UNIT-IIINeed for HSE Management SystemRegulations alone are not enough to maintain a very high level of safety in petroleum and allied industries, which have many inherent hazards.

In order to prevent major accidents and mishaps and to win confidence of general public, management leadership and commitment is very essential.Even for implementing and compliance of regulatory measures, a committed leadership is necessary.

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This can be achieved by establishing an effective and efficient Health, Safety and Environment (HSE) Management System.

Important features of an effective and efficient HSE Management System are:

HSE Policy

Every organization must have a written policy on health, safety and environment signed by the Head of the organization with date.

The copies of this policy should be displayed at prominent places in the organization so that everybody is familiar with its contents/intentions.

Some organizations ensure that every employee receives a copy of its HSE policy.

HSE policy spells out the values, beliefs and commitments of the organization towards health, safety of its employees, community and at the macro level of the nation.

What does ‘HSE POLICY’ Contain?

1. Health and safety of personnel and protection of environment override all production targets of organization.

2. Production and HSE are complementary to each other.

3. Safety and environment protection is everybody's business in the organization.

4. All statutory requirements must be complied with at all times.

5. All personnel must use approved safe working procedures without making any risky short cuts.

6. All personnel - owner or contractors - must be given relevant training before assigning them work

7. All plants, facilities and work procedures/ systems must be audited periodically by in-house teams as well as external agencies.

8. Plant and ambient environment as well as various effluents must be monitored continuously to maintain a clean and safe environment in and around the plant.

9. A very high standard of house keeping must be maintained at all places of work-plants, offices and facilities.

10. Every employee must be subjected to medical check-up for early identification and treatment of any occupational health hazard.

11. All employees must keep abreast with the latest codes, standards and practices on health, safety and environment.

12. All accidents, however small, must be investigated and followed up. The lessons learnt from these accidents should be disseminated to all levels of workforce

What does ‘HSE POLICY’ Contain? (Cont…..)

13. No modifications in plant, facilities will be done without proper scrutiny and approval by an authorized person(s)

14. No contractor will be engaged without ascertaining his safety performance / record

15. Non-compliance of this policy will attract severe disciplinary action

What does ‘HSE POLICY’ Contain? (Cont…..)

HSE Organization

It is important that the Chief of HSE should report to the Head of the organization in order to have HSE management of an organization an efficient and effective.

HSE should be an advisory function reporting to the top management and all other officials should be directly responsible for Health, Safety and Environment activities pertaining to their respective departments.

HSE Organization ( Cont…..) If HSE Chief occupies a junior position in the organizational hierarchy, he cannot work without fear or clash of interest with other functional managers.

HSE Chief should have authority and importance say in the decision making process. Even some regulatory agencies also recommend HSE Chief reporting directly to the Head of the organization.

HSE Chief should be a qualified engineer with long experience in various functions.

HSE Organization ( Cont…..)

He should have a team of qualified professionals to advise on safety, occupational health, fire protection and environment.

The number of professionals in HSE will depend on the size and diversity of the organization.

Custodianship / Ownership

Health, Safety and Environmental management is a teamwork. Every member of the team contributes in maintaining a high level of safety in his area of work.

In order to manage HSE effectively in a petroleum installation or complex which is usually a large entity it is important and desirable to demarcate each area of the installation / complex and assign the ownership / custodianship to a senior member of the concerned area.

Custodianship/Ownership ( Cont…..)These areas are commonly called safety districts. A big petroleum complex may have 10-15 safety districts. These districts should be shown on the layout drawing of the complex with all the boundaries clearly identified and marked. The objective of safety districts is to decentralize the HSE responsibility to the functional owner/ custodian of the area who is fully responsible and accountable for all management functions in his district.

Plans and ProceduresPlans and procedures are the basis of setting up an effective and efficient management system.

A large number of industrial accidents and mishaps have occurred all over the world due to human errors and the main cause of these errors has been the lack of written procedures and/or non-compliance of the same.

