HSE Manual: Health, Safety and Environmental Management Systems
HSE Manual: Health, Safety and Environmental Management Systems
EP 95-0100
HSE
MANUAL
1.1 Refer Headings 3.2, 3.7, 3.8, 4.1, 4.2 and 5.5 slightly modified to be 19/11/01 EP-HSE
description consistent with Self Assessment Questionnaire Revision 01.1
Figure III and sub note modified to reflect these changes.
1.2 Refer Headings 4.2, 4.4, 4.5 and 4.6 changed to 4.5, 4.4., 4.6 and 4.3 13/12/01 EP-HSE
descriptions respectively
Contents
CONTENTS
INTRODUCTION
Key objectives
This Revision 1 to EP95-0100 seeks to amalgamate EP 95-0100 and EP 95-0140. The key objectives
are to:
provide EP Operating Units (OUs) with one concise and comprehensive guide on all aspects of an
HSE MS
provide a framework for HSE MS which incorporates the requirements of the ISO 14001: 1996
Environmental Management System - specification with guidance for use
include those elements of Sustainable Development, which are addressed within HSE MS such as
consultation, environmental and social impact assessments etc.
Key changes
No new requirements are included in this guide. However, the opportunity has been taken to integrate
and consolidate existing requirements to provide a more concise format (Figure I). In particular:
In the previous Manual, text from the E&P Forum guidelines for HSE MS was included,
supplemented with additional Shell guidance, describing how things were to be done in Shell. The
content of this revision remains fully in line with E&P Forum (now OGP ) guidelines, but the
specific E&P Forum text has been removed.
ISO 14001 requirements are now fully integrated into the guidelines, rather than being separately
listed. This means that these guidelines are now also aligned with other external specifications
based on ISO 14001 such as OHSAS 18001 and BS 8800 for Occupational Health and Safety.
OGP - International Association of Oil and Gas Producers formerly E&P Forum
Shell Inte rna tional Explor atio n & P rod uctio n B.V .
Shell Inte rna tional Explor atio n & Prod uctio n B.V.
EP HSE HSE
V olume I Management
Volume I
HSE
Managemen t
V olume I
Systems
guidance requirements
fully integrated
To maximise the usability of the guideline, the elements of the HSE MS (Refer Figure II) have been
divided into 33 sub elements (Refer Figure III) defined such that the entire HSE MS is covered in a way
which is consistent with the SIEP Self Appraisal Questionnaire. For each sub element, the following are
provided:
Group HSE MS Procedure requirements: setting out the Group requirements as specified in the
mandatory Group Procedure for HSE MS.
Expectations: the key requirements to implement a particular sub element.
Typical supporting documents and procedures: the types of procedures or other documentation
typically expected to be found in an organisation to support the implementation of a particular sub-
element. Good examples of such procedures and documentation are to be found in a location on the
EP HSE web site dedicated to supplement these guidelines.
Relevant Shell guidelines: sources of further information and references.
Terminology
When comparing the various references on HSE MS there are some minor differences in terminology
and headings. The descriptions in this guideline are the same as the previous EP95-0100. Key
differences are:
The section entitled Hazards and Effects Management Process in this Manual has replaced the
Evaluation and Risk Management in the E&P Forum guideline.
The Shell Group Procedure for an HSE Management System does not include a section 'Planning
and Procedures' and splits 'Organisation, Responsibilities, Resources and Documentation' into
two sections and combines the sections 'Audit' and 'Review'.
ISO 14001 terminology is different and a cross reference table is included in the Appendix II.
It is now a requirement that operating units and joint ventures submit an annual letter of HSE
assurance, confirming compliance with the Group HSE Commitment, Policy and Procedure for an HSE
MS.
An HSE management system facilitates the management of HSE hazards and effects associated with
the business of the organisation. This includes the organisational structure, planning activities,
responsibilities, standards, documentation and resources for developing, implementing, achieving,
reviewing and maintaining the organisation's HSE Policy and meeting it's stated objectives.
The system concentrates on critical activities and should ensure that they are properly controlled and
that measurements are made and reported so as to enable monitoring of overall performance and
identification of areas for improvement. Management systems should provide a structured process for
the achievement of continual improvement, the rate of that is generally set by the organisation itself
taking into account client and parent company requirements.
An HSE MS will bring improvement in HSE performance in the longer term but only after the
company is 'working and improving the system'. This requires time for behaviour and attitudinal change
to support compliance with a system.
The EP Position on Global Environment Standards required all OUs to have implemented an HSE MS
by end 1999 and that the environmental component of the HSE MS of all OUs operating major
facilities is certified (by end of 2000). These targets were met except in the case of a few companies
where completion was delayed.
Other environmental targets set by the Shell Group are contained in the Group Minimum
Environmental Expectations. For EP, these are described in the EP Minimum Environmental
Expectations.
Following this Guideline will ensure that the requirements of the mandatory Group HSE Policy and
HSE MS procedure are met.
Shell recommends that H, S and E are managed within an integrated HSE Management System, but in
the longer term, it is expected that Management Systems, which encompass all aspects of the business,
will become the norm. Some Shell companies already operate within one system thereby reducing
overlap and duplication. In bigger companies, these systems often relate to clusters, departments or
business units.
