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Gu 292
Gu 292
Keywords: Asset Manager, CAP, Chemical, Custodian, Initiator, Log, Register, SHOC Card,
TREM Card, Waste.
This document is the property of Petroleum Development Oman, LLC. Neither the whole nor any
part of this document may be disclosed to others or reproduced, stored in a retrieval system, or
transmitted in any form by any means (electronic, mechanical, reprographic recording or otherwise)
without prior written consent of the owner.
Version 1.0 Chemicals Management Guideline
Signed :............................................................
Frans Willekes,
Corporate Functional Discipline Head for Health,Safety and Environment
Contents
1. Introduction...........................................................................................................................3
1.1 Background.......................................................................................................................3
1.2 Purpose..............................................................................................................................3
1.3 Distribution/Target Audience & Further Copies..............................................................4
1.4 Structure of This Document..............................................................................................4
1.5 Review & Improvement....................................................................................................4
Appendix E.................................................................................................................References 20
1. Introduction
1.1 Background
Section 2.4 list the HSE Business Control documentation which control some of the
aspects of Chemical managent. In addition , several business control documents regarding
procurement and logistics cover aspects of Chemical mangement.
These documents replace the requirements outlined in the Chemicals Management Manual
Volume One (TSE/ENV/95/003) and forms part of the PDO HSE Management System.
1.2 Purpose
This guideline is intended to be used by PDO staff and contractors involved in the
management of Chemicals.
The guideline is logically divided into a scope, which defines chemicals management, and
a detailed description of the activities involved in chemicals management throughout the
lifecycle. Disposal of chemical residues is dealt with in detail in the Waste Management
Guideline (Ref.4).
Any user of this document who encounters a mistake or confusing entry is requested to
immediately notify CSM using the form provided in PDO’s HSE Management
Procedure - Documentation and Document Management.
This guideline shall be reviewed by the CSM Department as necessary , but no less
frequently than every four years. However, changes to the current version may be made
in less than four years as the need arises depending upon the issue of new and relevant
environmental legislation and/or major organisational changes in PDO.
In this guideline chemicals are defined as all liquid, gases and solid substances, except
radioactive and explosive materials, which are purchased in
containers/drums/packages/tankers. It does not include chemicals after they have been used
in the process, e.g. drilling muds, production water (which are covered in the Specification
for Aqueous Effluents, SP 1006 (Ref 5)) or gaseous chemicals (which are covered in detail
in the Specification for Emissions to Air, SP 1005 (Ref 6)). Liquid chemicals include oil
products, such as fuels and lubricants, and crude oil in drums and tankers, but not in
process equipment, including pipelines.
With every chemical application there is a hazard that must be identified beforehand so
that the risk factor can be measured and managed. The following sections of the guideline
are intended to identify the roles of the responsibilities of those involved in chemical
management and to allow these parties to “manage the risk” at each stage of the chemical
lifecycle.
For Chemicals supplied by Contractors, the Contrcat Holder is responible for making sure
that the Contractor complies with the Chemical mangement requiremenst as outline in
PDO's Procedures and Specifications
2.3 Description
Before a chemical can be selected for a specific application in PDO, a clearly defined
technical justification for the chemical requirement must be made by a chemical initiator
(see glossary) using a SHOC Card Request Form (Refer to Appendix A). The chemical
must then be approved by the Chemicals Approval Panel (CAP) before the SHOC card is
issued. This SHOC card is only relevant for the designated application of the chemical.
No chemical, even for trial purposes can be used in PDO unless it has a SHOC card. If it
does not have a SHOC card, then the Chemical Approval Procedure must be followed as
outlined in Section 2.2.1.3. Existing SHOC cards for approved Chemicals can be seen in
the Chemical Management Manual Volume 2 or can be accessed through the TKM
webpages.
The Chemical Initiator is responsible for raising the SHOC Card Request and providing the
required information to assess compatibility, effectivenssss, economical justification and a
plan to monitor its effectiveness during use.
