GW 52 Rig HSE Case

Part 6 – Performance Monitoring

PART 6.0 – PERFORMANCE MONITORING

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6.0 Introduction............................................................................................................ 3

6.1 Performance Monitoring....................................................................................................... 3

6.1.1 Plan of Mornitoring..................................................................................................4
6.1.2 Mornitoring Method.......................................................................................................... 5

6.2 Performance Monitoring....................................................................................................... 6

6.2.1 Incident Reporting and Analysis....................................................................................6
6.2.2 Behaviour-Based Observation Systems.......................................................................8
6.2.3 Health/Environment Monitoring and Measurement...................................................13

6.3 Audit and Compliance............................................................................................................. 18

6.4 Certification...................................................................................................................................... 21

Appendix 1: Rig HSE Monitoring and Inspection Program

APPENDIX 2: HSE PERFORMANCE TRACKING SHEET

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6.0 Introduction

This part of Performance Monitoring is specially formulated to standardize the monitoring and
measuring management in the company, effectively monitor HSE status, and provide basis for
HSE management in the company.

Performance Monitoring can be considered to have three major aspects: Periodic Monitoring,
Audit and Audit Compliance, and Verification of HSE Critical Activities/Tasks and
Equipment/Systems.

Eriell Oilfield Services B.V. defined the arrangements for Periodic Monitoring by supervisors and
other line management to ensure that plans and operations are implemented and maintained and
for measuring HSE performance (incident reporting and analysis, behaviour-based observation,
etc).

Assess the overall effectiveness of the HSE Management through Audit and Audit Compliance
including Management review of HSE performance against the HSE management objectives.

Verification of HSE Critical Activities/Tasks and Equipment/Systems for implementation and

effectiveness. See Part 7 HSE CRITICAL TASKS for more details.

6.1 Performance Monitoring

EOFS will use both active and reactive key performance indicators to measure safety
performance.

 Active monitoring provides feed back on performance before the occurrence of an

incident, ill-health or an environmental incident.
 Use the EOFS/GWDC Unsafe Act/Unsafe Condition recording system.
 All unsafe acts and unsafe conditions are reported, analysed and followed up in the
monthly Review.

Project HSE team was formed between the monitoring and implementation personnel, from
Country Manager to Rig HSE Supervisor. The responsibility was distributed each other and carry
on during the operation.

The proactive (leading) HSE performance indicators was the one of the focus during in operation,
Reactive monitoring is carried out after the event and key performance indicators are:

 Total man hours worked

 Kilometres driven
 Training Hours
 Days Away from Work Case (DAFWC/ LTI / LTA)
 DAFW frequency rate (DAFWF)
 Numbers of Restricted Work Cases (RWC) or job transfers
 Numbers of Medical Treatment Cases (MTC)
 Numbers of First Aid Cases (FAC)
 Numbers of Non-Injurious Incidents and Accident
 Numbers of Dropped Objects
 Numbers of Spills
 Numbers of Near Misses or High Potential incidents (HIPO)
 Numbers of Road Traffic Accident
 Numbers of Property damage based on monetary value

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Leading KPI Target

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Items Units Yearly Target

Goal Zero Days Days 365

LTI Nos of Cases 0

TRC Nos of Cases 0

FAC Nos of Cases 0

TROI Nos of Cases 0

High potential Incident Nos of Cases 0

Env. Spill/Gas Release Nos of Cases 0

% participation/
UAUC Cards 50%
Day/Location

Hands Free Campaign % trained >90%

Nos of Refresher training >85%

DROPs
Nos of Self Check by Rig Site Mthly

Nos of refresher training >85%

Temporary pipework
Nos of self checks Mthly

Lifting & Hoisting Nos of self Checks Mthly

PTW Audits
Nos Mthly / Qtrly
Monthly & Qtrly

The details of HSE KPI or incident information should be report periodically and according to the
exact condition. Rig Manager and HSE advisor was the base of the management construction.
See Appendix 2 for the data collecting and analyzing.

6.1.1 Planning of Monitoring

HSE Department shall include the contents to be monitored and measured into the annual work
plan while preparing the plan and supervising the implementation.

The department or unit assigned for the monitoring and measuring tasks shall determine the
monitoring basis and resources allocation, define the monitoring contents, methods and
requirements, and make records for the specific measuring and monitoring items no matter what
monitoring methods are taken.