EPBM (Version 3)
To fully integrate HSE into the business, HSE critical activities, tasks and responsibilities must be
described within the same framework as other aspects of the business. The processes, activities and
related data entities of a typical Shell EP OU have been identified in the EP Business Model (EPBM
Version 3). This provides a useful starting reference for an OU to describe their business. Using a
common framework of activities across an OU ensures that the interfaces are fully defined. In the HSE
MS, those activities necessary to meet HSE objectives are of primary interest
Note:
The headings used in this Guideline largely follow the headings in the SIEP Self Appraisal
Questionnaire. The headings in italics within brackets are the full headings used in EP 95-0100
Revision 0.
Since they are closely associated, 'Management of Change' and 'Asset Integrity' remain under 'Planning
and Procedures. Revision 01.1 of the SIEP self-appraisal questionnaire is consistent with this.
To provide a more logical flow, the order of the sub elements under 'Hazard and Effects Management
Process' has been changed since EP 95-0100 Revision 0.
1.1 Visibility
Expectations
Top/senior management of each company shall provide strong and visible leadership to promote a culture
in which all employees share a commitment to HSE. Top/senior management shall:
Expectations
Top/senior management shall be proactive in target setting by:
- Jointly developing and discussing with their managers, employees and contractors HSE ‘result’
and ‘activity’ improvement targets and indicators.
- Ensuring staff shall have HSE ‘results’ and ‘activity’ targets in their appraisal.
- Participating in the review of all HSE ‘result’ and ‘activity’ indicators.
- Immediate and visible response and involvement in the case of an incident or any other upset of
normal business.
- Setting of "minimum expectation" levels.
Expectations
To demonstrate leadership and commitment, top/senior management shall show informed involvement
in HSE issues. This shall be achieved by leaders:
- Reviewing the progress both in the development and content of HSE Management Systems and
HSE Cases e.g. by being actively involved and show leadership initiative in HSE activities and
reviews, at both local and remote sites.
- Making available the appropriate resources and expertise to meet targets (e.g. finance,
technology, skills and training).
- Undertake relevant training.
- Being fully aware of the high priority areas for improvement identified in the HSE Management
System, particularly in relation to legal compliance and stakeholder issues and the status of the
follow up actions.
- Being personally involved in the improvement efforts arising from the formal senior management
‘Review’ of the HSE Management System.
Procedures
- Handbook / checklist for management inspections
- Procedure for developing HSE objectives, targets and plans
In setting objectives, management shall consider the overall risk levels of its activities and shall identify
those critical operations and installations which require a fully documented demonstration that risks have
been reduced to as low as reasonably practicable (ALARP).
This chapter addresses corporate intentions, principles of action and aspirations with respect to health,
safety and environment and the aim of improved HSE performance.
2.1 Content
Expectations
The company HSE and associated daughter policies shall be available to interested parties and shall:
- be consistent with the Shell Group HSE policy and include to the commitment to comply with
applicable legislation, the need for prevention of pollution, and continuous improvement
- be relevant and take account of the current and future nature and scale of the activities, products
and services of the company and stakeholder interests
- include the execution of HSE policies is a line management responsibility
- ensure HSE matters should be assessed before entering into new activities
- take the interests of stakeholders into account
- endorsed by the CEO.
The Chief Executive shall be the custodian of the HSE policy and be responsible for its review.
At least once a year the HSE policy shall be reviewed as part of the formal HSE Management System
review. (Refer 8.0 Review) This review process shall include the results of proactive consultation
with stakeholders on the content of the HSE Policy and take into account the continued relevance of
its intent, scope and adequacy.
Contractor policies shall be consistent with the company policies.
The HSE policy and implementation procedure for a Joint Venture (JV) under the operational control
of a Shell Company shall be the same in all material aspects as that of the Shell Group. The same
shall apply to new/future ventures not under operational control. (Refer Appendix 9 Management of
JV not under operational control of Group HSE Management System.)
For existing Joint Ventures not under the operational control of Shell, then the Shell shareholding
company shall use it's influence to urge it's fellow shareholders and co-venturers to adopt an HSE
policy and implementation procedure the same in all material aspects as that of the Shell Group or at
least 'appropriate'. (Refer Appendix 9 Management of JV not under operational control of Group
HSE Management System.)
- Daughter Policies e.g. smoking, AIDS, alcohol and drugs, bio-diversity, security
- Joint Venture Statement
- Contractors HSE policies
Procedures
- HSE MS Management Review procedure
2.2 Dissemination
Expectations
The HSE Policy shall be communicated to all employees and contractors.
The HSE policy shall be readily available to the public in a language and format that is easily
understood.
All employees and contractors shall be informed of the relevance of the HSE policies and be aware of
their personal role in meeting the requirements of the policies.
Records are retained to demonstrate that employees have received this information.
All employees and contractors shall be informed of revisions to HSE policies.
Procedures
- Staff induction procedures
- Contractor management procedures
- Communication procedures
Expectations
Each company shall establish and maintain documented health, safety and environmental objectives,
at each relevant function and level within the company. These should set out the long and shorter term
HSE aspirations of the company.