The SHOC Card Request Form is then sent to the relevant TKL/1, who will then pass it to
the relevant Production Chemistry specialist or other competent resources in or outside
PDO. After evaluation of the proposal the application can either be passed, rejected and/or
an alternative proposed. If passed, TKL/1 produces a Draft SHOC card which is circulated
to CAP members for approval or rejection on HSE issues using a SHOC Card Approval
Form . If the chemical is unanimously approved, TKL/1 will issue the SHOC card which
must be signed by TKL.. The normal timeframe to prepare a SHOC card is three weeks. If
the chemical is rejected by one or more members of the CAP, the Chemical Initiator has
the right to appeal, which can be made at a specially convened meeting of the CAP.
For an emergency supply of chemicals, a Waiver can be obtained from CSM/2, who will
consult with the other members of the CAP before issuing.
The CAP is composed of four permanent members plus 1 part-time member (TSP/13), who
will attend the biannual meetings only.:
The CAP formally meets twice per year to carry out reviews as described in the Terms of
Reference below. If there is a requirement for the CAP to meet additionally, due for
example, to hearing appeals on rejected chemicals, then the Chairman will arrange a
special meeting.
Review the Draft SHOC Cards produced and circulated by TKL/1 and either
approve or reject them. They may decide to approve the SHOC card subject to
some agreed modification. This is carried out by the individual members, i.e. no
formal meeting of the CAP is required.
Deal with appeals from Chemical Initiators, who have had their chemical(s)
rejected. This will require a special convening of the CAP.
On an annual basis:
Review chemical usage statistics to detect significant increases in use above the expected
norm, due to for example increase in oil or gas production;
Carry out a Chemicals Management Audit according to the Approved Integrated Audit and
Review Plan.
Direct Charge Chemicals are chemicals that are not normally stocked by Supply
Department. There is a danger in purchasing chemicals by this method that the
item may not be recognised as a chemical by the Purchasing Department and could
therefore by-pass the SHOC card system. Using this route for obtaining chemicals
should therefore be avoided. If it is necessary to obtain by Direct Charge, then the
order should be processed by the Supply Department on receipt of a requisition
from the Chemical Initiator with the SHOC Card attached. This SHOC Card may
be a draft card issued with approval from CSM/2.
This is a method where the Chemical Supplier is requested to store the chemicals
to be used by PDO on the Supplier's or on PDO's premises and to deliver them to
PDO on a "Call-off" basis as required. This is a preferred method of purchasing
chemicals, provided that the Suppliers apply the same standards in their facilities
as laid down in this manual. It is the duty of the Contract Holder to ensure that
ample warning is given to the Supplier of impending changes to chemical
requirements to avoid redundancy situations arising and hence creating the
possibility of generating chemical waste.
In some cases, chemicals are purchased by Third Party (contractors) for use in
PDO. The contract between PDO and the Contractor must include a clause
that all chemicals used in PDO must have a SHOC Card. It is the Chemical
Initiators' ( i.e Contract holder) responsibility to ensure that all Third Party
chemicals used in PDO have an approved SHOC Card. Wherever possible and
economically justified any surplus chemicals should be returned to supplier.
2.3.2.5 Projects
The Road Transport Safety Case (Ref 7) and its accompanying Manuals; Transport
Operations Manual (Ref. 8) and Managing Transport (Ref. 9) outline the principles
of PDO’s Transport Management System, and therefore the purpose of this section
of the guideline is to highlight areas which are particular to chemicals.
All spills and leaks of any chemical must be reported immediately to the PDO
Supervisor responsible for the transportation of the chemicals as indicated in the
Specification for Accidental Releases to land and Water (Ref 11).
Vehicles carrying chemicals must carry a Transport Emergency (TREM) card and
meet the minimum standards laid down in the Transport Standards Manual (Ref.
9). Chemicals as defined in this guideline are considered to be Hazardous
Materials and vehicles used to transport them will require a Royal Oman Police
(ROP) Hazardous Materials Permit.
All personnel involved in the transportation and handling of chemicals must have
sufficient understanding of the HSE aspects of the chemicals to enable them to
carry out their work safely, in an environmentally acceptable manner and not
endanger their health. CSM/1 can be consulted for advice on how this can be
achieved. Preference should be given to drivers who have literacy in either
English or Arabic as laid down in Reference 8.
