ADCO Procedure For Preparation of Project HSE Plan

ABU DHABI COMPANY FOR ONSHORE OIL OPERATIONS
PROCEDURE FOR PREPARATION OF
PROJECT HEALTH, SAFETY AND ENVIRONMENTAL (HSE) PLANS

ABU DHABI COMPANY FOR ONSHORE OIL OPERATIONS (ADCO)
Procedure for Preparation of Project HSE Plans
PREPARED BY:
Title Signature
Senior Safety Advisor (Technical)
REVIEWED BY:
Title Signature
Head of Technical Safety
Engineering & Major Projects Manager
APPROVED BY:
Title Signature
Safety and Environment Manager
Rev 1
Page 2
REVISION RECORD
Rev Date Originator Reviewed Approved Description
Rev 1
Page 3
CONTENTS
Page
1.0 Introduction
2.0 Scope and Timing
3.0 Objectives
4.0 Organisation and Responsibilities
5.0 Framework
6.0 General Requirements
6.1 Contractual Provisions
6.2 Project Health, Safety & Environmental Reviews (PHSERs)
6.3 Environmental Protection
6.4 Health
6.5 Hazard Identification and Risk Assessment
6.6 HSE Coordination Meetings
6.7 Safety of Office Personnel
7.0 Requirements for Engineering Design
7.1 General
7.2 HSE Studies
7.3 PHSERs (Stages 1,2,3)
7.4 HSE Philosophy
7.5 Project HSE Dossier
Rev 1
Page 4
7.6 Operating Manuals
8.0 Requirements for Construction
8.1 HSE Meetings
8.2 Contractor HSE Plans
8.3 HSE Inspections/Audits
8.4 Accident/Incident Reporting and Investigation
8.5 PHSER (Stage 4)
8.6 Permit To Work System
8.7 HSEInduction/Training
8.8 Accommodation / Catering
9.0 Requirements for Commissioning
APPENDICES
Appendix 1 Definition of Terms
Appendix 2 Project HSE Plan (Typical)
Appendix 3 HSE Plan - General Implementation Requirement
Appendix 4 HSE - related Activity / Deliverable Checklist
Appendix 5 References
1.0 INTRODUCTION
Rev 1
Page 5
The Project Health, Safety and Environmental (HSE) Plan (hereinafter called “The
Plan”) is the mechanism used to ensure that all HSE requirements during the
development of a Project are specified. This formal technique will ensure that the
Project HSE Philosophy is followed and that ADCO’s specific health, safety and
environmental requirements are met.
This document provides guidance to projects on the scope and application of Project
HSE Plans.
2.0 SCOPE AND TIMING
The Plan applies to all phases of a Project development until handover to the end user
and addresses both general and phase specific activities.
The Plan shall be issued at the Pre-project phase and should be formally reissued prior
to the commencement of each phase of development, when a closer definition of HSE
requirements has been established. In particular, the plan should be revised and re-
issued before the start of Basic Engineering and Detailed Engineering. The Plan may
be updated at any stage of the Project.
The Plan will provide a focus for the programme defining when HSE activities
shall be performed and the deliverables needed to satisfy the Plan.
A Plan shall be prepared for all medium to large projects. The requirement for Plans
for small projects may be waived at the discretion of Engineering and Major Projects
Manager.
While the preparation of a formal Plan may not be necessary for small Projects, the
general principles contained within this document shall still apply. In particular, all
projects shall address the requirement for HSE related deliverables and activities
referred to in Appendix 4.
Rev 1
Page 6
3.0 OBJECTIVES
The principal objectives of the Plan are to provide a framework in order to:
• Fulfill the requirements of ADCOs HSE policy and any specific HSE items
identified by the Project.
• Specify the main HSE procedures, codes of practice and standards to be applied
during the various phases of the Project.
• Identify and define the specific HSE studies which shall be undertaken.
• Specify the HSE reviews/audits which shall be performed.
• Define the contractual HSE management arrangements which shall be applied.
• Define the occupational health/hygiene requirements for the project.
• Define when the above activities should be performed.
Rev 1
Page 7
4.0 ORGANISATION AND RESPONSIBILITIES
The Project Manager/Team Leader shall have responsibility for preparing the Plan and
for monitoring its implementation and effectiveness. He shall also be responsible for
updating the Plan.
Key Project staff may be assigned the responsibility for implementing the activities
included in the Plan, but the Project Manager/Team Leader shall retain ultimate
responsibility.
Where appropriate, the assigned Project staff will be responsible for arranging
specialist advice and assistance to carry out activities. Specialist advice may be
provided by other ADCO Departments or by external consultants, where ADCO does
not have the in-house expertise.
The Project Manager/Team Leader shall consider the requirement for full-time or part-
time safety and/or environmental specialists within the Project organization during the
design, construction and commissioning phases.
Rev 1
Page 8
5.0 FRAMEWORK
The main HSE requirements to be addressed during preparation of the Plan for each phase of
the Project are described in detail in the following sections 6.0, 7.0, 8.0, and 9.0.
A list of typical HSE related activities and their possible phasing is given in Appendix 2. The
list is given as an example only, the actual requirement and phasing of HSE-related
activities shall be considered by each Project during preparation of the Plan.
It is recommended that Projects prepare the Plan in the form given in Appendix 3,
defining the main tasks/activities to be performed and responsibilities and timing of each
activity.
Rev 1
Page 9
6.0 GENERAL REQUIREMENTS
This section of the Plan specifies the essential HSE requirements which are applicable
to all phases of a Project.
6.1 Contractual Provisions
6.1.1 The Plan shall include provision for ensuring that all contracts include health, safety
and environmental requirements which are fully compatible with ADCO standards
and practices.
6.1.2 The Project shall ensure that relevant HSE related ADNOC/ADCO Standards, Codes
of Practice and International Standards are specifically identified in the tender
invitation/contract and that an order of precedence of requirement is clearly identified.
6.1.3 All Tender Invitations shall include provision for appropriate HSE related deliverables
and activities to be prepared by the Contractor or carried out during the period of the
Contract. A typical list of deliverables/activities is shown in Appendix 4.
6.1.4 All Tender Invitations shall include the requirement for the Contractor to provide HSE
Plans covering the complete scope of the Contract.
6.1.5 The Plan shall also include provision for confirming that, prior to award of a Contract,
the Contractor has fully addressed the detailed HSE requirements of the tender
inquiry. This will normally be accomplished by carrying out a comprehensive
assessment of each bidder’s HSE proposals, as part of the technical evaluation of bids.
6.1.6 It shall be a requirement of all Contracts that the Contractor carries out his own HSE
audits on design or construction contracts, at prescribed intervals. In addition, ADCO
will carry out PHSERs and audits of the Contractor.
Rev 1
Page 10
6.2 Project Health, Safety & Environmental Reviews (PHSERs)
The Plan shall include provision for PHSERs at appropriate stages of the Project in
accordance with ADCO document titled “Procedure for Implementation of PHSERs.
6.3 Environmental Protection
The Plan shall, where applicable, include provision for surveys, studies and
monitoring to ensure that the environmental effects of the Project have been fully
considered.
Activities related to environmental effects include the following:

• Environmental impact assessment.
• Environmental baseline survey.
• Environmental monitoring requirements.
Environmental protection activities should be conducted in accordance with ADCO

document No. EP. 30.99.90.014 titled “Strategy/Procedure for Conducting Safety
Studies”.
6.4 Health
Medical facilities and health standards required during the construction and
operational phases shall be addressed in the Plan.
The following areas should be considered:

• Medical fitness requirements.
• Medical facilities.
• Occupational health and hygiene.
6.5 Hazard Identification and Risk Assessment
The Plan shall include provision for appropriate studies to ensure that all potential
hazards are identified and evaluated.
Further details on the type and scope of safety studies to be conducted during
engineering design are provided in ADCO document No. EP.30.99.90.014 titled
“Strategy Procedure for Conducting Safety Studies” (to be issued).
These studies may include the following:

• HAZOP Studies
• QRA/HAZAN Studies.
• Risk Management.
Rev 1
Page 11
6.6 HSE Co-ordination Meetings
During the course of a Project, regular meetings shall be held to review the
implementation, monitoring, control and updating of the Plan.
The meetings should be chaired by the Project Manager/Team Leader with appropriate
representation from design, construction, HSE and operations disciplines.
The Plan shall define the purpose and frequency of HSE Meetings.
6.7 Safety of Office Personnel
Offices to be used by ADCO and Contractor Project personnel shall be pre-selected to

ensure that only buildings which meet the basic safety requirements are be used.
The Plan shall define the safety requirements for office buildings.
These requirements include the following:

• Suitable escape routes.
• Medical Facilities.
• Fire Detection/Protection.
Rev 1
Page 12
7.0 REQUIREMENTS FOR ENGINEERING DESIGN
The Engineering Design stages of the Project will include all aspects of conceptual design,
basic engineering design and detailed engineering design.
7.1 General
HSE-related design matters shall be addressed in sufficient detail in the early stages of
the Project. The majority of such work will be carried out by the design group, with
input and comment by safety and operations engineers.
It will be the responsibility of appropriate Project personnel to involve the HSE

disciplines in matters which have a health, safety or environmental implication.
7.2 HSE Studies
The Plan shall include requirements and responsibilities for implementation of HSE
studies during the engineering stages of the Project. For further details refer to ADCO
document No. EP.30.99.90.014 titled “Strategy/Procedure for Conducting Safety
Studies” (to be issued).
7.3 HSE Impact Assessments
The ADNOC Health, Safety & Environmental Impact Assessment (HSEIA)

Guidelines impose a requirement for ADCO to assess all projects to identify the need
for and, where necessary, to conduct independent HSEIAs of the projects.
Formal assessments of potential HSE impacts of projects, and where necessary,

independent HSEIAs shall be included as planned activities in the HSE Plan.
7.4 PHSERs (Stages 1,2,3)
The Plan shall define the scope and timing of the PHSERs (Stages 1,2,3,) to be
conducted during the engineering design phase in accordance with ADCO document
titled “Procedure for Implementation for PHSERs” (to be issued).
7.5 HSE Philosophy
The Plan shall include requirements and responsibilities for preparation and issue of a
HSE Philosophy document specific to the Project, identifying the HSE engineering
facilities and systems requirements.
Rev 1
Page 13
The HSE Philosophy document may be used as a basis for more detailed development of
design HSE criteria by the design contractor and should include the following HSE
related design considerations, as applicable:
• Layout and Access

• Escape Routes
• Communication
• Fire, Gas and Smoke Detection
• Emergency Shut Down Provisions
• Hazardous Area Classification
• Fire Protection (Active/Passive)
• Over Pressure Protection
• Equipment Identification
• Maintenance Considerations
• Lifting and Mechanical Handling
• Hydrogen Sulphide
• Storage and Handling of Hazardous Material and Chemicals
• Accommodation
• Ventilation
• Drainage
• Emergency Power
• Noise
• Environmental Protection.
7.6 Project Safety Dossier
A Project HSE Dossier detailing the reasoning and justification for all HSE related
decisions taken during the Project shall be established (an audit trail), and kept up to
date for inclusion in the final project handover documentation.
The requirement and responsibility for maintenance of the Project HSE Dossier shall
be defined in the Plan.
The topics to be included in the Safety Dossier will vary from project to project but
may include the following:
• HSE Impact Assessment Action items

• Safety-related design considerations
• HAZOP/HAZAN Studies
• PHSERs
• Environmental Issues
• Health.
Rev 1
Page 14
7.7 Operating Manuals
The requirement and responsibility for preparation of all manuals and procedures
required for pre-commissioning, commissioning, start-up, operating and maintenance,
and emergency conditions shall be addressed in the Plan.
Rev 1
Page 15
8.0 REQUIREMENTS FOR CONSTRUCTION
The construction phase of the Project shall include procurement, fabrication and
construction.
The Plan shall address the Project requirements and responsibilities for ensuring that
Contractors have the necessary safety standards set by ADCO and for confirming
compliance with those standards.
8.1 HSE Meetings
The Plan shall include requirements for HSE meetings to be held with contractors
during the construction phase. HSE meetings will include formal and informal (“tool-
box”) sessions.
8.2 Contractor HSE Plans
The Plan shall include the ADCO Project requirements and responsibilities for
assessing construction contractors’ HSE plans and site safety procedures (pre-contract
award).
8.3 HSE Inspections/Audits
The Plan shall include any requirements for HSE inspections and audits to ensure that
Contractors are fulfilling their HSE plans agreed at the commencement of their
contracts.
8.4 Accident/Incident Reporting and Investigation
The Plan shall include Project responsibilities for reporting and investigation of all
accidents, incidents and near-misses in accordance with ADCO’s HSE Policy
(Procedures Manual, Volume 10).
8.5 PHSER (Stage 4)
The Plan shall define any requirements for a Project Safety Review (Stage 4) to be
conducted during the construction stage.
8.6 Permit to Work System
The Plan shall address permit co-ordination procedures and the Permit to Work
System.
Rev 1
Page 16
It is important that responsibilities associated with permit coordination include all

