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MAN-EOCP-CORP-HSEQ-501
Revision List
- Printed copies are uncontrolled. For current controlled copies, please contact EOCP HSEQ Dept.-
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Table of Contents
1. INTRODUCTION ............................................................................................................................ 5
1.1 Overview........................................................................................................................................................................... 5
1.2 Purpose ............................................................................................................................................................................ 5
1.3 Scope ............................................................................................................................................................................... 6
1.4 References ....................................................................................................................................................................... 6
8 AUDIT ........................................................................................................................................... 30
8.1 Audit Plan, Process and Hierarchy ................................................................................................................................ 30
8.2 Audit Team and Frequency ............................................................................................................................................ 32
9 REVIEW ........................................................................................................................................ 33
9.1 Scope of Review............................................................................................................................................................. 33
9.2 Responsibility for Review ............................................................................................................................................... 33
ATTACHMENTS ................................................................................................................................... 34
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Accident Undesired event giving rise to death, ill health, injury, damage or other loss.
Corrective Action Any activity undertaken to address an incident or non compliance and if
possible, prevent its recurrence.
Contingency Plan A pre-established plan to mitigate an unusual situation which has the potential
for harm, which incorporates the best use of local as well as remote facilities
and resources.
EC Emergency Coordinator
Hazard The potential to cause harm, including ill health or injury, damage to property,
plant, products or the environment; production losses or increased liabilities.
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HSEQ Audit Independent, systematic and documented process of objectively obtaining and
evaluating verifiable evidence to determine that HSEQ-MS is effectively
implemented.
HSEQ Inspection Physical on-Project verification that work is performed and equipment is
maintained in accordance with existing HSEQ standards and procedures.
Incident Event that gave rise to an accident or had the potential to lead to an accident.
Lock-out Tag-out A documented system of physical barriers and notices that prevents the
accidental or inadvertent operation of equipment whilst it is being maintained or
inspected.
Near Miss An incident or potential incident which resulted in no actual harm to people, the
environment, facilities or business.
PD Permanent Disability
PTW Permit-to-Work
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1. INTRODUCTION
1.1 Overview
The management of EOCP profess to unequivocal commitment in providing a safe work place,
respect for the environment and the highest standards of operational professionalism.
The EOCP HSEQ manual describes the process for managing EOCP’s Health, Safety, Environment
and Quality Management System (HSEQ-MS) at the corporate level and within any project or
operational units.
The HSEQ-MS is an integrated management tool that describes the EOCP organization,
responsibilities, processes, practices, procedures and resources for implementing the company’s
HSEQ policies.
The model used to represent EOCP HSEQ-MS is based on the ISO 9001/ OSHAS 18001 principles
as shown in Figure 1.1 below.
1.2 Purpose
EOCP HSEQ-MS defines the Company’s HSEQ Policy, Guiding Principles, Strategic Objectives,
organization and the arrangements which are necessary to manage the identified health, safety,
environmental and quality risks associated with EOCP businesses.
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It provides a set of HSEQ expectations and requirements for all levels within the organisation
with a view to ensuring consistent reporting and control over operational risks;
Company’s Policies, Procedures and Best Practices are communicated; and
Training, auditing and improvement processes are in place to achieve these objectives.
The HSEQ-MS Manual is a corporate level document intended for use by managers to assure them
that all foreseeable risks will be effectively managed throughout the organization. Managers are
responsible for the provision of necessary business controls to ensure currency of the HSEQ-MS and
its effectiveness in the management of those risks.
The HSEQ-MS manual will be reviewed annually and updated accordingly. A review of this Manual will
also be triggered by any major incidents or due to any significant deficiencies found in the HSEQ-MS
arising from audits or reviews of other parts of the system or Company (e.g. review of HSE Cases or
ISO/ISM/Client audits). This manual is a live document and the EOCP Corporate HSEQ Department
shall be its custodian.
1.3 Scope
The scope of this document covers the activities of EOCP Leadership Team, the Corporate Office and
Project/Operational Site staff providing advice and guidance to all business operations on the
management of their activities under their operational control.
EOCP is primarily servicing the offshore oil and gas industry (pipe-laying/heavy lift/accommodation
barges, FPSOs, shipbuilding) and its business operations, encompasses the following:
Engineering and Procurement services;
Construction;
Project Management;
Hook-up and Commissioning;
Offshore support services including Installation; and
Operations and Maintenance.
In line with EOCP HSEQ policy, implementing and complying with the HSEQ-MS is the direct
responsibility of everyone in the Company within their own individual sphere of operations including
contractors engaged by EOCP.