2.3.3.5 Planning
Incompatible chemicals (see SHOC card, Section 8 for details) shall not be
transported together on the same vehicle.
Packaging (drums, bags, pallets, boxes, shrink wrapping, etc.) should be inspected
carefully by the receiving PDO representative. If defects are found which are
considered to be not in line with minimal HSE requirements (e.g. damaged or
leaking containers), then the material should not be accepted and sent back to the
supplier for corrective action after making the damaged container safe.
Upon receipt of bulk delivery of chemicals, the delivery truck as well as the
receiving storage vessel shall be inspected for damage, etc. before off-loading
takes place. It shall be ensured that competent personnel are available during the
off-loading to prevent delivery into wrong storage vessels. Any damage to delivery
truck as well as storage vessel shall be reported immediately by the receiving PDO
representative to PDO and Contractor supervisors.
Receiving PDO personnel shall ensure that chemicals delivered to PDO are
supplied in accordance with the requirements as specified in the order. All
delivered chemicals (individual units as well as outside packaging) must be clearly
and permanently labelled with chemical name, hazard identification, quantity,
MESC number (if applicable) and manufacturer in accordance with PDO and
international transport regulations.
TREM cards must be available for all chemicals to be transported and carried by
the driver in his vehicle during the transport. The TREM card details should also
be included in the Journey Management Plan, so that the Emergency Response
Team know how to deal with the emergency.
It must be ensured that the chemicals are clearly and permanently labelled with
chemical name, hazard identification, quantity, SHOC number (if applicable) and
manufacturer in accordance with PDO and international transport regulations.
Tanks containing chemical liquids shall be spaced and positioned such that they
present no danger to personnel and surrounding installations. They shall be clearly
identified, placed on an impermeable base and surrounded by protective bunding
to contain any spillage and prevent leakage beyond the base in accordance with
PDO-ERD-09-02 (Ref. 15).
All chemicals must have secure packages (drums, bags, sacks, etc.) to prevent
spoilage due to outside contamination or spillages. Chemicals in permanent
locations shall be stored on hard standing and provided with containment such that
accidental spillage will not result in pollution of the soil. Chemicals stored in
temporary locations, such as drilling sites, are excluded from this requirement due
to rapid consumption, but should have some form of containement in case of
spillage.
Hazardous chemicals shall be protected from the elements (i.e. sun, rain, storm,
etc.). Incompatible chemicals (see SHOC card, Section 8 for details) shall not be
stored together so as to prevent dangerous reactions occurring.
All storage of chemicals shall be organised such that the "first in / first out"
principle (i.e. older stock to be consumed first) is adhered to. This requires good
housekeeping of the storage area and accessibility of the material to be taken first.
no leakage of the chemical will occur in the period until the next inspection
and;
the chemical is still fit for purpose over the period until the next inspection.
If the chemical has been in storage for a long period of time and no off-take has
taken place over the past year(s), further storage of the chemical should be
questioned. The following steps should then be taken:
If not, proceed according to the guidelines for reuse, recycle and/or disposal
as outlined in the Waste Management Guideline.
It is essential that plans are in place for responding to emergencies and that the
effectiveness of such plans are examined regularly through emergency drills and
exercises. An inventory of the types and quantities of chemical in stock shall be
presented to the local Emergency services every 6 months and upon demand.
When the chemical itself is still found to be in a satisfactory condition, but the
condition of the packaging has deteriorated or has been damaged to such an extent
that it might not withstand the period until the next inspection, then the chemical
must be re-bagged or re-drummed in new containers.
Eye wash units and Safety Showers must be available in all areas where chemicals
are stored and handled ( ref HSE Standards manual, HSE/96/01). The units shall
be of the foot-plate actuated type, located in close proximity to where the
chemicals are stored. The units must be tested routinely. The units must be fed
with clean water and protected from direct sunlight to maintain a temeprature less
than 40oC . Dangerously hot water should not be used to feed emergency
equipment. Portable eye-wash units are also acceptable as long as they are well
maintained and stored in a cooled environment. The integrity of the units must be
checked frequently and the water replaced periodically.