Strategic objectives shall be consistent with
the HSE policy and commitments of the company
the products, and activities and services undertaken by the company
the Group HSE policies and commitments
Strategic objectives for a company shall address as a minimum, those aspects identified in the 'EP
HSE objectives and minimum environmental expectations e.g. flaring, venting, emissions and
discharges, certification and groundwater monitoring.
Strategic objectives shall address relevant legislation, permits, consents and other requirements.
The strategic objectives shall provide a framework for setting and reviewing HSE targets in the HSE
Plan (Refer 5.1 HSE Plan) to ensure continuous improvement.
Procedures
- Procedure for the development of HSE Plans
- Procedure for the identification of objectives and targets
- Procedure for updating, maintaining register of HSE legislation and obligations
Expectations
The organisational structure, roles, responsibilities, authorities, accountabilities and interrelations
(e.g. partners, contractors, regulators) necessary to implement the HSE MS shall be defined,
documented, communicated and reviewed at regular intervals.
The management of the organisation shall appoint (a) management representative (s) who shall have
clearly defined roles, responsibilities, authority and resources for ensuring that HSE MS requirements
are established, implemented and maintained in all locations and spheres of operation within the
organisation. These accountabilities should align with the EP Business Model (EPBM – Version 3).
The Management Representative shall be accountable to senior management and should have
sufficient knowledge of the company and its activities, and of HSE issues, with sufficient authority to
undertake the role effectively. They shall regularly report on the performance of the HSE MS to top
management for review and as a basis for improvement. They shall ensure the implementation of the
HSE MS in accordance with this Guideline. (SIEP guidelines, the Group Procedure, international
standard requirements and corporate risks (which assures compliance with SIEP guidelines, the
Group Procedure and ISO 14001).
The application of the HSE MS to a local operation or plant shall be the responsibility of the local
line management in accordance with the asset management hierarchy.
All HSE Critical Activities1 shall be identified and recorded in the HSE MS (see 3.7 Documentation
and Control HSE-MS) and HSE Case(s) (see 3.8 Documentation and Control HSE Cases).
Responsibilities shall be assigned to every HSE critical activity and inputs and outputs necessary for
its control recorded. Performance standards and mechanisms for verification shall also be in place.
Employee (company and contractors) competencies for HSE critical activities shall be defined and
responsibilities and requirements associated with the control of the activities understood by the
employee.
HSE responsibilities shall be updated and revised in conjunction with employees (company and
contractor).
1 HSE Critical Activities are those activities which when performed satisfactorily contribute to the control of hazards. An
HSE Critical Activity is an activity with an objective which contains some element of the four steps of the hazard and
effects management process i.e. - identify, assess, control and recovery. HSE critical activities can be at all levels within
the company. The objectives of those HSE Critical Activities for which senior management is responsible relate to such
things as establishing HSE policy, strategy and objectives, external relations and revising the HSE MS. Examples at a
'process' or technical support level are setting procedures, at a supervisory level or 'manage activity ' level - planning,
execution and monitoring and at task level - the direct management of control and recovery measures are HSE critical.
Expectations
The HSE Advisor (or management representative for HSE) shall have direct access to top/senior
management.
HSE advisors shall be HSE competent persons who meet the relevant regulatory and professional
requirements to be able to provide professional HSE advice to the line.
HSE advisors can be the custodian of the HSE MS but shall not be responsible for the management
of HSE critical activities. This is the responsibility of the line. HSE advisors are responsible for the
quality and timeliness of HSE advice.
HSE advisors shall monitor and communicate information on HSE issues (Shell, national and
international, legal requirements, stakeholder concerns) and best practice from internal and external
sources.
HSE advisors shall collate HSE performance reports and maintain HSE performance data for internal
use - including input to the review by top management and co-ordinate the preparation and
verification of the annual HSE Report.
HSE advisors shall maintain an independent schedule of HSE audits/inspections and participate in the
review of findings from all audits / inspections / incident investigations.
3.3 Resources
Expectations
Top/Senior management shall ensure that sufficient resources are available to ensure the effective
operation of the HSE MS and effective management of risks. This shall include resources available
for:
- prompt rectification of HSE–related deficiencies identified by the company or regulators
- on-going verification that HSE Critical systems function in accordance with the design intent and
objectives
- ongoing training to maintain and enhance competencies
high calibre line staff to be posted in HSE function.
Staffing HSE Critical Activities as specified.
Current resourcing levels shall be sufficient to meet the requirements for staffing all HSE critical
roles and shall be regularly reviewed.
Procedures shall ensure that any changes in resource level do not increase HSE risk e.g. leave
rotations shall ensure resourcing does not drop to a level that will compromise HSE Critical
Activities.
Procedures
- Manual of Permitted Operations (MOPO)
3.4 Competence
Expectations
All HSE critical activities shall have defined competency levels recorded in the HSE MS or HSE
Case.
All personnel who perform HSE critical activities are HSE critical staff and require appropriate
experience, qualifications and training to ensure their competence to undertake these important risk
control measures.
