Professional Documents
Culture Documents
HSE POLICY
DESIGNED FOR A
SAUDI CLIENT
Abstract
One of the fundamental tenets of the safety management system is that Safety Program is structure so
that it fits the organisation and values of the organisation. Sample Health, Safety and Environment
Policy of our member company on the lines of which we are planning to adopt is attached.
After due discussions, deliberations and approval, established system protocols like International
Safety Rating System (ISRS), A Safety Management System proprietary to protocol of M/s DNV will
be adopted. Sample safety manual on the lines of which we are planning to adopt is attached.
ISRS is a leading safety Management System protocol extensively used by over 7000 sites world
wide including more than 230 refineries and 25% of the fortune 500 companies. The system is an
excellent tool for auditing and bench marking Safety Management System (SMS). It is the most
widely endorsed and best tool available in the world to assess continually improve safety
performance.
ISRS provides a Systematic and Comprehensive basis for assessing performance based on Safety
program standards. It is a system of objectively measuring works being done to manage and control
all types of loss in an organisation and can also be used as a system to guide the development of
effective safety programs. ISRS does, however, encompass much more than the vital concern of
personal safety alone. It provides users with an assessment tool that quantifies the safety and loss
control performance and this in tun facilitates continuous Safety improvement. ISRS is also used as a
tool for benchmarking and setting goals for safety. The quantitative basis provided by ISRS also
allows organisations to compare their safety performance with that of International leaders best
known for their safety management.
HEALTH, SAFETY AND ENVIRONMENTAL POLICY
The Policy:
A) Organisational Set up
B) Employees' involvement
Our Health, Safety and Environmental Policy reflects the continuing commitment of
the board to protect lives and health of our employees, safeguard plant and building
and avoid adverse Environmental effects.
4. PERFORMANCE MONITORING
5. AUDIT
1.1 INTRODUCTION
The objective of the SMS is to ensure that the hazards inherent in all types
of operations in the Refinery have been systematically identified; that
arrangements are in place to control those hazards and to deal with the
consequences should the need arise; and that the necessary information,
training, auditing and improvement processes are in place.
The SMS Manual covers all phases of Refinery activities, which defines the
management system in place to manage the Refinery's HSE policy of
assuring safe operation.
The SMS manual has three parts. A brief summary of the contents of each
part is given below:
Part 1 of this manual describes the main elements of the Refinery's Safety
Management System including discussions on:
• The Safety Management System Manual.
• Application of SMS.
• Policy and Objectives
• Standards and Procedures
• Performance Monitoring
• Audit
• Management Review and Improvement Process
Part 2 of the manual provides the essential Fire & Safety regulations to be
followed in the refinery. This also includes various Safety critical activities
and procedures to be followed thereof.
The Owner of the SMS is the Executive Director (Refinery). As owner he issues
clear directives to the Custodian on how the SMS must be maintained and
implemented.
The SMS manual is to be updated when any major change occurs to applicable
legislation or to the Refinery's policy, its objectives and the system of achieving
them, including changes to the organisation. As a minimum requirement it is to
be reviewed once a year to ensure currency.
1.4 SMS APPLICATION.
Control and support at all levels in the Refinery organization is also required. The
SMS is founded upon the essential management level guidance, control and
support.
The Management Controls applicable to the SMS are contained in this Part
I of the SMS Manual. They cover policy and objectives (Section2),
organization aspects (Section 3), standards and procedures (Section 4),
performance monitoring (Section 5), audit (Section 6) and management
review and improvement (Section 11).
The process owner is responsible for setting up both business and HSE
related performance indicators for his process for carrying audits and
taking corrective action as often as considered necessary to assure the
effectiveness of the SMS.
Line supervisors ensure that the safety critical activities, which are
under their responsibility, are performed to standards by ensuring that
the executors of the safety critical activities are:
Various parties involved in applying the SMS, i.e. executors, line supervisors,
process owners and senior management, must be actively involved as part of
the live SMS.
All levels of management and line supervisory staff may refer this manual and
identify their responsibilities and accountabilities and what is required of them
to manage their particular part of the business in respect of HSE policy
requirements.