SHOC cards must be available at all locations to cover all chemicals being stored,
which can be consulted when dealing with emergencies ( ref 1008, Specification
for the Use of Energy, Materials and Resources). However, it is recommended
that a more simple sheet is displayed at the point where the chemical is stored.
This could be in the form of a large (minimum A4 size) information sign
identifying the stored chemical and highlighting the hazards present. Such signs
should contain the chemical name, the SHOC Number, the relevant hazard
symbols, the relevant PPE requirements and first aid measures. The sign should be
simple and easy to understand even by an illiterate person.
Staff working in chemical storage areas must have sufficient understanding of all
HSE aspects of the chemicals to enable them to carry out their work safely, in an
environmentally acceptable manner and not endanger their health or the health of
others. CSM/52 can be consulted for advice on how this can be achieved.
All chemicals kept in storage shall be clearly and permanently labelled with
chemical name, hazard identification, quantity, SHOC number and manufacturer
in accordance with PDO and international transport regulations.
The responsible Supervisor or Asset Holder shall maintain full and up-to-date
records of all chemicals stored [quantity, location and consumption].
The check list provided in OHMG Guidance Note No. 12 (Ref. 17) can be used to
inspect chemical storage areas. Inspections shall be carried out by the Responsible
Supervisor according to the Unit's HSE plans.
All production and drilling locations and any other location where chemicals are
used should include details of chemical handling as outlined in this guideline in
their operating procedures. Safety-Critical Task Sheets should be used to identify
HSE hazards.
Emergency plans should be in place to prevent and deal with any chemical
emergency. Personnel protective equipment, emergency equipment and chemical
information must be available/displayed as already described in Section 2.3.4.3
above. Drills must be conducted as per the Unit's HSE plans.
Similar to the storage areas, all staff handling chemicals in operational areas must
have sufficient knowledge to enable them to understand the HSE hazards of
chemicals. As well as the guidance given in Section 2.3.4.5 above, Suppliers
should be encouraged to provide this training as part of the chemical supply
contracts.
PDO's operating policy is, where possible, to have zero chemical waste. Hence
chemicals must be phased out completely (i.e. all old chemical consumed) before
alternatives are introduced. If a specific requirement for a chemical has ceased
then alternative usage must be sought. It is generally safer to consume the
chemical as per its designed function than to dispose of it into some other process
stream.
The quantities of chemical waste generated, by type and disposal route must be
reported to CSM/2 on a monthly basis as required by the Waste Management
Guideline.
Inspections shall be carried out by the Chemical Custodian as per the Unit HSE
plans.
2. Supplier: .......................................................
5 What will the chemical be used for compared to not using it?
.................................................................................
8. Is this chemical really required? Please supply answers to the following questions as
attachments (1-4) to this form:
8(a) If a replacement chemical, what is it's advantage over existing chemical? (Att. 1)
8(b) What benefits does the chemical give over not using it? (Att. 2)
8(c) Is the chemical effective? Please supply supporting evidence from field trial in Att.3.
8(d) Is the chemical economically justified? Please give details of alternatives, including
no use in Att. 4.
10. Please attach completed SHOC Questionnaire (yes/no) &/or MSDS (yes/no) (Strike out
as appropriate) as Att. 5.
11. Please supply plan for monitoring effectiveness of chemical during use in Att.6.
To be completed by TKL
The chemical is approved/rejected (Strike out as appropriate).
Appendix E References
(1) PDO, HSE Specification for Waste Management, SP 1009, 5/98.
(3) PDO, HSE Management Procedure - Documentation and Document Management, PR 1059, 6/98
(10) PDO, Emergency Procedures Part III, Contingency Plans Vol. III, Production Operations,
(11) PDO, Specification for Accidental releases to Land and Water, SP 1007, 5/98
(12) International Air Transport Association (IATA), Dangerous Goods Regulations, 1995.
(13) International Civil Aviation Organisation (ICAO), Technical Instructions for the Safe Transport of
Dangerous Goods by Air, 1995/96.
(14) International Marine Organisation (IMO), International Maritime Dangerous Goods Code, 1994.
(15) PDO, AEF, Spacing of Tanks and Tank Bunding Requirements, ERD-09-02, July 1993.