Allegato130002 Inglese

Eni S.p.A.
Divisione Agip
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ENI - DIVISIONE AGIP
ANNEX 1:
HSE GUIDELINES - APPLICATION REQUIREMENTS
Eni S.p.A.
Divisione Agip
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CONTENT
A.1 POLICY AND STRATEGIC OBJECTIVES.............................................................................3
B-1 RISK ASSESSMENT.....................................................................................................................6
B-2 LEGAL AND OTHER REQUIREMENTS..............................................................................19
B-3 OBJECTIVES AND TARGETS.................................................................................................23
B-4 HSE MANAGEMENT PROGRAMME(S)..............................................................................27
B-5 CONTINGENCY AND EMERGENCY PLANNING...........................................................30
C-1 ORGANISATIONAL STRUCTURE AND RESPONSIBILITIES, MANAGEMENT

REPRESENTATIVES, RESOURCES......................................................................................35
C-2 TRAINING, AWARENESS AND COMPETENCE..............................................................40
C-3 COMMUNICATION....................................................................................................................47
C-4 DOCUMENTATION AND ITS CONTROL...........................................................................51
C-5 OPERATIONAL CONTROL.....................................................................................................55
C-6 PROCUREMENT AND CONTRACTORS.............................................................................61
C-7 EMERGENCY PREPAREDNESS AND RESPONSE..........................................................66
D-1 MONITORING AND MEASUREMENT ................................................................................74
D-2 NON CONFORMANCE, CORRECTIVE AND PREVENTIVE ACTIONS..................80
D-3 HSE IMS RECORDS....................................................................................................................84
D-4 INTERNAL AUDIT.....................................................................................................................88
E-1 MANAGEMENT REVIEW ........................................................................................................96

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Divisione Agip
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HSE GUIDELINES-APPLICATION REQUIREMENTS
A.1 POLICY AND STRATEGIC OBJECTIVES
Define and document HSE policy (ies) and clearly state overall
HSE strategic objectives.
A-1.1 Definition of HSE Policy (ies)
A-1.2 Promotion of HSE Policy (ies)

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A-1.1 Definition of HSE Policy (ies)
Produce an HSE policy
The Organisation should ensure that its own HSE policy is consistent with Eni-Agip Division
HSE policy(ies) and with the Organisation's other policies.
Define commitment of HSE policy
Policy should give evidence of the Organisation’s commitment in the development and
implementation of HSE IMS and in the continual improvement of its efficiency.
The Organisation should define in its HSE policy the commitment:

• to continual improvement of its HSE performance, and reduction of the risk and hazard to
health, safety and environment of its activities, products and services.
• to comply as a minimum with:
− all relevant applicable legislation and associated codes of practice;
− all applicable (environmental) regulations and laws;
− all requirements of the reference standards.
• to apply responsible standards where laws and regulations do not cover all HSE aspects;
• to identify and satisfy stakeholders’ requirements with the aim of increasing the satisfaction
of the same.
• to work with government agencies and others (relevant enforcement agencies, industry
groups and external bodies) to develop and base responsible regulations and standards on
sound science and cost-benefit principles, to consider risks, costs, benefits and effects on
energy and product supply and on local communities welfare, and to understand and develop
HSE management and practice.
• to select contractors that may affect HSE performance of the Organisation so that
Contractors’ HSE standards are consistent with Organisation ones.
Contractors should manage HSE in line with the policy and require joint ventures under its
operational control to apply the policy and use its influence to promote it in its other
ventures.
The Organisation should require Organisation’s Contractors and partners to demonstrate the
same level of commitment to continuous improvement of HSE performance.
• to apply risk management tools, in order to:
− Identify the hazards arising from its business;
− Evaluate and manage the associated risk;
− Implement programs and appropriate protective measures to control such risks,
including appropriate monitoring of its potentially affected employees;
− Be prepared for any emergency and respond quickly, effectively and with care to
emergencies or accidents or incidents resulting from its operations, co-operating with
industry Organisations and authorised government agencies;
− Develop and maintain effective contingency plans, where appropriate in conjunction
with the authorities and emergencies services.
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A-1.2 Promotion of HSE Policy(ies)
Promote HSE policy
The Organisation should promote its HSE policy, involving employees and contractors in the
creation and maintenance of a supportive culture on HSE matters.
At this scope, HSE policy should be:
• implemented and maintained at all Organisation levels;
• easily understood, and translated if necessary;
• prominently displayed at worksites;
• regularly discussed in workplace meeting.
The Organisation should involve line managers in the management of HSE system and
programme by:
• setting HSE standards;
• establishing performance measurements systems;
• setting and monitoring HSE targets.
Document HSE policy and objectives
HSE policy, strategic objectives should be effectively documented, implemented, maintained,

communicated and be accessible in a comprehensible form to all personnel whether directly
employed, contracted or otherwise representing the Organisation.
HSE policy, strategic objectives and periodic performances should be publicly available to
interested parties.
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Divisione Agip
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B-1 RISK ASSESSMENT
Identify systematically the hazards, the effects and the impacts,

which may affect, or arise from, processes and activities, and
from the materials, which are used or encountered in them.
Evaluate (assess) risks and effects from identified hazards.
Select, evaluate and implement measures to reduce risks, effects
and impacts.
B-1.1 Identification of potential HSE hazards
B-1.2 Definition of acceptance criteria for the risks
B-1.3 Evaluation of the risks and effects from identified hazard
B-1.4 Assessment of risks acceptability
B-1.5 Identification of risk reduction measures
B-1.6 Implementation of the selected risk reduction measures

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The Risk Assessment Process

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Divisione Agip
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B-1.1 Identification of potential HSE hazards
Compile a list of activities undertaken by the Organisation for each process.
The Organisation should ensure that the identification of the HSE hazards, effects and impacts is
applied to all the phases of the processes and activities.
The identification analysis should cover all the phases and relevant activities at appropriate level
of accuracy from acquisition and exploration up to decommissioning, abandonment, dismantling,
disposal, reclamation and restoration. Besides, it should include all the temporary phases that are
foreseen in the life of the installation such as anomalous conditions dictated by maintenance
activities.
A reference starting point could be the document "Macroprocesso della Divisione Agip" (Doc.
N°. 1.3.1.3) that outlines all the phases and typical activities of the ENI-Agip Division.
For each activity, gather information on HSE aspects, including:

• Workplaces;
• Facilities;
• Materials;
• Personnel;
• Regulations;
• Procedures.
The action is aimed at identifying all the elements, which may be affected by a potential HSE
hazard that could arise from each activity and from the materials, which are used or encountered
in them.
Care should be taken to the HSE criteria and limitations applicable for each activity to develop
products compliant with the Policy, Eni-Agip Division Standards and/or Procedures and
Regulations.
Gathered information should be arranged in rows consistent with the relevant activity.
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Systematically identify HSE hazards in each activity.
The Organisation should involve appropriately personnel at all organisational level in the
identification of hazards.
For each activity, the most significant hazards should be identified in terms of:
• Potential sources of accidents;
• Potential sources of incidents;
• Human health hazards;
• Environmental hazards;
• Company Reputation hazards;
• Possibility of breaching applicable laws and rules;
• Possibility of violating Company Policy, assigned objectives and targets;
• Possibility of violating identified expectancy of stakeholders;
• Potential sources of economic loss.
Hazard identification should take advantage of a list of key words, deliberately chosen across a
range of complexity, mixture of hazards, sub activities, and other factors that may create a hazard
if they are lacking or deficient, e.g. culture.
TABLE 1 reports some example key words arranged in columns consistent with HSE elements
and appropriate sub elements.
The list should be supplemented or substituted by other key words as appropriate for the
particular Organisation or activity being considered.
The key words should be considered for each of the activities identified.
Identify the effects of each hazard
The Organisation should identify the main effects of each hazard and the main risk drivers and
the most suitable methods to control the hazard and to evaluate their effectiveness.
The identification of the hazards and effects should be performed using adequate specialised
techniques and systems, such as HAZID sessions, hazard and operability studies (HAZOP), event
of fault tree analysis, failure mode and effect analysis (FMECA).
When completing the H&S hazard analysis the following aspects should be considered:
• exposure of people (employee, contractors personnel, population);
• exposure routes (inhalation, swallowing, skin absorption, eyes/ears, radiation);
• exposure probability (hazard potential of material, chance of exposure occurring,
intensity and duration of exposure);
• working environment conditions (noise and vibration, lighting, thermal condition,
ergonomic factors, etc.).
The Organisation should involve personnel at all organisational level with specific expertise in
risk management, HSE issues, design and operations.
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TABLE 1 - KEY WORDS FOR HAZARD IDENTIFICATION
Engineering
Leadership Personnel Health Safety Environment
& Change
Policy Drugs/alcohol Substances Fire Weather Change
Commitment Selection Asbestos Explosive Seasons Modification
Communications Training Noise Road Waste Corrosion
Top - down Motivation Poison Flying Disposal Erosion
Elitist Competence Carcinogen Boat Energy/resource Stress
Standards Culture Stress Drown Emissions Structure
Guidance Temporary Biological Electricity Discharges Quality
Targets Experience Wild animals Hot work Water Design
Information Language Sewage Entry EIA/ Regulation Construction
Lessons Literacy Food/water Elevation Spills Maintenance
Plan Quantity Ergonomics Excavation Permits Specification
Organise Quality Lighting Diving Geography Standard
Control Certification Vibration Rigging Local sensitivity Inspection
Responsibility Size/strength VDU Hoisting Water intake Documentation
Feedback Supervision Radiation Scaffolding Conservation Technical Authority
Open Stand-ins Hot/cold Power tools Leisure
Remote Pressure History
Terrain Steam Wildlife/plant life
Long hours Machinery
Guarding
Others Others Others Others Others Others

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TABLE 1 - KEY WORDS FOR HAZARD IDENTIFICATION (CONTINUED)
Operating &
Contractors Purchasing Emergency Monitoring Security
Technical
Contract Type QA/QC Simultaneous Fire/explosion Audit Terrorism
Contractor Quality Order Start up Spill/leak Auditor Bomb
Experience Specification Shut down Dispersion Technical Threat
QA/QC Receipt One-off Structural Limits Theft
Planning Inspection Unusual Well control Permit Fraud
Qualification Storage Assemble Power Review Lighting
Schedule Handling Dismantle Collision Inspection Hi-jack
Personnel Segregation Specialist Weather General Politics
Coordination Inventory Expert Earthquake Critical Religion
Communication Critical Field changes Flood Hygiene Revenge
Technical Spares Overhaul Landslide Environmental Sabotage
Number Hazardous material Workover Communication Analysis Piracy
Subcontractor HSE equipment Procedure Epidemic Loss Invasion
Temp/casual Scrap Instruction Medevac Statistics Riot
Discipline Surplus Guideline Heart attack Reporting Weapons
Enforcement Transport Fatality Verification Kidnap
Monitoring Insurance Media Follow up Extortion
Audit Local purchasing Support Feedback War
Lost
Facilities
Others Others Others Others Others Others

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B-1.2 Definition of acceptance criteria for the risks
Identify applicable HSE requirements dictated by laws, rules and regulations.
The Organisation should establish procedures to identify and record all applicable HSE
requirements dictated by laws, rules and regulations, and other applicable requirements,
subscribed by the Organisation, in order to make them known to the interested personnel and
evaluate the hazards of their violation.
Set risk acceptance criteria consistent with detailed objectives and specific performances criteria
established.
The Organisation should establish the acceptance level for each risk.
Such criteria should be developed in the light of the policy, strategic HSE objectives, HSE risks
and operational and business needs.
Establish quantitative limits for performance criteria.
The Organisation should establish quantitative limits defining acceptance standards for each
performance criterion.
Such quantitative limits should satisfy, as a minimum, any relevant regulation and, in absence of
such regulations, the HSE Eni-Agip Division Standards or local objectives.
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B-1.3 Evaluation of the risks and effects from identified hazard
Evaluate the risks and the effects from identified hazards.
Risks to be evaluated are addressed in B1 – HSE Guideline, 3rd indent.
Assess the severity of each risk
Each risk should be quantitatively assessed by consideration of the following factors:

• the frequency of the exposure, i.e. how often the hazard is likely to occur;
• the likelihood of the hazard resulting in an accident;
• the magnitude of the consequences.
The Organisation should access to the admissible sources of such information, including:
• internal knowledge and experience of manager and HSE experts;
• industry frequency and failure rate database and co-operative research programmes;
• relevant international, national and Eni-Agip Division standards and codes of
practice;
• industry and trade association codes of practice and other guidance.
The severity of the risk can be graphically represented in the Risk Matrix (Fig. 1), taking into
account the probability of the occurrence of the event and the magnitude of its consequences.
Fig. 1 - Risk Matrix
Depending on the position of the point in the Risk Matrix, it is possible to classify the risk as high,
medium or low according to the following table:
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Legenda Area Risk
The level of risk is acceptable and no control

measure are required Low
The level of risk can be accepted only if the

costs to mitigate the effects are Medium
disproportionate to the benefits.
The level of risk is not acceptable and control

measures are required to mitigate the effects High
Record the risk evaluation results
Results of the evaluation should be recorded, together with the data sources and assumption used.
This record should be used by operations personnel developing procedures and issuing work
instructions and by key people to communicate the hazards that have been identified and the
measures that are in place to prevent and mitigate the risk of occurrence.
The hazard and effect documentation should be compliant with applicable legislative and
regulatory requirements to give evidence of effective application of hazard management.
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B-1.4 Assessment of risks acceptability
Compare each identified risk against the relevant acceptability level or criteria.
The Organisation should compare each identified risk against the relevant acceptance criteria to
decide if the level of the risk is acceptable.
The Risk Matrix (Fig. 1) is a useful tool to assess the risk acceptability from a qualitative point of
view and, if quantitative values are specified for the different definitions, also from a quantitative
point of view.
Assess the risk acceptability
The HSE Responsible of the Organisation should assess in appropriate document the risk
acceptability against the specified criteria .
If it is impossible to reach an acceptable level of risk, a residual risk should be taken into account.
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B-1.5 Identification of risk reduction measures
Identify prevention and mitigation measures to reduce potential HSE risks

The Organisation should identify measures to reduce risks and effects associated with the
identified hazard to within the tolerable criteria defined. Risk reduction measures should consider
and include as appropriate both those to prevent incidents (reducing the probability of occurrence)
and to mitigate the adverse effects (reducing the consequences).
Preventive measures include specific hardware to control hazardous operations and to maintain
asset integrity, such as:
• blow-out preventers;
• pressure release systems;
• personal protective equipment;
• security systems.
They also include organisational and system measures, such as:

• intrinsically safer designs;
• quality assurance, maintenance and inspection procedures;
• safe working practices;
• clear and well-communicated work instructions;
• use of Material Safety Data Sheet (MSDS);
• prophylactic medical treatments (vaccination, immunisation).
Mitigation measures should include steps to prevent escalation of developing abnormal situations
and to lessen adverse effects on health, safety and the environment and, ultimately, emergency
response measures to recover. Such measures include for the H&S aspects:
• ignition control systems
• blast walls;
• secondary tank containments;
• passive fire protection;
• gas/fire/smoke detection.
Select prevention and mitigation measures to reduce potential HSE risks.