An HSE competency assurance process should be in place for all HSE critical employees (company
and contractor). This shall document the required and actual HSE competence of employees.
The competency requirements of all HSE critical activities shall be periodically reviewed and
improved where possible. The competence of employees shall be reassessed and shortfalls addressed.
Procedures
- Competence assurance system
3.5 Contractors
Expectations
Contract HSE risk shall be formally assessed for every contract prior to the invitation to tender.
A person within the company shall be identified for every contract as being responsible for all
activities in the contracting process and the execution of the contract.
Contractor HSE competence shall be assessed against the HSE risk in every contract prior to contract
award.
Contractor mobilisation shall be conditional upon receipt of an acceptable HSE Plan based on the
level of HSE risk and suitable interface arrangements to ensure compliance with the company HSE
MS. All high-risk contracts shall have a documented demonstration as to how the risks from hazards
and effects are reduced to ALARP. This can be in the form of a HSE Case for major contracts or an
HSE Plan.
An HSE inspection / audit programme for all contracts shall be in place monitoring the effective
implementation of the HSEMS and interfaces between the contractor and company.
Contracts shall specify an inspection / audit timetable, action to be taken in case of non compliance
with standards, terms and conditions defining reward or penalties for HSE performance and the
requirement for at least an annual formal review of HSE MS for contracts running for long periods.
Companies are able to demonstrate that the HSE MS of contractors are subject to continuous
improvement in the course of project execution.
Procedures
- Contractor HSE management procedures
- Contractor HSE pre-qualification
- Model Contract HSE specifications
- Assessment of Contract HSE Plans
- Monitoring HSE in contracts
3.6 Communication
Expectations
The hierarchy of HSE meetings and information flows within the organisation shall be described and
documented.
All employees (company and contractor) shall be made aware of their HSE responsibilities during
their induction. Records of the HSE induction process should be maintained.
All employees (company and contractor) shall be aware of key HSE information, expectations and
process for raising concerns.
HSE Committees shall focus on relevant HSE issues and provide a framework for communication on
the management of these issues by:
- stimulating effective two-way communication on HSE issues between management and personnel
e.g. for the review of policies and procedures.
- engaging all staff in the implementation of HSE management
- serving as HSE advisory bodies to management and promoting suggestions for improvement
- monitoring measures taken for the prevention of accidents, their implementation and adherence
- organising inspections and audits focused on unsafe, unhealthy or environmentally unfriendly
practices
- reviewing reports of inspection and audits
- monitoring follow-up of accidents and incidents that have occurred
- endeavour to secure the co-operation of all persons in the promotion of HSE
- advising on HSE training, instructions and guidance of workers.
Procedures for internal HSE communication shall be in place and reviewed periodically. These shall
describe mechanisms for encouraging two way communications on HSE issues within the
organisation.
Procedures shall be in place for the management of external communications. These shall address:-
- HSE issues raised by stakeholders
- the registration and processing of public complaints
Information on the HSE policy, targets and performance shall be formally reported and available to
stakeholders, with a mechanism in place to collect feedback.
Methods shall be in place to motivate staff to be more aware of HSE controls and to develop an HSE
Culture. This can include:
- The direct and personal interest shown by a supervisor in his subordinate’s work through
immediate recognition or criticism, this remains a most powerful motivational and behaviour
modification technique in HSE matters.
- HSE performance boards sited in prominent locations with regular update provides focus to the
HSE effort.
- Incentive schemes can provide motivation and focus but should not be complex and time consuming
to manage and above all must be seen to be fair. They should preferably be based on proactive
indicators rather than reactive indicators such as, e.g. lost time incident (LTI) or total recordable case
frequency (TRCF).
- HSE performance targets in team and individual scorecards
Procedures
- Procedure for internal communication and reporting
- Procedure for managing external communications
Expectations
A system shall be in place for the management and control of documents in paper and/or electronic
format. This shall include formal administration, custodianship for technical correctness and
communication of correct use.
There shall be a manual that describes an HSE MS compliant with the guidance contained in this
document and international standards. This information shall be accessible to employees and
contractors in the most effective format. The manual shall be updated and upgraded in line with
requirements for continuous improvement.
The function of the manual is to describe or reference the processes, documents and standards used to
manage HSE and assist employees and contractors in understanding how the company will meet the
objectives of the HSE Policy.
The HSE MS may be described in different ways but typically this is done in a 5-part manual as
follows: -.
- A description of the management system under the same headings as this Guideline.
- A catalogue of HSE Critical Activities and the specification of these activities and their associated
tasks.
- A list of all the documents and standards referred to in Parts 1 and 2 with details.
Procedures
- Documentation and documentation management procedure
- Web management and control procedures
Expectations
The company shall identify and document those critical operations and installations, which require a
fully documented demonstration that risks have been reduced to a level as low as reasonably
practicable (ALARP) (Refer 4.0 Hazard and Effects Management). HSE Cases compliant with
regulatory requirements and EP guidelines shall be available for these operations and installations
defined as critical. The HSE Cases shall be endorsed by the Asset or Process Owner and by those
managing the asset or operation.
