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Libyan Branch – Corporate HSEQ-S Procedure for Contractors and Suppliers Management
Revision History
Written By Reviewed Endorsed Approved
Rev REASON FOR REVISION
and Date By and Date By and Date By and Date
Revised to include additional requirements A. Nair A. Ganidi A. Ganidi M. Oun
A5 and references. 02/05/10 02/05/10 02/05/10
TABLE OF CONTENTS
1 INTRODUCTION ......................................................................................................................................... 4
2 OBJECTIVE ................................................................................................................................................ 4
3 SCOPE ........................................................................................................................................................ 4
4 REFERENCE ............................................................................................................................................... 4
6 RESPONSIBILITIES ................................................................................................................................. 11
7 PROCESS DESCRIPTION........................................................................................................................ 15
ATTACHMENTS ............................................................................................................................................... 29
1 INTRODUCTION
This procedure enables Mellitah Oil & Gas BV (hereinafter referred as Company or MOG. BV) to
align contractors and suppliers with the Company HSEQ-S management system in order to avoid
undesired events and reduce intrinsic risks at an ALARP (As Low As Reasonably Practicable) level
in all activities carried out by Contractors during plant operations and project execution.
2 OBJECTIVE
This document outlines the standard and basic guidance requirements for contractors and suppliers
contracted to perform activities for or on the behalf of Mellitah Oil & Gas B.V. It also provides the
required index of procedures and work instructions and any other documentations deemed
necessary for the performance of the dedicated tasks (i.e.: QA/QC, HSE, Security, Occupational
Health) for running the plant or projects.
3 SCOPE
The contents of this document apply to all activities conducted on behalf of MOG BV at every its
operating sites, both offshore and onshore, for the production and delivery of liquid and gaseous
hydrocarbons.
Contractors’ HSE management systems shall be compatible with MOG Policies and principles of its
HSE IMS.
4 REFERENCE
[Ref.14] Eni spa msg-hse-eni spa-eng-r02 “Management System Guideline – HSE” Annex
G: Third-Party Monitoring
[Ref.15] Eni upstream 1.3.1.30 “Contract HSE Requirements for Abroad Activities”
[Ref.16] Eni upstream opi sg hse 036 ups r01 “Golden Rules Visible implementation
Monitoring Program (E-Gruvis) ”
Following is a list of abbreviations commonly used in this procedure, and is designed to help the
reader with their understanding of this document.
5.1 ACRONYMS
MS Management System
Undesired event giving rise to death, ill health, injury, damage or other
Accident loss (OHSAS 18001:2007). An alternative simpler definition: unplanned
event giving rise to undesired outcome (death, ill health).
Mellitah Oil and Gas B.V (MOG) Libyan Branch including Head Quarters
Company
and all operating sites
Conformity /
Fulfilment of a specific requirement.
Conformance
Continual
Recurring activity to increase the ability to fulfil requirements.
Improvement
Contractors/Suppli Both Parties are involved in the preparation and use of documents to
ers and Contract meet the HSE requirements of both the Tender documentation and the
Holders Post-Award HSE management requirements of a Contract.
Critical Activities Activities that have been identified by the hazards and effects
management process as vital to ensure asset integrity, prevent incidents,
and/or mitigate adverse HSE effects.
Anything with the potential to cause harm, including ill health or injury,
Hazard damage to property, plant, products or the environment; production
losses or increased liabilities.
A state of complete physical, mental and social well being, and not
merely the absence of disease or infirmity (WHO constitution of 1948.
Health
In this document, Health includes Occupational Health, Medical Support
and Community Health.
HSE Management Part of the overall management system that facilitates the management
System of the HSE risks associated with the business of the organisation.
Non-conformity
Non-fulfilment of a specific requirement.
/nonconformance
Those actions, activities or assets for which a person is held liable and
Responsibility
for which he alone must account.
6 RESPONSIBILITIES
This section defines the key personnel and their responsibilities for contractors and suppliers
management as outlined in the Organizational Chart for the applicable position.
OMC Chairman
Ensure that all contracts respect the requirements reported in this procedure.
Ensure that all required resources, facilities and personnel, are made available to conduct
Contractor management process
Ensure training and awareness is provided to departments that manage the contractor’s
process.
Ensure that the HSEQ specialist/professional will take a part in each Kick off Meeting
Ensure that HSEQ personnel are well trained to conducting HSEQ Audit.
Organize, with the collaboration of the HSEQ Department Managers Oil/Gas Divisions, each in
his area of competence; audit to the contractors to verify whether the requirements are
satisfied.