In some cases, courts have penalized the organizations because victims of the accident did not have written procedures to be followed by them.

Plans and Procedures ( Cont…..)

It is essential that well-written and approved operating and safety procedures of all important activities/functions performed in any petroleum installation are in place and the same are strictly followed.

No short cuts to these procedures should be allowed.

The various HSE related procedures should be developed broadly based on Process Safety Management System, PSM, which is a well-known framework of HSE management all over the world.

Plans and Procedures ( Cont…..)All these procedures should be compiled in the form of an HSE manual - many times called the HSE bible.

The procedures relevant to a particular installation should be identified and documented clearly in simple language so that everybody working in the installation understands these.

These procedures should also be accessible to all concerned.

The procedures should be revised and updated periodically to reflect changes that might have taken place over time.

(A) Safety Related Procedures Basic safety rules for employees, contractors and visitors

Safe work permit system

Pre-start up safety review

Entering and working in confined spaces

• Working at height

• Safe scaffolding and ladders

• Safe evacuation

• Safe handling of hazardous substances

• Safe handling of hydrogen sulfide, chlorine, ammonia etc.

(A) Safety Related Procedures ( Cont….)

• Safe uses of hoses

• Contactor safety

• Radiation safety

• Traffic safety inside and outside the installation

• Safe use of cranes, hoists and other mechanical devices

• Safety in manual handling of material

• Accident/ incident reporting and investigation

• Selection and safe use of personnel protective equipment

• Safe transportation of hazardous materials by road, water and rail

• Management of plant changes and procedures

Environment Related Procedures

• Air Pollution Control and Monitoring

• Effluent Monitoring

• Industrial Wastes Management

• Biodegradable and Office Wastes Management

• Fugitive Emission Monitoring

• Ground Water Monitoring

• Environment Inspection and Audit

Occupational Health Related Procedures

• Health Care System

• Medical Management of Obnoxious Substances

• Hygiene and Sanitation

• First-aid

• Health Risk Assessment

• Pre-employment and Regular Medical Checks• Wellness and Fitness Programme for Employees and Families• Emergency Medical Care

Fire Protection Related Procedures

• Fire Services Organization and Job Specifications

• Fire and Emergency Turnouts

• Rescue Operations

• Mutual Aid Scheme

• Inspection and Maintenance of Fire Protection Systems

• Emergency Drills and Fire Training

• Safe Use of Self Contained Breathing Apparatus and Other Life Saving Devices

Basic Safety RulesIt is absolutely necessary that all employees, contractors, visitors, vendors and other third parties must be fully aware of some basic safety requirements to be followed inside the installation because of inherent hazards in a petroleum installation,

Management should document these basic rules/ requirements and anybody entering the premises must be made familiar with the same.

This document should address following items related to the health, safety and environment aspects of the installation:

Basic Safety Rules ( Cont……)

Access/entry to the premises Prohibition of smoking, alcohol and drugs Restriction on naked lights, sparks, use of cameras and mobile phones Traffic control

Use of Personnel Protective Equipment, PPE

Safe Work Permit System

Accident/Incident reporting

Basic Safety Rules ( Cont……)

Maintaining good house keeping standard

Basic colour codes of piping/equipment, etc.

Electrical safety

Hazards of flammable products & Chemicals

Emergency Alarms & Communication & what to do in such situations

General Dos & don’ts

Basic Rules for Visitors:

As a bare minimum requirement, every visitor to the premises must be given a safety briefing before giving him an entry pass.