1.4 References
The main reference documents used in the development of this HSEQ-MS are as listed below:
E and P Forum, Guidelines for the Development and Application of Health, Safety and
Environmental Management Systems, Report No. 6.36/210;
American Petroleum Institute, Model Environmental, Health and Safety (EHS) Management
System, API Publication 9100A;
International Labour Organization, Guidelines on Occupational Safety and Health
Management Systems, ILO-OSH 2001;
Quality Management System, ISO 9001:2000.
Environmental Management System, ISO 14001:2004; and
Safety Management Manual, Emas Offshore and Marine Services
International Safety Management (ISM) Code, 1993;
The consistency between EOCP HSEQ-MS with ISO and ISM Standards is demonstrated in
Attachment A.
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The Senior Management is proactive in target setting. They do this through developing and discussing
improvement targets, ensuring staff have HSEQ goals in their appraisals, participating in the review of
HSEQ indicators, providing immediate and visible involvement in incidents and in setting Targets.
EOCP seeks to create and sustain a Company culture in which all employees share a commitment to
HSEQ. Both EOCP employees and contractors are involved in creating and maintaining this
supportive culture.
The Senior Managements demonstrate an informed involvement in HSEQ issues. They do this
through reviewing the progress in the development and content of the HSEQ Management System,
making resources available to meet set goals and undertaking relevant training. In addition, they are
fully aware of the high priority areas for improving EOCP HSEQ Management System and are
personally involved in improvements arising from formal management reviews of the HSEQ
Management System.
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EOCP HSEQ-MS describes the processes for identifying the legal HSEQ requirements that are
applicable to EOCP activities, products and services and for incorporating these legal requirements
into EOCP HSEQ policies, strategic objectives and the HSEQ-MS generally.
EOCP maintains procedures to determine and record legislative requirements and codes applicable to
its operations, products and services to ensure compliance with such requirements.
EOCP initiates, on a proactive basis, a bridging session in order to address any interface between
EOCP and Client’s HSEQ requirement. The agreed interface solutions are in place before any
fieldwork is initiated.
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SUPPORT SERVICES
The EOCP business unit is supported by common support services. These services include
Accounting, Project Controls, HSE, Quality, Information Technology , Communications, and Human
Resource provides support to both the Sales and Business Execution Processes. The EOCP
Organization Chart is illustrated in Attachment B.
Specific HSEQ roles and responsibilities of the EOCP Senior Management and other company
personnel including contractors are detailed in Attachment C.
Effective allocation of physical resources including facilities requires consideration of the HSEQ risks
that arise in all EOCP activities, including the supply chain.
Human resources include both EOCP staff and contractors. Effective HSEQ management relies on
the competence of these people.
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EOCP maintains a procedure to ensure competence by identifying training needs and providing
appropriate training for all staff and contractors. Training is provided through formal courses or through
structured programs in the workplace (on the job training). The extent and nature of training ensures
achievement of EOCP HSEQ policies and objectives. The training programs also meet or exceed
standards set by legislations and clients. Appropriate records of training are maintained with
subsequent refresher training scheduled on periodic basis. All EOCP contractors also are subjected to
this requirement.
Competency assessment process applies to initial recruitment and also to selection of personnel for
new tasks. The competency of staff and contractors to perform their duties is regularly reviewed and
evaluated, including appropriate consideration of training required to achieve desired competency
level for changing tasks, processes and equipment.
Any lapses of competency identified are addressed with appropriate formal or workplace training
conducted by their respective supervision.
4.3 Communication
HSEQ issues are communicated to employees, contractors, partners and other interested parties to
make them aware of:
Roles and responsibilities in achieving compliance with defined HSEQ policies and objectives;
Hazards and risks related to their work activities focusing on identification, evaluation, control
and recovery measures;
Assessed and approved deviations from agreed and documented operating procedures; and
Incidents and lessons learnt to avoid repetition in other locations or areas of the business.
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The HSEQ-MS provides a structured, documented management system that seeks to ensure that all
foreseeable hazards have been identified, risks assessed and the necessary control/recovery
mechanisms and procedures have been clearly defined. The HEMP of identify-assess-control-recover
provides the basis for the identification of deficiencies from which a prioritized Remedial Action Plan
for correction or improvement can be developed.
All HSEQ risks that arise out of and in the course of EOCP activities, including contractor activities are
reduced to a level that is as low as reasonably practicable (ALARP).
EOCP Management Team provides the required support and resources, to enable the implementation
of the required risk management activities.
EOCP trains selected personnel from different sections of the organization on the specialized tools for
hazard identification such as JSA, HAZIDs etc. The training is required since hazards and effects
identification requires specialized technique and system, operational experience and technical
knowledge.