PART - 1 : SECTION – 2
The Health Safety & Environment (HSE) Policy provides the directional
framework on the Refinery's objectives to safety management. It applies equally
to its employees, Contractors, Consultants, Agents and other Third Parties
engaged in work for, or on behalf of the Refinery, or associated with its activities.
The Safety Coordinator is the custodian of the HSE Policy and objectives.
Refinery HSE Policy & Objectives are communicated to all individual employees
in the Refinery. The key HSE policy statements and targets are also published
as a special document that is publicly put on notice boards throughout the
companies work facilities.
2.4 IMPLEMENTATION
Listed below are some of the reference documents covering health, safety and
the environment. These and other relevant documents are listed in Part three of
the SMS manual.
3.1 INTRODUCTION
All codes used in the Refinery are external documents normally relating to
Legislation or Industry Regulations and are outside the control of Refinery.
However, these codes are referenced in all Refinery Standards as applicable.
All Standards reviews are carried out by the line and approved by the relevant
department manager prior to issue.
In the context of SMS, Standards can be divided into four groups: i.e.
Management Standards, Equipment and Material Standards and working
methods Standards.
For the purpose of this manual, the term, "standards" covers all policies,
philosophies, codes of practice and procedures which are part of the
Safety Management System.
Standards are generated and maintained with the specific aim of providing
a means to:
φ Assure technical and operational integrity.
φ Assure quality and performance.
φ Standardize materials, equipment and documentation.
φ Transfer knowledge and improve communications.
All alterations in the Refinery are controlled by the MOC procedure which
describes the methods of performance of various SMS elements.
In the event the emergency leads to a fire or likely to escalate, the shift
officer will call for emergency response from the Shift Superintendent and
the fire station. On receipt of such call, the Shift Superintendent will reach
site and the fire station will immediately send an emergency turnout.
Depending on the nature and size of the emergency, minor or major
emergency siren will be sounded by the fire station.
The safety of all facilities and everyone on them is critically dependent on the
proper organization and control of work. This requires a disciplined approach to
all operations with effective planning, control and co-ordination of maintenance/
construction activities and modifications.
In order to control and perform, the large number and variety of work safely that
takes place in the Refinery a General Permit to Work Procedure and document
has been developed (refer Fire & Safety Regulation). All works in the Refinery
are carried out within the framework of the work permit system.
Two types of permits are used in the Refinery - hot work permit and cold work
permit. The Refinery has been divided into various zones for the purpose of
issue of permits. Each zone has a designated Fire Zone Signatory (FZS) and a
Gas Safety Inspector (GSI). All FZSs and GSIs are authorised by the General
Manager (OPS) - Refinery. FZSs and the GSIs issue work permits for any work
in their respective zones on behalf of the GM (OPS) -R who is the ultimate
responsible person for the proper functioning of the work permit system.
Hot work permits are issued by the GSIs and reviewed and countersigned by the
FZS of the same zone. All work involving the use of energy source or of highly
hazardous nature like work in confined space, excavation work, work involving
use of radiography etc. are covered by hot work permits.
All cold works without the use of any energy source are covered by cold work
permits. Cold work permits are issued by the GSIs.
Full details of the work permit system can be found in the Fire and Safety
Regulation. The custodian of this system is the Safety Coordinator.
The permit to work is a key tool to enhance safe work management. The
requirement for a Permit to Work is based on Job Safety Analysis which is
carried out by the personnel involved in the work authorization, supervision and
execution. This policy is being followed in all permit to Work training
programmes and specified in the work permit system.
With the introduction of SMS all Contractors will be required to follow the
requirement of SMS.
3.6.1 Management
3.6.3 Responsibilities
The Contractor accepts responsibility for the safety of its personnel and
of third parties and protection of the environment in which the work is
carried out. In addition, the Contractor is also responsible for:-
3.8.0 INTRODUCTION
The Safety Management System in the refinery has been developed in line
with the International Safety Rating System. The various systems and
practices for the development of SMS have been grouped under 25 system
elements as follows:
General policy:
It is the first step towards exhibiting management commitment. The head of
the refinery issues a policy statement stating the intended purpose and
goals to achieve. The policy statement addresses management commitment
for prevention of injury / damage to personnel, plant, equipment, material
and environment. The policy sets out programs to comply with legislative
requirements, prevent occupational health hazard, promote good house
keeping and responsible care towards community.