Establish a visit program for MOG personnel to conduct HSE Site visits
Appoint the qualified personnel for assessment of the contractors and the bids
Ensure HSE documental revision for each contract in order to identify all concerned HSEQ
requirements.
Ensure the review of Contractors HSE plans submitted to MOG and its compliance with the
company HSEQ requirements.
Verify that all the contractors, before the access to the plant, respect the requirement reported
in this procedure.
Contract Holder
The Contract Holder has a single point responsibility for the activity management of the Contract
and verification that the control mechanisms are in place. It is not expected that Contract Holders
can carry out all the activities listed in the following sections. Rather, Contract Holders shall call
upon professional personnel from relevant MOG BV. Departments when assistance with HSE
issues is required i.e. HSEQ Division manager can assist by designating an HSE specialist/
professional or other as for technical engineering.
He remains the Responsible for ensuring that received advice and actions taken are the best
possible solutions to any point in the execution of a Contract.
be responsible for the activity management of the Contract and verification that the process
mechanisms are in place
Advice on each process phase contract personnel involved in the project for each process
phase.
call upon professional personnel from MOG HSEQ Division when assistance with HSE issues is
required as the HSE team leader or a Technical Authority. He should ensure that their advice is
received and actions taken are the best possible solutions to any point of the contract
execution.
Ensure that there is a formal HSE monitoring for all contracts. Contract holder shall ensure that
the Contractor is fully aware and understands the importance of the quality and frequency of the
performance monitoring.
Address the full lifecycle of contracts and management of subcontractors from risk identification
and qualification, contract execution and finally to the close out of contractor/ subcontractor
(supplier);
Call for HSE resources skills, in the case of projects classified as "high risk" as the to provide
assistance to the project
Ensure as far as possible in consultation with the HSEQ Representative that the interfaces
between the parties (MOG BV, Contractor, Subcontractor) are clear and unambiguous. If the
strategy of the contract requires a sharing of activities in several contractual entities, he must
ensure that each entity is responsible for the attributed HSEQ aspects.
Submit any documentation HSEQ related documents to HSEQ Department for comments and
approval ensuring the interface with the contractor for comments, procedures validation,
documents and HSEQ process
Ensure that the HSEQ representative has completed a detailed assessment of the risks related
to the project by establishing a Risk Register. This should take into account certain aspects that
can be as follows:
▬ The location and nature of work to be done and the potential risks involved
▬ The arrangements due to management of change related to the potential risks of various
controls, approvals and processes during contract execution
▬ Ensure the assessment of potential risks based on the "scope of work" and confirmed that
the integration of the contractual attachment Annex 2 HSE requirements (hereinafter) is
appropriate.- Ensure that the bidder provides documentation justifying their HSEQ
management system;
▬ Asks the HSEQ Dept. to conduct external audits control on the proper application of the
HSE requirements of the contract;
▬ Ensure the collection of assessments HSE requirements and insert them into contractor
evaluation sheet/ Feedback.
▬ Ensure that the contractor had submitted the HSEQ detailed risk register before the kick of
meeting.
▬ Cooperate with HSEQ Department Manager to comply with the company auditing
procedures.
7 PROCESS DESCRIPTION
The approved Company HSEQ and Security Policies have been disseminated at all Company
facilities. It’s Mandatory that the operations of the Company be maintained & carried out in
compliance with the approved policies. Contractors & suppliers shall be aligned with the Company’s
HSEQ requirements and all Contractors shall fully comply with requirements stated in Company
procedures. Moreover Contractors shall employ competent HSEQ-S personnel to enforce and
maintain the policy.
This Procedure follows the HSEQ sequence of phases in contract management, which can be
described as follows:
1. Planning and Invitation to Tender (Announcement through MOG & NOC websites)
4. Mobilization
5. Execution
6. De-mobilization
7. Close Out
In some of the above contract phases form(s) shall be completed for the Contract to proceed.
These are detailed in each phase where required, including any reference documents that relate to
the forms. All forms necessary for the HSEQ Management of a Contract are given in the various
Attachments in this document.
Each phase also contains instructions for any relevant Deliverable(s), as well as the document
number and title for any reference material pertinent to that phase.
Risk Assessment
Contract holder, in collaboration with the HSEQ Division Manager and eventually the HSEQ
Department Managers Oil / Gas Divisions, each in his area of competence, shall conduct a
structured, formal HSE Risk Assessment of the Contract against contract scope, schedule and
strategy (as well as any existing HSE information from prior documents related to the same
package of work) with a view of minimizing the HSE exposure and level of risk for the Contract.