A safety briefing developed by petroleum refinery can be:

Access /Entry to the Premises

• Visitors should report to security gate for entry pass

• Every person must display a valid identification badge issued by the security

• Visitor should visit the designated area only for which he has obtained the entry pass

• He should be accompanied by a company employee

• It is forbidden to take children inside the premises

Tobacco / Alcohol Restrictions:

• The entire Refinery is a tobacco Free Zone

• Tobacco in any form – cigarettees , biddies, gutka etc. Is prohibited

• Use of alcohol and drugs is prohibited

Regulations on Naked Lights and Sparks

• Matchboxes, lighters, flashlights and cameras are not allowed inside the premises

• Use of 100% nylon or synthetic clothes inside the premises is prohibited

Traffic Rules

• Vehicles should have valid access pass to enter the premises

• All vehicles entering hazardous areas should have spark arrestor and a unit entry permit

• Maximum speed limit inside the premises is 30 km/hr

• Park the vehicle at designated places

• Overtaking is prohibited

• In case of an emergency alarm, stop the vehicle and take to the side of the road and wait for clearance

General Rules:• Visitor shall be responsible for his own safety

• Photography inside is prohibited

• Never go to the site in case of any fire or other emergency

• Visitor is not allowed to touch any equipment or interfere with the plant activities

• All persons must wear safety helmets and safe shoes in process areas. Requirement of any other personal protective equipment will be advised by plant personnel

• Use following telephone nos. in case required: Fire l00 Security 101, Medical 102

Permit to Work System

Introduction

If precautions are not taken during the work and while handling equipment for repair/ inspection, it can lead to serious accidents or mishaps as petroleum operations are hazardous in nature. e.g.

(1)An explosion can take place if a leaking pipeline is not completely isolated and made hydrocarbon free and a welder tries to weld it.

(2) An electrician can get electrocuted if he works on electrical switchgear without removing its fuses on the supply line and if someone by mistake switched on the supply.

Permit to Work System

(3) Any one can catch fire if he is involved in smoking or he uses any open flame like lighter/ match box etc near the Well Head.. (An area within 30 mts. of the Well Head should be treated as danger zone).

Thus, every petroleum installation must have an approved Permit to Work System in place.

The permit is an official record of safe working conditions agreed upon by the issuer and acceptor of the permit for carrying out any maintenance, repair, inspection or modification work.

Types of Permits

Various permits applicable in a petroleum installation are listed below:

• Cold Work Permit

• Hot Work Permit

• Confined Space Entry / Work Permit

• Excavation Permit

• Permit to Work on Electrical Equipment

• Permit for Closure of Roads

• Permit for using a Radioactive Source

Types of Permits ( Cont…..)

• Permit for Working Over / Under Water

• Vehicle/Crane Entry Permit

• Permit for Photography

• Rock Blasting Operations Permit

Elements of a Typical Work Permit

Every installation should design work permit formats as per its requirement and nature of activities.

OISD and NSC give guidelines for designing work permit formats. Some important elements of a typical work permit are as below:

1.Type of permit2.Date, time of issue and validity3. Description of location where work is to be carried out 4. Brief description of the work5. Detailed safety precautions to be taken

Elements of a Typical Work Permit( Cont….)

6.Name and signatures of person(s) issuing the permit

7.Name and signature of the person receiving the permit

8.Authorization by senior management person depending on seriousness of the hazard

9.Declaration of completion of job by the receiver with date and time.

Permit ProcedureA work permit is generally issued by an operating supervisor called the issuer of the permit to the maintenance supervisor or a contractor, called the acceptor of the permit after ensuring all the necessary precautions. The nature and location work to be done must be clearly specified in the permit by the issuer who should explain and show the same to the accepter.The issuer & the accepter of the permit must be clear regarding the precautions to be followed during work.

Permit Procedure ( Cont…….)After the completion of the work, both parties ( issuer & acceptor) must sign the permit to certify that the work has been completed as intended.Some of the precautions that are required to be taken for giving different work permits are as below:(1)Inspection of location of work.(2) Making the equipment free of HC & other hazardous material .(3) Cleaning the equipment(4) Testing the atmosphere for explosives & toxic gases.(5) Isolation of radioactive sources.(6) Covering Drains and Manholes(7) Putting proper tags/notices/warnings etc.(8) Providing proper illumination and ventilation.(9) Barricading the area(10) Providing necessary PPE(11) Providing proper scaffolding and ladders for working at height.(12) Providing fire fighting equipment(13) Providing standby rescue team

Training & Its Validation:Training is an essential part of any HSE Management program of petroleum industry to ensure safety.The training on HSE is given to all employees – new and also those who are already working, contractors, third parties and visitors to propagate the basic concepts of environmental management.