All members of the senior management staff upto the department head
level will spend some quality time at regular interval at the shop floor level
discussing exclusively HSE matters. This initiative is termed as safety
sampling by senior management staff. To aid senior management staff in
safety sampling, a standard checklist namely “safety sampling report format”
has been developed. At the end of safety sampling tour, senior
management staff will fill in this checklist and forward the same to the safety
coordinator.
Internal Audits:
GM (OPS) would form the teams and set out the process once every year.
Each team, which includes an employee, would carry out the internal audit
as per checklist developed for this purpose and submit reports to the GM
(OPS).
Internal audit is a technique, which calls for special skills. In order to equip
the persons involved in Internal Safety Audit, appropriate training will be
provided to them.
Employees too will have specific safety responsibilities, which are mostly
contained in standing orders and fire and safety regulations. The annual
performance appraisal of the employee will also reflect his performance in
safety.
No goals can be met unless there is proper planning. Refinery will plan
every year its objectives and targets for accomplishment of HSE goals
through the implementation of systems set out in SMS. The plan and
objectives would be congruent with the organization’s business objectives
and would be drilled down from the refinery level to individual department /
sections including the safety department.
Every line Manager will assess the training needs of individual staff based
on above requirement. The training requirement would be reviewed once in
a year to ascertain efficacy.
Every employee joining new to the organization or on transfer from one job
to a different job will be given proper orientation / induction about specific
HSE requirements of his assignments. This is an essential requirement in
order to allow the employee perform his work safely.
Training of senior Management staff and the safety coordinator:
Sr. Management staff and the safety coordinator are required to guide,
direct and monitor the implementation process for the SMS. This calls for
adequate information and appreciation of the various aspects of the SMS.
All the members of the senior management team and the safety coordinator
will be provided initial as well as refresher training on various aspects of
SMS not only at the introductory level but also at advance level.
The team carrying out planned general HSE inspection would classify
hazards based on potential pertaining to all substandard conditions and
practices so as to decide priority of intervention and management attention.
Section head of concerned area along with section head of maintenance of
that area will be responsible to rectify the substandard conditions / practices
within the time frame as suggested in the planned HSE checklist based on
the hazard potentials.
Section head of each area of will report every month to the safety
coordinator the details of remedial actions taking together with reasons for
delay if any for each of the observed substandard conditions and practices.
Based on that, safety coordinator will prepare a consolidated report of the
planned HSE inspections of all areas together with status of all substandard
conditions/practices and submit the same to the management safety
committee once a quarter.
The section head and the department head of each area will discuss the
status of the substandard conditions/practices highlighted in the planned
HSE inspection of his area in the sectional safety committee meeting as well
as departmental safety committee meetings which are attended by
employees also.
All planned HSE reports from all areas would be available for ready
reference.
Safety coordinator will carry out an analysis of all planned HSE inspection
reports to identify common and repetitive problems and their underlying
causes and forward the results of analysis along with appropriate
recommendations to all departments for taking corrective actions. Section
head of each area will take appropriate actions to remedy the
basic/underlying causes of substandard conditions/practices identified in his
area.
4. Critical Parts/Items
Section heads will prepare an inventory of safety critical
item/equipment/activity for each operation, activity, structure, equipment and
material pertaining to their jurisdictions. This list will be forwarded to safety
coordinator. This list will remain under constant review and updated
annually by the section heads.
Identified critical items, equipment, activity, structure and material will form
part of the planned HSE inspection checklist. Section head of each area will
also make a thorough assessment of the risk / hazard of each equipment,
material or structure in his area that can interfere with safety of other and
make necessary preventive actions. He will thereafter systematically review
and update the list of critical parts / items.
5. Preventive Maintenance
Section head (transport maintenance) will carry out a survey with the help of
element champions and employees of his area of all mobile and material
handling equipment to identify the requirement of pre-use inspection for safe
operation of that equipment. He will prepare pre-use checklist for all mobile
and material handling equipment.
Apart from that he would also specify the persons responsible for pre-use
equipment inspection for each equipment, determine the schedule and
extent of pre-use inspection, the stage of equipment operation when the
pre-use inspection is to be carried out, actions to be taken in case
substandard conditions are observed during pre-use inspection and also the
system to be followed for correction of such substandard items.