The HSE Case should also accurately reflect current practice at the location or site and be reviewed
as per described Case review cycles.
Contractors managing HSE critical activities shall have HSE Cases or equivalent documented
demonstration in place.
The HSE Case should demonstrate that controls in place reduce risks to ALARP.
The HSE Case shall detail activities that must be discontinued or restricted in given circumstances.
These circumstances might be when HSE critical equipment is not available, during adverse weather
or when particular non-routine hazardous activities are being carried out. This is described in a
Manual of Permitted Operations (MOPO), Manual of Simultaneous Operations (SIMOPS) or
Manual of non-Concurrent Operations.
The HSE Case is typically described in a 7-part document as follows: -.
- This includes summary of the Case objectives, the main findings and risks, and a brief introduction to
the main document. Sometimes the management summary is extracted as an executive document for
easy distribution to senior managers, leaving Part 1 as the Introduction.
- A description of those elements of the HSE Management System that are directly applicable to the
operation or facility.
- A description of those HSE-critical activities applicable to the operation or facility. This is recorded
at a level, which shows that the controls are in place, and that these are suitable and sufficient for the
risks addressed.
- A description of the operation or facility, adequate to provide background information to the hazards
and effects analysis, to enable a clear understanding of HSE-critical aspects. This will include, for
example, safeguarding systems and emergency response capabilities.
- This contains a demonstration that all hazards and effects have been identified, and the necessary risk
evaluation has been carried out and that necessary controls to manage the causes and consequences
are in place for those risks identified as significant through a process of ranking. Significant
environmental effects* will be included if the case is to be used for compliance with ISO-14001,
(*) For ISO 14001, this will include a description of those 'aspects' which result in environmental
effects.
- Typically, the controls and procedures in place to manage environmental, occupational health and
workplace hazards and effects (aspects) which occur across the company are described in one place
and referred to from the Case. Those responsible on the facility for ensuring that the procedures are
followed are identified in the management system in Parts 2 & 3 of the Case.
Part 6 Shortfalls
- This summarises any shortfalls identified, with a plan to resolve the findings and thereby improve the
operation.
- The Statement of Fitness explains that the hazards and effects associated with the installation or
operation have been evaluated and measures have been taken to reduce the risks to the lowest level
that is reasonably practicable. The Statement of Fitness must affirm that conditions are satisfactory
to continue the operation.
Procedures
- Specification for selection of facilities and operations requiring HSE Cases
an inventory of the major hazards to the environment and to the health and safety of people of all the
activities, materials, products and services.
an assessment of the related risks, implementation of measures to control these risks and to recover in
case of control failure.
Health risk assessment shall address physical, chemical, biological, ergonomic and psychological health
hazards associated with the work.
Environmental (impact) assessment (including a consideration of social impacts) shall be conducted prior
to all new activities and facility developments, or significant modifications to existing ones.
Soil and groundwater contamination shall be assessed and, where required, control or remediation shall be
in-hand.
Product stewardship shall be applied at all stages of product life cycle relevant to the company's
activities.
An HSE assessment shall form an integral part of any proposal for acquisition, divestment, abandonment
or merger of business entities.
There are 4 steps in the HEMP process: ‘identify’, ‘assess’, ‘control’ and ‘recover’. EP 95-0300 contains
detailed information on HEMP. For illustrative purposes these four steps are often described sequentially.
However in practice, the stages are not always distinct, and may be combined in procedures and/or
structured review techniques such as HAZOP, QRA etc. It must also be recognised that HEMP is an
iterative process.
Expectations
The HSE MS shall include procedures for the systematic identification of the health, safety and
environmental ‘hazards, effects and aspects’ that may either affect, or arise from, the activities and
services of the company. These shall cover routine, non-routine and emergency operating conditions
and activities of all personnel having access to the workplace and facilities at the workplace. The
HSE MS shall list the acceptable HEMP tools and identify employees responsible for using them.
Procedures for HEMP shall be based on the judgement of experienced staff, company, industry, Shell
and international standards; checklists and structured review techniques as described in Shell
guidelines.
The scope of the identification step shall include those activities that the company can have control of
and over which it can be expected to have an influence. It shall cover the whole lifetime of a project
(e.g. from inception through to decommissioning and disposal).
A comprehensive inventory or register of HSE hazards and environmental aspects for all units in the
company shall be maintained.
Procedures shall include a process for updating the hazard, effects and aspect inventories/registers as
a result of plant changes, changes to the operation or findings from e.g. job hazard analyses,
inspections or incident analyses.
4.2 Assessment
Expectation
The company shall develop and maintain procedures to assess the HSE risks and significance of the
identified ‘hazard, effects and aspects’ for all operations and assets, compliant with Shell Group HSE
Guidelines, EP HSE Manual guidance and international standards e.g. should be proactive rather than
reactive.
All hazards, effects and aspects identified in the HEMP process shall be ranked in terms of risk.
A qualitative assessment of risk is adequate for most situations but for example in the comparison of
more complex alternatives, or as a regulatory requirement, it will be necessary to undertake a
quantitative risk assessment (QRA). (Refer EP 95-0352)
A process shall be in place to determine on the basis of risk, those hazards, effects and aspects that
require controls and the nature of these controls (i.e. those deemed 'significant' in ISO 14001
terminology) 1.