6.1.1.1 CLASSIFICATION OF MONITORING AND MEASURING

 Performance monitoring and measuring: include the monitoring and measuring to the
completion status of objectives, targets and management program; the compliance
evaluation of laws, regulations and other requirements;

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 Safety technology monitoring: includes the monitoring of special equipment, safety

protection devices and monitoring equipment;
 Occupation health monitoring: includes the occupational hazards monitoring and
employee health status monitoring;
 Environment monitoring: refers to regular monitoring of environmental pollutants;
 The monitoring and measuring of operational control: include the monitoring of
construction process, workplaces and actual operations;

6.1.1.2 Implementation of Performance Monitoring and Measuring

Safety Technology Monitoring
 The regular monitoring of special equipment, safety devices and fire fighting facilities is
entrusted to the qualified testing and inspection institution by HSE Department;
 The supervision and inspection of the daily operation status of special equipment, safety
devices and fire fighting facilities is organized by HSE Department.

Monitoring of Operational Control

 HSE special audit and inspection. Each department carries out the supervision and
inspection to the workplaces according to professional inspection standard. HSE
Department organizes the audit and inspection for all elements of the system operation
situation, the control situation of major risks and significant environmental aspects in the
production process every half a year; each department conducts an inspection at least
once every quarter to the control situation of major hazards and significant environmental
aspects within the project.
 Safety observation and communication. Management people at each level shall conduct
observations of the employees’ behaviour and materials at workplaces according to the
plan or randomly, deliver on-site training by communicating with employees, improve
employees’ ability of safety observation and communication, and implement STOP card.
The ground level employees shall identify potential hazards for each other through
observation and communication, and carry out the on-site training. All employees shall
participate in risk identification and control, reduce the phenomenon of breaking rules and
regulations and reduce the construction risks in workplaces.

6.1.2 Monitoring Methods

The management of any activity requires monitoring and verification to ensure that activities are
carried out and standards are achieved. Effective management requires a process of monitoring
through observation and/or measurement of what is actually happening, comparison with
specified requirements, feedback and where necessary correction. To be effective, the monitoring
must be performed at several different levels of detail. Table 1 lists a range of methods.
Method Objective
Unsafe act auditing A measure of how well individuals understand basic HSE standards.
A demonstration of management commitment to detail.

Supervisory checks A demonstration of management commitment to HSE.

A reinforcement of the role of the line supervisors.

HSE inspection A management check to ensure standards are being achieved.

Non compliance is recorded and remedial action instigated.
Localised improvements may result from an inspection

HSE audit A management check to ensure that agreed systems are in place,
commensurate with the risk that will ensure standards are achieved.
Non compliances are recorded and remedial action instigated.
Project wide improvements may result from an audit.

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HSE Review A management check that all action being taken to manage HSE is suitable
and sufficient to ensure business objectives are being met.

Recommendations are recorded and remedial action agreed.

A complete change of approach towards HSE management may result from
a review.

Monthly Considered good practice for both commercial and HSE monitoring.
Review Meetings Should review the results of all the above monitoring methods plus results of
any performance indicators reported during the contract.
A formal agenda should be set and minutes recorded.

It is preferable for the meetings to be held on site.

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6.2 Periodic Monitoring

6.2.1 Incident Reporting and Analysis

Any Incident would be avoidable, if it occur, details should be reported and obvious. The content of the
report shall at minimum include the names and nationalities of the personnel, the operator, name of
facility, Time and location of incident, and rescue requirements.

The following was the procedure:

 If any incident happen in the site, the witness must report to rig HSE supervisor or rig
manager immediately.
 After getting the report, rig HSE supervisor and rig manager shall check the spot, injury
person immediately then report to HSE manager and Company man on site in half an
hour.
 At the same time rig HSE supervisor shall contact with camp medic if somebody injury.
 According to the condition of the IP, camp medic send the IP to Client clinic after basic
treatment if available. Any incident case shall be reported to Client medic by camp medic.
If more seriously, the local public medical service would be applied.
 Service party report to HSE supervisor if they operate in the site and to HSE manager if
they stay in the camp.
 The major incident (RWC, DAFW, FATALITY) shall be reported to Country Manager in
two hour by HSE manager.
 The investigation must be started in an hour by rig manager and rig HSE supervisor.
 The further investigation must be started in 12 hours by HSE manager, rig manager and
HSE supervisor.
 The primary report shall be submitted to Company and HSE manager in 24 hours by HSE
supervisor.
 The further report shall be submitted to Country Manager in 48 hours.