The Organisation should evaluate all the identified reduction measures and select those suitable
for reducing risk to a level deemed in compliance with the Company criteria reflecting amongst
other factors, local conditions and circumstances, the balance of cost and benefits and the current
state of scientific and technical knowledge.
Risk Reduction criteria should follow the alternatives in the sequence of preference:
• Remove risk;
• Reduce risk level by appropriate measure;
• Introduce controls.
Reconfirm by review that the reduction measures selected cover all identified risks.
The Organisation should re-appraise activities to ensure that all the risks have been adequately
covered and that the reduction measures proposed enable the fulfilment of local or Eni-Agip
Division HSE objectives.
The analysis should identify hazards arising from risk prevention and mitigation and recovery
measures and should evaluate the tolerability of the residual risks.
This action should involve all the existent controls to determine whether they are adequate or if
revisions are needed.
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B-1.6 Implementation of the selected risk reduction measures
Develop HSE Action Plans to cover all identified risks.
The Organisation should develop an Action Plan to control risks by planning the selected
reduction measures and the upgrading of existing controls, as found necessary.
The plan is aimed at showing what needs to be done in order to ensure that the risk level is under
control and tolerable throughout all the phases of the processes and to meet the assigned HSE
objectives.
The Action Plan should also prioritise actions according to the severity of the risk and should
assign individual responsibilities for actions to be undertaken.
Establish methods to monitor the effectiveness of the HSE Action Plan.
The Organisation should establish methods for monitoring of required risk reduction measures to
ensure both the effectiveness and timeliness of their implementation.
Effective risk reduction measures and follow-up require visible commitment of management and
on-site supervision, as well as the understanding and ownership by operations personnel. HSE
Plan should include, but not be limited to:
• Clear definition of roles, responsibilities and authority for key personnel for HSE
Management;
• Training of new and/or temporary employees upon hiring;
• Periodic training and awareness programs for existing employees;
• Continuous monitoring of activities and results to demonstrate the effectiveness of
systems implemented to meet the Company’s policy and the identified
requirements.
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Review periodically HSE Action Plans to cover new activities or changes in the existing
processes.
The Organisation should perform periodic reviews of Action Plans to ensure the fulfilment of the
HSE objectives.
This review should in addition be performed, if one of the following condition occurs:
• the activities being carried out by the Organisation have, or are going to be
changed;
• the risks associated with the activities changed, or are going to;
• new projects start in new areas;
• new or amended legislation is issued;
• an organisational restructuring takes place.
The Organisation should maintain procedures for planning and controlling changes, both
permanent and temporary, in people, plant, processes and procedures, to avoid adverse
consequences.
The procedures should be suitable to address the (HSE) issues involved, according to the nature
of the changes and their potential consequences, and should address:
• Identification and documentation of the proposed change and its implementation;
• Responsibility for reviewing and recording the potential hazards from the change or
its implementation;
• Documentation of the agreed change and implementation procedures;
• Authority for approval to implement the proposed change.
Procedures should describe how the Organisation will interpret, and assess the implications of
new or amended legislation and how revised regulatory requirements are to be incorporated in
the (HSE IMS).
The Organisation should establish separate plans for the (HSE) management of new operations
(relating, for example, to acquisitions, developments, products, services and processes), or
modified operations where the modification introduces significantly different (HSE) concerns, to
define:
• (HSE) objectives to be attained;
• mechanism for their achievement;
• resources requirements to achieve (HSE) objectives;
• procedures for dealing with changes and modifications as projects proceed;
• corrective mechanisms, which should be employed, should the need arise, how they
should be activated and their adequacy should be measured.
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B-2 LEGAL AND OTHER REQUIREMENTS
Identify and make available the legal and other HSE

requirements.
B-2.1 Identifying and collecting the whole legislative chart, permits and
legal regulations
B-2.2 Reviewing and updating the legislative framework

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B-2.1 Identifying and collecting the whole legislative chart, permits
and legal regulations
Establish and maintain a procedure to identify applicable laws, codes standards, rules,
regulations, etc… as the basis of the activities that are performed and of authorisations that are
necessary for the purpose.
The Organisation should identify and update systematically and regularly all legal requirements
and the ones which may have some HSE impacts and/or may influence the activities in the
different phases of every oil & gas exploitation venture.
This systematic examination should precisely include the compliance as a minimum with:
• all relevant applicable legislation and associated codes of practice;
• all current and applicable regulations and laws;
• all European Directives, rules and standards with reference to the activities of the
Company;
• the international instruments and their interpretation, wherever the Company operates in
the world;
• all applicable laws in force in the countries in which each Company operates;
• all requirements of the reference standards;
• the requirements subscribed by the Company and the others to which the Company itself
subscribes;
• the applicable requirements to the above, and the requirements of subscribed agreements.
Prepare and organise a list of applicable laws, codes, regulations, rules etc according to items
such as:
• Environment:
− Water
− Air
− Wastes
− Soil, etc.
• Occupational Health;
• Industrial Safety;
• Health and Safety of public (community);
• Radiation Protection;
• Security;
• Quality etc.
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Organise a list of authorisations and relevant requirements
Set up, maintain and update a list of the authorisations and of the relating, possible and acquired
prescriptions (or to be acquired for new installations) for the activities of each installation of
competence.
Identification of the applicable requirements.
Such interpretation requires expert and possible assistance by a lawyer.
Besides this involves that, with the aim of realising the compliance with the above and in order
to develop and base responsible laws, regulations and standards on sound science and cost-
benefit principles, to consider risks, costs, benefits and effects on energy and product supply,
and to understand and develop HSE management and practice, the Company should work with:
• suitable Health, Safety, Security, Social Accountability, Environment, Quality
Management and Radiation Protection Units;
• Legal Affairs Office;
• government agencies;
• relevant enforcement agencies;
• industry groups;
• external bodies.
Implementation of procedures to ensure respect and control of requirements.
Procedures should consider:

• Establish the steps to be performed (calendar of planned actions; detailed procedures for
collection analysis; review of samples; limits imposed by law and more restricted limits
defined by Company to ensure law limits are satisfied etc.);
• Responsibility for verification of respect of the requirements;
• Actions in case of non-conformance and situations which are regarded as offences to law
(how to manage documentation, how to react to external requests etc.).
Make available to the line management the interpretation of the applicable laws and rules and
outline procedures to be followed.
Procedures should be further developed by line management if more details are necessary and to
establish who is in charge of activating the procedure.
The diffusion of relevant information on the above and on updating should be realised by:
• recording statutory requirements and codes applicable to the (HSE) aspects of both
Company’s and Eni-Agip Division’s operations, products and services;
• communicating at defined intervals such updating information both to Company and Eni-
Agip Division personnel.
The Organisation should prepare a procedure to ensure the recording of all statutory
requirements and codes applicable to the HSE aspects of its operations, all regulations, the plans
for the renewal of the authorisations etc.
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B-2.2 Reviewing and updating the legislative framework
Establish procedures for systematic identification and review of variations of laws, rules,
standards, etc
When modifications or issue of new applicable laws occurs, it is necessary to recognise them
and evaluate their impacts on all the activities of Company.
A procedure is required for establishing periodical review of the existing state of authorisation.
Company should ensure a systematic contact with the Local Administration and with the
Governmental Control Agencies.
Maintain an appropriate register of the applicable legislation
It is necessary to formally record and file the legislative framework in a dedicated register to be
maintained at Company level. This legal archive should include as a minimum:
• the applicable legislative body;
• the identified reference standards requirements;
• the authorisations and permits framework, and the relevant renewal programs;
• the monitoring and surveillance plans to ensure control and respect of the requirements;
• the communications and information transmittals within the Company and Eni-Agip
Division;
• the communications, mails and formal acts with the Local Administration and the
government/enforcement agencies.
A section or a partial replication of the register should be installed at the operation centres and
sites, in which only the pertinent records, authorisations and data are filed, maintained and
periodically up dated as necessary.
The use of a local archive system at the operative sites helps to:
• ensure that working personnel be aware of the specific requirements to comply with;
• improve the control and respect of the defined surveillance and monitoring plans;
• plan the renewals of the expiring authorisations.
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B-3 OBJECTIVES AND TARGETS
Establish detailed HSE objectives and performance criteria at

relevant levels.
B-3.1 Identification and definition of HSE objectives and targets
B-3.2 Definition and selection of performance indicators and criteria
B-3.3 Review of HSE objectives and performance criteria

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B-3.1 Identification and definition of HSE objectives and targets
Establish and maintain procedures to define detailed HSE objectives and targets at relevant
levels of the Organisation
The Organisation should define and set up detailed HSE objectives and targets, in line with Eni-
Agip Division objectives assigned to the Geographical Area, and include them in short and long
term plans.
HSE objectives should include aspects specific to HSE and should be set annually as a minimum,
taking into account the following:
• Company HSE Policy,
• Eni-Agip Division strategic objectives,
• stakeholders expectations,
• identified HSE risks in the activities,
• operational and business requirements (e.g. the legal and political environment in which the
Company operates).
The objectives should clearly demonstrate the effective commitment of the Organisation to
operate for the sustainable development, the respect of all applicable requirements and the
employment of the best industrial practice by means of:
• minimisation of environmental impacts (harmful discharges, emissions, wastes, etc.) from
operative activities (involving Company, Contractors and stakeholders), also exceeding
legislative requirements,
• efficient use of energy and natural resources,
• minimisation of accidental losses (e.g. injuries, equipment damages, product losses, etc.),
• promotion and set up of joint agreements with stakeholders to pursue specific HSE targets
• support R&D programmes relevant to Company’s HSE needs.
The objectives should be:

• formally assigned and documented,
• clearly defined, realistic and achievable, also taking into account for next future available
technologies.
HSE objectives should be cascaded down and deployed appropriately throughout the
Organisation at relevant levels.
Where possible, site-dedicated or project specific HSE objectives should be set, based on
Company ones with applicable financial targets included in operating budgets.
Individual tasks and targets should be defined for personnel and positions to which are assigned
HSE critical activities (e.g. managers, supervisors), or be incorporated in individual job
descriptions.
These individual objectives should be derived from the shared Company HSE objectives.
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B-3.2 Definition and selection of performance indicators and criteria
Establish and maintain procedures to set performance criteria for critical activities and tasks,
which stipulate in writing the acceptable standard for their performance
The Organisation is committed to planning, allocating, and evaluating work carried out by teams
or individuals, to achieve its objectives safely and effectively.
The performance management should be achieved by:
• ensuring that everyone involved in Company work has a clear understanding of the business
objectives and priorities, particularly the relationship between HSE objectives with
commercial and operational activities;
• setting and updating work targets for teams and individuals based on business and HSE
objectives;
• planning work to make the most effective use of people’s abilities;
• allocating work to people in terms of the results expected;
• identifying performance issues which may affect the achievement of business and HSE
objectives;
• establishing suitable performance criteria and indicators for identified critical activities and
tasks;
• giving feedback to individuals on their performance against the results obtained.
The Organisation should identify and maintain meaningful performance criteria and indicators at
all levels.
Performance criteria and indicators are the main technique, along with audits and management
review, to establish the degree to which objectives set out in the HSE IMS are achieved.
Typical world-wide accepted performance indicators for HSE matters are:
• Lost Time Injury Frequency (LTIF),
• Total Reportable Case Frequency (TRCF),
• Injury Severity,
• Total Reported Sickness Absence,
• Total New Cases of Occupational Health,
• Incident Total and Potential,
• Emergency Shut Down (ESD) Trips and Alarms,
• Planned Discharges,
• Unplanned Discharges (Environmental accidents).
Performance indicators should be issued according to the specific objectives assigned within
HSE Plans.
This set of criteria should constitute written standards for management performance in HSE
programme, setting out “who does what, and when or how often”.
The Organisation should regularly monitor performances through line management

communication (individual or collective).
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B-3.3 Review of HSE objectives and performance criteria
Review periodically the objectives and performance standards criteria in the perspective of
continual improvement and further compliance with growing Organisation expectations
Progress in achieving HSE objectives should be reported and recorded at management meetings at
least monthly, and communicated through the line management.
Such achievements should be reported to the Geographical Area of Eni-Agip Division.
The objectives and performance criteria should be periodically reviewed (typically at the
management review) to ensure that they:
• are still reflecting the requirements of the HSE Policy and management programmes,
• have been reached totally and effectively, or
• have to be modified, re-addressed or renewed to better achieve the targets.
The Organisation should ensure that the results of these assessments and the effects of these
controls and reviews would be considered when setting its objectives.
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B-4 HSE MANAGEMENT PROGRAMME(S)
Establish and maintain (an) HSE management programme(s) for

achieving the objectives and performance criteria.
B-4.1 HSE Management Programme

