.2 Standards................................................................................................... 9
4.3 Colour Coding .......................................................................................... 11
4.4 Pipeline Identification ............................................................................... 11
4.5 First Aid Stations in Ras Laffan ............................................................... 12
4.6 Lifting Equipment Certification ................................................................. 12
4.6.1 Certification Authority ....................................................................... 12
4.6.2 Authorized Companies ..................................................................... 12
4.6.3 Lifting Appliances (Also Known As Lifting Machines) ...................... 12
4.6.4 Lifting Tackle (Also Known As Lifting/Loose Gear) .......................... 13
4.7 Road Safety ............................................................................................. 13
4.8 Protection of Overhead Pipe Bridges ...................................................... 13
4.9 Radiation .................................................................................................. 13
5.0 Related Documents and References ....................................................... 15

Table 4.2 Table of Regulation Sections .................................................... 5

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1.0 OBJECTIVES

The Health, Safety and Environmental Conservation Policy endorsed by H.E.

The Minister on 31st of May 1994 includes the statement that it is Corporation
Policy to conduct its activities such that;
A systematic approach to be followed for managing Health, Safety and
Environmental issues in Ras Laffan Land Lease Agreements,
All practical efforts are taken to ensure the Health and Safety of its employees
and all other persons who may be affected directly or indirectly by its activities.
The management of Health, Safety and Environment (HSE) risks associated
with contracted activities is a key part of the HSE management system of Ras
Laffan Industrial City given the fact that a large proportion of QPs inherently
hazardous oil and gas business is carried out using contractors.

Ras Laffan Industrial City (RLC) is committed to the management and

protection of the environment and to comply with all Safety legal requirements.
Accordingly, it will plan and operate its business in a manner to continuously
monitor all activities within RLC, identifies the Health, Safety and
Environmental aspects that may have significant impacts on neighbouring
communities, end users, employees, customers and shareholders.

2.0 SCOPE

The objective of these regulations is to establish minimum mandatory

requirements regarding standard safe working practices in Ras Laffan
Industrial City by all stakeholders. It shall apply throughout the contracting
process from contract initiation and planning through mobilization, execution,
de-mobilization, and close-out of the Land Lease Agreements.

3.0 DEFINITIONS and ABBREVIATIONS

3.1 Definitions

Approve To accept as satisfactory, permit or officially

agree.
Continual Process of enhancing the OH&S management
improvement: system, to achieve improvement in overall
occupational health and safety performances,
in line with the organisations OH&S policy.
Contractor An individual or organisation performing work
for RLC, following verbal or written agreement.
Subcontractor is synonymous with contractor.
Documentation Any written information describing, defining,
specifying, certifying or reporting activities,
requirements, policy or results.
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3.1 Definitions (continued)

Employee Means any person who is employed by Ras

Laffan Industrial City and who receives or is
entitled to receive remuneration.
End User A company, firm, or RLC department that uses
services, facilities, and occupies RLC land for
the purpose of manufacturing a product or
providing a service to RLC or other tenants
within of RLC.
Environment Surroundings in which an organisation
operates, including air, water, land, natural
resources, flora, fauna, humans, and their
interrelation.
NOTE: Surroundings in this context extend
from within the organisation to the
global system, for example; any
environment which is effected or
impacted upon as a result of Ras
Laffan Industrial Citys business.
Hazard: Source or situations with a potential for harm in
terms of injury or ill health to the workplace
environment, or a combination of these.
Health Means to be free from illness or injury
attributable to occupational or other causes.
Interested Party An Individual or group concerned with or
affected by the HSE performance of the
organisation.
Organisation Company, corporation, firm, enterprise,
authority or institution, or part or combination
thereof, whether incorporated or not, public or
private, that has its own functions and
administration.
Safety Means protected from any risk or hazard.
Shall A mandatory action.
Should A preferred course of action or activity.
Standards/ A set of established patterns, models, or
Regulations principles that are generally accepted as being
the correct or acceptable operational methods
and behaviours.
TRACT The Land Leased to a Company by Qatar
Petroleum.
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3.2 Abbreviations