9. Compliance Requirement.
In order to achieve these objectives, general fire & safety rules have been
compiled up by the Fire and Safety Department in consultation with Staff
and employees of various departments. These rules will be made available
for information of all personnel working within the refinery premises in
easily understandable languages through
The general Fire & Safety rules displayed in the Control rooms and
workshop will be checked for readability and condition along with the
planned HSE inspection to be carried out as per schedule. The Jumbo
Display boards will be inspected once in six months by Safety Officers and
carryout refurbishing as required.
These general Fire and Safety rules will be reviewed by the Fire & Safety
Department whenever there is a major change in Process, equipment,
system etc and at least annually along with the Safety Diary.
2. System for framing Specialised work rules:
Whereas, some tasks are of routine nature and may not pose any special
hazard to the persons executing the task or the environment, there would
however be some tasks, which are inherently hazardous to the people and the
environment.
These tasks, need to be performed with special attention and care. For safe
work, it is therefore, essential to identify these tasks and also to relate these
tasks with the occupation performing the same.
Refinery is a high hazard area. It is therefore essential that, all work in the
refinery area to be regulated by a work permit system.
The team carrying out the occupation survey and preparing the inventory of
various tasks performed in the refinery will to classify the identified tasks as
per their hazard potential. In addition to the occupation survey, the team will
The regulation of work in the refinery through permits will be governed by the
work permit system described in Chapter 10 in Fire & Safety Regulations.
The cold work permits will be issued by Gas Safety Inspectors of respective
areas whereas hot work permits for high hazard jobs will be issued by Gas
Safety Inspectors as well as the Fire Zone Signatories. The shift in-charge of
the area where the work would be carried out shall issue clearance
certificates based on the permits issued for the job. The job condition listed in
the permits / clearance should be as listed in the procedures developed for
the critical tasks. In addition, conditions as required by the prevailing
conditions at the workplace at the time of executing the tasks shall also be
laid down in the clearance.
The GSI's and FZS's of respective areas in the refinery would be nominated
by the General Manager (Operations)-R which will be reviewed and revised
as required quarterly.
All GSI's, FZS's and the users of the work permit system will be made aware
about the need for the work permit system as well as the risks involved in
various jobs through training workshops conducted periodically for this
purpose. The details of all such workshop shall be documented and
maintained in In-plant training center as well as the Refinery Training Center.
All permits will be made in triplicate - the original with the execution agency,
second copy with Fire Station and third copy with the issuer of the permit. All
permits are required to be registered centrally at the fire station before
approaching for clearance certificate to start the work.
Both Cold & Hot work clearances will be issued in duplicate - the original with
the executing agency and the copy with the issuer. However, before starting
work, the hot work clearances are to be registered centrally in the fire station.
The work permit system will be reviewed periodically atleast once in two years
along with the review of specialised work rules by a team comprising of
Management as well as on Non-Management staff and constituted by the
General Manager (Ops)- R. During such review, all major and high potential
accidents during the previous period shall be examined and changes if any, in
the work permit system felt necessary shall be incorporated.
a. A pocket book of relevant Fire & Safety rules will be distributed to all
existing employees under proper acknowledgement.
b. All new employees will be issued with this pocket book at the time of
joining the refinery by Staff Section (for Management Staff)/ IR Section (for
Non-Management employees) / Training Center (for trainees &
apprentices) with proper acknowledgement.
c. All acknowledgements would be forward to and centrally kept with the
Manager - Safety.
d. For existing employees, the first line supervisors will discuss these rules
progressively with his employees atleast once in a week so that all the
employees working with him are aware about the rules. For all new
employees, the section head (T&D) would ensure briefing of the rules at
the time of first induction in the training center.
e. The section heads through their first line supervisor / Section Head (T&D)
(for all new employees) will document such rule education programmes
appropriately (Communication book / logbook etc.) mentioning therein the
various rules that have been discussed and the name of the persons
present in such discussions.
f. The Section Heads would examine atleast once in a year the extent of
understanding of the rules by the employees by administering a written
objective type questionnaire.
g. They may also consider recognising employees with high degree of
awareness. The employees needing further education would also be
known through such testing and appropriate actions can be taken for
further education.
h. The section heads will obtain suggestions from employees for review of
rules and pass on the same to the safety section for necessary revisions
as may be required.
i. In case of new/transferred employees, the concerned section heads will
ensure that specific rules pertaining to his new areas of operations are
explained to the employee. He would also ensure that the new employee
has understood all the rules.