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B-4.1 HSE Management Programme
Establish and maintain, within the Organisation’s overall work programme, plans for achieving
(HSE) objectives and performance criteria.
The Organisation, with the aim to ensure the effective implementation of the Policy, the
strategic objectives and targets, should prepare and issue a HSE Management Programme
document, that should:
• be approved, endorsed and signed by the Senior Management, typically at the
commencement of the year;
• set out a programme for the implementation and achievement of the defined Organisation’s
HSE targets;
• identify specific actions in order of their priority to the Organisation, dealing typically with
individual processes, projects, products, services, sites or facilities within a site.
The HSE Management Programme should be formalised and distributed according to line
management and relevant responsibilities, and should take into account factors such as:
• the overall goals of the HSE Management System and the Policy;
• the designated responsibilities and authorities in charge for the achievement of the
objectives at relevant functions and levels of the Organisation;
• the allocated resources (human, physical, financial) required to effectively implement the
programme(s);
• the premises for the implementation of departmental HSE programmes and for establishing
individual tasks and targets, which should then be agreed with individuals as part of their
annual performance appraisal;
• the defined schedules by which the targets are to be achieved, detailing activities and
intermediate milestones;
• the actions to motivate and encourage greater workforce involvement in creating,
executing, achieving and improving HSE management and objectives;
• Contractors activities management in perspective of the achievement of defined HSE
objectives and targets;
• performance indicators and controls definition;
• performance measurements, monitoring arrangements and feed-back to personnel involved
in the process;
• any new legislation or codes of practice’s major change that may lead to invalidate or
modify schedule and targets fulfilment;
• technological, operational and organisational change (e.g. new projects, change of roles), in
order to dynamically reflect, review or revise programmes or priorities if necessary;
• performance recording and analysis on a regular basis (e.g. at the management review), to
provide feedback and to identify areas for further actions and improvements.
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Contractors HSE programme
When Organisation is prone to use Contractors for processes that may affect HSE objectives,
the Organisation should:
• identify and analyse the processes assigned to Contractors, and address relevant risks;
• ensure steady control and monitoring of Contractors HSE IMS processes, objectives and
targets;
• include objectives in the Contract specifications and clauses, and highlight their importance
in the Contracts awards (e.g. by means of an incentives strategy);
• evaluate performance according to specific criteria and methods (e.g. scoring models).
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B-5 CONTINGENCY AND EMERGENCY PLANNING
Identify foreseeable emergencies by systematic review and

analysis.
B-5.1 Identification of foreseeable emergency scenarios
B-5.2 Preparedness of emergency response plans
B-5.3 Monitoring of the effectiveness of response plans

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B-5.1 Identification of foreseeable emergency scenarios
Identify foreseeable emergency scenarios from the hazard identification and risk assessment.
Foreseeable emergencies should include:

• Fire and explosion;
• Failure of key controls, of power sources or of services;
• Structural failures;
• Worksite death, injury, sickness;
• Diving, marine and aviation incidents;
• Man overboard or missing person situations;
• Spills and unplanned release of product or other materials (pollution);
• Security incidents such as breaches, sabotage, kidnap and extortion;
• Outbreaks of disease;
• Breakdown of law and order;
• Geophysical and natural events;
• Other events highlighted by the hazard and effects identification.
The Organisation should define scenarios which Company and regional capabilities can cope
with (Tier 1 and Tier 2 emergencies) and link with Eni-Agip Division for Tier 3 emergencies.
Evaluate HSE exposures that could arise from each emergency scenario.
The Organisation should carry out risk assessments and/or specialist studies to identify and
evaluate HSE exposures, which could arise from each emergency scenario identified.
The Organisation should involve personnel at all organisational levels with specific expertise in
risk management, HSE issues, design and operations.
Identify response measures for each emergency scenario identified.
The Organisation should identify emergencies response measures to apply in emergency

situations.
Emergency response measures should include:

• Emergency shut-down systems;
• Fire-fighting devices;
• Emergency evacuation and escape procedures;
• Rescue craft;
• First-aid equipment and personnel;
• Specialist medical treatment;
• Oil-spill clean-up systems.
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B-5.2 Preparedness of emergency response plans
Develop an emergency response plan to address all the emergency scenarios identified.
The emergency response plan should:

• provide adequate guidelines for response to specific emergencies for key team members;
• provide adequate regulatory and technical background information, including authority
contacts, reporting requirements, and reference/listing of technical information;
• be in compliance with national/local regulations;
• aim at limiting losses, public exposure, legal liabilities, fines,…
Establish manpower resources including roles and responsibilities of emergency response

organisation.
The Organisation should develop, document and maintain a procedure for establishing
manpower resources able to respond to the identified emergencies.
The procedure should include:
• clear statements of intent;
• an organisation chart;
• simple explanations of what is required from each discipline;
• details of structure;
• manning levels;
• interrelationships of emergency teams
Establish adequate training needs for staff
The Organisation should develop, document and maintain a training programme, including:
• full scale exercises in conjunction with outside authorities/agencies;
• drills, such as emergency shut-downs, fire and spill drills, in each area to rehearse and test
detailed plans;
• First-aid techniques for local exposures.
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Establish internal and external communications
The Organisation should develop an adequate procedure for establishing:

• communication with authorities, relatives and other relevant parties;
• information releases to the public in the event of an emergency;
• public HSE information (such as the need for evacuation of off-site areas) to appropriate
authorities in the event of an emergency.
This should include when appropriate national and municipal authorities, utilities and local
users, river authorities, air, road, rail, marine transport authorities. The procedure should
address possible evacuation of off-site areas and co-ordination with outside agencies.
The procedure should cover who is, and is not, authorised to make statements to the press, TV
etc. How non-spokespersons should handle requests for information, what types of information
should be provided at what stages in what form. (e.g. company and site fact sheets, distribution
lists for press statements and telephone enquiry logs should be prepared in advance).
Establish facilities and equipment for emergency response teams
The Organisation should establish systems, arrangements and procedures for:

• making available dedicated company equipment, facilities and personnel for the various
emergency response teams;
• providing personnel refuge, evacuation, rescue and medical treatment;
• providing adequate emergency lighting and power;
• mobilising third party resources for emergency support;
• preventing, mitigating and monitoring environmental effects of emergency actions;
• ensuring that adequate systems regarding emergency, protective/rescue equipment are
provided:
− detection/alarm systems for hazards such as smoke, hydrocarbons, toxic substances;
− fire extinguishing systems and fire-fighting equipment;
− other emergency and rescue equipment, such as breathing apparatus, emergency
escape air packs, eye baths and showers, blankets, stretchers, and rescue
equipment to cover local exposures.
• ensuring that first aid facilities and equipment are adequate and well maintained;
• carrying out regular maintenance on pollution control equipment.
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B-5.3 Monitoring of the effectiveness of response plans
Establish methods to assess the effectiveness of emergency response plans.
To assess the effectiveness of response plans, the Organisation should maintain procedures to
feed back experience from live emergency (investigations), scenario drills, exercises and other
suitable means into emergency plans
Procedures should be in place for the periodic assessment of emergency equipment needs and
the maintenance of such equipment in a ready state.
Establish criteria to record the results of the tests.
The Organisation should:

• make and update at appropriate intervals a record of such identified potential emergencies,
in order to ensure effective response to them;
• besides it keep records of training, exercises, reviews and corrective actions taken to
improve the plan.
Develop a procedure to review the response plan.

• ensure that the response plan is regularly reviewed;
• maintain a procedure to define who is responsible for updating the plan, when/how often,
the system for making changes and the (numbered) distribution list. Copies should be sent
to regulatory agencies, industry groups/mutual aid partners and Eni-Agip Division HSE
Manager.
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C-1 ORGANISATIONAL STRUCTURE AND

RESPONSIBILITIES, MANAGEMENT
REPRESENTATIVES, RESOURCES.
Define, document and communicate the roles, responsibilities,

authorities, accountabilities and interrelations of personnel who
manage, perform and verify activities having an effect on the
risks of the activities, facilities and processes.
Provide the necessary resources (human, technical competence,
technology, financial) to actuate and control the IMS.
C-1.1 Definition of HSE organisational structure
C-1.2 Documentation and communication of HSE responsibilities
C-1.3 Allocation of HSE resources

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C-1.1 Definition of HSE organisational structure
Define HSE organisational structure.
The organisation should typically define the structure as:

• General Manager (or equivalent figure) having overall responsibility for the HSE
issues, particularly for respecting the laws,
• Line Managers that have operating responsibility in the application of the HSE
System,
• Company HSE Representative having among other tasks the responsibility for
supporting with technical competence the General Manager.
Identify roles and responsibilities of HSE organisational structure.
The Organisation should identify HSE roles, responsibilities, authorities, accountabilities and
interrelations of personnel who manage, perform and verify activities having an effect on the
risks of the Organisation’s activities, facilities and processes.
Department Line or Functional Managers should:

• implement HSE policy within their area of responsibility;
• have a general responsibility to minimise the risks to the health and safety of personnel and
any environmental impact, by assessing work activities under their control as frequently
and to the degree of depth that the level of risk requires;
• ensure that:
− the work is properly planned and resources allocated;
− appropriate controls are implemented;
− personnel are adequately trained, instructed and supervised;
− HSE information is made available to their staff.
All personnel should:

• have a responsibility to co-operate to ensure that the workplace is safe for everyone who
may be affected by their actions, and to take reasonable care not to do anything, which may
endanger themselves or others, or cause avoidable damage to the environment;
• be responsible to report any unsafe acts or conditions, which they have observed.
Contractors and visitors should be responsible to comply with all HSE procedures and
regulations of the Organisation.
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C-1.2 Documentation and communication of HSE responsibilities
Document HSE roles and responsibilities.
Roles and responsibilities should be formally documented and communicated.
In addition, the Organisation should document the HSE responsibilities of all the members of
the Business Unit management in a stand-alone document, so that everyone within the
Organisation is aware of everybody else's HSE responsibilities, not just their own.
Include HSE responsibilities in job description.
The Organisation should include HSE responsibilities in job descriptions for all relevant
personnel and, as a minimum, for all Business Unit managers, so that:
• Business Unit manager should ensure that Organisation's HSE policies are clearly
understood, maintained and not compromised in all aspects of the Company's business;
• Production Manager should ensure that the day by day engineering, maintenance and
production operations at the field fully comply with Eni-Agip Division and Organisation's
HSE standards;
• Procurement and Contracts Manager should ensure that Business Unit contractual
conditions include requirements for standards of HSE protection that fully comply with
Eni-Agip Division and Business Unit policies and legislative requirements;
• Organisation charts should be sufficiently detailed to completely describe the HSE
responsibilities of each key person.
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Set up an HSE communication system.
The Organisation should set up an HSE communication system, as mechanism for:

• feeding back lessons learned and other useful information to the workforce;
• getting their input.
An HSE communication system should ensure that employees and contractors:

• are familiar with the HSE issue and legal requirements relevant to their area of work;
• understand the potential impact of the operations and activities, for which they are
responsible, on health, safety and environment;
• are aware of and comply with the relevant HSE sound working procedures;
• co-operate in defining the training programmes and in implementing HSE plans and
procedures;
• take note of all potential hazards to health, safety and environment and promptly report all
accidents, incidents or near misses.
At this scope the Organisation should select the most suitable methods to achieve effective HSE
communications, depending on the size of the Business Unit, the operations being undertaken
and local culture.
More commonly used HSE communications methods are:
a) Notice Boards
The Organisation should make available information to employees and contractors in
dedicated HSE notice boards positioned in every workplace.
b) Meetings
The Organisation should hold periodic HSE meetings on operational sites to ensure an
effective dissemination of information between management and employees at all levels.
c) HSE Committee
The Organisation should establish an HSE Committee, composed of representatives of both
management and the workforce, as forum for proactive discussion on all occupational
Health, Safety, Security and Environmental issues.
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C-1.3 Allocation of HSE resources
Allocate necessary HSE resources.
The Organisation should allocate sufficient resources to actuate and control HSE IMS, in terms
of:
• human resources;
• technical competence;
• technologies;
• financial resources.
Resources allocation should include:

• facilities, plant and equipment to meet legislative and regulatory requirements;
• personnel, equipment and infrastructure to respond to and mitigate emergency situations;
• availability of management for HSE audits and reviews;
• resources for new developments.
The allocation of necessary and justified resources for HSE matters is widely regarded by staff
and other interested parties as indicative of Company commitment to HSE policy and
objectives.
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C-2 TRAINING, AWARENESS AND COMPETENCE
Ensure all personnel, both Organisation’s and Contractor’s, is

competent, trained in and aware of the implication of its
activities for HSE aspects.
C-2.1 Identification of competence requirements
C-2.2 Definition of training necessity and supply
C-2.3 Personnel competence appraisal
C-2.4 Content of courses (general)

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C-2.1 Identification of competence requirements
Basis of the competence requirements is the analysis of the activities, to define:

- HSE implications (e.g. hazards and consequences);
- Positions to which are assigned critical activities and tasks for HSE Management
The Organisation should prepare a procedure to:

• carry out this analysis of its activities derived from the Hazards and Effects Analysis
performed for risk management purposes. In such an analysis the HSE implications and
identified the measures to ensure their control would be defined;
• perform the analysis for ordinary, anomalous and exceptional conditions, including
emergencies;
• include activities that are assigned to or involve contractors.
Critical activities are meant to be the ones that involve (as an example) management of major
risks for health and safety of personnel, or that are connected with respect of law requirements,
particularly if consequence may imply degradation of relations with authorities, or stop of the
activity.

• review competence requirements in correspondence of modifications of the activities;
• establish periodical review of defined necessary competence, considering modification of
expectancies, of technologies, objectives, etc;
• establish periodical review of personnel competence to ensure adequate competence is
maintained.
Identification of competence for all personnel, with specific requirements for personnel to
which HSE critical activities and tasks are assigned.