DL Director of Ras Laffan

EDR Engineering Department Ras Laffan Projects
EMS Environmental Management System
HSE Safety, Health, Environment, Risk Management
and Quality which refers to the organisational
structure, planning activities, responsibilities,
practices, procedures, processes and resources
for developing, implementing, achieving,
reviewing and maintaining the HSE Policy.
HSE Management The part of the overall management system that
includes System organisational structure,
planning activities, responsibilities, practices,
procedures, processes and resources for
developing, implementing, achieving, reviewing
and maintaining the HSE policy.
HSE Policy Statement by the organisation of its intentions
and principles in relation to its overall HSE
performance that provides a framework for
action and for the setting of its HSE objectives
and targets.
ISO International Organization for Standardization
LLA Land Lease Agreement
MSDS Material Safety Data Sheet
OEL Occupational Exposure Limits
OHSAS Occupational Health and Safety Management
systems.
PPE Personal Protective Equipments- Apparel or
apparatus which is worn to minimize the risk of
injury or impairment to any part of the human
body through physical contact, absorption or
inhalation of a hazardous material.
RHT Safety Division of RLC Heat Safety and
Environment
RLC QP Directorate: Ras Laffan City
RLIC Ras Laffan Industrial City
TLLA Temporary Land Lease Agreement
Contract HSE The HSE Plan of the contractor stating how the
Plan HSE risks in the contract will be and managed in
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order to meet QP HSE requirements for

protecting people, assets and the environment.
It should cover the contract phases from pre-
mobilization, through contract execution, to
demobilization. It demonstrates the contractors
understanding of the requirements stated in the
Contract HSE specification and should state the
HSE policy, procedures, and standards to be
adopted in carrying-out the contract.
Contract HSE This refers to the HSE requirements defined for
specification a particular contract in order to eliminate or
minimize the risk. It is usually based on the
result of the HSE assessment for the contract
and forms the framework within which the
contractor makes the contract HSE plan on
which he is monitored.
Risk is the combination of the likelihood (or
Risk probability) of an event occurring and the
severity of the outcome.
Risk = likelihood of an event x severity of
outcome.
A systematic examination of a task, job or
Risk Assessment process for the purpose of identifying the
significant hazards that are present, deciding if
the existing controls reduce the risk to an
acceptable level, and if not, deciding what
further control measures must be taken to
reduce the risk to an acceptable level.

Incident An Incident is a general term for any unplanned

event, or chain of events, which has, or could
have caused, injury, illness, damage or loss. It is
used to include all accidents and near misses.

Lost Time Injury A work related injury, which renders the injured
(LTI) person unable to perform his regular job or
Restricted Work on any day after the day on
which the accident occurred. Note: if, in a single
incident 20 people receive lost time injuries,
then it is accounted as 20 LTI's (not 1 LTI). Lost
Time Injuries are the sum of Fatalities (FAT),
Permanent Total Disabilities (PTD), Permanent
Partial Disabilities (PPD), and Lost Workday
cases (LWC).
LTI = (FAT+PTD+PPD+LWC)
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Shall Throughout this document, shall means that

an activity or requirement is mandatory

Local Ignition Shall include but not limited to:

Sources Electric and gas welding torches.
All naked flames, fires, exposed incandescent
material
including pyrophoric deposits, electric arcs and
sparks.
Blow lamps, primus stoves and tar boilers.
Grit and shot blasting machines.
Internal combustion engines.
Power operated
grinders, and cutting machines.
Electric and communication equipment of
industrial type i.e. which is not flame proof,
intrinsically safe, or of an approved
type.
Power operated ferrous tools.
Hand operated ferrous tools in contact with dry
concrete,
stone masonry.
Diesel engines, which are not provided with
approved
exhaust and inlet air cut-off systems, ancillary
electric
equipment and any other machine capable of
producing a
local source of ignition.
Matches (safety or otherwise) cigarette
lighters, nonapproved
electric torches and battery operated items such
as
transistor radios.
All instruments embodying the use of electricity
either in the
driving, indicating or recording mechanism,
which are not
"flame-proof" or "intrinsically safe".
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Electrical Any producer, carrier or consumer of electrical

energy
equipment
Lifting equipment A generic term used to cover both Lifting Tackle
(or Gear) and Lifting Machines (or appliances)
Lifting Equipment shall mean any work
equipment for lifting or lowering loads, and
includes its attachments used for anchoring,
fixing or supporting it. It includes any lifting
accessories that attach the load to the lifting
machine in addition to the equipment that
carries out the actual lifting function. For details,
refer to the QP Lifting Equipment technical
Regulations; Document No.: QP-REG-Q-001,
Revision 3.