This may be accomplished by administering an objective type written test. The
section head will certify the new employee is fit for the job.
a. During all communications with employees, the first line supervisors and
the section heads will encourage compliance of required rules and
procedures by the employees.
b. Find out the employees who are observed to be consistently following
all required rules and procedures and also taking more than standard
precautions in doing a job thereby preventing accidents.
c. Commend such employees giving them adequate recognition to
continue with such positive behaviour. This may be accomplished as
below.
I. Appreciate his behaviour in presence of other employees.
II. Mention about his good behaviour in group meetings like
Sectional / Departmental Safety Meetings and record them.
III. Issue him an appreciation letter with a copy to his dossier.
IV. Recognise consistently outstanding performers by awards
during departmental / sectional safety functions.
The Safety Coordinator will compile accident and incident statistics and
will communicate these studies, arranged department wise to Director (R),
Executive Director (R), General Managers and other Department Heads
monthly. He will also compute every month for the entire refinery as well
as dept./section wise frequency and severity rates of work
injuries/illnesses and also rates of property damages, fires and adverse
environmental events. The computed results will be communicated to all
senior managers every month.
The Safety Coordinator shall prepare analysis of the incidents for the
refinery as a whole as well as department, section and occupation wise.
The analysis will cover unsafe act, unsafe condition, personal factors,
body part affected etc. The detailed analysis will be communicated to
Director (R), Executive Director (R), General Managers and other
department heads monthly. He will analyze every month each accident /
incident to ascertain the underlying causes (immediate / basic / lack of
control). The causes as ascertained shall be analyzed for the whole
refinery as well as dept./section wise.
Safety department will provide dept. wise accident statistics/ records to all
supervisors by putting the information on the Intranet and will maintain all
accident/incident statistics and analyses in a central location at least for a
period of two years.
1. Administration:
φ Operating Procedures,
φ Inspection Reports,
φ Change Management Analysis,
φ Training programme evaluation reports,
φ Performance appraisal reports,
φ Hazards and risk in the process plants,
φ Accident / incident analysis,
φ Applicable statutory regulations / Codes / Standards.
φ Training program evaluation reports.
Section Heads in coordination with Section Head (T&D) shall carry out
training needs analysis as above once in a year.
Section Head (T&D) will prepare and update annually training plans for
each individual employee and administer training programme accordingly.
3. Instructor Qualifications:
Section Head (T&D) shall prepare a list of training instructors based on
their knowledge and skill for administering identified training programmes
based on Training needs analysis.
He will evaluate atleast once in two years the list of training instructors to
ensure that their qualifications and skills are up-to-date.
4. Training Systems:
Section Head (T&D) will develop and use appropriate lesson plans to guide
and standardise employee training so that training meets the employee
needs.
The training department and In-plant Training Center will issue certificates
of competence for the successful completion of employee training courses.
Section heads will identify in their area equipment, the operation of which
would require license.
Section Head (T&D) will evaluate the training programmes once in a year
and produce a written report of his evaluation to the DIR (R), ED-R, GM's
and the department heads. The evaluation will cover the following areas:
φ Comparison of number of people needing training and the numbers
received the training.
φ Quality of the lesson plans for employee training courses as highlighted
by the trainees.
φ Teaching techniques and aids adapted.
φ Comments of the course reviewer.
φ Results of written / oral tests, if any.
φ Observation reports / proficiency on the job after the training.
φ Review of changes based on accident / incident analysis.
φ Review of risk analysis.
φ Review of teaching aids used in training.
3.8.9 PERSONAL PROTECTIVE EQUIPMENT (PPE)
All employees, who are required to use PPE, will be able to participate in
the selection of equipment, through discussion in Safety Committees and
Group Communication meetings.
Safety Personnel will carry out PPE compliance surveys at various areas
once at least every quarter. The results will be communicated in writing to
Plant Manager, Safety Coordinator.
