Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report

Introduction
Akakus Oil Operations (AOO) is developing and implementing an Occupational Health and Safety
Management System (OHSMS) to manage the health and safety risks arising from operations at its
various sites and facilities in Libya. AOO intends to seek certification of the OHSMS against the
OHSAS 18001:2007 management standard: the gap analysis described in this report is a step in
preparation for seeking certification.
The objective of the gap analysis is to compare present arrangements in AOO for occupational health
and safety against the requirements of OHSAS 18001:2007 to identify the significant findings and
recommendations for improvements. An plan is proposed for the implementation of the initial
improvement actions.
A multi-disciplinary team of HSE professionals and oil and gas engineers from Repsol and REMSA
undertook the gap analysis between the 28th September and 2nd October 2010. The Scope of Work for
the gap analysis is attached at Appendix 1.

Methodology
The methodology for the gap analysis was to visit the AOO headquarters and operational sites, meet
with managers and supervisors and observe operations first hand to gather information on the OH&S
and process safety arrangements, both as documented and as applied. The HSE professionals in the
analysis team concentrated on the comparison with the requirements of OHSAS 18001:2007, whilst
the oil and gas engineers looked at the process safety arrangements and practices.
The gap analysis team comprised:
 Carlos Salvador Roldan Head of HSE, Europe, Asia, Africa (EAA) Region
 Enrique Villalobos Herrera Senior Facilities and Production Engineer, EAA Region
 Miquel Lacarra Senior Project Engineer, REMSA
 Paul Reed HSE Management Systems Advisor, EAA Region
Also participating in the gap analysis:
 Gonzalo Carillo Recalde Head of HSE, REMSA
 Carlos Wigstrom Broncheur Operations HSE Management Systems Advisor, AOO

The team visited the Akakus Headquarters, the Zawia tank farm and the El Sharara facilities to
perform the gap analysis.
The findings relating to OH&S management and those relating to process safety were considered
separately and are presented separately in this report. The analysis of the OH&S management
arrangements is included in the form of a spreadsheet (attached at Appendix 2) showing the OHSAS
18001:2007 requirements and the equivalent section from the AOO HS MS. The main findings and
recommendations in relation the management arrangements and those relating specifically to process
safety are included below in the text of this report.
A close-out presentation was made to AOO management on Monday, 4 th October, to seek comment
on the gap analysis before preparation of this report. The slides used at that presentation are also
attached at Appendix 2.