For the qualitative portrayal of risk and screening criteria for potential incidents and chronic effects,
the concept of the risk matrix (Figure 4.0) shall be used.
In all cases consideration shall be given to risk reduction to achieve a level deemed 'as low as
reasonably practicable' (ALARP), reflecting cost-benefit considerations.
Hazard assessment and significance evaluation methodology takes into account:
- Legal and regulatory requirements
- Company and Group policies
- Company and Group standards
- Reputation - consideration of the concerns of stakeholders and in particular the public and
employees
- Industry Standards
- International Standards
- Lack of available information to determine risk or significance e.g. uncertainty in scientific
knowledge
- Financial/ cost benefit considerations of risk reduction measures
The assessments (hazard register and aspect tables/registers) shall be updated at specified intervals
defined in procedures. The assessments shall be reviewed when circumstances change as part of the
change control procedure.
1 In ISO 14001, a 'significant' environmental aspect is an environmental aspect that has or can have a
significant environmental impact and as such must be subject to procedural control.
Assessments shall be conducted by qualified and competent personnel and solicit input from
personnel directly involved with the risk.
CONSEQUENCE INCREASING
S Environmen A B C
LIKELIHOOD D E
Severity
Reputatio
Never Heard of Incident Happens Happens
People
Assets
n
Company our location
t
Company
0 No health No damage No effect No impact
effect/injury
1 Slight health Slight Slight effect Slight impact
effect/injury damage
2 Minor health Minor Minor effect Limited
effect/injury damage impact
3 Major health Localised Localised Consider- Low
effect/injury damage effect able impact Risk
4 PTD* or 1 to Major Major effect National Medium
3 fatalities damage impact Risk
5 Multiple Extensive Massive International High
fatalities damage effect impact Risk
* Permanent Total Disability
4.3 Recording
Expectations
Records of the hazard and effects management process shall be documented and kept up to date.
Where there is an HSE Case, the records shall be included in Part 5 (Refer 3.8 Documentation - HSE
Cases).
The HEMP process shall record the activities that must be discontinued or restricted in given
circumstances i.e. a Manual of permitted operations (MOPO) or a Manual of Simultaneous
Operations (SIMOPS).
The recovery action that should be taken in the event that a control fails shall be documented.
All documentation shall be kept up to date, accessible and understood by the supervisors responsible
for operational decisions.
Systems shall be in place to ensure that all recommendations and actions arising from hazard and
aspects analyses and reviews are recorded and closed out.
Procedures
- Change Management Procedures
Expectations
Performance indicators shall be in place for all HSE-critical activities. These shall be documented in
the specification of the activity together with parties responsible for each indicator.
Performance against each indicator shall be monitored and measured routinely. The results shall be
trended and reviewed (Refer 6.1 Performance Monitoring).
Procedures for reviewing employee performance shall include HSE performance indicators. Good
team/employee HSE performance shall be rewarded by team/staff appraisal systems.
Expectations
During the design stage, HSE risks shall be made ALARP. Emphasis shall be on the prevention of
incidents through removal or reduction of hazards and lowering the probability of incidents.
In the operations phase, the HSE MS procedures shall provide a demonstrable link between each
significant risk and a set of controls or risk reduction measures e.g. through a HSE Case, critical
activity records.
The controls shall be commensurate with the risks. Responsibilities for their implementation shall be
clearly defined, understood and assigned to an individual.
Control shall include documented procedures or work instructions which are developed and
maintained stipulating responsibilities, HSE requirements (e.g. maintenance, contractor management,
suppliers) and acceptable standards for performance. These will cover situations where their absence
may result in deviations from the HSE policy and the objectives and targets.
Controls shall be reviewed and updated through inclusion in improvement programmes (HSE Plans
and HSE Case remedial action plans).
Procedures
- Procedure for the inventorisation, evaluation and registration of Hazards, Effects and Aspects.
- Procedure for the Management of Change
- Permit to work
- Hazardous Area Classification Plans
- Operational control procedures and work instructions
4.6 Recovery
Expectations
Control and recovery procedures shall be in place and recorded in the HSE MS and HSE Case. The
recovery action that should be taken in the event that a control fails shall be documented. The persons
responsible for maintaining and implementing each procedure shall be defined. Responsible parties
shall be competent and clearly understand their responsibilities.
Procedures for the recovery from scenarios with high risk and for emergency response shall be in
place and subject to testing and review. Procedures shall be regularly updated in light of incidents,
analysis of the drills and industry best practice (Refer 5.5 Contingency Planning and Emergency
Response).
Procedures
- Emergency Response Procedures
- Oil spill clean up procedures
- Medevac Procedures
Emergency response procedures (including medical, operational and environmental emergencies) shall be
regularly tested.
Expectations
Within its Business Planning Cycle, the company shall prepare an annual HSE Plan to meet the
company policy and continuous improvement objectives, one and five year targets, as well as making
good any deficiencies identified in the HSE MS. The plan shall clearly identify accountable parties
and targeted completion dates, based on one and five year performance targets for continuous
improvement (Refer 2.3 Strategic Objectives). The Plan shall be linked to the Business Plan.