In hazards identification process, the type of hazards associated with either the activities or equipment
and their effects shall be identified. The screening criteria shall also be established in order to define
the acceptable and unacceptable level of risk.
EOCP maintains a procedure to evaluate risks and effects from identified hazards against screening
criteria, taking account of probabilities of occurrence and severity of consequences to people,
environment, facilities and business.
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ALARP is the basis to be used when uncertainties arise from evaluation and agreed by all parties
involved.
Once the hazards and its effects have been identified and assessed, they shall be considered against
an HSEQ risk screening criteria. Screening criteria are values or standards against which the identified
hazards or effect can be judged such as occupational exposure limits, gas emission limits, wastewater
discharge limits and engineering standards.
In cases where the relevant HSEQ risk screening criteria is defined by local legislation or clients
standards, such requirements shall be complied with. However, where EOCP HSEQ risk screening
criteria is more stringent, the more stringent requirement shall be complied with.
For a qualitative risk assessment, the assessed risk can be regarded as either:
Low Risk - denoting risks low enough not to warrant further action or study;
ALARP Area - denoting risks which fall within the ALARP area. These will be considered for
cost effective mitigation; and
High Risk - denoting risks that are so high that action to reduce them must be taken.
Events within the “High Risk” and “ALARP Area” categories of risk will be considered for further study.
The EOCP Risk Assessment Matrix shall be used for the qualitative overview of risk and screening
criteria in risk assessment carried out throughout EOCP operations. Figure 5.1 illustrates the EOCP
Risk Assessment Matrix.
Hazard evaluations are recorded, together with the data sources and assumption used. These records
which are used by operation personnel in developing procedures and issuing work instructions,
documented in any of the following documents:
Hazards and Effects Registers; and
Critical Operating Procedures.
Risk reduction measures also include recovery preparedness measures which address emergency
procedures as well as restoration and compensation procedures.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
Production loss
Rare (1) Unlikely (2) Credible (5) Likely (8)
Certain (10)
Environment
Reputation
Assets/
People
Happens
Rarely or Occurred Happen
Incident has several times
never heard several times several times
occurred in per year on a
of in E and in E and P per year in
EOCP particular
P industry industry EOCP
location
No
None (0) No injury No loss or damage No effect
impact
No disruption to
Insignificant (1)
Minor injury, First production.
Slight effect
Local media LOW
aid Loss/repair cost less interest
than 10K USD RISK
Possible disruption
Recordable case, to production. Local TV,
Minor (2) Minor effect
MTC, LTI Loss/repair cost less national papers
than 100K USD
Production
Moderate (3)
Multiple LTIs, one shutdown.
Local effect
Considerable ALARP
PD Loss/repair cost less impact
than 1M USD AREA
Major production
Major (4)
One fatality, shutdown.
Major effect
National TV,
international
HIGH
multiple PDs Loss/repair cost less
than 10M USD
papers RISK
Loss of facility. International
More than one
Critical (5) Loss/repair cost Massive effect TV, extended
fatality
more than 10M USD coverage
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
The Corporate HSEQ Plan is reviewed at the HSEQ Steering Committee and approved by the MD.
The Departmental/Project Managers cascade the corporate plan, with the assistance of their
supervisors and use it as input to their respective HSEQ plans.
In general, emergency at operation/ project site must be handled directly by the operation and service
unit management. EOCP Crisis Management Team (CMT) headed by the Managing Director will only
be activated when the emergency condition escalates to a higher level requiring outside resources.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
The ERP is reviewed annually, led by the HSE Manager together with EC and OSC to identify
weaknesses and propose improvements. The findings of the system review are presented to the
HSEQ Steering Committee. The ERP is simulated throughout the year by a series of table top and live
exercises followed by post mortems. Reports and reviews are recorded for documentation purpose.
EOCP maintains HSEQ records which are made available to all clients and suppliers as needed to
demonstrate HSEQ compliance and the effectiveness of the operation of the Management System.
The Departmental/Project Manager in liaison with the QA Manager will be responsible for co-
ordinating the dissemination of any HSEQ records to clients and suppliers. HSEQ records must be
legible and traceable to the product or activity they represent. HSEQ records retained on the projects
are normally outlined in the HSEQ Plan, QA/QC Plan, Inspection and Test Plan, contracts and/or
project plans.
Measures are taken to prevent damage or deterioration to all records retained. Records are retained
for a period of time in accordance with contract or statutory requirements, whichever is greater.
Documentations are legible, dated (with dates of revision), readily identifiable, numbered (with a
version number), maintained in an orderly manner and retained for a specified period.