interfaces between construction, commissioning and existing operations.
8.7 Safety Induction/Training
The Plan shall include all requirements and responsibilities for development of a
programme of ADCO managerial, supervisory and employee induction, HSE and
skills training.
(Contractors’ HSE Plans shall will include requirements for induction/safety training
of their own and sub-contractors’ personnel).
8.8 Accommodation/Catering
The Plan shall include provision for ensuring contractors’ compliance with ADCO
requirements for accommodation, catering and welfare standards.
Methods of checking/ensuring contractors’ compliance include reviews of contractors’

proposals for accommodation/catering during bid evaluation and also audits of camp
standards after contract award.
Rev 1
Page 17
9.0 REQUIREMENTS FOR COMMISSIONING
The commissioning stages of the Project will include pre-commissioning,

commissioning, start-up and handover to the end-user.
The Plan shall include all HSE related procedures and requirements for the
commissioning stages.
Responsibilities for activities during the commissioning phase shall be defined in the
Plan so that all personnel are aware of their responsibilities for health and safety of
ADCO and Contractors’ personnel.
Typically, the Plan shall include the following activities associated with the
commissioning phase:
• Training of commissioning/operations personnel.
• Commissioning Co-ordination Procedures.
• Operating and Emergency Procedures.
• Pre-start-up Audit (PHSER5).
Note: Responsibility for some activities during the commissioning phase may lie with the
end-user e.g. training. However, they should be included in the Plan to ensure they are
completed by the appropriate time.
Rev 1
Page 18
APPENDIX I
DEFINITION OF TERMS
1. General
Within this document Health, Safety and the Environment are deemed to mean the
following:
Health - Freedom from disease, other chronic disability or nuisance

arising from ADCO activities.
Safety - The absence of injury to people, or physical damage to assets

both inside and outside a facility, as a result of ADCO activities
where the word “Safety“ is used this should also be taken to
mean “Health” and “Environment” where applicable.
Environment - The absence of harm to human and natural resources inside and
outside the facility and the minimization of degradation of air,
water, groundwater and land as a result of ADCO activities.
2. Pre-Project Phase
The conceptual (feasibility) stage of proposed development, generally during preparation

of Project Identification Document (PID) and Terms of Reference (TOR).
3. Project Phase
The stages of a project development from basic design through to commissioning, after
formation of an engineering team.
4. Project Health, Safety & Environmental Reviews (PHSERs)
A stagewise audit of the health, safety and environmental aspects of a project from
conception to post-commissioning (including construction activities) in order to
determine any shortcomings or non-compliance with standards.
5. Health, Safety & Environmental Impact Assessment (HSEIA)
A stagewise independent assessment of the HSE impacts and risks associated with new
and/or existing facilities (refer to ADNOC Guidelines for HSEIA’s)
6. Hazard & Operating Study (HAZOP)
Rev 1
Page 19
A systematic procedure for identifying the hazards and operability problems of a facility
which could arise under abnormal operating conditions.
7. Hazard Analysis (HAZAN)
A quantitative method for assessing the hazard inherent in a facility where hazard is
defined as the product of the consequences of an event and the likelihood of that event
occurring. The method permits the ranking of hazards and can also be extended to the
cost-benefit analysis of precautionary or remedial measures.
8. Quantified Risk Assessment (QRA)
The quantitative evaluation of the likelihood of undesired events and the likelihood of
harm or damage being cause together with the value judgments made concerning the
significance of the results.
9. Quality Assurance/Quality Control (QA/QC)
All the systematic actions that are necessary during a project to ensure that the required
quality is specified, obtained and maintained.
10. Project HSE Plan
The planned HSE documentation and activities requirements at each stage of the Project
and operation of the facilities.
Within this document the Project HSE Plan is referred to as the “Plan”.
11. HSE Screening Study
A preliminary study at the conceptual or feasibility stage to determine any possible major
health, safety or environmental hazards associated with the scheme.
12. HSE Philosophy
A document identifying the basic requirements of the safety engineering facilities and
systems which is used as a basis for more detailed development of design safety criteria
and safety related deliverables.
13. Project HSE Dossier
Rev 1
Page 20
A record of all documentation on health, safety and environmental matters relating to the
Project.
14. Construction HSE Plan
A comprehensive plan indicating the HSE management and organizational techniques to