• identify the necessary competence, acquired through education, training, personal
abilities, skills developed through experience;
• analyse HSE requirements as well as the single Health & Safety, Environment, Quality,
Social Responsibility, Security, Radiation Protection;
• document identified necessity in terms of a “specification” connected to the activities and
tasks, to allow understanding and review when necessary;
• identify content of training courses that may provide the necessary competence;
• include when possible the identified content in the professional training of personnel;
• verify HSE competence is adequate for achievement of Company policy and objectives.
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C-2.2 Definition of necessity for training and supply
Necessities of training for the operating personnel
The line management should:

• ensure that adequate competence for the execution of the tasks is maintained;
• perform (with the assistance of HSE manager or equivalent position if necessary) the
systematic definition of training necessities through a periodical review of competence of
personnel and comparison with necessities/objectives.
Indications of above can be derived by:
- modifications of activities, plants, etc.
- modification of regulations;
- modification of contents of the common training programmes for the qualification of
personnel;
- non conformance reports highlighting areas of weakness related to training/awareness
in HSE issues;
- periodical reviews and management reviews in which new objectives, modification of
activities, expectancies by stakeholders (as an example PSA agreement requirements,
expectancies of local communities), etc. have been identified and discussed;
- analyses of HSE competence of personnel and training provided in the previous years;
• provide training through:
- specific courses;
- HSE awareness meetings (or related to one of the HSE aspects)
- specific seminars or conferences.
Seminars and conferences represent a mean for increasing competence of high level personnel
and for enhancing communication with other companies. They may not be subjected to a
systematic planning, being organised by independent organisations.
Analysis of training requirements and inclusion in the budget.

• establish a procedure for reporting the identified necessity of training and for the definition
of the budget for personnel training;
• specifically identify the HSE necessities in the budget, to allow accounting of the
expenditure for the HSE issues. The budget should include allowance for attending
seminars and conferences as may be found necessary during the period covered by the
budget.
Planning of training activities.
Once approved and inserted in the budget, the Organisation should:

• plan training activities and give adequate priority in the organisation of the work. Planning
is performed:
- identifying the specific training course (or the content of the course to be required and
purposely designed by course supplier);
- inserting the training period in the activities to be performed by the personnel
interested, in agreement with the organisation unit to which the personnel refer.
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Management of the training courses
The Organisation should ensure that training courses and awareness sections are subjected to
control actions with reference to:
• Identification of content actually provided to the participants;
• Evaluation of efficiency of organisation and tutors;
• Evaluation of the effectiveness on the preparation of the personnel
• Suggestions for improvement.
If training is provided by Contractors, qualification activities and feed back should be activated
as for any other contract.
Recording of personnel qualification and of training activities provided

• set up and maintain a system of records to provide:
- identification of qualification of personnel;
- recording of HSE and professional training activities provided, including reference to
their content.
• agree with Eni-Agip Division HR Dept. the training courses for expatriates.
The system should allow review of the information contained for:

- planning purposes
- overall analyses of competence of the personnel
- monitoring of specific objectives and requirements.
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C-2.3 Personnel competence appraisal
Establish procedures for initial recruitment and/or selection of personnel for such activities and
tasks that require a defined competence in HSE issues.
Apply this for Company personnel and for contractors.

• carry out appraisal of personnel competence normally when activities or plant are modified,
when selecting new personnel, or when changing the tasks assigned;
• address the following aspects in an appraisal session:
- technical appraisal, to ensure adequate qualification for the execution of the job;
- HSE competence appraisal, to ensure adequate qualification in the specific
management of HSE issues;
- Necessity for additional training in some of the above aspects;
- Conclusions on ability of the person for the position to be assigned.
Additional appraisal of specific attitude of personnel may be required by Human Resources and
Organisation Unit according to Company Rules or for specific positions, and it is not addressed
in this standard.
The term “technical” is used to state the competence for the execution of specific tasks
connected with the position other than related to HSE.
Technical competence appraisal
The Organisation (namely: the competent line manager or equivalent position) should ensure
the evaluation of personnel training and experience about technical aspects, concerning the
tasks to be performed should consider:
• the qualification specified for the job;
• necessity of specific training courses
• siding to expert personnel for a specified period.
HSE competence appraisal
The Organisation (namely: the competent HSE manager or equivalent with the co-operation of
the line manager) should perform HSE competence appraisal for the personnel:
• who operates the HSE Management System;
• whose task has significant HSE implications or could produce significant HSE impacts;
Appraisal concerning the tasks to be performed should consider:

• the qualification specified for the job;
• necessity of specific training courses
• siding to expert personnel for a specified period.
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Global assessment
Technical Competence Appraisal and HSE Competence Appraisal converge to a global

assessment of the ability of the personnel to cover the position, subjected if necessary to
specified training or siding.
The Organisation should plan follow up to ensure that the conditions for the training and siding
on the job documented in the assessment are adequately satisfied.
Recording
The Organisation should establish a form reporting the items raised for the appraisal to
document the assessment.
The form should be:

• signed by the competent line manager and HSE manager;
• be stored as a HSE record for a defined number of years (typically 5 years).
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C-2.4 Content of courses (general)
Courses
The Organisation should foresee general training courses addressing the following items:
• Integrated Policy of the Company;
• legal requirements connected with the activities of the trainees;
• HSE effects connected with the activities of the Company and specifically of the trainees;
• Organisation of the HSE Integrated Management System set up to give assurance of correct
management of risks;
• Manual of the HSE IMS
• Procedures of the HSE IMS specifically connected with the activities of the trainees
• importance of conformances of behaviour, actions, processes, products and services to the
Integrated Policy, the procedures and the requirements of the HSE Integrated Management
System and possible consequences of non conformance;
• Emergency scenarios, preparedness and response, expected behaviour of the trainees.
Specific courses should be held for part or other issues with respect to the above.
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C-3 COMMUNICATION
Ensure communication of HSE information, consistent with

Policy and with applicable legislation and regulation.
Ensure reception and response to communications from
interested parties.
C-3.1 Communication within the Company and Contractors
C-3.2 Communication with external parties

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C-3.1 Communication within the Company and Contractors
HSE Communication Management
The Organisation should establish and maintain procedures to ensure effective internal
communication between operative sites and departments according to the line management, in
order for:
• safe and efficient operations to take place;
• establish effective communication of HSE information;
• ensure consistency with its policy and with applicable legislation and regulation.
In particular, the Organisation should:

• set up an HSE committee structure to provide a formal, structured mechanism for employee
feedback on HSE matters;
• establish documented arrangements (e.g. scheduled meetings) to ensure that the workforce is
consulted about those HSE issues in the workplace which affect them, in order to have an
informed contribution to these issues;
• provide for non-management personnel to choose (a) representative(s) from their own group to
facilitate communication with senior management on matters related to health, safety and the
environment;
• ensure that periodical meetings (typically with a monthly timescale) of the HSE Committee
take place, in order to discuss the effectiveness of the management system at all levels;
• produce, wherever necessary, bulletins and notices to cascade information to employees and
contractors, relating to HSE issues;
• establish promotional competitions for teams at worksites based on compliance with Company
HSE programme standards and objectives;
• carry out a systematic review of HSE information needs.
Systematic HSE communications should be constituted (but not limited) to the following:
• dissemination of Company HSE objectives through the line management;
• formal feedback on remedial actions taken to face critical issues or occurring accidents;
• periodical reports on the effectiveness and level of implementation of the HSE IMS (i.e. to be
discussed at the management review);
• summaries of the impact of the new legislation or reviews of the Eni-Agip Division
requirements on Company activities;
• details of initiatives and projects on HSE matters within the Company and external within the
oil industry;
• HSE notices, investigations and reporting learnt from incidents from one site which may apply
elsewhere;
• information on incidents from third parties, or safety and health alerts, to prevent similar
occurrences within Company activities;
• documentation relating projects, resources and budgets allocated for HSE matters;
• reports on periodical emergency trials and drills;
• minutes of meetings and briefings on HSE sensibilisation, motivation and awareness
promotion;
• bulletin boards, newsletters, posters, placards, booklets and hazards awareness
programs/campaigns (particularly at worksites and operative centres). HSE bulletin boards
should be located so that every employee has the opportunity to see one during the working
day, and should be issued in style and language easy comprehensible by all employees;
• HSE audits results and reporting;
• HSE annual report (also in view of a contribution to editing the Eni-Agip Division one).
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Workforce Involvement
Employees should:
• participate in hazard and risk assessments workshops and meetings, and be proactive in
review activities of policies and procedures to manage risks;
• be informed of their responsibilities to report hazards (such as sub-standards acts or conditions
outstanding or not consistent with legal requirements and regulations) to their immediate
supervisor, or other available member of management according to the organisation structure;
• have free access to HSE IMS documentation and to general information on Company
activities via suitable systems (documents circulation, email/library systems, web browsing
access, etc.);
• select their HSE appointee(s) to be represented in the HSE Committee;
• attend to the HSE meetings and daily workplace briefings to discuss current HSE topics;
• receive feed back of findings derived from HSE inspections/housekeeping checks and in
general from the accident investigation, reporting and analysis process, and be involved to
transfer “lessons learnt” into standards, procedures, training programmes, rules and permits
systems, etc.;
• be consulted where there are any changes that affect workplace health and safety.
Communication with Contractors
The Organisation should establish and maintain procedures for receiving and responding to
communications from Contractors and Suppliers concerning its HSE aspects, performance and
management.
In particular, the Organisation should:
• ensure adequate information and promote Contractor’s awareness on Company initiatives and
targets on HSE issues, also including Contractor’s employees in HSE awareness meetings and
campaigns on critical/topical problems;
• provide them with the Company HSE Policy(ies) and, in case of bids or when stipulating
business agreements and purchasing contracts, with the relevant HSE IMS procedures and
documentation,
• hand over or prepare new ad-hoc written instructions on specific HSE matters, to perform
soundly and effectively the required duties and activities;
• involve Contractors in periodic HSE team meetings at the worksites to discuss general and
current HSE issues, such as the co-ordination of objectives between Contractors and Company
to improve levels of safety, health and environmental protection in operative activities.
Contractor’s participation and attendance at these meetings should be documented.
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C-3.2 Communication with external parties
Communications with interested parties
The Organisation should establish and maintain procedures for receiving and responding to
communications from interested parties, including customers, government agencies and the public,
concerning its HSE aspects, performance and management.
The Organisation, taking into account the Eni-Agip Division policy and communications ruling
public relations with interested and third parties, should appoint a function for external
communications formally linked to the Eni-Agip Division who:
• discipline personnel participation to public workshops, community roundtables, official
meetings, local radio/TV/press interviews;
• prepare a communication plan with the aim of promoting Company reputation within local
communities (i.e. meeting and guided visits at the facilities and worksites, information
material such as booklets, posters, multimedia presentation, HSE magazines, etc.);
• prepare formalised instructions to deal with external notifications or claims on HSE issues
according to the line management;
• prepare press releases in case of emergency.
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C-4 DOCUMENTATION AND ITS CONTROL
Establish and maintain appropriate information to describe the

core elements of the IMS and their interaction and to provide
reference to related supporting documentation.
Establish and maintain adequate control that documents and
data required for HSE management are:
- located;
- periodically reviewed and formally revised as necessary;
- available at the locations where operations essential to the
effective functioning of the IMS are performed.
C-4.1 Implementation of HSE information system
C-4.2 HSE Documentation control

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C-4.1 Implementation of HSE information system
Identify HSE information needs.
The Organisation should identify HSE information needs, including:

• Legislation and other external HSE information;
• Training material;
• Research and development information;
• Catalogues of materials and services from recognised HSE agencies;
• Current HSE equipment supply catalogues;
• HSE magazines;
• HSE books.
Identify and classify HSE applicable documentation.
The Organisation should identify HSE applicable documentation, covering:

• HSE system documents;
• HSE studies and technical report;
• HSE records.
The Organisation should classify HSE documentation, according to the following levels:
• Eni-Agip Division;
• organisational Divisions and Business Units;
• individual functions and operations;
• Contractors and partners.
Implement the HSE documentation system.
The Organisation should ensure that the information necessary for the implementation and
maintenance of the HSE system is recorded, retrieved and modified in a traceable, effective
manner.
For this purpose, the Organisation should implement the HSE documentation system to manage
information, in a suitable medium such as paper or electronic form, that:
• Describes the core elements of HSE system and their interaction;
• Provides direction to related documentation;
• Includes definition of responsibilities for maintaining this information.
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Establish requirements for HSE documentation.
The Organisation should establish requirements for managing HSE key documents and data
required to ensure that they are:
• classified;
• identified with an appropriate code;
• properly located;
• legible;
• dated (with dates of revision);
• identified with the appropriate Organisation, division, function or activity numbered (with a
version number);
• maintained in an orderly manner and retained for a specified period.
Define responsibilities for documentation management.
The Organisation should establish policies and responsibilities for the management of
documents and their distribution to employees, Contractors, government agencies and the
public.
At this scope, the Organisation should ensure that personnel are made aware of the
documentation procedures, especially are known the responsibilities for maintaining HSE
information (this includes: approval, emission, modification and distribution of documents).
Address HSE document contents.
The Organisation should provide instructions for addressing the contents of HSE documents in
order to ensure that the information they contain is set out in a consistent manner.
The Organisation should define HSE documents structure, covering standard sections, such as:
• purpose (objectives of the document);
• application (boundaries and restrictions to the applicability of the document);
• performance standards (criteria for verifying the document);
• responsibilities (key responsible of document application);
• reference documents (list of external and internal documents having implications on the
document content);
• procedures (detailed description of the methods to meet the targets/requirements).
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C-4.2 HSE Documentation control
Review HSE documentation system.
The Organisation should periodically review:

• HSE information needs to ensure they remain relevant to the Organisation activities;
• HSE documents and data to feedback findings and "lessons learned" into HSE standards,
procedures or training programmes.
The Organisation should use sources, such as:

• Accident investigations/causal analyses;
• HSE audits;
• Environmental surveys;
• Health surveys;
• Workplace inspection analyses;
• Major hazard studies;
• HAZOP studies;
• Critical part analyses;
• Critical task analyses;
• Other external sources.
"Lesson learned" should be incorporated in:

• Management standards
• Inspection procedures;
• Task procedures;
• Emergency procedures;
• Rules and permit systems;
• Training programmes;
• Engineering controls;
• Purchasing controls;
• Contractors control;
• Other control systems.
The Organisation should define type of documents to be submitted to Eni-Agip Division

Geographical Area and HSE Manager; they should include as a minimum:
• Accident investigations and reports;
• Accident/Incident trends;
• Environmental data;
• HSE reports;
• Major hazard studies.
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C-5 OPERATIONAL CONTROL
Plan operational control activities to include all aspects of the

exploration and development cycle (including maintenance), in
order to ensure that such activities are carried out under
specified conditions to manage identified risks.
C-5.1 Planning the Operational Control
C-5.2 Design and Construction
C-5.3 Operations and Maintenance
C-5.4 Management of Change and Decommissioning

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C-5.1 Planning the Operational Control
Conduct activities and tasks according to procedures and work instructions developed at the
planning stage or earlier, in accordance with HSE Policy
Planning the operational control is an essential element of developing and maintaining the HSE
IMS by ensuring risk control strategies and workplace precautions are put in place and
proportionate to the needs, hazards and risks of the Organisation.