Section Heads / Site Supervisors will enforce the standards and procedures
for the use of PPE and will use appropriate forums to discuss the
requirement with their employees. PPE should be specifically discussed at
Safety Committee Meetings. They will identify non-users of required PPEs
and consider the same while evaluating safety performance of individual
employees.
Section Head (Medical Services) will maintain a list of all occupation and
related tasks for all operational areas.
He will analyze the occupations and the tasks in consultation with Plant
Managers and Safety representative to identify and evaluate any
occupational health and hygiene hazards to which employees may be
exposed. He will also review the Hazard / risk analysis reports, accident /
incident analysis of the past three years, inspection reports, change
management results, applicable regulations etc, for the identification and
evaluation of health and hygiene hazards. A survey of employees and
managers also would be carried out to identify and evaluate health
hazards.
Section head (material services) along with concerned Section heads will
carry out survey of each plant area for identification/evaluation of
chemical, noise, radiation, illumination, vibration, extreme temperatures,
biological, ergonomic, physical and stress related hazards.
Management will provide full time professional medical officers and full-
fledged medical centre facilities for employees for attending to employees
health problems arising out of work or otherwise.
Manager Medical Services will properly maintain reports of all first aid
cases and will review all first aid cases and investigate those cases, which
are high potential.
8. Communication:
All restricted duty cases arising out of any health problems will be
reported to the Sr. Manager. Similarly employees will report
immediately all injury / sickness cases as per Fire & Safety
regulations.
Safety coordinator will prepare a long-term plan for the refinery setting
targets for attaining higher ISRS levels in respect of safety management
system and also other HSE related goals together with a road map to
achieve these goals. While preparing the plan he will involve all
departments as well as cross-section of employees at all levels in
formulating such long-term HSE plans.
Once the plan has been finalized he will obtain approval from the Senior
Manager for refinery long-term HSE plans.
Safety coordinator will 0rganize system audit every quarter of all plant
areas to evaluate compliance with the various requirements under the 20
ISRS elements of the refinery safety management system. He will
communicate the results of such compliance audit to all departments as
well as to management safety committee.
Safety coordinator will prepare an action plan to bridge any gap that might
have been identified in any of the twenty elements under the SMS
performance standards audit. He will thereafter follow up with Section
heads implementation of the actions to bridge the gaps once every two
months.
4. Perception Surveys
Safety coordinator will organize once a year survey across the refinery to
ascertain employer perceptions about refinery’s safety arrangement system
as well as their awareness levels.
φ Fatality
φ Lost Workday Case (LWC) - LTAs
φ Medical Treatment Case (MTC) - Minor Injuries
φ First Aid Case (FAC)
5 AUDIT
5.1 INTRODUCTION
All audits within the Refinery would be as per procedure laid down.
The Safety Coordinator is responsible for compiling the safety audit plan
in consultation with the functional departments, for review/assessment
by the Management Safety Committee. He is responsible for preparing
and Coordinating the implementation of the audit plan for all activities.
Reasons for rejection of any safety improvement action from the above are
approved by the concerned HODs. Deviations from the recommendations of the
above are also approved by the concerned HODs. Where the auditee and
auditor cannot agree on corrective actions resolution should be sought with the
Management Safety committee. Progress on all corrective actions is reported at
regular intervals to the top management and the Safety Coordinator through the
departmental monthly report until the audit recommendations are finally closed
out. Safety coordinator puts up a consolidated information to the Management
Safety Committee.
PART - 1: SECTION – 6
6.1 INTRODUCTION
An annual HSE Plan is produced and runs from 1 April to 31 March. The Safety
Coordinator in co-operation with the line departments prepares it.
The HSE Plan sets targets for all levels of the organisation. Application of this
plan and the cascading down of its targets to individual tasks and targets ensures
that all staff have clearly defined HSE objectives. These tasks and targets, are in
line with the over all Refinery objectives and will be annually reviewed during the
staff reporting exercise. The outcome of this annual review will go back into the
next years targets.
6.3 REVIEW OF PERFORMANCE AND EFFECTIVENESS OF THE HSE PLAN
AND SMS
The Refinery HSE improvement strategy is set against the long term
targets of zero accidents and progressive reduction of emissions, effluents
and discharges of waste that are known to have a negative impact to the
environment with the ultimate aim of eliminating them.