Policies and responsibilities are established for the modification of documents and their availability to
employees, contractors, government agencies and the public.
A complete hard copy set of signed and approved HSEQ-MS documentation are kept by the HSEQ
department.
The EOCP HSEQ documentation is structured into 5 levels as shown in Figure 6.1 and Table 6.1.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
Note : The HSE-MS Documentation Hierarchy as illustrated above is deployed on projects and
operations in varying stages and is adapted as applicable depending on the work scope.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
R
Level IV Process Maps/Procedures e
v
Intent of this is to provide detail process to i
achieve goals. This is provided, for the ease of ST e
implementation, in the form of written narrative, w
Procedures or Process Maps or a combination D
of both. e
s
i
g
n
END
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
Note : The below describes the key activities performed by the HSE Function and associated procedures that support its successful implementation .
Management Review
Doc No.: PM-EOCP-CORP-HSEQ-535
HSE LINKAGE OF PROCESSES Internal & External Quality Audits
Doc No.: PM-EOCP-CORP-HSEQ-533
HSE Site Inspection Procedure
Doc No.: WP-EOCP-CORP-HSE-534
Audit &
Review
Legal & Other Requirements HSE Training & Competence Evaluation Hazards & Effects Management HSE Objectives & Targets HSE Performance Measurement, Monitoring &
Identification Procedure, Procedure Procedure Establishment Procedure Reporting Procedure
Doc No: BP-EOCP-CORP-HSE-506 Doc No: PM-EOCP-CORP-HSE-507 Doc No: PM-EOCP-CORP-HSE-509 Doc No : WP-EOCP-CORP-HSE-513 Doc No: WP-EOCP-CORP-HSE-529
Job Safety Analysis HSE Management Programs Corrective & Preventive Action
Internal & External Communication Procedure Establishment Procedure Doc No: PM-EOCP-CORP-HSEQ-531
Procedure Doc No: PM-EOCP-CORP- Doc No: WP-EOCP-CORP-HSE-514
Doc No: WP-EOCP-CORP-HSE-508 HSE-510 Incident Notification, Investigation & Reporting
Emergency Response Preparedness Doc No: PM-EOCP-CORP-HSE-532
Risk Control Procedure Procedure
Doc No: PM-EOCP-CORP-HSE-515 HSE Documentations & Records Procedure
Doc No: WP-EOCP-CORP-HSE-530
Emergency Equipment Management
Occupational Health & Hygiene PPE Management Procedure Procedure
Management Procedure Doc No: WP-EOCP-CORP-HSE- Doc No: WP-EOCP-CORP-HSE-516
Doc No: WP-EOCP-CORP-HSE- 511
512 Operational
Control Procedures
Environmental Management Procedure Contractor HSE Management of Facility Material Handling Permit-to-Work
Doc No:WP-EOCP-CORP-HSE-536 Management Procedure Integrity Procedure Procedure (PTW) Procedure
Doc No: WP-EOCP-CORP- Doc No: WP-EOCP-CORP- Doc No: WP-EOCP- Doc No: PM-EOCP-
HSE-528 HSE-536 CORP-HSE-523 CORP-HSE-526
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0
Note : The below describes the key activities performed by the Quality Function and associated procedures that support its successful implementation .
Problem Resolution
Coordination of Quality
Procedure Development, Issue & Corrective & Preventive Action Customer Satisfaction
Resources
Change Control Doc No.: PM-EOCP-CORP-HSEQ-531 Doc No.: PM-EOCP-CORP-QMS-504
Doc No.: PM-EOCP-CORP-QMS-538
Doc No.: PM-EOCP-CORP-QMS-541
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
6.3.4 Engineering
The Engineering Core Process describes how the company plans and control the design and
development of the product in accordance to the requirements of the contract. It encompasses the
following activities:
Review Design Basis and Criteria
Plan Design Work
Produce/Monitor Design
Control Design Change
Check and Review Design
Design Verification
Design Validation
Approve Design
Deliver Design to Procurement and Construction
The Engineering Core Process is verified through application of EOCP’s Core Process Elements listed
(but not limited to) below:
Identify all design input and deliverables
Establish schedule for deliverables
Implement design QC Plan
Management of change
Resolve design queries
Check document and conduct design review
Validate internal / external design equipment
Check output meets design basis
Obtain client approval for changes
Internal/external approval of design dossiers
Procurement, construction and operations review and validation
Establish equipment list and material take off
The end results of the interrelated actions undertaken through-out the Engineering Core Process is
the actual design to be constructed or fabricated by the company in accordance to the requirement of
the contract. In some instances the Engineering process is the final deliverable.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
6.3.5 Procurement
The Procurement Core Process describes how the company plans, selects and obtain defect-free
equipment, materials and services from its suppliers and subcontractors that satisfy its customer’s
requirements. It encompasses the following activities:
Planning
Enquiry
Evaluation
Award
Order coordination
Release and Delivery
The Procurement Core Process is verified through application of EOCP’s Core Process Elements
listed (but not limited to) below:
Establish Procurement Plan including integrity assurance/performance measures
Obtain client approval on supplier listing
Establish export compliance and requirements
Rationalise resource plan
Establish criticality strategy, as required
Package risk identification
Establish evaluation criteria
Review and conduct audits
Check purchase order package for completeness prior to issue
Package risk management
Review final documentation
Reconcile and close-out purchase orders
The end results of the interrelated actions undertaken throughout the Procurement Process is the
successful selection of the right supplier and/or subcontractor to provide the equipment, materials and
services to the company to complete the deliverable as required by the contract. In some instances
the Procurement process is the final deliverable.