Main Findings and Recommendations

The findings set out in this section represent those aspects of OH&S management and process safety
that will require either a significant cross discipline effort to achieve the necessary improvements, or
Which represent an increased risk for AOO operation. The full findings are included with the
attachments at Appendix 2.
These findings and recommendations do not necessarily capture all of the issues to be addressed for
OHSAS 18001 certification. They are the result of a gap analysis based on observation of operations
and interviews with managers and supervisors but they cannot be considered as the results of a full in-
Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report
depth audit. Further work will be required before a pre-certification audit can be undertaken; a plan for
the initial actions to be undertaken is included below.
In the following tables of findings and recommendations the “Ref” column refers to the relevant section
of OHSAS 18001:2007.
OH&S Management Findings and Recommendations
Ref. OH&S Management Findings
4.1 Occupational Health: focus of the OH&S
MS is on safety; the occupational health
content needs to be strengthened
4.3.1 Hazard Management: the documented
hazard management arrangements are
appropriate for routine activity risk
assessment but not for the risks associated
with complex process hazards.
4.3.1 Management of Change: there is no
evidence that the Management of Change
procedure is being applied to the hazard
management process.
4.3.2 Legal Requirements: a schedule of
applicable Libyan laws, NOC requirements
and international conventions / agreements
should be attached to the OH&S MS for
conducting the legal compliance evaluation.
4.4.1 Organisation Structure: little evidence of
approved documented organisation
structure. Job descriptions are not available.
HSE roles (outside the HSE team), basically
defined, but are not followed (understood).
4.4.1 Management Commitment: senior
management commitment to effective HSE
management could be strengthened.
4.4.2 HSE Training: no evidence was found of a
systematic approach to HSE training to
demonstrate that people are competent on
the basis of education, training or
experience.
HSE training is being delivered, however it
needs to be linked more closely to identified
and evaluated risks.
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Recommendations
Consider the development of a health
management system including: medical
facilities provision, prolonged exposure to
hazardous chemicals, noise exposure, heat
stress, fitness to work, catering and food
hygiene, substance abuse, accommodation
facilities, recreation arrangements, health
promotion.
Define and document the process risk
management methodologies (HAZID,
HAZOP, bow-tie analysis, etc) to be applied
to new facilities and upgrades and to the
assessment of existing facilities.
Implement the Management of Change
procedure to ensure that all changes (to
processes, to the organisation, to HSE
procedures, to specifications, etc) are subject
risk assessment.
Verify the Libyan laws, NOC requirements
and international conventions / agreements
applicable to AOO operations and attach to
the OH&S MS.
Define and document the organisation
structure for AOO and prepare job
descriptions. The HSE roles for all positions
(not just HSE Dept.) should be defined.
Senior management to review how it
demonstrates a visible commitment to HSE
management and implement appropriate
initiatives.
Implement an HSE training management
system for HSE Critical positions and non-
critical HSE tasks.
HSE Critical positions in line departments to
be identified and responsibilities defined.
Appropriate training programmes to be
developed and delivered and competence
verified.
Training management system to include for
the evaluation of training effectiveness.
Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report
Ref. OH&S Management Findings
4.4.3 Communications: internal communications
(all departments and facilities – not just HSE)
are not sufficiently robust.
4.4.4 Operational Documents: basic
documentation required at the control room
is not available (updated P&IDs, operation
manuals, specific procedures for routine
operations, PSV and ESDV testing log,
facilities area classification layout, etc)
4.4.5 Technical documents: documents,
including equipment and instrument
manuals, are not being properly stored and
handled.
4.4.6 PTW Procedure: a formal PTW procedure is
in place but implementation is limited due to
poor comprehension of the system by task
supervisors and area authorities. Currently
the PTW system is reliant in the HSE
department.
4.4.7 Emergency Response: ER arrangements
are only partially implemented.
4.5.3 Incident Investigation: ownership of the
incident investigation process remains with
HSE Dept. and not with the line departments.
Appropriate levels of seniority for
investigations are not being applied.
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Recommendations
Review and strengthen internal
communications arrangements. Areas for
attention include:
 Technical briefings for operational
personnel;
 Processing of field generated Change
Requests;
 Availability of process information, e.g.,
updated P&IDs at operations location;
 Involvement of all concerned
departments in the Scope of Work of
construction and procurement contracts;
 Training for operational personnel on
newly installed equipment.
Verify documentation requirements of all
operational facilities and ensure provision of
up to date documents.
Verify document control arrangements
including version control, storage and
distribution.
Transfer responsibility for the PTW system to
the production department; line managers
and supervisors to take over day to day
implementation.
Hold targeted training to ensure full
understanding of the PTW system by
production supervisors, permit signatories,
area authorities, and permit requestors.
Complete the implementation of the planned
ER arrangements, in particular:
 Specialized training for emergency
response team and crisis management
team members;
 Improve emergency communications
systems;
 Establish mutual aid arrangements with
local organisations;
 Hold drills and exercises to practice ER
arrangements.
Transfer ownership of the incident
investigation process to the line departments
and support with training as appropriate.
Incident investigations to be led by a line
department manager or supervisor
depending upon the severity of the incident
(in line with the Incident Investigation
Procedure guidance).
Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report
Ref. OH&S Management Findings
4.6 Management Review: the management
review process for OH&S has not yet been
implemented.
Process Safety Findings and Recommendations
Ref. Process Safety Findings
4.4.2 Technical Training: no evidence was found
of a systematic approach to technical training
of field personnel to demonstrate that people
are competent on the basis of education,
training or experience.
4.4.3 Internal communications:
Not all the networks and facilities
modifications carried out in the field are
afterwards reflected in the corresponding
P&IDs, which seem to be updated in the
Engineering database but were not found
available at the operations locations.
Operational personnel have not received any
technical briefing on the new compressing
units which are at an advanced stage of
construction in the operational area of the
GOSPs.
Except from the GOSP IR – EPCC Contract,
the scope of work of construction and
procurement contracts have been prepared
with only minor involvement from Operations
and HSE staff. Safety department has no
input or involvement on the purchase and
acquisition specifications definition.
4.4.4 Operational Documents: basic
documentation required at the control room
was not found to be available (updated
P&IDs, updated equipment manuals, specific
procedures for routine operations, ESDV
testing log, facilities area classification
layout, updated cause & effect charts etc).
4.4.5 Technical Documentation Management:
copies and versions of critical safety
technical documents such us procedures,
standards, books and manuals should be
available to end users and properly
controlled. Some information (mainly HSE
related) was found to be catalogued and
accessible on the AOO intranet, but there is
still room for improvement in this regard.
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Recommendations
Implement the OH&S Management Review
procedure (this will also support the
demonstration of management commitment
to OH&S – see 4.4.1 above)
Recommendations
Implement an training management system
to include for technical training of field
personnel.
With all the many and important changes in
the process taking place these days within
AOO operations, it is important to guarantee
that field personnel technical training
coverage, content and quality is appropriate.
Implement the ‘Request Change’ procedure
to ensure that any modification in the plant is
translated into the corresponding P&IDs
update.
Ensure operations personnel receive
appropriate training from vendors on new
installed equipment.
Review and improve technical and safety
critical information flows between
departments and between the field and
headquarters (both directions).
Review contract preparation procedures to
ensure field operations, maintenance and
HSE personnel can review and input to
contract scopes of work.
Establish a systematic procedure for
updating and making accessible for the field
personnel a set of safety critical technical
documents.
Verify documentation requirements of all
operational facilities and ensure provision of
up to date documents.
Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report