be used before and during the construction process, including the Health and Safety
element in tenders, and a system for the prequalification and selection of Contractors.
15. Modification Review
A periodic review to ensure that the HSE implications of design and construction
modification have been fully considered and that the necessary change control procedures
have been applied.
16. Commissioning Co-ordination Procedure
The procedure defining the interfaces and responsibilities of Project and Operations
personnel for handover and acceptance of systems to be commissioned.
Rev 1
Page 21
APPENDIX 2
PROJECT HEALTH SAFETY AND ENVIRONMENT PLAN (TYPICAL)
Rev 1
Page 22
APPENDIX 3
HSE PLAN
GENERAL IMPLEMENTATION REQUIRERMENT
Element Task Who? When? Status Comment

1. Organization and • Prepare, agree and issue HSE Plan
Responsibilities
• Assign HSE responsibilities to Project Staff
• Arrange specialist advice and assistance on

safety issues as required:
• ADCO departments
• External consultants
• Review requirement for HSE specialists [part

time or full time?]
2. Framework • Prepare a program of HSE related activities in

Plan format.
3. General requirements • Ensure all tender inquiry documents/contractors

include health, safety and environmental
requirements
3 (a) Contractual • Review all tenders to ensure HSE issues fully

Provisions addressed by bidders.
• Ensure major contractors include provision for

internal audits of design/construction.
• Include appropriate Codes and Standards in

tender inquiry/contract documents
3 (b) PHSERs • Review and agree PHSER program (number of
stages and timing).
• Prepare, agree and issue terms of reference for

PHSERs.
3 ( c) Environmental • Establish environmental protection program.

Protection • Baseline surveys
Requirements • EIA
• Environmental monitoring
• Noise
3 (d) Health • Establish medical fitness requirements of

personnel.
• Include provision for appropriate medical

facilities.
Establish occupational health and hygiene

requirements:
• Construction phase
• Operations phase
• Ensure accommodation and catering comply

with ADCO Standards.
Rev 1 Page 24

3 (e) Hazard identification • Prepare Hazop Program
• Identify possible QRA/Hazan studies.
• Develop procedure for storage and handling of

hazardous materials.
3 (f) HSE Co-ordination • Establish terms of reference/team membership

Meetings for HSE coordination meetings
• Prepare a program of meetings.
4. Requirements for • Prepare, agree and issue project specific HSE

Engineering Design philosophy document.
• Establish requirements for HSE Dossier and set

up procedures for inclusion of appropriate topics
• Establish requirements and responsibilities for

preparations of all manuals and procedures
• Operating
• Maintenance
• Pre-commissioning/Commissioning
• Emergency
• Carry out design PHSERs (1,2,3).
5. Requirements for • Establish program of joint HSE meetings with
Rev 1 Page 25

Construction contractors.
• Review all contractors’ Construction HSE Plans

and site safety procedures (pre-contract award).
Develop program of HSE inspections and audits of

contractors.
• Establish procedures for Permit To Work system
and permit co-ordinations.
• Set up training program for all project personnel

(including contractors’ personnel).
• Carry out Construction PHSER (Stage 4).
• Check contractors’ compliance with ADCO

accommodation/catering standards
6. Requirements for • Develop training program for commissioning/

Commissioning operations personnel.
• Prepare commissioning co-ordination

procedures.
• Carry out Pre-start up PHSER (Stage 5)
7. Requirements for • Carry out post-commissioning PHSER (Stage 6).