4.0 RESPONSIBILITIES and STANDARDS

4.1 Responsibilities
The responsibility for developing and amending this document is Health Safety
and Environment (HSE) Manager. The responsibility for ensuring compliance
is the Land Lease signatory.
All contractors, subcontractor, and End User entering into a Land Lease
agreement, irrespective of the Land Lease Agreements duration, are to
ensure that the requirements of all relevant Qatar Petroleum / Ras Laffan HSE
regulations and the QP HSE Mandate, signed by the Minister of Energy,
relevant Qatar National Laws and other requirements as described in the LLA,
are implemented and adhered to in accordance with Land Lease Agreement,
par. 6 (ix).
All end-users EPC contractors must establish a comprehensive safety
program, as well as a policy procedure in line with the RLC standards and
guidelines as referred to in QP-RHT-001

The rules and regulations in this document have been compiled to govern
HSE activities of Contractors in all phases of the QP contracting process with
particular emphasis on the contract execution phase. They are applicable to
all contracts in Qatar Petroleum whether at the corporate, regional or
operational levels of the corporation. The extent to which they are applicable
to a specific contract however depends on the nature of the work and level of
HSE risk that is present in the contracted work or service. Compliance to
these rules and regulations does not in any way relieve contractors from their
responsibility to comply with all other relevant QP policies, standards and
procedures including specific contractual HSE requirements and location-
specific requirements, they are also not a replacement for the applicable
State of Qatar laws and regulations.
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As part of its HSE-MS, the contractor must have HSE plans that describe how
the controls for hazards and effects management are implemented. The plans
should allocate sufficient human, physical and financial resources toward
improving HSE performance. The contractor must also have and use a
comprehensive set of procedures such as change management procedures,
incident management procedure, and emergency response procedures.
Procedures and work instructions are required to ensure that activities and
tasks are carried out in a manner meeting the required company standards.
The contractor should maintain procedures to ensure that HSE-critical
facilities and equipment which it designs, constructs, procures, operates,
maintains and/or inspects are suitable for the required purpose and comply
with defined criteria.

Not withstanding the provisions above, small contractors who may not have a
formalized HSE Management System, shall still have a basic understanding
of managing HSE in their operations and be prepared to provide and
demonstrate a simple but effective management system. They must be able
to make hazard assessments, apply and enforce controls to manage residual
HSE hazards and effects, apply location-specific and State HSE laws and
regulations correctly. They shall also demonstrate ability to respond effectively
to emergency situations.

QP shall, at its discretion, carry out HSE pre-qualification of potential

tenderers to determine in terms of HSE their suitability or otherwise to tender
for and be awarded a contract. The contractor shall make available all
necessary HSE information requested to aid the pre-qualification. In addition
to the submitted information, QP shall make use of past HSE performance
information that may be available in its database, concerning that particular
contractor, to reach a decision.

HSE Induction, Training and Competence

HSE INDUCTION
All contractor employees including subcontractors shall undergo an HSE
induction or orientation before being allowed to work on QP location. The
induction shall amongst other things such as specific contract and site HSE
issues, include the contents of this document. Contractor shall keep records
showing that each employee has attended an HSE induction session.

HSE TRAINING
In view of the hazardous nature of working in the oil and gas business,
Contractor shall, at its own cost, ensure that all employees including
subcontractors undergo HSE training adequate for health, safety and
environmental protection while engaged in works or services for QP. Such
training shall, at a minimum, include but not limited to the following
courses/training as applicable:
H2S & Breathing Apparatus
Permit-to-Work Computer based Training
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Permit-to-work workshop
Gas Testing
Confined Space entry
Job Hazard Analysis
Summary incident investigation
Tripod Beta & Detailed Incident investigation
Manual Handling
Basic Fire Fighting
Electrical Safety
Chemical Handling
Safe Plant Maintenance
Helicopter Underwater Escape Training (HUET)
First Aid Course
Hazard Management Training
IOSH Managing Safety
IOSH Construction Safety
NEBOSH General Safety Training
Defensive Driving
Environmental Management course

HSE COMPETENCE

The Lessee shall have an HSE competence development programme to, on

an ongoing basis; improve awareness, skills and knowledge of HSE
protection by the workforce, particularly in its areas of business.
Foremen, Supervisors and the contractor manager should all be regarded as
key personnel and must have some HSE training including some of the
courses indicated above.