The Construction Management Core Process is verified through application of EOCP process
elements listed (but not limited to) below:
Establish construction management plan
Prepare project quality control plan which is linked to subcontract QC management plan
Prepare Inspection and Test Plan
Include integrity assurance/performance measure
Conduct gap analysis/pre-start audit (action plan)
Review/audit/approve subcontractor work processes
Monitor cost against budget and progress against schedule
Ensure change control is managed, reviewed and approved.
Review construction documents for completeness and ascertain punch list items
Ensure customer property including intellectual property is protected and maintained
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
The end result of the interrelated actions undertaken throughout the construction management core
process is the successful management and completion of the project to the satisfaction of the
customer. In some instances this process is the final deliverable.
6.3.7 Construction
The Construction Core process describes how the company construct or fabricate the product
according to the requirements of the contract. It encompasses the following activities:
Receiving equipment/materials]
Prepare materials
Fabrication activities
Mechanical completion
Pre-commissioning/commissioning
Verification and Validation
Load-out
The Construction core process is verified through application of EOCP’s core process elements listed
(but not limited to) below:
Identification and ensure traceability of materials
Ensure compatibility of materials
Check and ensure qualification of personnel
Establish inspection requirements
Ensure control of welding consumables
Ensure change control is managed, reviewed and approved
Check testing requirements
System completion checks
Ensure correct load out equipment
The end result of the interrelated actions undertaken throughout the construction process is the
successful completion of the deliverable to the requirements of the contract. In some instances, this
process is the final deliverable
The construction procedures are defined at the project stage and identified in the project plans.
6.3.8 Installation
The installation core process describes the installation of the constructed or fabricated product as
required by the contract. It encompasses the following activities:
Selection of vessels/tugs/barges
Mobilisation and demobilisation
Field installation
Tie-ins
The installation core process is verified through application of EOCP’s core process elements listed
(but not limited to) below:
Establish required size and capacity
Ensure marine warranty surveyors approvals
Monitor and ensure that certification of personnel are valid
Ensure incident and accident free installation
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
The end result of the interrelated actions undertaken throughout the installation process is the
successful installation of the constructed or fabricated product. In some instances this process is the
final deliverable.
Hook up and commissioning process are verified through the application of elements including but not
limited to:
Maintenance of job cards
Maintenance of the commissioning management system
Completion of the commissioning procedure check-lists
Detailed performance standards will give the measurable values that the organisation requires to meet
in order to achieve its goals. Strategies will be developed, planned, organised and implemented to
meet the standards and the performance will be monitored, reviewed and developed to give
continuous improvement or reinforcement to the process.
6.3.11 Marine
The marine core process describes how the company deals with operation and maintenance of marine
vessels. It encompasses the following activities:
Operation and Maintenance of Pipe Lay Barge; and
Operation and Maintenance of Floating Production Storage and Offloading facility.
The marine core process is verified through application of EOCP’s core process elements listed (but
not limited to) below:
Instruct the fleet and shore based staff on policies and procedures in compliance to the
International Safety Management (ISM) Code for Safety Operations of Ships and Pollution
Prevention
Ensure marine warranty surveyors approvals
Monitor and ensure that certification of personnel are valid under international marine codes
Minimise and if possible eliminate pollution to marine environment
Monitor progress of projects and production activities against planned schedules
Minimise repairs and defects of marine vessels
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
EOCP maintains procedures to ensure that facilities or installations are suitable for the required
purpose and comply with relevant legislative requirements, industrial codes and international
standards throughout facilities life cycle i.e. design, procurement, construction, installation, operation
and maintenance phase.