Attachment 1 is a useful tool used to categorize the contract activity as high (Exploration, Drilling,
Development project), significant (refurbishment activities, specific non routine activity as welding,
lifting) or negligible (good services).
The main goal of the HSE Risk Assessment is to identify and assess the major hazards and risks
associated with the contract.
The HSE Risk Assessment shall include or enable HSEQ department in the execution of the
contract.
Details shall be formally recorded with future actions identified and, wherever possible, action
parties nominated.
Contract Holder shall use the results of the HSE Risk Assessment to develop HSE Requirements at
an adequate level for inclusion in Tender Document. Attachment 2 provides a not comprehensive
framework of HSEQ-S requirements for contracted activities assessed as High level risk category.
For other risk category levels, modification shall be implemented.
The standards in the HSEQ Management System shall at least be comparable to the minimum
requirements of this document and should cover the quality and HSE aspects of work contracted by
MOG BV.
The questionnaire aims to discover the information required to assess the extent to which the
management of HSE is systematically organized by the Contractor.
Contractor shall complete the questionnaire. The Contractor should be advised by the Contract
Holder to cover all activities relating to a contract (including off-site support) and not just those
conducted on MOG BV sites.
Contract Holders shall emphasize the need for complete answers substantiated by supporting
documentation as far as is practicable. It should be remembered that increasing amounts of detail
(and therefore information required to support it) will need to be requested as risk increases.
When Contractor submissions are received, the Contract Holder shall rate the submissions as
described in Contractor HSEQ Prequalification Questionnaire.
Once the Invitation To Tender (ITT) has been launched, the Contract Holder shall ensure that the
Contractor(s) submits:
a draft HSE plan to manage the work and address all the associated HSE risks through the
different phases of the project, on the basis of the information provided in the Contract Scope of
Works and
Details provided shall fully describe the manpower including roles and responsibilities of the
individuals stated in the organization chart and clearly indicate the policies, procedures and
standards to be adopted during each phase of the contract.
Site Visit
Contract Holder shall arrange a site visit if deemed appropriate or as a result for the HSE Risk
assessment. The purpose is to allow familiarization with the Contract Scope of Works and the
impact that site conditions may have on all aspects. Depending on the complexity of the scope,
consider a dedicated discussion with the contractors on the HSE aspects of the contract.
In any contract of technical complexity and/or high value, the Contract Holder shall visit the site to
become familiar with site conditions, prior the receipt of Tender Documents.
Contract Holder, with the assistance of the HSEQ Division Manager, shall conduct a HSE
Evaluation of the contractor submission. The evaluation includes a review of their submission
documents as well as a visit to their office and/or site
Contract Holder shall communicate or meet with Contractor(s) if further clarification is needed for
Tender submission. This meeting, if required to be held following written requests for clarification,
shall establish where improvements in proposed HSE risk management will be required if contract
is awarded.
Contract Holder shall consider the results of the HSE evaluation and evaluate which Contractor(s)
will require additional MOG BV supervision to ensure that the management of HSE risk is carried
out correctly.
Contract Holders should be conscious of the fact that thorough understanding of a Contractor’s
abilities to manage HSE issues can only be obtained by careful study of the whole of a Contractor’s
HSE management system as for, but not limited to the following:
financial resources of the Contractor that are available for HSE management
If necessary, an award recommendation has to be added by the Contract holder and shall highlight
any anomalies or additional qualifications accepted from the original Tender documentation issued.
The Contract Holder may withhold approval of the Contractor until the Contractor provides
satisfactory explanations and assurances that no reduction in the quality of key HSE personnel will
result from changes. Replacement of Key HSE personnel is not allowed without prior approval from
HSEQ Division Manager. CVs shall be provided for any replacement personnel different from those
already submitted to MOG BV.
7.2.4 Mobilisation
Kick-off Meeting
Contract Holder shall hold MOG BV internal kick off meeting with the presence of the involved
departments to ensure that:
Company Representative and Company Site Representative(s) are fully aware of their
delegated powers under the Contract.
All personnel involved with the Contract understand the contents of the Contract.
Contract Holder shall then conduct a kick off meeting with the Contractor immediately after
Contract award and before the execution of any work. This is essential to ensure that all contractual
obligations, including HSEQ, are thoroughly and mutually understood. The kick-off meeting is the
first formal meeting between Contract Holder and Contractor after the award of a contract.