INCIDENT REPORTING AND INVESTIGATION

The Lessee shall immediately report and investigate all HSE incidents, any
death on their occupied land or camp, including near misses that occur during
the course of the contract in accordance with the QP corporate procedure for
incident management.
They shall notify QP immediately of any HSE incidents, even if no injury
occurs and provide QP with a written report within 24 hours. Contractors shall
investigate all the HSE incidents beyond immediate causes to identify the root
causes. The Contractors written investigation report shall include the root
causes of the incident and a corrective action plan to prevent further
occurrence of similar incidents. A doctor's release for injuries requiring
medical treatment by a physician shall be provided before the injured
personnel return to work.
In addition, the contractor shall notify and invite concerned QP
regional/operational HSE Adviser to be present while investigating incidents
that occur within contractor and subcontractors activities while on QP
premises.
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4.2 Standards
The requirements associated with this document are the standards accepted
and authorised but not limited by Management for implementation at Ras
Laffan Industrial City. These standards are divided into five sections as
indicated in QP-RHT-001 define the minimum performance to which Tract
occupiers will comply to ensure that the Occupational Health and Safety
management requirements complies with internationally accepted practices
and contributes towards our objectives of achieving an incident free Ras
Laffan Industrial City. See Related and Reference Documents.

Table 4.2 Table of Regulation Sections

Section 1.00 - Premises / Housekeeping
Element 1.11 Building and Floors
Element 1.12 Lighting: Natural and Artificial
Element 1.13 Work Environmental Stressors and Ventilation: Natural and Artificial
Element 1.14 Sanitation and Plant Hygiene Amenities
Element 1.15 Pollution Prevention: Air, Soil and Water
Element 1.21 Aisles, Storage and accessible areas demarcation
Element 1.22 Good stacking and storage practices
Element 1.23 Factory and Yard: Tidy
Element 1.24 Waste Management
Element 1.25 Colour Coding: Plant and Piping
Element 1.26 Resource Conservation Program
Section 2.00 - Mechanical, Electrical and Personal Safeguarding
Element 2.11 Machine Guarding
Element 2.12 Lock-out System and Usage
Element 2.13 Labelling of Electrical Switch Gears and Critical Valves
Element 2.14 Ladders (registers) and Stairs, Scaffolding
Element 2.15 Lifting Machines and Lifting Tackles
Element 2.16 Boilers, Pressure Vessels and Compressed Gas Cylinders
Element 2.17 Hazardous Chemical Substances (HCS) Control
Element 2.18 Motorised Equipment Checklist, Licensing
Element 2.21 Portable Electrical Equipment
Element 2.22 Earth Leakage (E/L) relays: Use and Check
Element 2.23 General Electrical Installations and Machinery in Hazardous Locations
Element 2.30 Hand Tools
Element 2.31 Ergonomics
Element 2.40 A Personal Protective Equipments (PPE)
Element 2.40 B Head Protection
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Table 4.2 Table of Regulation Sections