Ref. Process Safety Findings Recommendations

4.4.6 Layout Adequacy: with the addition of new Carry out a layout adequacy review of the
important items to the plants there are plants to identify the particular situations in
situations in which minimum distance which disposition of equipment is out of AOO
between equipment, layout adequacy and and /or international standards.
areas classification have become a safety
concern.
4.4.6 Pre-commissioning, Commissioning, Ensure clear specifications, role definitions
Start up and Handover (PCSH): operational and documented procedures for the PCSH
personnel who receive new equipment are phases of projects are prepared and are
not receiving the proper training and available to operations personnel.
instructions to guarantee its safe operation
Ensure appropriate training is provided.
as an integral part of pre-existing process
and plant.
4.4.6 (PCS) Access Permission Policy and Implement in the PCS different users’ profiles
Override Management: there is a document along with a proper permission policy.
for Overrides and Inhibits that has been
approved by AOO, but since the upgrade of
the ABB PCS System, there is no proper
permissions policy in place, this has resulted
in almost any operator being able to override
and inhibit F&G and ESD systems,
operational settings, alarm signals and
automatic emergency control actions.
4.4.6 Inspection Philosophy: some inspection Review the schedule maintenance for all the
services for critical equipment were found to equipment items, carry out all the overdue
be overdue. Consequences related to services and establish the required
failures of emergency equipment like ESDVs measures to guarantee that inspections take
or pressurized vessels like degassers and place always in due date.
flash drums, can be of a tremendous
importance.
4.4.6 Instruments Set Points Database: critical Continue and extend the initiative to record
safety information like safety devices and all the instruments and safety devices and all
alarms set points has not been previously the set points in the maintenance database.
recorded and maintained in an up-to-
standards manner. Just until recently the
instruments were not being considered as
individual pieces of equipment in the
maintenance database (Maximo).
4.4.6 Overloaded Equipment: due to the addition Identify all these types of problems and the
of new facilities to the different GOSPs, most appropriate solution for each case.
some equipment items that have not been
Within the GOSPs A-NC115 and A-NC186
upgraded accordingly are proved to be
where additional equipment has been
overloaded and may become a source of
recently installed the revision of HAZOP
loss of containment.
analyses previously carried out can be of a
good help in this regard.
4.4.6 Corrosion Management: there is no Implement a proper and up to standards
dedicated unit in AOOs organization dealing corrosion management system and
with corrosion. Corrosion field personnel supporting organization.
(corr-lab) report to Operations whereas
cathodic protection staff report to
Maintenance and cover as well Engineering
commissioning works and handover from
vendors.

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Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report