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Format of Incident Report

Incident Details
Date and Time
Well Location
Incident Location
Injured Person Name
Damaged Equipment
Other Loss
Incident Type
Injuries Type

Description of the Incident

Word Description and PHOTOS/SKETCHES (Low Resolution)

Investigation Findings
 Personnel
 Equipment
 Tools
 Procedure
 Environment

Other findings

Conclusions

Immediate Causes
 Inadequate safety devices;
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 Inadequate PPE;
 Failure to follow procedures;
 Etc.

Underlying Causes:
 Inadequate Supervision;
 Inadequate procedures;
 Etc.

Latent (Management) Failures:

 failed to adequately train supervisors.
 failed to ensure Toolbox Talks were routinely held.

Recommendation:

Action Required Priority Target Date Action Party Action Status (Open or Action Taken Date
H/M/L (EOFS) Party (Client) Closed) (If Closed) Completed

Issue Safety Alert to all

units
Replace

HSE advisor conduct

Improve
Update
Safety program
Coaching
Introduction of TRIC,
PTW,
STOP
Etc.

6.2.2 Behavior-Based Observation Systems

What is Behavior-Based Observation?

Behavior-Based Observation is a process that helps employees identify and choose a safe
behavior over an unsafe one. EOFS will strive for the elimination of all behavioral based incidents
and injuries by observation and communication of our behaviors. This will be accomplished
through management support and employee ownership to promote a safe working environment.

The Garraf Project HSE Department would plan, develop, implement, and supervise operation of
the Behavior-Based Observation Process. During the work over operation in rig site, this process
would be encouraged to apply any time. Employees should be trained to carry out the Process on
a continuous basis and to establish and maintain a high standard of safe work behavior.

Why look at behaviors?

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 85% of all incidents involve“at-risk”behavior

 Proactive approach vs. reactive
 Consequences control behavior
 Feedback is a very powerful tool
 The same at risk behavior can lead to different consequences
 Nothing Happens
 Near Miss
 First Aid
 Restricted Work
 Lost time
 Fatality

What causes at risk behaviors?

 Lack of knowledge, skills, and ability
 Management systems
 Rewards and recognition
 Facilities and equipment
 Disagreement on safe practices
 Personal factor
 Culture

What is Basic Behavior Principles?

Safety in the workplace is a combination of three measurable components: the person, their
environment, and their behavior. Only when these three elements are combined can workplace
accidents be eliminated.

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Risk Management, tools,

processes, equipment, engineering,
systems

Complying, coaching,
Recognising,
Knowledge, skills, communicating, leading
Intelligence, motives,
Personality

We could draw a conclusion that “A Total Safety Culture….Requires continual attention to

these three factors!”
The person component consists of the employees:
 Physical capabilities
 Experience, and
 Training
The work environment represents:
 Engineering Controls,
 Equipment,
 Job task, and
 The work culture
The final most often overlooked component is behavior-what the person does on the job.

WHAT IS BEHAVIOUR?
 Is an observable act
 Something we can measure
 Something we can manage

Kinds of Behaviour

Safe At Risk
Enabled Behaviour Difficult Behaviour Non-Enabled Behaviour
Have total control Have limited control Have no control
- Choice to work safely or at- - Possible to do the work safely - Not possible to do the work safely
risk but difficult

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ENABLED BEHAVIOUR

ACCESS STEPS ARE

AVAILABLE AND USED  ACCESS STEPS ARE
AVAILABLE, BUT NOT USED 
DIFFICULT BEHAVIOUR

ACCESS STEPS ARE AVAILABLE, BUT AT THE OTHER END

OF THE YARD
NON-ENABLED BEHAVIOUR

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ACCESS STEPS ARE NOT AVAILABLE AT THE FACILITY

Behavior-based observation system is based on four key components:

 A behavioral observation and feedback process;
 A formal review of observation data;
 Improvement goals, and
 Reinforcement for improvement and goal attainment.

Behavioral Observation and Feedback

This is one of the most important components of the process. Observations provide direct,
measurable information on employees safe work practices.
 Employees are observed performing their routine task. The observer documents both safe
and unsafe behaviors.
 The employee is then provided positive feedback on the safe behaviors and non-
threatening feedback on the unsafe behaviors. They are also provided with suggestions
on correcting the unsafe behaviors.

Formal Review of Observation Data

The data is then analyzed to determine the employee’s improvement in safe behaviors. It can be
looked at as an overall percentage. Example: If there were 20 items on the checklist and the
worker performed 17 of them safely, then he would get a score of 85% safe. The improvement
between observations could be graphed and displayed for employees to view. When the graphs
shows improvement, it provides positive reinforcing feedback to employees.