A process shall be described for the development of the HSE Plan. The process shall indicate
resources required responsibilities and the timetable to build the HSE Plan.
HSE Plans shall cover such activities as existing operations; modifications to existing facilities,
acquisitions; new developments; abandonment programmes; geological surveys; exploration of
development programmes.
HSE Plans shall take into account present and anticipated future legislative and regulatory
requirements (identified in registers of legislation), intolerable hazards, effects and aspects,
technological options, financial, operational and business requirements and views of stakeholders.
HSE targets relating to the Company HSE Plan shall be communicated to employees annually.
Procedures
- Procedure for the development of HSE Plans
- Procedure for the updating and maintaining register of HSE Legislation and Obligations
- Business planning guide.
Expectations
The company shall establish and maintain procedures that ensure: -
there is a clearly defined responsibility for asset ownership
that there is a signed statement of fitness to demonstrate that existing operating facilities, new
facilities and modifications to existing facilities are designed constructed and commissioned in
accordance with company and external standards, codes and regulations
deviations from the design intent and/or the existing standards and codes require authorisation in
accordance with the companies management of change procedure (Refer 5.4 Management of Change)
there is an auditable process of validation by engineers and supervisors of both the original design
and subsequent changes
the documentation necessary (including the HSE Case) to support operation, maintenance and
inspection is complete prior to facilities start-up
those activities and equipment critical in the safeguarding of asset integrity shall be identified in the
MS (typically in the HSE Case, Asset Reference Plan or Operations Reference Plan)
the equipment critical in the safeguarding of asset integrity during the life cycle shall be subject to
controls including maintenance , performance testing, and inspection, a transparent inspection
philosophy and programme and a programme of recorded management and cross-discipline/cross-
facility inspections
the company shall establish and maintain procedures that ensure that the design of new facilities shall
be conducted in line with the Hazard and Effects Management Process. (Refer Part 4 Hazards &
Effects Management Process)
Procedures
- Operations Philosophy and/or Maintenance Strategy
- Company design and engineering practices
- Change Management Procedure (e.g. design, construction, operation, inspection and maintenance)
Expectations
All HSE-critical activities and the supporting tasks shall have written procedures or work instructions
in place as necessary. HSE Critical Activities for the company shall be listed in Part 2 of the HSE
MS.
HSE standards and procedures shall be listed in Part 3 of the HSE MS. The appropriate standards
and procedures shall be readily accessible to employees, suppliers and contractors and be written in a
way that users will understand. Asset Managers shall ensure that relevant HSE procedures and
requirements for their assets are communicated to suppliers and contractors.
A defined process for the development and review of HSE standards, procedures and work
instructions shall be in place, which includes employee involvement. This process must ensure that
HSE objectives are achieved, best practices are incorporated and legislative requirements are met.
Shell Design and Engineering Practices (DEP) or equivalent company standards shall be consistently
applied and variances shall be subject to a control procedure.
There shall be evidence that in addition to the formal review cycle, modifications to standards,
procedures and work instructions are initiated by operations personnel and reviewed in light of
incidents.
Procedures
- Procedures and work instructions for ‘Operational Control’
- Documentation management and control system
Expectations
The company shall maintain written procedures for the planning and control of all changes (i.e. not
only equipment changes but also organisational restructuring), both permanent and temporary, in
people, plant, plant controls, processes, and procedures, to assess HSE impact and avoid adverse
HSE consequences.
Change control procedures (corporate, BU/asset, projects) shall document the evaluation and
approval process, and the responsibilities and competencies of those involved.
Comparative analysis and documentation of the HSE impact of implementing the change as well as
the HSE impact of the implemented change shall be an integral part of all change control procedures.
Procedures
- Change Management Control procedure
- Security and control of process equipment software
Procedures
- Emergency response documents including interfaces with outside organisations and response
equipment
Procedures
- Procedure for HSE Reporting and HSE data collection (incl. accidents and near miss).
- Procedure for Monitoring
- Procedure Manual for compliance monitoring
- Complaints handling system
- Staff appraisal system
6.2 Records
Expectation
The company shall establish and maintain procedures for the identification, maintenance and
disposition of HSE records. These should include:
- Reports of audits and reviews
- Audit tracking data
Procedures
- Document Management Code of Practice
- Web Management Code of Practice
- Procedure for HSE Data Reporting and Record Keeping
Expectation
The company shall maintain procedures for defining responsibility and authority for:
- the handling and investigating of non conformances with legislation, regulations, HSE MS
policies, procedures and standards
- identify root causes and taking action to mitigate any consequences arising from such non
conformances
- the initiation and completion of corrective and preventative actions
Procedures
- Procedure for non-conformance
- Legal Compliance Monitoring
- Change Control Procedure
Expectation
The company shall maintain procedures for the reporting and investigation of hazardous situations,
near misses and incidents, which are compliant with the Company and Group policies and procedures
and international standards.
Incidents shall be investigated in a timely manner, with accountabilities assigned, and progress on
recommended actions monitored until close out.