The agendas of the kick-off meetings is entirely at the discretion of the Contract Holder. The
Contract Holder requires the HSEQ Division assistance with either kick-off meeting or an HSEQ
professional to assist.
During either or both of these meetings, the Contract Holder shall ensure the following minimum
objectives are covered:
Establish that the Contractor completely understands the risks within the Scope of Work and
has committed the resources detailed in the Contractors tender submission the HSE
Requirements
Ensure that the Contractor has or can put systems in place to manage risk and these are
suitable and sufficient to meet standards
Highlight any areas for improvement in the Contractors requirements Tender submission, and
agree on any actions necessary, by either MOG BV or the Contractor, to remove deficiencies.
Resolve any issues arising from a variation to contract since the award
Introduce any new Contractor(s) to the details of MOG BV’s HSE policies, standards and
systems.
Note: If necessary the Contract Holder schedule a HSE Workshop to focus on all outstanding HSE
issues relating to a contract. Ideally the Workshop will be held at the site where most of the
activities will take place. The HSE Workshop is held to bring all the disciplines together from
company and Contractor to interrogate the HSE management proposal from the contractor and in
particular the HSE Risk management details submitted as part of the technical evaluation. A major
focus will be on the control measures proposed to manage the risk and these are to be recorded
and auctioned by the contractor. In addition it is an opportunity to review any changes to the
Specific Contract HSE Management Plan.
In the case of Contractors and all parties agree in writing on the Kick off meeting statements, then
Contractor Manager shall deliver the current Contractor’s HSE Plan for review and approval. This
HSE plan shall incorporate any MOG BV comments arising from the kick off meeting and the HSE
Workshop, and also any further mandatory MOG BV requirement. Full details for the preparation of
an HSE Plan are given in Attachment 2.
A bridging document should be included to the HSE plan to hold the raised HSE issues involving
different parties related to the project, in particular the gaps between the Contractor HSE-MS as
implemented and the MOG BV HSE-MS requirements as well as other parties that could influence
HSE issues during the execution of the project.
The Bridging document that is jointed to the HSE plan shall address the emergency procedures
and recovery plans held by the different parties including third party participants to ensure smooth
operation, with no uncontrolled major hazards that may cause unnecessary danger to people, the
environment and assets.
Any conflicts between the HSE-MS systems of participating companies should be resolved
One party should have overall responsibility and control of the project work; this will typically be
the Contractor
MOG BV may require having primacy in some (serious) emergency incidents, and the situations
where this will take effect should be clearly identified in the contract and project HSE plan or
bridging document.
Third parties should be identified as early as possible at the beginning of the project
Training
Contract Holder shall ensure that all MOG BV and Contractor personnel training has been
completed with all personnel involved, receiving approval from HSE trainers. Training records will
contain name(s) of trainee(s), name of training course and completion grade with feedback. HSE
Training shall be ensured according to a training matrix adapted to a the project
Contract Holder shall develop a Company HSE Monitoring program to be able to fulfill the
requirements of contractor HSE feedback
Contract Holder shall, throughout the period of a Contract, monitor the Contractor’s HSE
performance against the Contractor’s HSE Requirements Contract document and its HSE Plan.
Implementation of the MOG BV HSE monitoring program shall take place when the Contractor
commences mobilization.
Contract Holder shall prepare the Company HSE Monitoring Program specific to the project in the
Audit plan that is submitted to the OMC Chairman for review and approval.
MOG BV HSE personnel shall complete Contract HSE Performance Reports to detail the results of
all monitoring activities. A template and guidance note for these reports is provided in Attachment 3
“Golden HSEQ Rules Visible Implementation Monitoring Program (Gruvis)”. Contract Holder will
submit to HSEQ Division Manager the HSE Feedback form Attachment 4
Both the Gruvis feedback (Attachment 3) and the HSE feedback (Attachment 4) are completed
during the execution of the contract periodically (monthly, quarterly basis) that depends on the
project progress or after an event such as a major/ significant incident/ accident. These feedbacks
are collected and communicated to Contractor and HSE section for filing and constituting one of the
basic references for the Non- conformities / preventive and corrective actions as well as the HSE
tracking actions, should be monitored by HSE section on site .
HSEQ Division Manager and his team should support the audit as required by the Contract Holder
Contract Holder shall conduct a pre-execution HSE audit to determine that the Contractor has
achieved the pre-execution targets stated in the Contractor’s HSEQ Requirements (Attachment 2)
and HSE Plan, and that mobilization is complete.