Improvement Goals
Setting improvement goals increases the effectiveness of feedback and the success of the
behavior-based safety process.

Reinforcement for Improvement and Goal Attainment

Management must provide immediate, positive feedback to reinforce safe behavior. Rewards can
be an effective means of reinforcing goal attainment.

Results
 Increased efficiency
 Increased productivity
 Increased morale
 Increase profitability

SAFETY CYCLE

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Critical
Critical
Behaviou
Behaviou
r
r
Checklist
Checklist
Data Entry
& Analysis

Action
Planning

CRITICAL BEHAVIOR CHECKLIST

1.0 Body Position Safe/At-Risk 4.0 Procedures Safe/At Risk

1.1 Line of Fire 1.1 4.1 Lockout/Tagout/Energy Isolated 4.1
1.2 Pinch Points 1.2 4.2 Confined Space Entry 4.2
1.3 Eyes on Path 1.3 4.3 Hot Work 4.3
1.4 Eyes on Task/Hands 1.4 4.4 Permit-To-Work 4.4
1.5 Ascending/Descending 1.5 4.5 Communication of Hazards 4.5
4.6 Pre/Post Job Inspection 4.6

2.0 Body Use/Ergonomics Safe/At-Risk 5.0 PPE Safe/At Risk

2.1 Lifting & Lowering 2.1 5.1 Head 5.1
2.2 Twisting 2.2 5.2 Eyes & Face 5.2
2.3 Pushing & Pulling 2.3 5.3 Hearing 5.3
2.4 Overextended/Cramped 2.4 5.4 Respiratory 5.4
2.5 Response to Ergonomic Risk 2.5 5.5 Hand 5.5
2.6 Posture 2.6 5.6 Body 5.6
2.7 Grip/Force 2.7 5.7 Fall/Work at Height 5.7
5.8 Foot 5.8

3.0 Tools and Equipment Safe/At-Risk 6.0 Environment Safe/At Risk

3.1 Selection/Condition 3.1 6.1 Walking/Working Surfaces 6.1
3.2 Use 3.2 6.2 Housekeeping 6.2
3.3 Vehicle Selection/Condition/Use 3.3 6.3 Storage 6.3
3.4 Guards 3.4 6.4 Lighting 6.4
3.5 Barriers & Warnings 3.5 6.5 Weather Extremes 6.5
3.6 Secure Tools and Equipment 3.6 6.6 Health and Hygiene 6.6
3.7 Mechanical Lifting & Lowering 3.7

7.0 Stop Work/Intervene/Other Safe/At Risk

7.1 Stop Work & Assess Situation 7.1
7.2 Intervene (observer) 7.2
7.3 Other (explain 7.3

Observation Process
 Employees advised that they are going to be observed for safe and at-risk behaviors
 Trained observer watches employee/employees for +/- 15 minutes
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 Observer fills out form

 No Name recorded
 Immediate Feedback
 Database – record in the register (e.g. rig site stop register)

6.2.3 Health/Environment Monitoring and Measurement

The following Occupational Health exposure risks should be considered during the operation in
Iraq Garraf Field:

Physical
Workplace Noise
Heat
Sunlight
Dust

Chemical
Benzene
Hydrogen Sulphide (H2S)
Paints and Coatings

Noise

Exposure to excessive levels of noise can cause permanent damage to hearing known as Noise
Induced Hearing Loss (NIHL). The aim of EOFS's hearing conservation program is to safeguard
the hearing of all personnel engaged in activities which involve exposure to noise by keeping
noise exposures in the workplace within mandated limits.
The maximum sound pressure limit for plant and equipment design shall be 85 dB(A) measured at
one meter, the objective being to maintain the work area noise level below 85 dB(A).

The standards for hearing conservation defined in Table3 shall be adopted.

Action Action required

Level Personal Noise Dose Noise Level
dB(A) (Leq) (8 hr)
80 Identify jobs where noise dose exceeds 80 Identify and mark working areas and
dB(A) activities where steady noise levels
Include such personnel in an audiometric exceed 80 dB(A). Noise level layout to
program. be displayed at the facility.
Make hearing protection available
85 Personnel shall not be exposed to a Identify and mark working areas and
personal equivalent continuous noise dose activities where steady noise levels
of 85 dB(A) over a working day. exceed 85 dB(A). Noise level layout to
be displayed at the facility.
Mark tools where noise levels exceed
85 dB(A) .
Mandatory use of hearing protection
115 Personnel shall not enter areas where Identify and mark working areas and
steady noise levels are above 115 dB(A) activities where steady noise levels
irrespective of duration or the use of exceed 115 dB(A). Noise level layout to
hearing protectors. be displayed at the facility.
135 Personnel shall not enter areas where Identify and mark working areas and
impulse noise levels are above 135 dB(A) activities where impulse noise levels
irrespective of duration or the use of exceed 135 dB(A). Noise level layout to
hearing protectors. be displayed at the facility.