The company shall foster a culture of openness in reporting all incidents and near misses.
Employees shall be aware of the near miss and incident reporting procedures and participate in
incident investigations.
Any corrective or preventative action taken to eliminate the causes of potential incidents shall be
appropriate to the magnitude of problems and commensurate with the HSE risks encountered.
Training shall be provided in incident investigation to appropriate staff throughout the company.
The company shall implement and record any changes in the documented procedures resulting from
corrective and preventative action. Lessons learnt from accidents and incidents shall be disseminated
to relevant personnel and contractors.
Procedures
- Incident Reporting and Investigation Procedures
7 AUDIT
Expectations
The company shall establish and maintain an audit programme and procedure for HSE audits to be
carried out in accordance with Group and international standards and regulatory requirements.
A rolling (e.g. five year) audit plan shall be established including HSE audits of all facilities and
operations on a fixed time scale appropriate to the facility and the risks associated with the activity or
the operation.
Audit programmes shall include:
- HSE MS audits
- ISO 14001 audits (where appropriate)
- independent audits (that is, audits led by auditors approved by the EP Business HSE Advisor on
behalf of the Company)
- specific activity audits (facilities, start up, drilling, seismic, occupational health).
A detailed annual plan for audits shall be in place, that shall cover the whole HSE MS including
operations and projects that have been contracted out.
Only personnel, who have received adequate training, shall lead audits. (Refer 7.2 Auditor
Competency).
The company shall maintain an effective control process to ensure that audit findings are recorded,
prioritised, corrective actions identified, action parties are assigned and targeted completion dates are
identified and findings tracked to final close- out. Best practices and key lessons learned should be
shared with all locations/assets as appropriate.
A periodic review by management of audit findings/trends and follow up action plans shall take place
(Refer: 8.1 Review).
Procedures
- Management of Contractor HSE
- HSE Audit procedure
Expectation
Audit procedures shall specify the requirements of audit teams in terms of competency, experience in
subject area of the audit and impartiality.
An audit focal point or department responsible for the audit process shall co-ordinate the appointment
of competent HSE auditors.
A competence assurance system shall be in operation to define auditor competence and ensure that
relevant HSE auditor training is provided.
A number of staff from different areas of the company shall be competent to carry out HSE audits.
Procedures
- HSE Audit Procedure
Expectation
Contractors shall provide senior personnel to participate in company led integrated HSE audits of the
operations contracted to them.
Contractors shall have an HSE Audit process and schedule for audits, which includes audits carried
out by independent auditors. Records of results of audits, findings and corrective actions are
retained.
8 REVIEW
Group HSE MS Procedure Requirement
Management shall regularly review the suitability and effectiveness of the system.
8.1 Review
Expectations
A formal process shall be in place for top/senior management to review the effectiveness and
suitability of the MS in managing HSE risks and ensuring continuous improvement in HSE
performance.
The Review shall address but not be limited to:
- the findings of previous reviews;
- the need to change HSE policies and strategic objectives;
- the impact of significant organisational, location or activity changes;
- the HSE concerns of employees, contractors and external stakeholders;
- the provision of adequate resources and competent personnel to achieve HSE targets objectives
and strategies;
- audit findings;
- Self Appraisal Assessment (HSE-MS);
- verification of closure of corrective actions resulting from HSE reviews, audits, self assessments,
inspections and incident investigations and
- review of legal compliance.
Management Reviews of the MS shall take place on an annual basis preferably within the Business
Plan cycle and before the preparation of the annual Assurance Letter.
The completeness and validity of the data used as the basis for submission of the Annual Letter of
HSE Assurance to SIEP will be assessed.
Performance against annual HSE Plans and Department HSE Plans shall be reviewed regularly.
Results of Management reviews and identified remedial actions shall be documented and monitored
until conclusion.
Procedures
- HSE MS Management Review procedure
APPENDIX I
FIVE PARTS OF AN HSE MS MANUAL
An HSE Management System may be described in different ways but typically this is done in a 5-part
manual as follows: -
The most fundamental obligation for the company is to assemble and maintain a register/copies of HSE
legislation (local, national and international) applicable to their operations. Such a register consists
typically of laws, permits, licences, regulations, international treaties, codes of practice and other
requirements.
Shell Group policy on standards is to rely, to the maximum possible extent on external international
standards, such as ISO. The active participation in the development of such standards is aimed at
minimising the additional requirements necessary when these standards are adopted in the Group DEPs,
SSHEC Guidelines and in Shell companies and projects.
APPENDIX II
COMPARISON WITH OTHER STANDARDS
Relevant Clauses in:-
OHSAS
18001
HSE -MS - this Guideline
APPENDIX III
GLOSSARY
The general glossary for the EP HSE Manual is now in a separate Section EP95-0010 Glossary.
INDEX
A N
ALARP, 2.0, 3.5, 3.8, 4.2 near misses, 6, 6.4
Aspects, 3.8, 4.2, 4.5, App I (part 5) non compliance, 3.5, 6.3
Asset Integrity, 5.2
asset management, 3.1 O
C Operations Reference Plan, 5.2, 5.5, References