Ref. Process Safety Findings Recommendations

4.4.6 Out of Standards Solutions: several out of Identify all the out of standards installations
standards solutions were observed at the within AOO operations and implement the
production facilities. These present safety necessary corrective measures to stop using
hazards as they have not been properly those equipment and to prevent this kind of
engineered. Examples include: a container solution from being implemented in the
converted to a water tank equipped with an future.
ESP and an external centrifugal pump to
send the produced water to the NC186 water
treatment plant; lifting and hoisting
equipment (homemade overhead cranes and
structures); wooden supports for water GRP
(Glassfibre Reinforced Polymer) lines.
4.4.7 Emergency Response Systems: the Carry out regular fire and spillage drills and
firefighting network has been extended to use those exercises to re-evaluate the
cover the operational areas where new location, preparedness, amount, availability,
equipment has been installed but tanks and and redundancy of emergency equipment
pumps still remain as per the original design. and resources.
Fire station and trucks are located at the Verify the firefighting system capacity and
CCX some hundred of meters away from the coverage against industry standards..
operational area of GOSP A – NC115 this
may or may-not be a proper location for this
equipment, but no study was found to
support the basis of it.
The Scenario 19 of the Emergency
Response Plan related to oil spill or release
in the process vessels and especially in the
main 30” El Sharara to Zawia pipeline is not
fully implemented, for example no spillage
drill has ever been performed.
4.5.3 Lessons Learned Database: after having Implement a lessons learned database and
had and investigated many incidents and ensure availability of learnings to all
mishaps, no evidence was found of proper personnel.
lessons learned documentation and
The communication of lessons learned
communication.
through safety alerts or safety meetings is an
easy to implement measure that helps to
prevent incident reoccurrence.

Action Plan
The action plan proposed below represents only the first phase of a longer series of activities leading
to OHSAS 18001 certification. At this stage it is not possible to identify with certainty all of the actions
that will eventually need to be undertaken because, firstly, there are too many unknowns about the
facilities and, secondly, accountabilities for HSE and process safety are not clear. The first phase
actions address these issues and three specific process safety concerns that warrant immediate
attention.

Carry out a detailed assessment of the current facilities in terms of equipment, risks, and
controls:
 Update and upgrade technical documents: P&IDs, process flow diagrams, equipment manuals,
operating procedures, etc;
 Carry out HAZOPs of all facilities to determine the hazards, risks and necessary controls
associated with the facilities and the completeness of process safety arrangements.

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Akakus Oil Operations: OHSAS 18001:2007 Gap Analysis Report

Clearly define accountabilities for HSE and process safety

 Improve HSE leadership and commitment of the management team;
 Hold training and familiarization visits to other sites and facilities to raise awareness and expertise
with respect to HSE and process safety management;
 Define accountabilities for HSE and process safety;
 Establish and implement systems to effectively audit HSE and process safety performance.

Process safety concerns that warrant immediate attention

 The proximity of the flare to the storage tanks at GOSP A NC186;
 The sump tank at GOSP A-NC115 which is venting vapour and gases and is located in the middle
of an operational area;
 The fuel gas compression condensate flash drum C168 at GOSP A-NC115 which is operating with
a gas bypass fully opened and its PCV is just regulating excess gas.

Proposed Phase 1 Action Plan

Conclusions
The analysis demonstrates that although AOO has made significant progress in the development of its
documented OH&S MS the implementation of the system is not moving forward at a similar pace.
There appear to be two reasons for this:
 firstly, the implementation of an OH&S MS involves change for the whole company, at all locations
and at all levels, and such changes take time to become embedded in day to day work practices;
 secondly, such changes require an effective internal communications system to ensure all
personnel are aware of and accept the new OH&S requirements and the effective transfer of
technical and HSE information. This present study has identified weaknesses in the internal
communication processes of OAA.
In addition to the OH&S MS issues the gap analysis has highlighted a number of weaknesses in
relation to process safety which demonstrate that the necessary controls for safe operation are not all
in place. All of these factors are slowing the implementation of the OH&S MS and will need to be
addressed before progress on OHSAS 18001 certification can be made.
As the two issues of OH&S management and process safety are interdependent (even though they
have been described separately in this report) they will need to be addressed in an integrated manner
to ensure the benefits of any remedial action plan are optimized across both areas.
The HSE Manager and his team will need the support and commitment of all members of the AOO
management team to achieve the objective of OHSAS 18001 certification. The management team
has already demonstrated its commitment to effective OH&S management by its decision to work
towards this goal; their ongoing commitment and support will ensure success in this endeavour.
The gap analysis team expresses its thanks and appreciation to the AOO management team for its
support during their visits to the Akakus facilities.

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Appendix 1 – Gap Analysis Scope of Work

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Appendix 1 – Gap Analysis Scope of Work

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Appendix 2 – Attachments

The following working documents prepared by the gap analysis team are included for reference.

Gap analysis spreadsheet

A structured comparison of the AOO OH&S MS against the requirements of
OHSAS 18001:2007.

Close-out Presentation
The slides from the close-out presentation to the AOO management team on
Monday, 4th October 2010.

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