• carry out expert surveys and systematic assessments to identify and evaluate HSE hazards
and risks associated to the activities, processes and materials. Risk assessment should be an
inherent part of how tasks are planned, to ensure the hazards are identified and risks to
personnel, systems and assets is minimised to a level which is tolerable according to HSE
Policy(ies), standards and regulations. Reference should be made to the risk screening and
management process performed earlier in the planning phase;
• plan how risks arising from work activities are controlled, so that the necessary control
forms and measures can be defined, implemented and put in place before the activities start;
• establish and maintain procedures to ensure design, construction, operations and
maintenance of critical facilities and equipment are suitable for required purpose and
comply with defined criteria such as Company standards and legal requirements;
• review and, wherever necessary, further develop and customise the selected controls and
procedures to match and cover particular risks or critical local situations;
• act for preparing, implementing and controlling written instructions and practices to provide
practical control for activities in which risks have been identified. All executive documents
should be formally issued and controlled over the signatures of an issuing
authority/department and responsible manager;
• provide formal training/briefing sessions for all employees who will be affected by the
introduction of any new or revised procedures and practices. The training sessions should be
held immediately prior to the implementation of new/reviewed documents, and should be
formally recorded together with a list of attendees;
• assure that all workplace instructions, practices and rules are discussed involving
supervisors and employees before finalising and issue;
• systematically review and update all procedures and instructions (e.g. at the management
review), particularly when major changes are made to process or equipment or as a result of
operating experience, in order to assess their effectiveness in addressing the identified HSE
risks or Company requirements;
• provide arrangements to ensure that site and workplace controls are enclosured into notices,
signs and tags and clearly displayed at the key locations (e.g. control rooms, loading points,
etc.).
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C-5.2 Design and Construction
Define, plan and implement structured control activities during the project engineering design, in
order to ensure the respect and compliance with HSE Policy and standards

• plan the design activities in compliance with Eni-Agip Division and Company procedures
and approved project management standards;
• provide design arrangements (i.e. safety check lists) to identify hazards and measures to
eliminate or mitigate risks, in order to achieve the maximum level of intrinsic safety with
reference to plants, equipment and facilities. Check lists should help to verify the compliance
between design specifications and safety criteria, and the implementation of design changes
or Scope of Work variations imposed by HSE studies and analyses;
• define and establish communication interfaces between Company personnel and, wherever
necessary, design and construction Contractors. Contractors should be qualified and selected
from Eni-Agip Division or Company Vendor’s List;
• define and explicitly highlight in the Design Basis and Premises the applicable rules,
standards and legislation;
• ensure that project documents and data are subjected to formal checks and validation at the
end of each design stage with respect to what declared in the Design Basis and Premises, and
to what resulted from operability and HSE risk assessment studies. This validation activity
should be performed with periodic progress meetings, attended also by Contractors;
• carry out staged HSE reviews during the project life-cycle (e.g. at project milestones or in
presence of planning inconsistencies). Reviews should be documented and should allow
identifying and anticipating potential non-conformances and inadequacies, in order to plan
and implement design modifications and/or corrective actions if needed.
• prepare a set of high-level operative and maintenance procedures (e.g. plant manuals) aimed
at controlling the HSE issues of the project. These procedures should be re-addressed and
well-tuned in the commissioning and start-up phases;
Define, plan and implement structured control activities during the procurement and construction
phase, in order to ensure the respect and compliance with HSE Policy and standards

• carry out a risk assessment process on construction phases, in order to identify potential
conditions of hazards increase for existing facilities and ongoing activities (e.g. simultaneous
operations);
• define, wherever necessary, alternative and equivalent HSE management controls and
measures to be implemented during those anomalous conditions, to ensure an acceptable
level of risk;
• define and maintain operational control procedures and instructions to be implemented
during construction activities to manage HSE issues consistently. Conformance between
design requirements and construction activities should be periodically verified with on-site
inspections and documented periodic meetings with Contractors, in accordance to the project
management plan.
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C-5.3 Operations and Maintenance
Establishing and maintaining documented procedures that stipulate operating criteria to cover
situations where their absence could leave to deviations from the Organisation policies and the
objectives

• systematically identify hazards and risks arising from routine and non-routine operation
activities;
• set up and implement specific written procedures and formal workplace instructions to
manage the risks arising from the everyday occupational and safety hazards presented by
work activities. The procedures and arrangements to put in place should be (but not limited
to) typically the following:
− Permit to Work system (to be used for the control and co-ordination of all non-routine
or safety critical work activities on the installation and worksites). Daily permit to work
meetings should be held at the worksites to co-ordinate jobs planned with jobs currently
in progress, and recorded on a regular basis;
− Manual Handling instructions (to reduce the likelihood that the manual handling tasks
will cause injury to personnel);
− Hazardous/Chemical Materials management procedure (to provide a risk assessment
and a set of controls or precautions to safely contain and use the substances identified
with material data sheets, contributing to reduce the exposure risks). The risk
assessment and relevant control measures should address PPE requirements and relevant
training, should include also substances provided by contractors, and should be
reviewed periodically to confirm their existing suitability;
− SIMOPS (Simultaneous Operations) procedure, containing instructions and guidance
for installation and worksites management and supervision of concurrent/combined
operations;
− Travel Safety Management (covering land, air and sea), etc.;
• define and put in place additional controls to be established and formally issued to
workplace personnel to mitigate environmentally adverse effects during operations. Such
environmental management controls should involve also Contractors activities, and should
cover (but not limited to) the following matters:
− waste management minimisation, treatment and control (from waste identification and
origin to disposal method and site);
− environmental emissions controls and monitoring programme;
− water discharges management;
− noise pollution control and monitoring programme, etc.;
• develop and ensure formal procedures for each location taking into account the security
issues and the number of workers at the location. Procedures should cover the following
factors:
− pass and access system;
− handling of visitors;
− security of housings and physical assets (e.g. guards and/or alarm systems, inspections
planning, etc.).
• provide a formal HSE Case or booklet, collecting all health, safety and environmental rules
and procedures previously addressed, and put in place a system for updating the rules as
facilities, processes or equipment are changed;
• take precautions that rules, procedures or their extracts are posted in locations that reinforce
their message and purpose, and are checked regularly to ensure they are in good conditions.
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Establish and maintain procedures to plan and execute preventative maintenance in order to
ensure plant and equipment operations under specific conditions in compliance with HSE Policy
and Company standards

• identify all the items (plants, equipment) to be subjected of maintenance intervention, and
relevant characteristics;
• identify and define critical parts/HSE devices (e.g. ESD and PSV, critical
condition/monitoring control equipment, etc.) that, in case of malfunctioning/failure or bad
calibration, may have a significant/major impact on health, safety and the environment;
• establish preventative maintenance criteria and define inspection and testing cycles, taking
into account the type of equipment, HSE criticality, the degree of instrumentation, the
history of equipment and running hours;
• set up and implement an adequate preventative maintenance system; such a system should
be typically on software/computer basis or organised in formally issued written procedures,
instructions and records. The system should hold details of plant/item inventory, long term
maintenance plans and schedules of routine inspections, and maintenance history;
• ensure adequate resources (manning, spare availability) and personnel competencies to
perform efficiently the planned tasks;
• carry out dedicated risk assessments and develop short term work plan when planning non-
routine jobs, in order to put in place additional protection measures to minimise risks to
personnel, assets and the environment;
• maintain and update a records archive of maintenance dates and performed works, including
breakdowns and accidents;
• perform a systematic review and analysis of performed interventions and feed backs (both
planned and on demand, e.g. in case of failure), in order to verify the effectiveness of the
maintenance programme and criteria, and to identify corrective and preventive actions to be
put in place.
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C-5.4 Management of Change and Decommissioning
Formally assess, manage, document and approve the health, safety, security, environmental,
quality, technical and other impacts of temporary and permanent changes.

• prepare and implement a formal procedure to assess and manage risks arising from any
temporary or permanent modifications to existing plant and facilities, and define the relevant
measures to control or mitigate them. The procedure should constitute a structured and
formal framework to manage each stage of the process from the initial design to handover
of the completed work;
• assess the modifications, both singularly and cumulatively, in terms of impacts on the pre-
existing installation accepted level of risk (e.g. interactions with existing equipment and
operating philosophy). This assessment should be documented;
• provide, wherever necessary, to amend the installation HSE Case to reflect significant
changes made to the installation or its management systems;
• ensure that an appropriate abandonment and restoration programme is designed and carried
out if appropriate.
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C-6 PROCUREMENT AND CONTRACTORS
Evaluate and select contractors based on their ability to meet the

specified requirements and those of reference standards, and to
operate a IMS that is consistent with the requirements and
provisions of the reference models and that is compatible with
the HSE IMS of the Organisation.
Define and implement controls that ensure contractors conform
to specified requirements and to those of reference standards.
C-6.1 Qualification of contractors and suppliers
C-6.2 Selection of contractors and suppliers
C-6.3 Control of contractors and suppliers

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C-6.1 Qualification of contractors and suppliers
Establish a procedure for the qualification of contractors and suppliers.

The Organisation should establish and maintain documented procedures to qualify contractors
and suppliers, ensuring they operate a management system that is consistent with HSE policy
and requirements of the Organisation.
Such procedures should pay (in addition to the other topics reported in the C.6 HSE Guideline -
4th indent) particular attention to the definition of methods for monitoring and assessing
contractor performance against agreed HSE objectives and performance criteria.
Perform a pre-qualification of Contractors/Suppliers.

The Organisation should pre-qualify contractors/suppliers, taking into account the following
factors:
• HSE history and performance record;
• HSE policy, standards, procedures, training, audits;
• Security factors, such as screening of personnel;
• Special/local factors.
Such activity should be aimed at identifying any potential conflicts with the Organisation's HSE
IMS and policy. It should be commensurate to the risk associated to the service to be provided.
The Organisation should assess the suitability of contractors' HSE arrangements (policy,
practices and procedures), their HSE awareness and accountability. Such information should be
gather by means of audits, interviews or questionnaire, covering:
• Company profile and ability to effectively administer contracts;
• previous experience within oil industries;
• ability to recruit, train , manage and assess personnel that they are contracted to supply;
• quality assurance;
• safety and loss prevention, accident record;
• environment management;
• technical competence;
• onshore support facilities.
Contractors and suppliers should submit evidence in support of their capacities.

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Maintain an approved list of pre-qualified Contractors.