A review of the existing noise layout and personal exposure levels shall be conducted by HSE
Department every year, or as facilities, equipment and operations change.

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Noise shall primarily be controlled at the source. Noise control shall be implemented considering
the following hierarchy:
 Define noise limits before the design and purchase of new equipment and tools.
 Use engineering principles of segregation and enclosure.
 Maintain plant and tools properly.

Where it is not feasible to control noise at source, the following control measures shall be
implemented:
 Reduce the number of exposed personnel by separating noisy from non-noisy work.
 Reduce exposure times by job sharing and automation.
 Provide personal hearing protection.

Personnel exposed to a daily noise does of 80 dB(A) shall have an audiometry test conducted
every two years. In cases where personal daily noise dose exceeds 52 dB(A) audiometry testing
shall be performed every year.

Record keeping-audiometry results are to be retained as part of the individual’s medical file.
Training-all personal exposed above 80 db(A) shall be trained on the health effects of noise
exposure.
Counseling-all personnel with a recorded hearing loss.

Reporting of noise induced hearing loss shall be in accordance with Incident Investigation and
Report Procedures.

Heat

There are many International Standards for Heat Exposure. However, these may be not fully
inappropriate to the work environment in Iraq Garraf Project.

In the absence of appropriate quantitative standards, health risk exposure due to heat shall be
controlled, as appropriate to the environmental conditions, by applying the following:
 moderating work rate
 forced ventilation and air conditioning
 shade
 water supply
 scheduled rest breaks
 scheduling work in cooler parts of the day, or at night
 programming work for a cooler part of the year

All personnel shall be vigilant in identifying the symptoms of heat stress in themselves or their co-
workers. These symptoms include:
 rashes
 heat cramps
 heat syncope (fainting)
 heat exhaustion (dizziness, tiredness, general weakness, delirium)
 heat stroke (body temperature above 40C, skin very hot, often sweating has stopped,
confusion, unconscious)

If heat stress symptoms are identified, work shall cease until appropriate measures to control heat
exposure are implemented.

Sunlight

Exposure to ultraviolet (UV) radiation from the sun can lead to the following health effects:
 Sunburn (skin redness, tenderness, swelling, blistering, fever, nausea)
 Premature wrinkling
 Skin cancer
 Sun sensitivity (allergic reaction to sun exposure)
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 Immune system suppression and disease

 Eye damage (including burning of the cornea, cataracts)

Health risk due to the sun's radiation shall be controlled, as appropriate to the environmental
conditions, by applying the following:
 Scheduling heavy work in order to limit exposure to the sun between 10 a.m. and 4 p.m.
 Shade
 Protective clothing to cover the torso, legs and arms
 Headgear or a hat to protect the face, ears, neck and eyes
 Sunglasses rated for protection against UV radiation
 High Sun Protection Factor (SPF) sunscreen for all exposed areas of skin should be
made available by the Employer

All personnel shall be vigilant in identifying the symptoms of sunburn in themselves or their co-
workers, and shall take appropriate measures to protect themselves from the sun's radiation.

Dust

Personnel shall not be exposed to levels of dust or Man Made Mineral Fibres (MMMF) in air in
excess.

MMMF include those fibres that are manufactured from natural rock or other materials, readily
melted slags, glass or metallic oxide fibres. They can be classified into four groups:
 insulation wools
 refractory or ceramic fibres
 continuous filament fibres
 special purpose fibres

Exposure shall be controlled considering the following hierarchy:

 Use engineering principles of enclosure, isolation, local exhaust ventilation and wet
techniques
 Provision of respiratory protective equipment.

Chemicals

A wide range of chemicals are used in the Petroleum industry. Chemicals of particular concern,
with respect to management of health hazards, are those which:
 cause irreversible harmful effects (e.g. carcinogens)
 are absorbed through the lungs or skin
 have an exposure response relationship which is ill defined
 have stringent occupational exposure limits (OELs)
 have poor warning properties
 are volatile

Benzene

Benzene is a component of many crude oils and has been detected in condensates. Prolonged
and repeated exposure to benzene has been associated with the development of leukaemia.

The benzene content of process streams shall be measured. The use of pure benzene is not
permitted.