Pre-procurement and pre-construction assessment of new facilities and equipment includes explicit
assessment of appropriateness to meet HSEQ requirements and emphasizes design as the best
preventive measure to reduce risk and adverse HSEQ effects.
EOCP procedures and systems for ensuring facility integrity address structural integrity, process
containment, ignition control and systems for protection, detection, shutdown, emergency response,
evacuation and life saving.
Operational personnel are put through vigorous training and assessment to understand and implement
arrangements set in the PTW/LOTO programs.
Especially for large and longer-term contracts, there is a need for early identification of clear and
common HSEQ objectives from the onset and it is imperative to include these in the contract.
Contractors are required to develop HSEQ management system interface documents aligned to
satisfy EOCP HSEQ policies, manual, procedures and work instructions. All contractors’ activities,
products and services must meet the local and international legislations pertaining to HSEQ and
EOCP HSEQ-MS requirements.
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Title Procedure No. Rev.
Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ – 501 0
All EOCP contractors are pre-qualified with a rating for HSEQ competency and performance. EOCP
personnel in charge of contractors are responsible for assessing the possible risks of contracts before
awarding and ensure that the contractor’s HSEQ plan is:
assessed for fitness prior to contract award;
reviewed for compliance and fitness prior to mobilization;
monitored for compliance during the execution phase; and
reviewed during contract close out.
The EMP identifies and plans on operations that are associated with or may have identified
environmental impacts consistent with its HSEQ Policy, Objectives and Targets, in order to ensure that
they are carried out under specified conditions, by:
establishing, implementing and maintaining documented procedures to control situations
where their absence could lead to deviation from the HSEQ Policy, Objectives and Targets;
stipulating the operating criteria in the procedures; and
establishing, implementing and maintaining procedures related to the identified environmental
impacts of goods and services used by the organization and communicating applicable
procedures and requirements to suppliers, including contractors.
Activities and tasks are conducted according to procedures and work instructions developed in
accordance with HSEQ policies and set objectives and targets:
At management level, activities will normally take the form of plans and actual implementation;
and
At departmental/project level, activities shall be in the form of executing activities and tasks
assigned.
Successful implementation of EOCP HSEQ-MS requires that it be viewed as part of the way EOCP do
things. HSEQ management is an integral part of our business.
Responsibility for conducting critical tasks is clearly communicated to the individuals involved. Each
responsible person monitors and regularly reports the performance of the critical activities using set
performance indicators.
People identified as responsible for critical tasks must take ownership. To achieve this, it is essential
for Project staff to be genuinely involved in developing the HSEQ-MS, HSEQ Plans and Operational
Safety Cases.
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EOCP regularly measures, records, tracks and reports HSEQ performance against objectives and
targets set in the HSEQ plan and in maintaining control of critical activities.
EOCP develops procedures for periodic review of performance against annual Corporate and
Departmental/Project HSEQ Plans.
Proactive monitoring provides information in the absence of any incidents, health impairment, damage
to the receiving environment or breach of laws. Proactive performance indicators are forward looking
and predictive, aimed at raising the awareness of the possibility of incidents that might happen.
Reactive monitoring provides information on incidents that have occurred and provides insights into
means of preventing similar incidents in the future. Reactive performance indicators provide evidence
of deficient HSEQ performance.
A monitoring program also regularly examines progress towards achieving set departmental/project
level HSEQ Objectives and Targets.
Procedures are established for collection, analysis and interpretation of monitoring data.
7.5 Records
EOCP establishes a system for records management in order to demonstrate the extent of compliance
with legislative requirements, HSEQ policies and its requirements and to record the extent to which
planned objectives and performance indicators which has been met.
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The retention times of records are captured, recorded and analyzed, such that evidence is available of
the achieved compliance levels, to identify problem areas, to ensure the effectiveness of actual
implementation and its traceability.
Incidents may affect people or the environment, or the assets and reputation of EOCP.
EOCP defines requirement relating to the investigation and reporting of incident including near misses
that may arise and in the course of EOCP business activities.
All incidents including near misses, that arise within EOCP activities are investigated and reported in
accordance with EOCP corporate procedures and Client reporting standards as applicable..
All incidents are reported immediately to appropriate supervisors and responsible manager, who will
then take the required actions including participating in incident investigation, reporting and
implementation of corrective actions and preventive measures.
For contractors, they need to notify all incidents to the respective EOCP contract in-charge and Project
HSEQ personnel.
The Project HSEQ personnel must notify the Client within 24 hours. Notification to the authority
concerned will be managed by the EOCP HSEQ Manager or his designate in project organization.