Operations
Rev 1 Page 26
APPENDIX 4
HSE-RELATED ACTIVITY/DELIVERABLE CHECKLIST

Deliverable Required Responsibility
Yes √ No x
Project HSE Plan
HSE Philosophy Document
PHSER Stage 1
PHSER Stage 2
PHSER Stage 3
PHSER Stage 4
PHSER Stage 5
PHSER Stage 6
Design HSE Criteria
Operating & Maintenance Philosophy
HVAC Philosophy
Control Philosophy
Communications Philosophy
Emergency Shutdown Philosophy
Fire Detection/Protection Philosophy
Relief, Blow Down and Flare Philosophy
Emergency Power Philosophy
Isolation Philosophy
Noise Control Philosophy
HSE Impact Assessment
Environmental Baseline Studies
Project HSE Dossier/HSE Register
HAZOP Studies
Fire and Gas Detection System Specification
Area Classification Drawings
Cause/Effect Diagrams (F&G/Process)
Fire Protection Specification (Active/Passive)
Relief Valve Specification
Lifting/Mechanical Handling Review
Fire and Explosion Assessment
HSE-RELATED ACTIVITY/DELIVERABLE CHECKLIST

Deliverable Required Responsibility
Yes √ No x
Gas Dispersion Analysis/Study
Radiation Analysis/Study
Safety Signs Drawings
Safety Layout Drawings
Escape Route Drawings
Simultaneous Operations Procedures
Construction HSE Plan
Pre-contract HSE Assessment
Construction Site Audits
Contractor HSE Plan
HSE Inspection Audits (Construction)
Contractor HSE Inspections
Emergency Procedures
Operating Procedures
Project Training Manual
Noise and Vibration Studies
Operations Manual
Reviewed By:…………………….. Job Title…………………………. Date……………

Approved By:……………………… Job Title…………………………. Date……………
Rev 1
Page 28
APPENDIX 5
REFERENCES
In this document reference is made to the following ADCO documents. The

latest issue of each document shall be used.
To be advised : Procedure for Implementation of PHSERs.
EP 30.99.90.014 : Strategy/Procedure for Conducting Safety Studies.
ADCO Procedure Manual Volume 10 (HSE)
Rev 1
Page 29

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ABU DHABI COMPANY FOR ONSHORE OIL OPERATIONS

PROCEDURE FOR PREPARATION OF

PROJECT HEALTH, SAFETY AND ENVIRONMENTAL (HSE) PLANS

Procedure for Preparation of Project HSE Plans

Senior Safety Advisor (Technical)

Head of Technical Safety

Engineering & Major Projects Manager

Safety and Environment Manager

Procedure for Preparation of Project HSE Plans

Rev Date Originator Reviewed Approved Description

Procedure for Preparation of Project HSE Plans

2.0 Scope and Timing

4.0 Organisation and Responsibilities

6.0 General Requirements

6.1 Contractual Provisions

6.2 Project Health, Safety & Environmental Reviews (PHSERs)

6.3 Environmental Protection

6.5 Hazard Identification and Risk Assessment

6.6 HSE Coordination Meetings

6.7 Safety of Office Personnel

7.0 Requirements for Engineering Design

7.2 HSE Studies

7.3 PHSERs (Stages 1,2,3)

7.4 HSE Philosophy

7.5 Project HSE Dossier

Procedure for Preparation of Project HSE Plans

7.6 Operating Manuals

8.0 Requirements for Construction

8.1 HSE Meetings

8.2 Contractor HSE Plans

8.3 HSE Inspections/Audits

8.4 Accident/Incident Reporting and Investigation

8.5 PHSER (Stage 4)

8.6 Permit To Work System

8.8 Accommodation / Catering

9.0 Requirements for Commissioning

Appendix 1 Definition of Terms

Appendix 2 Project HSE Plan (Typical)

Appendix 3 HSE Plan - General Implementation Requirement

Appendix 4 HSE - related Activity / Deliverable Checklist

Procedure for Preparation of Project HSE Plans

2.0 SCOPE AND TIMING

Procedure for Preparation of Project HSE Plans

• Specify the HSE reviews/audits which shall be performed.

• Define the contractual HSE management arrangements which shall be applied.

• Define the occupational health/hygiene requirements for the project.

• Define when the above activities should be performed.

Procedure for Preparation of Project HSE Plans

4.0 ORGANISATION AND RESPONSIBILITIES

Procedure for Preparation of Project HSE Plans

Procedure for Preparation of Project HSE Plans

6.0 GENERAL REQUIREMENTS

6.1 Contractual Provisions

Procedure for Preparation of Project HSE Plans

6.2 Project Health, Safety & Environmental Reviews (PHSERs)

6.3 Environmental Protection

Activities related to environmental effects include the following:

Environmental protection activities should be conducted in accordance with ADCO