The extent of training depends on the target group.Leaflets and bulletins are published and circulated for general awareness. The training received by the new employees and contractors is called the initial training which includes comprehensive classroom and practical training in the various HSE procedures applicable installation like basic Fire Fighting Training before he is assigned any work.

Training & Its Validation ( Cont…..)Third parties like Truck Drivers carrying products in / out of the installation and various vendors should also be given HSE training so that they understand the basic safety rules to be followed in the installation.

Every vehicle carrying hazardous goods must display product’s technical name, emergency phone no.etc.

Similarly, visitors should be given a safety brief before entry into the installation so that they don’t do something unknowingly that may put themselves or others into danger.

Many good Companies issue entry passes / ID cards to those entering the premises only after they have received the required HSE training

Training & Its Validation ( Cont…..)Methodology Of Training:

HSE training should be a mix of theoretical classroom lectures & practical training in the use of various fire and safety equipment and appliances.

Extensive use of audio visual aids is used for effective training.

To ensure that a candidate has understood the instructions, some validation is a must. This can be achieved through an objective test at the end of training lession.

Accident Reporting and Investigation

In spite of good systems in place and people taking all precautions while doing their work, the possibility of an accident can not be ruled out.

Thus, it is necessary that each organization should have a good accident reporting and investigating system in place.

Many people, at times, tend to look at accident investigation as an exercise to collect some facts for the sole objective of putting blame on someone for his errors and omissions to set an example.

But, in fact, accident investigation should be a learning process to prevent accidents and for many other purposes.

A proper investigation helps to identify the root cause (s) of an accident enabling the management to take appropriate corrective measures.

The objectives of an accident investigation are listed below:

1.To Define the root cause (s) of the accident to take appropriate corrective measures

2.To Define management errors

3. To Define operating errors

4.To Prevent further accidents

5.To Educate Management and Staff

6.To Identify violations of company procedures

7.To Satisfy insurance requirements

8.To Satisfy News Media

Methodology of Accident Investigations

• The first step is to have a proper accident reporting system.

• In this direction, every petroleum installation should make a standard procedure for notification and reporting of any accident to the concerned officials of the installation and outside agencies.

• This procedure should list the contact telephone numbers of key people. These numbers should be displayed at prominent locations in the installation.

• Whenever an accident takes place howsoever small, it must be investigated.

• The investigation team should be set up which should go into all details .

• If required, external help of a professional accident investigator can be taken.

Methodology of Accident Reporting & Investigations ( Cont…..)

• The team should make an honest report so that right decisions can be taken. Many a times investigations done by internal teams are not very objective.

• If we have to learn from an accident and take proper corrective actions to avoid recurrence, the investigation report must be frank and unbiased.

• There should be a system to follow up the investigation report.

• Management should ensure that an agreed upon actions are completed in a time frame.

• The lessons learnt from the accidents should be disseminated to all the concerned personnel in the complex.

HEALTH, SAFETY & ENVIRONMENTAL AUDIT

Statistics show that the root cause of many major accidents and mishaps all over the world is human error.

And the main cause of human errors has been the lack of written procedures and /or non-compliance of the same.

Many a times systems /procedures are not followed and hardware is not maintained, inspected and tested as intended.

Sometimes the procedures are bypassed because of negligence & over- confidence.

HEALTH, SAFETY & ENVIRONMENTAL AUDIT

Auditing is required to exercise control on the total HSE Management System and ensure that the systems are working effectively and a desired level of Health, Safety & Environmental Standards are maintained as per the requirements of the Company policy and statutory requirements. Such Audits are conducted periodically.

Objectives of AuditsMajor objectives of audits are:

• To ensure that all statutory requirements are met fully.