Hydrogen Sulphide (H2S)

H2S is a highly toxic gas. Brief exposure to high concentrations of H2S can cause rapid
unconsciousness without warning symptoms. Death due to respiratory paralysis may follow within
a few minutes.

At low concentrations H2S has the odor of rotten eggs. At high concentrations, however, the odor
is not detectable due to rapid paralysis of the sense of smell.
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H2S exposure shall be managed in accordance with Industry Standard.

Personal H2S monitors shall:

 Be tested and approved for use in hazardous areas
 Be tested and certified for the detection of H2S in ambient air temperature conditions
from 0oC to 55oC
 Cover a range of 0-50 ppm with a continuous read-out
 Sound an audible alarm at 10 ppm
 Be provided with a reliable field calibration kit and calibrated at least once per day, or
once per shift
 Be maintained and/or repaired by technicians trained and certified by the manufacturer,
or the manufacturer’s appointed agent

Paints and Coatings

Many paints, solvents, thinner and stripping fluids contain hazardous chemicals which give off
toxic vapors which will cause dizziness, nausea, eye and nose irritation, and if allowed to become
concentrated by inadequate ventilation, may lead to more severe symptoms such as
unconsciousness, vomiting or bronchitis.

Certain paints may contain heavy metals, which are highly toxic (e.g. lead, mercuric oxides).
These are not now common, but may be encountered when stripping old equipment.

Although few paints and coatings are corrosives or particularly irritant to the skin, contact
dermatitis is a frequent result of insufficient protection, particularly if paint thinners or solvents are
used for skin cleaning.

Water-based paints/coatings shall be selected in preference to solvent-based paints/coatings,

whenever practicable to do so.

The following precautionary measures shall be implemented, particularly if solvent-based paints /

coatings have to be used.
 Self-contained breathing apparatus shall be worn when painting in confined spaces.
 Respiratory protection shall be worn when spray painting, unless specific exhaust
ventilation systems are in place
 Goggles, overalls and impermeable gloves shall be worn when handling or mixing
products
 Long-sleeved and long-legged clothing shall be worn

Other control measures shall include:

 The airflow from behind the operator shall be maintained at a minimum of 1.5 m/s
 Paint spray equipment shall be regularly maintained, and users trained to use it correctly
 Solvents shall not be used for cleaning the skin, and appropriate skin cleansers shall be
provided

During the work over operation, pollution to the environment or surroundings exists. A spill
prevention procedure will be developed to describe the activities to avoid spillage and gives
general guidelines on responding to spill.

Spills Cleanup and Storage

Minor Spills

 Minor spills typically involve small quantities of oil, gasoline, paint, etc., which can be
controlled by the first responder at the discovery of the spill.
 Use absorbent materials on small spills rather than hosing down or burying the spill.
 Remove the absorbent materials promptly and dispose of properly.
 The practice commonly followed for a minor spill is:
 Contain the spread of the spill.
 Recover spilled materials.
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 Clean the contaminated area and/or properly dispose of contaminated materials.

Semi-Significant Spills

 Semi-significant spills still can be controlled by the first responder along with the aid of
other personnel. This response may require the cessation of all other activities.
 Clean up spills immediately:
 Notify the EOFS Project Team and Company man on site immediately.
 Contain spread of the spill.
 If the spill occurs on paved or impermeable surfaces, clean up using "dry" methods
(absorbent materials, cat litter and/or rags). Contain the spill by encircling with absorbent
materials and do not let the spill spread widely.
 If the spill occurs in dirt areas, immediately contain the spill by constructing an earthen
dike. Dig up and properly dispose of contaminated soil.
 If the spill occurs during rain, cover spill with tarps or other material to prevent
contaminating runoff.

Significant/Hazardous Spills

 For significant or hazardous spills that cannot be controlled by personnel in the immediate
vicinity, the following steps shall be taken:
 Notify the EOFS Project Team and Company man on site immediately and follow up with
a written report.
 Notify the local emergency response. All emergency phone numbers would be available
at the worksite.
 Notification shall first be made by telephone and followed up with a written report.
 The services of spills shall be obtained immediately. Work over personnel shall not
attempt to clean up the spill until the appropriate and qualified staff have arrived at the job
site.
 Other agencies which may need to be consulted include, but are not limited to, the Local
Fire Department, the City Police Department, Division of Oil and Gas Producer, etc.