Lesson-learnt from incidents are disseminated as widely as possible during daily tool box meeting
(TBM) and HSEQ Alerts; in particular where lesson-learnt from the incident has lateral applications to
the EOCP businesses as well as activities conducted by the clients. The HSEQ alerts are distributed
internally as well as to the clients’ office, business partners and other stakeholders.
Any major incident such as fatality, lost time injury (LTI), major spillage, occupational illnesses and non
compliance to legislative requirements shall be reported directly to EOCP Senior Management in
accordance with the company’s Emergency Response Plan.
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actions shall be documented and evaluated for effectiveness and, if necessary changes made to
procedures and work practices to prevent recurrence.
Preventive action is directed toward eliminating the causes of potential non-conformances. It shall be
to a degree appropriate to the magnitude of problems encountered. Non-conformance/observations
raised as a result of Management System reviews and audits will be reviewed by the management for
preventive action, where applicable.
EOCP defines the requirement in term of responsibility and authority for initiating investigation and
corrective action in the event of non compliance with specified requirements relating to HSEQ-MS.
Situation of non- compliance may be identified by the monitoring programs, through communications
from employees, contractors, customers, government agencies or the public or from investigations of
incidents.
For any sign of non-compliance to HSEQ-MS, associated with procedures and legislative
requirements, the responsible manager in association with HSEQ Corporate will initiate an
investigation with an intention to establish the causes of non compliance and develop relevant
mitigation measures.
The party responsible must ensure the followings are executed in the event of any HSEQ non
compliance:
Notify relevant parties;
Determine the root cause of non compliance;
Initiate the necessary investigation;
Provide corrective action with consultation of HSEQ committee;
Ensure the preventive action are in place for long term measures;
If necessary, revise procedures to incorporate actions to prevent recurrence; and
Communicate the non compliance to all staff and contractors as a lesson learnt.
Progress in implementation of corrective and preventive action are monitored and presented at EOCP
HSEQ Steering Committee Meeting.
7.8 Non-Conformance
Non-conformance may be sudden and temporary, or they may persist for long periods. They may
result from deficiencies or failures in the HSEQ-MS itself, failures in plant or equipment or from human
error.
Quality Manager or his delegate will be responsible for the control of non-conforming materials and/or
processes. This will include the identification, documentation, evaluation, segregation, disposition and
preventing the use of non-conforming materials and/or processes. Quality Manager or his delegate will
also be responsible for the notification of affected departments when non-conforming materials and/or
processes are detected.
Non-conformance is reported when there is a deviation from the agreed system, procedure or
specified requirements that affect the safety, quality or continuity of the operation. Quality Department
performs trend analysis as required and decided by the HSEQ Steering Committee during
Management Review.
Investigating non-conformance should fully establish the causes, including failures in the HSEQ-MS.
Investigations enable the planning of corrective action including measures for:
Restoring compliance as quickly as possible;
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Implementing corrective action will not be complete until the effectiveness of the above measures has
been demonstrated. This includes making the appropriate changes to EOCP procedures and records.
8 AUDIT
8.1 Audit Plan, Process and Hierarchy
EOCP believes that audits are essential for improvement and reaching the company’s objectives. This
is achieved by a combination of periodic assessment and/or audit of projects and business
management and support activities.
Internal audits are carried out with a minimum frequency of once a year and/or as required by the
contract. External Audits are conducted as required on a project or bid normally on a vendor or a
subcontractor’s facility.
Auditing addresses the periodic assessment of system performance, its effectiveness and inherent
suitability against the business requirement. EOCP defines the requirements in respect of internal
HSEQ-MS auditing, to provide assurance to management that:
HSEQ management within the EOCP conforms to HSEQ-MS;
The planning and implementation of activities within the EOCP is consistent with achieving the
intents of EOCP HSEQ policies, strategic objectives, targets and plans; and
The level of understanding and implementation of the stipulated HSEQ requirements and the
extent, to which they are adhered to in the Company, is appropriate and effective.
Audit Plan
EOCP maintains an audit plan, dealing with the following:
Specific activities and areas to be audited. Audits will cover the operation of the HSEQ-MS
and the extent of its integration into project activities and specifically address the elements of
the HSEQ-MS;
Frequency of auditing for specific activities/areas. Audits will be scheduled on the basis of the
contribution or potential contribution of the activity concerned to HSEQ performance and the
result of previous audits; and
Responsibilities for auditing specific activities/areas.