Element 2.40 C Eye and Face Protection
Element 2.40 D Footwear
Element 2.40 E Protective Clothing
Element 2.40 F Respiratory Equipments
Element 2.40 G Hearing Conservation
Element 2.40 H Safety Harness
Element 2.40 I Hand Protection
Element 2.40 J Control over Personal Protective Equipments
Element 2.50 Electrical, Mechanical, Protective Equipments, Traffic Signs and Symbolic
Signs
Section 3.00 Fire Protection and Prevention
Element 3.01 Fire Extinguishing Equipments
Element 3.02 Locations Marked, Floor Clear
Element 3.04 Maintenance of Equipments
Element 3.05 Storage of Flammables / Chemicals and Explosive Material
Element 3.06 Emergency Alarm System
Element 3.07 Fire Fighting, Drill and Instructions
Element 3.08 Security System
Element 3.09 A Emergency Planning
Element 3.09 B Fire Prevention and Emergency Control
Section 4.00 Incident Recording Investigation
Element 4.11 H, S & E Incident Records
Element 4.12 Internal Incident Investigation
Element 4.13 Statistics
Element 4.22 HSE Risk Financing
Element 4.23 Incident Recall
Section 5.00 Health and Safety Organisation
Element 5.01 Corporate HSE Policy
Element 5.02 HSE Risk and Impact Assessment
Element 5.03 Legal requirements and / or Standards
Element 5.04 HSE Objectives and Targets
Element 5.06 System Review
Element 5.10 Responsibility of Chief Executive Officer
Element 5.11 Appointments
Element 5.12 HSE Representatives
Element 5.13 HSE Committees
Element 5.14 Communication
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Table 4.2 Table of Regulation Sections

Element 5.15 First Aid and Occupational Health Service Facilities
Element 5.21 Awareness and Promotion
Element 5.22 Injury and Occupational Diseases Experience and Star Grading / HSE
Performance Board
Element 5.24 HSE Reference Sources
Element 5.25 Annual Report
Element 5.30 HSE Training
Element 5.32 Medical Services
Element 5.33 Selection and Placement
Element 5.39 Environmental Monitoring
Element 5.40 Inspections and Actions
Element 5.41 Bi-annual Self Audits
Element 5.42 HSE Design Specifications
Element 5.43 Contractors Control
Element 5.50 Written HSE Work Procedures
Element 5.51 Planned Task Observations and Behaviour Based Approach to HSE
Element 5.52 Work Permits

4.3 Colour Coding

QP operates a system whereby ALL Lifting Equipment is colour coded with a

unique colour, at six (6) monthly intervals after inspection where applicable.
This colour is confirmed and validated by memorandum and prominent display
boards. Equipment not colour coded in accordance with the required colour
code shall not be utilized in any QP operational areas.
Red colour is reserved specifically for items scrapped or that are not to be
used.
Contractors operating within QP operational areas shall comply with QP colour
code system as published every six (6) months by QA Department. Mobile and
Fixed Lifting Appliances may be prominently marked with the Date of
Inspection in addition to application of the colour code. Refer to QP-REG-Q-
00.R3

4.4 Pipeline Identification

Pipelines are an important means of conveying liquids, gases, steam and air. It
is however impossible to find out what a pipeline contains from its external
appearance. In-line with QP/RLC's Loss Prevention Philosophy and
commitment to make its facilities safe, it is therefore required that all pipelines
shall be clearly colour coded and labelled, in accordance with the Regulations
as defined herein together with the referenced standards. (RLC/GL/002/2004)
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4.5 First Aid Stations in Ras Laffan

Guidelines for the establishment and operation of first aid Stations within Ras
Laffan industrial city

4.6 Lifting Equipment Certification

It is QP's mandatory requirement that all Contractors or suppliers who have

undertaken QP work shall have their lifting equipment certified by an approved
inspection/certification authority/company.

4.6.1 Certification Authority

All lifting equipment such as cranes, chain blocks, loose tackles etc. shall be
certified by an authorized and liable company as indicated below. Any
equipment which is not certified by such a company will not be approved by QP

4.6.2 Authorized Companies

1) Bureau Veritas (BV)

2) Det Norske Veritas (DNV)
3) Germanischer Lloyds (GL)
4) Lloyd Register (LR)
5) American Bureau of Shipping (ABS
6) Competent inspection companies who have obtained QP's prior approval.
7) In case of queries, IEI Section, Quality Assurance Department should be
contacted.