Vehicle and Equipment Maintenance

If maintenance on site, use a designated area and a secondary containment, located away from
drainage courses, to prevent the runoff of spills.
Regularly inspect onsite vehicles and equipment for leaks and repair immediately.
Check incoming vehicles and equipment (including delivery trucks, and employee and
subcontractor vehicles) for leaking oil and fluids. Do not allow leaking vehicles or equipment on
site.
Always use secondary containment, such as a drain pan or drop cloth, to catch spills or leaks
when removing or changing fluids.
Place drip pans or absorbent materials under paving equipment when not in use.
Use absorbent materials on small spills rather than hosing down or burying the spill.
Remove the absorbent materials promptly and dispose of properly.
Promptly transfer used fluids to the proper waste or recycling drums. Don’t leave full drip pans or
other open containers lying around.
Oil filters disposed of in trashcans or dumpsters can leak oil and pollute weather water. Place the
oil filter in a funnel over a waste oil-recycling drum to drain excess oil before disposal.
Oil filters can also be recycled. Ask the oil supplier or recycler about recycling oil filters if available.
Store cracked batteries in a non-leaking secondary container. Do this with all cracked batteries
even if you think all the acid has drained out. If you drop a battery, treat it as if it is cracked. Put it
into the containment area until you are sure it is not leaking.

Vehicle and Equipment Fueling

If fueling on site, use designate areas, located away from drainage courses, to prevent the runoff
of spills. Discourage “topping off” of fuel tanks. Always use secondary containment, such as a
drain pan, when fueling to catch spills/ leaks. The fuelling operation should be allowed by RM or
Base Manager ahead.

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General Measures

To the extent that the work can be accomplished safely, spills of oil, petroleum products,
substances and sanitary and septic wastes should be contained and cleaned up immediately.
Store hazardous materials and wastes in covered containers and protect from vandalism.
Place a stockpile of spill cleanup materials where it will be readily accessible.
Train employees in spill prevention and cleanup.
Designate responsible individuals to oversee and enforce control measures.
Spills should be covered and protected from weather water run-on during rainfall to the extent that
it doesn’t compromise clean up activities.
Do not bury or wash spills with water.
Do not allow water used for cleaning and decontamination to enter drains or watercourses. Collect
and dispose of contaminated water in accordance with Waste Management.
Place proper storage, cleanup, and spill reporting instructions for hazardous materials stored or
used on the project site in an open, conspicuous, and accessible location.
Keep waste storage areas clean, well organized, and equipped with ample cleanup supplies as
appropriate for the materials being stored. Perimeter controls, containment structures, covers, and
liners should be repaired or replaced as needed to maintain proper function.

6.3 Audit and Compliance

6.3.1 Introduction and Scope

Auditing is seen as an important management tool to check the quality and

comprehensiveness of the business controls in the company or with sub-contractors. This
section is mandatory with regards to HSE audits to be conducted on EOFS Garraf operations.

6.3.2 Responsibilities

Project Manager
Project Manager is the executive leader of the audit and is responsible for the organization and
coordination of audit activities. Project manager shall provide competent staff and verify that
adequate HSE audits are conducted to give the required assurance that HSE-MS requirements
are met.

HSE Manager
HSE manager shall prepare the annual HSE audit program with input from others, and be
responsible for the planning and implementation organization of the audit for related elements, the
special audit and the professional audit of HSE management system, and also responsible for
follow-up tracking and verification.

Other Line Managers

Other line managers shall ensure compliance with the requirements of this procedure by
developing and implementing audit plans and providing follow-up and close out of audit
recommendations. Participates and cooperates with the audit for related elements of HSE system,
organizes the professional audit and the special audit in accordance with the business division,
conducts the cause analysis to the non-conformance found in the audit, develops and implements
corrective and preventive measures.

Rig Manager
Rig manager shall implement audit recommendations, particularly when assigned actions for
support for follow-up and close-out.

6.3.3 Audit Procedure

The hierarchy of HSE audits and inspections is illustrated in the diagram below.

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Corporate HSE audits (Level 1) shall be carried out to assess the appropriateness and
effectiveness of HSE-MS, as applied at the asset level.

Asset-level HSE audits (Level 2) shall be carried out within individual assets to assess compliance
with HSE-MS.

Task verification and workplace inspections (Level 3) supplement the formal HSE management
audit process. These activities are described in various project control documentation and shall
not be discussed further in this procedure.

EOFS believes that the following Audit processes are adequate for its purposes and needs:

Unsafe Act/Unsafe Condition Audit

EOFS/GWDC Unsafe Act / Unsafe Condition Audit is in place. As a fundamental employment

condition, all personnel are obliged to report all unsafe acts and unsafe conditions which occur on
work site. The Unsafe Acts and Unsafe Conditions are collated, analyzed and reported on a
quarterly basis, Trends, areas of concern, action points, action parties, and target dates for
completion are established.