Audit Process
EOCP maintain procedures for audits to be carried out, as a normal part of business control, in order
to determine:
Whether or not HSEQ-MS elements and activities conform to planned arrangements and are
implemented effectively;
The effective functioning of HSEQ-MS in fulfilling the company’s HSEQ Policy, Objectives and
performance criteria;
Compliance with relevant local and international legislative requirements pertaining to HSEQ;
and
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EOCP establishes the audit protocols that covered the following as a minimum;
Allocation of resources to the auditing process;
Methodologies for conducting and documenting the audits, which may involve the use of
questionnaires, checklists, interviews, measurements and direct observations, depending on
the nature of the function being audited.
Procedures for reporting audit findings in a controlled manner to those responsible for the
activity/area audited, who should take timely action on reported corrective actions and
opportunities for improvement reporting should address:
o conformity or non-conformity of the HSEQ-MS elements with specified requirements;
o effectiveness of the implemented HSEQ-MS in enabling objectives and performance
criteria to be met;
o implementation and effectiveness of corrective actions from previous audits; and
o conclusion and recommendations.
System for auditing and tracking implementation status of audit recommendations; and
Distribution and control of audit reports.
The HSEQ audits are carried out internally by personnel from within the company but independent of
the part being audited. However EOCP may also choose to engage external auditors where and when
deemed necessary. The audit and review are carried out on quarterly basis and shall be initiated by
the Operation Manager. The audit team are selected by the Operation Manager whom will ensure that
audit team members possess broad knowledge on HSEQ matters and are experience in auditing
practices and disciplines.
The audit team gathers information by observation, through interviews and by checking
documentations and hardware. The principal documents to be reviewed during the exercise include
the following:
HSEQ manual and procedures;
Incident Reporting files;
Permit-to-work and execution of critical activities;
Medical log book;
Inspection records;
Equipment and machineries;
Adherence to HSEQ policies and objectives;
Adherence to procedures and work instructions; and
HSEQ statistics and performance.
Audit Hierarchy
EOCP operates a multi-tiered system for HSEQ audit type comprising:
Tier 1: Corporate HSEQ Audits led by HSEQ Specialists as appointed by the EOCP Senior
Management. Audit findings are reported to the responsible managers of the audited
departmental/project, copied to the MD and the HSEQ Steering Committees;
Tier 2: Internal HSEQ Audits led and conducted by a departmental/project HSEQ audit team
as appointed by departmental/project management. Audit findings are reported to
Departmental/Project Managers. Procedures on how to conduct audits are provided by the
HSEQ Manager;
Tier 3: Contractor’s HSEQ Audits led and conducted by EOCP HSEQ Specialists as appointed
by EOCP Senior Management. Audit findings are reported to Operations Director and
contractor’s Senior Management. Procedures on how to conduct these audits are provided by
the HSEQ Manager; and
Tier 4: HSEQ Site Inspection conducted by Operation Manager, HSEQ Department and
Discipline Supervisors.
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Audit Team
People conducting HSEQ audits are appropriately trained to be able to carry out the task objectively,
impartially and effectively.
Audit team members are selected so that their skills and knowledge are appropriate to the audit type
and scope. The audit team must have:
A broad knowledge of HSEQ matters;
Attended HSEQ Auditing training;
Adequate independence from the activities being audited, to enable objectives and impartial
judgment;
Operational experience in the area being audited;
The necessary expertise and experience in auditing practices and disciplines;
Specialist HSEQ or other technical expertise or support, if necessary, from a wider range of
specialists; and
The support and authority from management to procure the necessary information.
In order to maintain independence and objectivity, the Audit Team Leader and the majority of the audit
team will not have a direct reporting line to the Principal Auditee.
Audit Frequency
All business processes are periodically audited, with the frequency and depth of HSEQ auditing being
determined based on:
The level of risk for the activity;
How critical the process or activity is, in relation to EOCP business objectives;
The contribution or potential contribution of the activity concerned to EOCP overall HSEQ
performance; and
The results of previous audits.
All business processes activities and facilities must be audited within a year.
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9 REVIEW
At periodic intervals the effectiveness of the Management System will be reviewed by the HSEQ
Steering Committee which comprises of the EOCP HSE Manager, Quality Manager, Operations
Director, and representatives from the various departments as required. As a minimum, management
review meetings will be conducted once a year.
The review process is documented and its result recorded, to facilitate implementation of consequent
changes.
Reviews are used to reinforce continual improvement of HSEQ-MS.
The minutes of the review meetings are held by the HSE or QA/QC Manager whom ensures that
timely follow-up meetings are arranged to review progress. No item is closed until the approved action
plans for improvement has been completed and found to be satisfactory. Minutes of the review
meetings are distributed to the relevant managers and to contractors for dissemination at their
management meetings.
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ATTACHMENTS
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