The execution of the post mobilization phase of Contract work shall not be initiated until the
requirements of the pre-execution HSE audit have been met.
The Contract Holder must approve each of the checks before subsequent actions can be
started. For example, the Contractor cannot start transporting material until drivers have been
qualified and vehicles have passed inspection checks.
In such a situation, the pre-execution HSE audit may consist of the Contract Holder determining
the satisfactory completion of driver training and vehicle inspection before the field site is
audited and fieldwork begins.
Following any HSE audit, or any inspection in support of an audit, the resulting findings should
be discussed with the Contractor's site and office management.
Contractor shall respond to the Contract Holder, confirming the minutes and advising the
remediation schedule and/or confirming that all audit recommendations will be or have been
carried out.
The Contract Holder shall agree with the Contractor on a procedure for monitoring the
implementation of the inspection/HSE audit findings i.e. Action tracking Plan.
Contractor Manager shall advise, in writing, Contract Holder that all items from the pre-execution
audit requiring remediation have been completed
Contractor Manager shall issue Pre-execution Completion Report and request HSE
Commencement Certificate (Attachment 5)
Contract Holder shall issue the HSE Commencement Certificate (refer Attachment 5) to Contractor
Manager, subject to any exceptions noted on the HSE Certificate.
Contract Holder shall withhold issuing the HSE Commencement Certificate if any of the activities
listed on the HSE Certificate require exception that leads to unsafe operating conditions.
7.2.5 Execution
Contract Holder shall implement the Monitoring Plan to monitor the Contractor’s performance
against the Contractor’s HSE Plan/ HSE requirements.
Contract Holder shall participate in all planned HSE planned audits, incident investigations,
meetings and reviews.
Contract Holder shall perform a project HSE Risk Assessment periodically during the execution of
the Contract. In particular, revised risk assessment shall be triggered by any additional
requirements that lead to an increased Scope of Works, thereby requiring a Variation in the
Contract.
Revision will also allow the incorporation of any additional HSEQ requirements arising from the
process of Contract execution.
MOG BV shall apply HSE penalties and defaults to the Contractor, as allowed in the Contract, for
unauthorized deviation(s) from the HSEQ Requirements of Contractor’s HSE Plan. The Contractor
Manager is to be advised in writing of all Penalties and Defaults being imposed according to MOG
BV HSE disciplinary policy.
Reference HSE Monitoring Program (audit plan specific to the project) Attachment 3 &
Document(s): Attachment 4
Report on deviations
7.2.6 De-mobilisation
Contract Holder shall ensure that the Contractor demobilizes from the site of work in accordance
with all contractual agreements including the Contractor’s HSE Plan.
Contract Holder shall approve the Site Restoration Certificate (refer Error! Reference source not
found.) and issue it to the Contractor.
MOG BV. Representative/Site Representative may sign the Site Restoration Certificate at the
discretion and approval of the Contract Holder.
Deliverable(s) Approved Site Restoration Certificate (Error! Reference source not found.)
and copy to MOG HSEQ Division Manager
Reference All relevant Contract documents, including the Contractor’s HSE Plan
Document(s):
Contract Holder shall prepare the Final Contract HSE Performance Report to be submitted to the
Contract Department. The report is to be finalized and submitted not later than 90 days after
demobilization.
The Contract Department shall review it as necessary and file the report for future use.
Agree and confirm physical status of the Work /Services against the Contract.
Note all items to be completed and/or rectified and formally document with Contractor.
Prepare a Contractor Performance Report to record the execution of the Contract, including
technical competence and all HSE aspects alongside with HSE feedback
Ensure any penalties have been applied in accordance with the Contract.
Confirm that all charges made under the Contract are valid.
Agree and sign the statement of final account, applicable for all Contracts.
Note: The Contract Holder’s responsibility for management of the Contract shall end on completion
of the statement of final account
Reference Attachment 3 & Attachment 4 conducted during the execution of the project
Document(s):
The below table summarises the deliverables during the contract phases by both company and
contractor
Invitation to
Development of HSEQ requirements (adapt X
Tender Annex 2 to the project)
Complete documentation required in
Attachment 2-HSE Requirements during the X X
Invitation To Tender phase
Complete HSEQ questionnaire MOG-HSEQ-
X
Tender Phase F-242 Rev A1 with all answers
Audit plan X
Contract
Pre-commencement HSE inspection /audit X
Award and
findings report
Mobilisation
Letter of pre-execution of HSE inspection/audit X
report to Contractor
ATTACHMENTS