Internal Operations Audit

Internal Operation Audits are scheduled throughout the year. The frequency is quarterly. Audit
reports with Action points, Action parties, and Target Dates are recorded in the Monthly Review
until such time as the Action Points are closed out.

External Operations Audit

Section covers external audits in Project, including review and audit in Companies where EOFS
Garraf Project has contractual rights, excluding audits carried out by external auditors. No matter
the procedure or the plan, the periodically audit and review should be taken.

Audits of the overall HSE Management System

During the operation in Iraq, the Management would be alterable based on the seven elements,
any details or substructure change would be considered and updated.

Audits of Maintenance, inspection and certification

Camp and rig site work as the base of operation and related activities, its function should be kept
at a effect level. For example at the first stage of construction, related certification would be
available. E.g. the permission from local and related party for the camp construction, the
monogram of accommodation OEM, the catering service health card, etc.

Site inspection would be carried out weekly according to checklist from Project HSE Team, any
fault or shortcomings should be record and corrected.
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Audits of Service suppliers' compliance with EOFS HSE requirements

Periodically audit the service suppliers' and reinforce the communication for promote the service
level.

Audits of training plans

Periodically audit the training effectiveness and alter it according to real condition.

Inspections of WORKSITES, work activities and support facilities

Periodically audit and alter it according to real condition.

Lifting operation

A document describes recommended practices and recommendations for all mechanical lifting
operations in rig site in order to minimize the associated risk. Refers to lifting Procedure in detail.

Fire fighting response

A document describes recommended practices and procedures for fire prevention and control and
fire prevention. Any change of condition, the detail should be alternated according to the reality.

Competency assurance

RELATED PERSONNEL in trades or disciplines where recognized industrial qualifications exist

(e.g. crane operators, forklift operators, and welders, etc) shall possess a current certification of
qualification.

EOFS would make effort to take action on it, the scope of that shall cover as a minimum:
 all trade/discipline skills engaged in the provision of the WORK.
 clear definition of the minimum level of specific knowledge and skills required for each
position.
 for each individual, a measure of their current knowledge and skills.
 for each individual, the preparation and implementation of a knowledge and skills.
 development program to take them up to and beyond that minimum defined for their
 position.
 testing of individuals by personnel qualified to undertake such testing to verify that.
 knowledge and skills have been effectively acquired and are being implemented in the
work place.
 recording of all competency assurance activities in an auditable manner.
 monitoring of the competency assurance program.
 recognized industrial qualifications for all trades/disciplines to be established.

6.3.4 Management Review and Improvement

The following processes are in place:

 Project performance is reviewed by comparing the actual operational phase times and
overall well performances in days against programmed times based on past wells.
 Equipment performance is reviewed by analyzing rig downtime on monthly basis, periodic
reporting and is guided by Quality Policy.
 Safety performance is reviewed against company objectives as stated in the EOFS
Garraf Project Annual HSE Schedule.
 The Internal Auditing described above is reviewed by EOFS Garraf Project Management
line staff on a 6 months basis.

The review program is structured to involve EOFS Garraf Project entire line management:
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 Front line Supervisors (Drillers, Mechanics)

 EOFS Garraf Project Sub-contractor and Third Party Contractor Supervisor.
 Rig Manager/ Tool pusher / Site HSE Supervisor
 HSE Manager
 Area Management
 Corporate Management

To monitor performance first hand, EOFS Garraf Project Top Management members make a field
visit once per month at least. Department Management members make a field visit twice per week
at least.

6.4 Certification

Rig GW-52 is constructed in accordance with the standards described in Part 3 of the HSE Case.

Additional equipment manufactured at the rig site will require appropriate certification prior to use,
e.g. pressure vessels and lifting equipment/padeyes. It is the responsibility of the Rig Manager to
ensure that any such additional equipment is fit for purpose and safe to use prior to entering
service.

All lifting equipment (i.e. slings, harnesses, shackles, etc.) will be inspected and certified prior to
use. Fixed equipment will be re-certified annually for continued use, slings etc. will be re-certified
on a six monthly basis. Details will be contained in the Rig GW 52 lifting equipment register. It will
be the responsibility of the Rig Manager to ensure that all sub-contractor lifting equipment is
provided with equivalent lifting registers.

Appendix 1: Monitoring/Inspection Program

Appendix 2: HSE Performance Tracking Sheet

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