4.6.3 Lifting Appliances (Also Known As Lifting Machines)

Any lifting machine, driven by manual or mechanical power which is able to
raise, lower, suspend or transport loads and includes the supporting structure
and all Plant,
Equipment and gear used in connection with such a machine, but excludes
continuous mechanical handling devices (i.e. conveyors).
Cranes (mobile, tower, pedestal, etc.)
Wall/pillar cranes, derricks
Runway beams, pad eyes, gin pole and gin wheels
Winches, hoist (air and electric), crabs, telfer hoists
Chain blocks, Tirfors, pull lifts, trolleys
Powered working platforms
Elevators and Lifts
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4.6.4 Lifting Tackle (Also Known As Lifting/Loose Gear)

Any item used to connect a load to the lifting appliance, but which is not
in itself, capable to lift, lower, transport or suspend the load, such as;
Chains and wire ropes
Chain, wire rope and webbing slings
Rings, links, hooks, shackles, eye bolts, swivels, blocks, snatch
blocks
Beam clamps and plate clamps
Lifting beams, frames, baskets
Waste skips, tool boxes, cargo nets, containers, pallets, etc.

4.7 Road Safety

No unauthorized usage of transport shall be tolerated. The Contractor shall
ensure that all forms of transport are correctly fitted with the appropriate safety
equipment.
The Contractor undertakes to ensure that all drivers comply with the following
basic rules and Qatar State Traffic Regulations and Laws.

4.8 Protection of Overhead Pipe Bridges

It is the policy of RLC that all overhead pipeline bridges in common corridors be
protected against any accidental damage.
These pipelines carry dangerous hydro carbons and other chemicals which
possess properties that can give rise to major accidents in case of a rupture
and hence the protection is insisted.
All Overhead Pipe Bridges at RLC shall are adequately be protected against
accidental damage by vehicles. (QPR-RLP-007)

4.9 Radiation

Guiding Principles
The following principles shall be adhered to in order to achieve ideal radiation
protection and safety:
Determine ideal procedures for radiation protection and safety in prevailing
Set standards for restricting exposure and preventing accidents and mitigating
their impacts in case of occurrence;
Satisfy prevailing protection and safety standards when approving engineering
procedures and controls; and
Benefit from acquired expertise and the latest updates.
Understand the basic principles of practical radiation protection including time,
distance, shielding, containment and good housekeeping.
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Back Ground

It is the responsibility of all personnel and RLC contractor staff to

comply with Ras Laffan safety policy at all times and to observe safety
requirements when on site.

All radiation workers are required to be trained and have received

appropriate information and instruction

Radiation workers must be competent in the safe use of radioisotopes

and the necessary equipment.

All Radiation workers must be registered.

All radiation workers must have understanding of the radiation

protection procedure and local rules, their purpose and how to use
them to secure compliance with the regulation.

Personnel

Radiation Protection Officer (Competent Person)

Ras Laffan, Contractors and End Users shall appoint in writing one or move
suitably qualified employee(s) as RPO(s) (Radiation Protection Officer)

The competent person shall meet the requirements of Supreme Council

for Environmental and natural Reserves (SCENR), Qatar and shall be
registered accordingly.

The above person shall be responsible for the control, storage, issue and
transportation of radioactive sources. He shall conduct audits to ensure
that all instruction and standards are complied with.

He is responsible for reviewing the work permits and communicates the

comments and /or observations to the competent Authority before starting
Radiography on Site

He shall ensure that all the works involving joining radiation planned,
monitored and carried out as per the prevailing SCENR regulations and
standard.

He will provide advice during an emergency involving a radioactive

source. His duties shall include overseeing safe work practices, dealing
with emergencies, investigating and reporting incidents.

The names, location and telephone contact number of RPO shall be

available at the work site where work involves ionizing radiation.
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5.0 Related Documents and References

QPR-RHT-002 - HSE Policy Implementation Document

QPR-RHT-003 - HSE Management System Manual
QP-RHT-001 - QP Safety Regulations for Contractors
ISO 9001:2000
ISO 14001:2004 BSEN
OSHAS 180001:2007
QP/RLC Regulations
RLC Quality Management System Documentation
Management of Health and Safety at Work Regulations
Qatar Laws and Regulations
QP-REG-S-001
QP-REG-Q-00.R3
RLC/GL/002/2004
Guidelines for the Establishment and Operation of First Aid Stations in Ras
Laffan Industrial City
RLC Radiation Protection Procedure
Enquiry Guidelines for Death of Employees RLC, End Users and Contractors
inside RLC