The Organisation should maintain an approved Vendor List of pre-qualified contractors, based
on:
• their capacity and technical competence to do the work required;
• availability of required manpower;
• previous experience of similar work;
• HSE competence and performance.
The Organisation should maintain appropriate records of Contractors’ commitment to:

• conform to all requirements of company’s standard;
• participate in the Organisation’s monitoring activities requested;
• promptly correct any non-conformance identified against the requirements of the reference
standard;
• promptly and completely inform the company of any and all relevant business
relationship(s) with other Contractor(s) and Subcontractor(s).
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C-6.2 Selection of contractors and suppliers
Establish HSE requirements to be used in procurement and necessary support activities.
The Organisation should prepare technical specifications, including HSE requirements to be

used in procurement and necessary support activities, taking into account the requirements
stated in Eni-Agip Division HSE policy.
Such requirements should cover:
• the complete identification of the characteristics of supply, services and specific works;
• identification criteria of suitable suppliers and contractors;
• adequate planning of purchasing and necessary support activities.
The Organisation should set the minimal acceptable performance against HSE requirements for
inclusion of contractors and suppliers in the invitation to tender stage.
Participate in the assignment stages of contract.
The Organisation should involve an HSE representative in participating in the assignment stages
of contract:
• prerequisites for tenders;
• evaluations of offers;
• contract review meetings;
• kick-off meeting.
The HSE representative should ensure that HSE requirements are fulfilled and appropriate
responsibilities for HSE aspects are defined and assigned to the contractors
Distribute HSE support documentation to contractors.
The Organisation should distribute copies of HSE policy and system procedures to contractors
and strategic suppliers that contribute significantly to the achievement of the HSE objectives.
Procedures should facilitate interfacing of Contractors’ activities with those of the Organisation
and with those of the Contractors, as appropriate. This may be achieved by means a specific
interface document between Organisation and Contractor so that any differences may be
resolved, and procedures agreed, before work commences.
KOM and Contractor’s HSE planning of the activities
The Organisation should formally invite the Contractor to a Kick-Off Meeting (KOM), held for
clarifying the Organisation expectations and the Contractor’s planning with regard to any HSE
aspects in the activities to be carried out; also, the content and timing of the HSE reporting made
by the Contractor to the Organisation should be established.
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C-6.3 Control of contractors and suppliers
Perform HSE audits and inspections on contractor activities.
Where Contractors are carrying out critical activities or where they are about to be carried out
critical activities, the Organisation should perform periodic HSE audits and inspections.
Such surveillance is aimed at ensuring that HSE management systems of contractors are
providing and sustaining the required level of control.
The frequency of audits should depend on the criticality of the service supplied and should be
focused on the most critical HSE aspects.
Audits may be required before a contract is awarded or during the contract execution period or
both.
Assess Contractor’s HSE performances
The Organisation should make a full assessment of Contractor’s HSE performance, especially at
the end of each project.
The Organisation should maintain reasonable evidence that HSE requirements are being met by
Contractors and Subcontractors.
Report Contractor’s HSE performances
The Organisation should ensure that the following report are submitted to monitor contractor’s
HSE programme:
• Planned inspection reports:
• External inspection reports;
• Records of HSE committee meetings;
• Accident investigation reports;
• Loss data.
• Other.
Feedback collection on contractors performance.
The Organisation should feedback:

• finding into pre-qualification and selection procedures;
• any lessons learned during the project into standards and procedures.
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C-7 EMERGENCY PREPAREDNESS AND RESPONSE
Identify the potential for, and response to, incidents and

emergency situations, and for preventing and mitigating the
effects that may be associated with them.
Periodically review and test, where applicable, emergency
preparedness and response plans and procedures on a regular
basis, in particular after the occurrence of incidents or
emergency situations.
C-7.1 Identification of potential emergency situations
C-7.2 Preparedness of detailed emergency response plans
C-7.3 Review of emergency response plans and procedures
C-7.4 Testing of emergency response procedures

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C-7.1 Identification of potential emergency situations
Identify potential emergency situations that could arise from activities.
The Organisation should identify potential emergency situations and incidents that could arise
from activities carried out in all the workplaces.
Foreseeable emergencies should include:

• Fire and explosion;
• Failure of key controls, of power sources or of services;
• Structural failures;
• Worksite death, injury, sickness;
• Diving, marine and aviation incidents;
• Man overboard or missing person situations;
• Spills and unplanned release of product or other materials (pollution);
• Security incidents such as breaches, sabotage, kidnap and extortion;
• Outbreaks of disease;
• Breakdown of law and order;
• Geophysical and natural events;
• Other events highlighted by the hazard and effects identification.
The Organisation should compile an inventory of all potentially hazardous substances, including
basic materials, intermediates, chemical, solvents, gases, emissions and wastes.
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C-7.2 Preparedness of detailed emergency response plans
Develop detailed emergency plans for particular locations, sections and departments.
The Organisation should detail specific plans for particular locations, sections and departments,
including:
• detailed instructions for each emergency scenario;
• the designation of a central control area;
• the control of hazardous materials;
• evacuation of people to predetermined safe areas;
• search and rescue plan;
• casualty identification, recording, evacuation;
• traffic control plan;
• the removal or protection of vital equipment and materials;
• all clear and re-entry procedure;
• procedures to notify personnel of emergencies and to define their participation;
• internal and external/public reporting requirements.
The plan should ensure that essential emergency services, telephone numbers and addresses,
such as hospitals, doctors, poison control centres, fire departments, ambulances are listed in the
plan, regularly updated, and displayed at key/communications locations e.g. first aid points,
switchboard.
The Organisation should make available the emergency response plan where it will be used.
Define organisation responsibilities for each emergency scenario.
The Organisation should establish procedure to ensure that:

• there is an emergency control organisation with clearly defined individual and team
responsibilities;
• required support services and external experts, such as medical or environmental
consultants, have been identified and retained;
• the emergency team(s) are adequate in terms of size and qualifications to deal with
probable emergency situations.
The Organisation should define and identify in detail the necessary competence, roles and
responsibilities, both for the individual and for team members, for emergency response and
control.
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Provide adequate training for staff
The Organisation should provide staff for adequate training in the emergency response
arrangements.
The preparedness of personnel to deal with emergency situations should be maintained through
a programme of emergency training and emergency drills and exercises, aimed at ensuring that
personnel:
• are clearly briefed in their roles and responsibilities in emergency situations;
• receive appropriate training to fulfil their roles during emergency situations;
• receive appropriate training to respond to the media accordingly to the communications
procedure;
• receive specialised training in first aid techniques for local exposures.
The Organisation should give initial and refresher training to emergency response team
personnel in accordance with applicable processes and procedures.
Maintain internal and external communications.
The Organisation should communicate the emergency response plans to:

• command duty personnel;
• emergency services;
• employees and contractors who may be affected;
• others likely to be impacted.
The Organisation should provide an effective means of communications with the main centre of
operations to each work unit. An alternative communication services should be available in case
of interruption of normal systems during an emergency situation, in order to ensure that actions
to be taken during emergencies are not jeopardised by unsound communications.
The Organisation should develop a procedure for providing public HSE information to
appropriate authorities (national and municipal) in the event of an emergency.
The procedure should address possible evacuation of off-site areas and co-ordination with
outside organisations (police, fire brigades, civil defence groups, emergency planning
departments, local hospitals) to provide personnel and equipment in the event of an emergency.
The Organisation should develop a procedure for information releases to the public in the event
of an emergency. The procedure should cover:
• who is, and is not, authorised to make statements to the press, TV, …;
• what types of information should be provided at what stages in what form;
• designation of a "press office";
• arrangements for handling VIPs, inspectors and other visitors.
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Make available facilities and equipment for emergency teams.
The Organisation should be make available dedicated facilities for the various Emergency
Teams.
The Organisation should provide a dedicated emergency control centre (ECC), containing:
• Enough space to house the team and other personnel/management;
• that may be present in an emergency;
• Layout plan i.e. who sits where;
• Organisation chart for command and control;
• Communications equipment;
• Telephones and faxes;
• Dedicated lines for public enquiry,
• Computers/modems;,
• Television and radio(s);
• Information boards;
• Emergency Plan;
• Emergency Log;
• Plant and emergency equipment drawings;
• Lists of telephone numbers, including contractors, government, depts. etc.;
• Site hazard maps including local homes, hospitals, schools, roads and railways etc.
The Organisation should make a contingency plan for relocation of the ECC, if the main one is
unavailable.
The Organisation should provide adequate emergency lighting and power, ensuring that they are
regularly tested with results recorded and defects immediately repaired.
The Organisation should ensure that:

• Emergency safety devices are adequately identified e.g. colour coded;
• personnel are familiar with the location and operation of Emergency safety devices;
• Emergency safety devices are checked/exercised regularly to ensure they are in good
working order.
The Organisation should provide adequate protective/rescue equipment, such as:

• Detection/alarm systems for hazards such as smoke, hydrocarbons, toxic substances;
• Fire extinguishing systems and fire-fighting equipment;
• Other emergency and rescue equipment, such as breathing apparatus, emergency escape air
packs, eye baths and showers, blankets, stretchers, and rescue equipment to cover local
exposures.
The Organisation should ensure that first aid facilities and equipment are adequate and well
maintained, and that a list of names of designated first aiders is prominently displayed in the
first aid room/location(s).
The Organisation should ensure that there is a system to identify, classify, and safeguard vital
records.
The Organisation should provide adequate oil spill control equipment and support services that
may be in-house, backup/mutual aid or a combination.
The Organisation should carry out regular maintenance on pollution control equipment.
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Develop a post-event plan.
The Organisation should develop, document and maintain a written plan for restoration of
business activities in the event of loss of any major facility due to an emergency.
The plan should include procedures for business interruptions in purchase agreements,
contracts, and insurance program.
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C-7.3 Review of emergency response plans and procedures
Assess the effectiveness of response plans
The Organisation should periodically assess the effectiveness of emergency response plans in
term of:
• protecting people;
• compliance with national/local regulations;
• limiting losses;
• limiting public exposure, legal liabilities, fines.
The assessment should be performed in particular after the occurrence of incidents or

emergency situations, ensuring that they are adequately investigated, analysed and followed up
to prevent recurrence.
The periodic assessment should cover the emergency equipment needs and the maintenance of
such equipment in a ready state.
Record corrective actions
The Organisation should keep records of training, exercises, accident/incident investigations,

reviews and corrective actions taken to improve the plan.
Review the emergency response plan

• ensure that the response plan is regularly reviewed;
• maintain a procedure to define who is responsible for updating the plan, when/how often,
the system for making changes and the (numbered) distribution list. Copies should be sent
to regulatory agencies, industry groups/mutual aid partners and Eni-Agip Division HSE
Manager;
• provide a system that feeds back experience from live emergency (investigations), drills
and exercises into emergency plans and procedures.
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C-7.4 Testing of emergency response procedures
Test the emergency response procedures
To assess the effectiveness of response plans, the Organisation should:

• perform drills and exercises in each area to rehearse and test the emergency response
procedures. Such tests should be aimed at testing specific elements of the onshore
emergency response system, including emergency staff roles and responsibilities;
• perform at least one major exercise to test the whole emergency system, including the
interfaces between the internal response teams as well as with the key external agencies.
Record the results of the tests
The Organisation should critically review the results of the tests, recording any improvement,
suggestion or corrective actions taken to improve the plan.
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D-1 MONITORING AND MEASUREMENT
Routinely monitor and measure the most important

characteristics of activities and operations that may have a
significant adverse effect on HSE performance.
Monitor actions set up to achieve the assigned objectives.
Periodically verify the conformance to the applicable laws and
internal standards.
D-1.1 Monitoring of activities and operations
D-1.2 Measurement of HSE performances
D-1.3 Verification of compliance

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D-1.1 Monitoring of activities and operations
Establish a procedure for monitoring activities and operations.
The Organisation should establish and maintain documented procedure to monitor regularly the
most important characteristics of activities and operations that may have a significant adverse
effect on HSE performance.
For each relevant activity and operation, the Organisation should:

• identify and document the monitoring information to be obtained, and specify the accuracy
required of results;
• specify and document monitoring procedure, and locations and frequencies of
measurements;
• establish, document and maintain measurement HSE control procedures;
• establish and document procedures for data handling and interpretation and develop
prevention programmes;
• establish and document actions to be taken when results breach performance criteria;
• assess and document the validity of affected data when monitoring systems are found to be
malfunctioning;
• safeguard measurement system from unauthorised adjustment or damage.
Plan monitoring activities.
The Organisation should plan monitoring activities on a calendar year basis, aimed at:
• checking HSE procedures and plans are effectively followed at all levels;
• verifying the conformity of products to the relevant requirements;
• verifying the compliance with HSE management programme, operational criteria,
applicable legislation and regulatory requirements;
• identifying weakness areas in the HSE IMS.
The frequency of monitoring activities should be in accordance with the nature and extent of the
risk due to each activity and the ongoing operations.
The Organisation should concentrate monitoring activities on the areas where the most benefit
should be produced.
Carry out monitoring activities.
The Organisation should carry out monitoring activities, including:

• regular monitoring of progress toward objectives and targets achieved by implementation
of HSE plans;
• regular inspection of facilities, plant and equipment against specific performance criteria;
• systematic observation of the work and behaviour of first line supervisors to assess
compliance with procedures and work instructions;
• regular analysis of discharges, emissions and waste disposal;
• health surveillance of staff, including exposure monitoring and medical surveillance;
• monitoring in appropriate phases of the processes, the characteristics of products to verify
that they conform to relevant requirements.;
• monitoring of the perception of stakeholder on the level to which the Organisation satisfies
their requirements.
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Calibrate and maintain monitoring equipment.
The Organisation should establish and maintain documented procedures for the calibration and
maintenance of monitoring equipment in accordance with law’s requirements and on the basis
of manufacturer instructions/recommendations.
Monitoring equipment should be under control of the relevant departments, which should
be also responsible for the collection and filing of the calibration records.
Record the results of monitoring activities.
The Organisation should record results of the monitoring activities in order to:
• document evidence of product conformance to relevant requirements;
• track performance in gaining HSE targets at all levels of the Organisation;
• demonstrate the conformity to HSE standards and requirements.
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D-1.2 Measurement of HSE performances
Develop a set of key performance indicators.
The Organisation should develop a set of key performance indicators as the logical basis for the
setting of HSE targets and driving continuous improvement across operations and for
developing standards of reporting and verification.
Such performance indicators should be:

• simple to identify, collect, measure, understand and use;
• objective, verifiable and reproducible;
• immediate ad consistent indications of the level of performance within identified normal
and abnormal range;
• relevant to the Organisation's activities and operations, and understood by line
management;
• consistent with the Organisation's HSE policy;
• practical, cost-effective and technologically feasible.
Apart from overall HSE performance indicators, the Organisation should establish a set of
specific Health Performance Indicators (HPI) to be used for:
• helping to protect the health of employees and others;
• giving line management a better understanding of the health issues relevant to their
operational responsibility;
• highlighting important health issues and set priorities;
• enabling measurements of performance against predetermined targets;
• maintaining credibility and confidence both within the company and towards the general
public and stakeholders.
The HPI should be basically of two types:

• proactive ones, to monitor exposures (e.g. at work) or other factors (e.g. life style factors),
which may influence health before an illness occurs; examples are:
− health risk assessments completed vs. total population at risk;
− compliance with occupational exposures limits;
− potability of water;
− compliance with company policy for immunisations;
− number of individuals undergoing health surveillance, etc.
• reactive ones, to monitor the consequences of exposures, e.g. incidents, ill health and
evidence of deficient health protection; examples are:
− occupational illness frequency,
− incidence of identified infectious/preventable disease,
− number of medical evacuations,
− sickness absence,
− number of medical re-deployment due to occupational ill health, etc.
The Organisation should communicate throughout the Organisation HSE performance

indicators (both inputs and outcomes).
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Measure regularly HSE IMS performances.
The Organisation should measure regularly HSE IMS performances.
Detail and frequency of measurement needs should be establish with reference to risk exposure
and/or performance in order to facilitate subsequent corrective and preventive action analysis.
Collect measures to assess HSE performances.
The Organisation should collect HSE measures throughout the reporting cycle for using them
externally to represent performance in Organisation’s paper and web-based reports, and
internally for performance comparison against target.
The systems of records should include information that allow following the trend of
performances, operating controls and the conformance to objectives and targets of the
Organisation.
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D-1.3 Verification of compliance
Establish a procedure to verify the conformance to the applicable rules.
Results of monitoring and measurement activities should be communicated to the Organisation's

responsible for HSE performance analysis.
The Organisation should establish and maintain a documented procedure to periodically verify
the conformance of HSE IMS to the applicable rules.
The Organisation should take into account all the suitable sources of information, such
as:
• HSE and technical internal audits;
• corrective and preventive actions;
• reports on non-conformity;
• accident, near miss and emission reports;
• HSE records;
• process feed-back;
• bench marking reports;
• HSE indicators analysis.
Determine the compliance to applicable rules.
The Organisation should use HSE performance indicators to determine when and what IMS
changes are necessary.
The Organisation should perform statistical analyses of monitoring and measurement data and
should focus the analyses on determining the possible areas of HSE IMS improvement.
The statistical analyses used should depend on the type of data itself and the type of report to be
prepared.
Report the results of monitoring activities.
The Organisation should periodically report the results of monitoring activities in order to show
commitment at the highest level the progress on achievement of HSE targets and objectives.
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D-2 NON CONFORMANCE, CORRECTIVE

AND PREVENTIVE ACTIONS
Ensure adequate treatment and corrective actions to solve non

conforming situations and remove causes of non-conformance,
including incidents and quasi-incidents, by determining the
causes, planning adequate corrective actions and timing for
implementation, defining responsibility for that, applying controls
for their monitoring, verifying effectiveness of actions
undertaken.
D-2.1 Management of non conforming situations
D-2.2 Implementation of corrective actions
D-2.3 Monitoring of corrective actions

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D-2.1 Management of non conforming situations
Establish responsibilities and authorities in management of non-conforming situations.
The Organisation should clearly define the mechanism and responsibility for follow-up of
incidents.
The defined responsibilities for follow-up of an incident should be appropriate to the severity of
its real or potential consequences.
Establish a procedure for the management of non conforming situations.
The Organisation should establish a procedure to manage the non conforming products
according to the following principles:
• adopting measures to eliminate the NC;
• authorising their use, following release of an adequate waiver from the appropriate
authorities;
• adopting suitable actions to prevent use or applications originally planned for the products.
Maintain records on non-conforming situations and on actions undertaken.
The Organisation should establish a procedure to maintain records on nature of NC and on

actions undertaken in their respect, including waivers obtained.
When a non-conforming product is detected after its delivery or use, the Organisation should
adopt adequate measures on actual or potential effects, resulting from the NC.
The Organisation should establish, implement and record any changes and results in the
documented procedures resulting from corrective and preventive action.
Share lessons learned across personnel.

• ensure that lessons learned from investigations are shared across Organisation and
personnel taking appropriate action upon reception of such information;
• encourage mutual sharing of lessons learned and good practice within the wider energy and
chemical industry.
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D-2.2 Implementation of corrective actions
Investigate causes of incidents.

The Organisation should investigate all incidents, including high-potential near-misses, in order
to:
• establish their root cause and identify actions to minimise the chance of recurrence;
• satisfy the Eni-Agip Division requirements for reporting and investigation;
• provide a factual record of the immediate circumstances of the incident;
• identify underlying HSE IMS weakness, which caused the incident.
All the incidents should be investigated at a level, depth and speed appropriate to the
seriousness of the actual or potential consequences.
At this scope, the Organisation should appoint an investigation team, whose size and
composition depends on the particular incident. Major incidents should be investigated by a
multi-function/level team with participation and leadership from outside the Business Unit.
Team members should be properly trained to carry out their task objectively and effectively.
The investigation analysis should comprise:

• review of the incident site and circumstances;
• interview of witnesses;
• examination of equipment and procedures
• analysis of operating conditions, data and other evidence.
The investigation team should prepare a concise, accurate and informative report containing
proposed remedial actions and recommendations to appropriate personnel.
Plan suitable corrective actions.

The Organisation should plan suitable corrective actions, including measures for:
• restoring compliance as quickly as practicable;
• preventing recurrence;
• evaluating and mitigating any adverse HSE effects;
• ensuring satisfactory interactions with other components of the management system, such
as quality management;
• assessing the effectiveness of the above measures.
Review proposed corrective actions.

The Organisation should review all proposed corrective and preventive actions through the risk
assessment process prior to implementation. Any corrective or preventive action taken to
eliminate the causes of actual and potential NC should be appropriate to the magnitude of
problems and commensurate with the HSE risk encountered.
The appropriate department manager should approved the most suitable remedial actions,
ensuring that any recommendations made in the incident report have been carried out.
Implement approved remedial actions.

The Organisation should prepare a follow up programme for the implementation of approved
remedial actions, identifying responsibles, resources and time scale.
The time scale for completion of the corrective action is driven by the risk rating, so that the
most serious problems should be addressed as a high priority.
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D-2.3 Monitoring of corrective actions
Apply controls to monitor corrective actions.

• apply controls to ensure that any preventive actions taken are effective;
• monitor the progressing of corrective actions through to completion and closing out, when
their effectiveness has been demonstrated and when the appropriate changes are made in
procedures, documentation and records.
Record status of corrective actions.
The Organisation should maintain records on status of corrective actions undertaken, ensuring
that management is made aware of their progression.
Actions not effective should be recorded specifying the causes of their unsatisfactory
implementation.
Verify the effectiveness of corrective actions.
At appropriate intervals, the Organisation should verify the effectiveness of corrective actions
undertaken and the performance of HSE Integrated Management System.
This review should address:

• need for changes to HSE policy;
• possible revisions of HSE strategic objectives and consequent amendments to HSE plan
and procedures;
• resource allocation for corrective action implementation and maintenance.
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D-3 HSE IMS RECORDS
Maintain a system of records to demonstrate compliance with

policy(ies) and requirements.
Record and report accidents and incidents which affected, or
could have affected, HSE performance, so that the relevant
lessons can be learned and appropriate actions taken.
D-3.1 Management of HSE IMS records
D-3.2 Reporting of incidents and quasi-incidents

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D-3.1 Management of HSE IMS records
Identify HSE IMS data to be gathered, processed and recorded.
The Organisation should identify the extent of HSE IMS data necessary to demonstrate the
compliance with HSE policy and requirements and the achievement of HSE objectives.
In addition to legislative and regulatory requirements, records should include:

• reports of audits and reviews;
• situations of non-compliance with HSE policy;
• improvement actions;
• any incidents and follow-up actions;
• any complaints and follow-up actions;
• supplier and contractor information;
• inspection and maintenance reports;
• product identification and composition data;
• monitoring data;
• training records.
Provide a system to store and maintain HSE IMS records.
The Organisation should define a procedure which establish systems to store and maintain
records, as appropriate to the HSE system and to the Organisation.
Establish a procedure to manage HSE IMS data.
The Organisation should establish and maintain a procedure for the identification, maintenance
and disposition of HSE records, regarding their availability and confidentiality.
The procedure should ensure the integrity, accessibility and control of such records, covering:
• appropriate monitoring, checks and review processes to detect and correct errors and
omissions;
• tasks and responsibilities from data processing and review assigned to both line
management and HSE advisers. It is responsibility of line management to ensure
conservation and submission of reliable, accurate and complete data;
• definitions used and the scope of the data management and reporting in accordance with
Organisation’s Guidelines.
• retention times of HSE records.
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D-3.2 Reporting of incidents and quasi-incidents
Establish a procedure for reporting and recording of incidents and quasi-incidents.
The Organisation should establish a procedure for the reporting and recording of incidents,
which affected, or could have affected, HSE IMS performance.
The procedure should cover all incidents occurring both onshore and offshore, including near
misses, which do not result in injury or property damage,.
The main aims of the reporting and recording procedure should be to:
• establish the facts, circumstances and causes of incidents and to make certain that
appropriate action is taken to prevent recurrence;
• communicate to appropriate personnel the facts and circumstances of the incident and the
main recommendations made;
• comply with applicable statutory requirements;
• establish the facts surrounding the incident for use in relation to potential insurance claims
or litigation;
• evaluate cost losses, including man-hours, property loss, equipment damage, production
loss, penalties and general losses.
Implement a reporting system to acquire key data of incident.
The Organisation should implement a reporting system to acquire the key data of incident and
notify them to HSE department responsible and to the statutory enforcing authorities, as
appropriate.
These data should include as a minimum:

• details of any injuries, occupational illness or adverse environmental effects;
• details of involved and/or injured person(s);
• a description of the circumstances;
• details of the event;
• details of the outcomes;
• potential consequences;
• adverse effects on HSE IMS performance.
The Organisation should ensure that the reporting system is kept simple to encourage reporting
of all incidents, including near misses.
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Collect incident data for statistical analysis.
The Organisation should maintain records of incidents and quasi-incidents reports.
Where appropriate, the Organisation should use statistical control methods to formulate
conclusions in interpreting significance of statistics.
The statistic analysis should consider the following factors:

• frequency;
• severity;
• types of incidents;
• equipment/substances involved;
• activity at the time of the incident;
• parts of body;
• age of persons involved;
• length of service;
• time of day;
• other significant factors.
The results of statistical analysis should be disseminated to all levels of operating management
and to HSE committee.
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D-4 INTERNAL AUDIT
Plan and execute audits at suitable intervals to:

- determine level of application and effectiveness of the HSE IMS,
- verify compliance with legislative and other applicable requirements
and standards;
- verify areas of improvements for HSE IMS;
- review the results of previous audits.
D-4.1 Audit Planning
D-4.2 Internal Auditing
D-4.3 Auditing Contractors/Suppliers
D-4.4 Management of corrective actions

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D-4.1 Audit Planning
Establish a HSE audit programme.
The Organisation should establish and maintain a documented, risk-based audit programme for
periodic HSE IMS audits to be carried out, as a normal part of business control, in order to:
• Determine whether or not the HSE IMS:
− conforms to planned arrangements for HSE management, including the requirements
of the reference standards, HSE IMS elements, HSE targets and activities;
− has been properly implemented, maintained, documented and updated;
− is effective in fulfilling the Organisation’s HSE policy, objectives and performance
criteria;
− is in compliance with relevant legislative requirements.
• Determine identification of areas for improvement, leading to progressively better HSE
IMS.
• Review the results of previous audits.
• Provide protocols, reports, procedures and information on the results of audits to
management and maintain relevant records.
The Organisation should base the audit programme, including any schedule, on results of risk
assessments of the Organisation’s activities, and on results of previous audits.
Establish procedures for audits.
The Organisation should establish and maintain procedures for audits, covering the following
points:
• audit purpose (compliance audit, validation audit);
• audit scope (specific activities/areas to be audited);
• audit criteria;
• frequency of auditing specific activities/areas;
• allocation of resources to the auditing process;
• personnel requirements and competencies;
• 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;
• system for auditing and tracking implementation status of audit recommendations;
• distribution and control of audits reports.
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Define responsibilities in the auditing process
The Organisation should clearly define responsibilities in the auditing process, relevant to HSE
Area that carries out audits and Business Units/Areas to be audited.
HSE Area should be responsible for ensuring:

• identification of audit team members and lead auditor;
• planning of audit/assessment activities;
• compilation of checklists for audit/assessment;
• preparation of a preliminary report;
• preparation and issue of an audit final report;
• follow-up and close-out, when necessary, of the corrective actions.
Responsibilities of Business Units/Areas to be audited should be:

• determine the audit objectives;
• define the audit scope;
• plan the audit/assessment activities;
• provide authority and resources required for audit execution;
• approve plan of audit activities;
• receive the final audit report and determine its distribution.
Provide adequate training to auditors
The Organisation should provide adequate training to the personnel conducts audits to carry out
the task objectively, impartially and effectively.
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D-4.2 Internal Auditing
Conduct objective and periodic internal audits
The Organisation should conduct objective and periodic internal audits at a frequency
determined by risk exposure, criticality of the activities and/or performance. By this means that
critical areas should be monitored more frequently than those which are deemed to be less
critical.
Internal audits should be aimed at ensuring that HSE procedures have been implemented and
that they achieve the desired results.
The Organisation should conduct internal audits on three levels:

• BU/Area internal audits, to identify and correct problems;
• regularly scheduled Eni-Agip Division audits by teams of HSE professionals and senior
managers from throughout the Organisation;
• external reviews by independent consultants to assure that Organisation internal auditing
system remains effective.
Identify audit team members
Audits should be conducted, wherever possible, by personnel independent of those having direct
responsibility for the activity being examined (outside the Business Unit/Area involved).
Audit team members should be chosen among the specialists of Health, Safety, Security,
Environment and Quality Areas of the Organisation. External specialist HSE or other technical
expertise could be selected, if necessary.
Audit teams require personnel with broad knowledge of HSE matters, experience in auditing
practices and disciplines and operational experience in the area being audited. They should be
briefed, trained and accredited. In particular, lead auditor should be qualified as requested by
ISO 10011/2.
Plan internal audit activities
The HSE audit team, in co-operation with the responsible of the Business Unit/Area to be
audited, should:
• determine objectives and scope of the audit;
• identify functions and/or individuals within the auditee's Business Unit/Area having
significant direct responsibilities regarding HSE system;
• obtain the reference documents for auditing, including HSE policy, procedures and
previous records;
• gather other useful information about activities, products, services, workplaces and
structure of the auditee's Organisation.
On the basis of the preliminary examination of documents, the audit team should prepare a
checklist and prepare a plan of audit activities that should be confirmed by the Business
Unit/Area to be audited.
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Carry out internal audit activities.
The audit team should carry out audit activities, according to the following steps:
• Organise a preliminary meeting in order to:
− introduce the members of audit team to the Organisation management;
− review objectives, scope and audit plan;
− provide a short summary of methods and procedures in conducting the audit;
− confirm that the resources and facilities needed by the audit team are available;
− agree on audit time table and closing meeting
− promote the active participation by the auditee.
• Collect evidence, interviewing personnel, examining documents, observing activities and
conditions.
• Review all the audit evidence to determine non-conformities with the HSE audit criteria
and to document them in a clear, concise manner.
• Hold a closing meeting with the Organisation management to present audit findings to the
auditee in such a manner as to obtain their clear understanding and acknowledgement of the
factual basis of the findings.
Prepare internal audit report
Audit findings, conclusions and recommendations should be submitted in documentary form to

appropriate member of the Organisation management.
The following items should be covered in the audit report and follow up of audit findings:
• specific examples of non-compliance or deficiencies, including possible nature of the
problems, where evident;
• appropriate corrective actions suggested;
• follow up of the implementation and effectiveness of corrective actions suggested in
previous audits.
The audit report should be sent to the auditee's Organisation and distributed in accordance to the
audit plan.
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D-4.3 Auditing Contractors/Suppliers
Conduct audits at Contractors/Suppliers, when necessary.
The Organisation should conduct external audits at Contractors/Suppliers, when necessary, in

order to:
• monitor the compliance of their activities with HSE requirements;
• evaluate the capability of their processes to fulfil product requirements;
• assess the effectiveness of their HSE systems.
The Organisation should conduct external audits on the following levels:

• project audit, aimed at verifying the respect of contractual requirements from
Contractors/Suppliers;
• HSE integrated system audit, aimed at ensuring the effectiveness of Contractors/Suppliers
HSE systems in the fulfilment of the Organisation HSE requirements and, consequently,
the compliance of their HSE systems with HSE standards (ISO 9001, ISO 14001, BS 8800,
OHSAS 18001);
• HSE system audit, limited to one of the HSE systems.
Identify audit team members
External audits should be conducted by personnel chosen among the specialists of HSE Areas of
the Organisation.
For each audit, the HSE Area of the Organisation should designate a Lead Auditor, which is
responsible for the identification of the audit team members.
Audit team should be composed of personnel with broad knowledge of HSE matters, experience
in auditing practices and disciplines, properly briefed, trained and accredited.
Plan audit activities
The HSE audit team should prepare an audit plan, covering:

• objectives and scope of the audit;
• methods and procedures in conducting audit;
• Contractors/Suppliers units/areas to be audited;
• Functions and/or individuals within the auditee's Contractors/Suppliers organisation,
having significant direct responsibilities regarding HSE system;
• reference documentation of the Organisation, including contracts, HSE policy, procedures
and manuals, applicable laws and standards;
• HSE documentation of Contractors/Suppliers organisations;
• time table of audit activities;
• complete checklist of the audit, compiled with reference to the applicable standard and to
the Contractor/Supplier HSE requirements;
• table of contents, format and distribution list of audit report.
Contractor/Supplier should co-operate, providing personnel, resources and arrangements to

carry out audit activities.
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Carry out audit activities
The audit team should carry out audit activities, according to the following steps:
• Organise a preliminary meeting in order to:
− introduce the members of audit team to the Contractor/Supplier organisation
management;
− register names of the Contractor/Supplier organisation responsible persons;
− explain objectives, scope and plan of audit;
− provide a short summary of methods and procedures in conducting the audit;
− confirm that resources and facilities needed for auditing are available;
− agree on audit time table and closing meeting;
− clarify any doubts relevant to audit.
• Collect evidence, interviewing personnel, examining documents, observing activities and
conditions;
• Review all the audit evidence to determine non-conformities with the HSE audit criteria
and to document them in a clear, concise manner;
• Hold a closing meeting with Contractor/Supplier organisation management in order to
present audit findings in such a manner as to obtain their clear understanding and
acknowledgement of the factual basis of the findings.
Evaluate the HSE system of Contractors/Suppliers
The audit team should judge HSE systems of Contractors/Suppliers, assigned a point to each of
the HSE requirements, according to the following classification:
• requirement not fulfilled/ignored without justification;
• requirement not adequately fulfilled;
• requirement adequately fulfilled;
• requirement completely fulfilled;
• requirement fulfilled in excellent manner.
The score associated to a HSE requirement can be obtained multiplying the point assigned with
the relevant weight, reported in “scoring model” tables for Quality, Environment and Safety
systems.
The final score assigned to the Contractor/Supplier HSE system is given by the sum of the
scores of all the HSE requirements.
Prepare the audit report
Audit findings, conclusions and recommendations should be submitted in documentary form to

appropriate members of the Contractor/Supplier organisations.
The following items should be covered in the report and follow up of audit findings:
• specific examples of non-compliance or deficiencies, including possible nature of the
problems, where evident;
• appropriate corrective actions suggested;
• final score of HSE system.
The audit report should be sent to the Contractors/Suppliers organisations and distributed in
accordance to the audit plan.
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D-4.4 Management of corrective actions
Implement corrective actions
The Organisation should examine all the non-conformities detected in an audit (both internal
and external, i.e. carried out by Eni-Agip Division) and should propose the most suitable
corrective actions to be taken.
At this scope the Organisation should identify the nature of the problems to avoid correcting
only the effects and not the causes.
This activity should be split in the following steps:

• examination of non-conformity;
• identification of the responsible of the involved process;
• identification of the causes of non-conformity;
• proposal of corrective/preventive actions;
• implementation of corrective actions selected.
Monitor corrective actions
The Organisation should carry on control activities, including internal audits, to monitor the
implementation status of corrective actions up to their closure.
If the effectiveness of corrective actions is not adequate, the Organisation should review them.
Record status of corrective actions
The Organisation should maintain a system to control and monitor all the phases of this process,
recording the status of all the actions implemented.
The corrective actions plan should relevant to external audits should be submitted to Eni-Agip
Division.
Review the effectiveness of corrective actions
At appropriate intervals (e.g. at the Management Review), the Organisation should review the
effectiveness of corrective actions implemented and the performance of HSE system.
This review should address:
• need for changes to HSE policy;
• possible revisions of HSE strategic objectives and consequent amendments to HSE plan
and procedures;
• resource allocation for HSE implementation and maintenance.
Eni S.p.A.
Divisione Agip
Doc. n. 1.3.0.2 Pag. 96 of 98
E-1 MANAGEMENT REVIEW
Review, at appropriate intervals, the adequacy, suitability and

continuing effectiveness of the HSE IMS and its performance, the
policy(ies), procedures and performance results, versus the
requirements of the reference standard and other subscribed
requirements including the strategic objectives and targets.
Review the “Conformance Matrix” to update the level of compliance
with Eni-Agip Division Guidelines.
E-1.1 Review planning and documentation preparation
E-1.2 Management Review meeting

Eni S.p.A.
Divisione Agip
Doc. n. 1.3.0.2 Pag. 97 of 98
E-1.1 Review planning and documentation preparation
Review planning
The Organisation should plan the management review, including the following items:
• definition of documentation;
• definition of the responsible of review plan issue;
• definition of the schedule and the agenda;
• information of all those concerned by internal communication.
The management review should be carried out at least every year and/or each time the
Organisation considers the necessity.
HSE Review Committee

• foresee a HSE Review Committee, chaired by the Company Managing Director, which is
responsible for the evaluation, the review and improvement of the effectiveness of the HSE
Integrated Management;
• ensure that management representatives (Department or Function Managers plus co-opted
members as necessary) attending the review are appointed and nominated according to the
relevance of their management responsibilities.
Collecting of documentation

• ensure the collecting of all documents, coherently with what defined in the review planning,
and the information to attest the development and execution of the activities of HSE
Integrated Management since the last review;
• prepare a report concerning the Status (level of application and effectiveness) of the IMS,
provided at least with the following information documents, relating to the interested
organisational level:
− report of previous management review meeting;
− HSE Integrated Policy
− HSE objectives and ongoing HSE programmes, defined in the previous management
review, and relevant work progress;
− Conformance Matrix and Eni-Agip Division Standards application status;
− integrated HSE audit reports;
− non-conformance/observation records;
− preventive and corrective action records;
− incident, accident and near misses statistics;
− legislative and authorisation updates and potential regulatory developments;
− product or activity changes;
− research and development outputs;
− stakeholders expectation changes;
− emerging/growing concerns in specific areas;
− external information (market analyses and pressures, incident/accident occurrences,
etc.);
− concerns of employees, contractors, customers, government agencies, etc.;
− whatever useful information.
Eni S.p.A.
Divisione Agip
Doc. n. 1.3.0.2 Pag. 98 of 98
E-1.2 Management Review meeting
Documentation evaluation.
Meeting attendants should:

• examine and discuss the report on the Status of the IMS, supported by the collected
documentation;
• review audit findings, the implementation of outstanding action items and performance
against HSE objectives
• assess the efficiency and the effectiveness of the IMS, and consider the need for modifying
activities, procedures or organisation structure;
• consider the adequacy of the Integrated Policy, and revise or establish new HSE objectives
and targets and relevant programmes;
• examine the Conformance Matrix, if necessary, and investigate the possibility to remove the
holds and improve the compliance with the Eni-Agip Division Standard;
• evaluate the need for improving personnel training, skills and awareness toward HSE
matters;
• look for any emerging trends in HSE management, and identify possible solutions to HSE
problems.
Proposals approval and meeting close out.
Keeping into account the considerations and the decisions arisen during the session, meeting
attendants should:
• identify corrective actions;
• identify preventive actions;
• define new objectives and targets;
• prepare HSE improvement programmes and HSE plans;
• allocate relevant budgets and resources;
• define actions to better comply with the Eni-Agip Division Standards, and modify the Matrix
and the Company Standards accordingly;
• approve the actions above, identifying which ones are beyond the Company responsibilities,
in order to report them directly to the Eni-Agip Division level;
• document all the meeting findings and taken actions in a formally issued Management
Review report.

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Eni S.p.A.

Doc. n. 1.3.0.2 Pag. 1 of 98

ENI - DIVISIONE AGIP

Doc. n. 1.3.0.2 Pag. 2 of 98

A.1 POLICY AND STRATEGIC OBJECTIVES.............................................................................3

B-1 RISK ASSESSMENT.....................................................................................................................6

B-2 LEGAL AND OTHER REQUIREMENTS..............................................................................19

B-3 OBJECTIVES AND TARGETS.................................................................................................23

B-4 HSE MANAGEMENT PROGRAMME(S)..............................................................................27

B-5 CONTINGENCY AND EMERGENCY PLANNING...........................................................30

C-1 ORGANISATIONAL STRUCTURE AND RESPONSIBILITIES, MANAGEMENT

C-2 TRAINING, AWARENESS AND COMPETENCE..............................................................40

C-4 DOCUMENTATION AND ITS CONTROL...........................................................................51

C-5 OPERATIONAL CONTROL.....................................................................................................55

C-6 PROCUREMENT AND CONTRACTORS.............................................................................61

C-7 EMERGENCY PREPAREDNESS AND RESPONSE..........................................................66

D-1 MONITORING AND MEASUREMENT ................................................................................74

D-2 NON CONFORMANCE, CORRECTIVE AND PREVENTIVE ACTIONS..................80

D-3 HSE IMS RECORDS....................................................................................................................84

D-4 INTERNAL AUDIT.....................................................................................................................88

E-1 MANAGEMENT REVIEW ........................................................................................................96

Doc. n. 1.3.0.2 Pag. 3 of 98

HSE GUIDELINES-APPLICATION REQUIREMENTS

A.1 POLICY AND STRATEGIC OBJECTIVES

A-1.1 Definition of HSE Policy (ies)

A-1.2 Promotion of HSE Policy (ies)

Doc. n. 1.3.0.2 Pag. 4 of 98

A-1.1 Definition of HSE Policy (ies)

Produce an HSE policy

Define commitment of HSE policy

The Organisation should define in its HSE policy the commitment:

Doc. n. 1.3.0.2 Pag. 5 of 98

A-1.2 Promotion of HSE Policy(ies)

Promote HSE policy

Document HSE policy and objectives

HSE policy, strategic objectives should be effectively documented, implemented, maintained,

Doc. n. 1.3.0.2 Pag. 6 of 98

HSE GUIDELINES-APPLICATION REQUIREMENTS

B-1 RISK ASSESSMENT

Identify systematically the hazards, the effects and the impacts,

B-1.1 Identification of potential HSE hazards

B-1.2 Definition of acceptance criteria for the risks

B-1.3 Evaluation of the risks and effects from identified hazard

B-1.4 Assessment of risks acceptability

B-1.5 Identification of risk reduction measures

B-1.6 Implementation of the selected risk reduction measures

Doc. n. 1.3.0.2 Pag. 7 of 98

The Risk Assessment Process

Doc. n. 1.3.0.2 Pag. 8 of 98

B-1.1 Identification of potential HSE hazards

Compile a list of activities undertaken by the Organisation for each process.

For each activity, gather information on HSE aspects, including:

Doc. n. 1.3.0.2 Pag. 9 of 98

Systematically identify HSE hazards in each activity.

Identify the effects of each hazard

Doc. n. 1.3.0.2 Pag. 10 of 98

TABLE 1 - KEY WORDS FOR HAZARD IDENTIFICATION

Others Others Others Others Others Others

Doc. n. 1.3.0.2 Pag. 11 of 98

TABLE 1 - KEY WORDS FOR HAZARD IDENTIFICATION (CONTINUED)

Others Others Others Others Others Others

Doc. n. 1.3.0.2 Pag. 12 of 98