• To ensure that set procedures are complete, up to date and compliant with applicable standards, codes, company policies, good engineering and process safety practices.• To ensure that the management systems in place are effective.• To identify opportunities where the systems and procedures can be strengthened. • To check on the training & preparedness of personnel to handle any emergency situations• To Cater to public opinion.

Types of Audits

HSE audits are broadly categorized as: (1) Internal audits (2) External audits.

Internal AuditsInternal audits can be periodic detailed audits of an installation conducted by a multi-disciplinary team drawn from various departments of the installation.

In a company having more than one site, inter-site audits by combined teams drawn from various sites can also be a good method of conducting internal audits.

An internal audit may take 3-4 days by a team of 4 - 5 professionals from different disciplines.

The audit team reviews the systems, procedures and facilities for complete and updated documentation and their compliance.

Each plant /facility of an installation should be audited every two to three years.

Besides detail or comprehensive internal audits, there are mini audits.

Internal Audits ( Cont…..)

A mini safety audit is of short duration (typically 2-3 hours) conducted by a two - men team using checklists to ensure the compliance of a particular procedure at a time.

Such audits are done more frequently to cover various procedures relevant to the installation.

This is a very useful and quick method of finding the weaknesses/ deficiencies in the system.

Another type of internal audits is called BSC audits. These are self-audits based on British Safety Council's standard checklists. Each plant/department maintains these checklists for various systems pertaining to its activities.

Internal Audits ( Cont…..)

External Audits

The external audits are done by outside or third parties approved by statutory authorities to meet the requirements under various statuary rules and regulations.

In leading companies, external audits are done not only to meet statutory requirements but also to bring in a fresh approach and additional objectivity through a third eye.

The external audits are supplementary to the internal audits.

Some typical external audit agencies approved by various statutory, authorities include:

1.OISD

1. British Safety Council

2. National Environmental Engineering Research Institute, NEERI

3. Central Labour Research Institute

4. Loss Prevention Association, LPA

5. National Safety Council, NSC

6. Engineers India Limited, EIL

8. Lloyds Register of Shipping

9. Det Norske Veritas

10. Comet Consultancy Services

11. Netal Chromatographs

12. KLG/TNO

13. SGS India Limited

Methodology of AuditsThough each external audit agency might have its own methodology and approach to conduct an audit, a common methodology for conducting internal audits is given below

Composition/Selection of Audit Team

The team for a comprehensive internal audit comprise member each from operation, engineering / maintenance, technical services / technology, HSE and any other specific discipline if required. The chief of the installation through an office order nominates the team.The team comprises of two members - one from the area /department to be audited and the other from HSE.

Conducting the Audit

To start with, the team holds a kick-off meeting to discuss the plan of action.

They try to collect all relevant data of the area / plant / department they are going to audit. The team visits the area and talks to various personnel there to get feedback about their plant / area.

The team checks the various systems / procedures and records. The safety aspects of the plant are checked using checklists.

Conducting the Audit ( Cont…..)

These checklists could be standard lists made as part of a written audit procedure and supplemented by specific checklists made for special systems/equipment by each team before starting the audit.

Checklists are very useful as they save a lot of time and also to ensure that all aspects or sub-systems have been looked into and not missed.In case of mini audits, the two-men team goes to the area where audit is to be done. The team ensures the compliance of the procedure under audit by using a standard checklist made for the particular procedure

They check the level of compliance by talking to the plant personnel and seeing the situation in the field and rate the item on a 1-5 scale (1 is least compliant, 5 full compliance).

The overall compliance level is indicated in percentage.

Audit Report

After completing an audit, the team prepares a draft report which is presented to the custodian / manager of the area and his team.

After discussion, the final report with action plan for implementing the agreed recommendations is issued by the leader of the audit team to the concerned action parties with copies to top management team.

Follow-up

The effectiveness of the audit lies in the degree of implementation of the agreed recommendation.

Therefore it is essential to monitor the implementation programme. HSE plays a pivotal role in monitoring the recommendation; of various audits and presenting the implementation status to the top management.