Hse & Security Plan - SPDC - 21

KGG
KENT GERMAN GLOBAL (KGG) LTD
FOR: SERVICING & PROVING OF BULK OIL METER & CORIOLIS
CLIENT: SHELL PETROLEUM DEVELOPMENT COMPANY OF NIGERIA

LIMITED (SPDC)
OUR REF: KGG/SPDC/HSSE/001/21
LOCATION:
HSE, SECURITY PLAN & POLICIES
ACTION NAME DESIGNATION SIGNATURE

Prepared By Moses E. QHSE Coordinator
Reviewed By V.Onofua BDM
Approved By K.Odia CM
DOC. NAME: HSE, SECURITY & QUALITY REV NO: 0
PLAN DOC NO:
KGG KGG/SPDC/HSSE/001/21
PROJECT TITLE: FOR: SERVICING & PROVING DATE: 11th JAN.,21
OF BULK OIL METER &
CORIOLIS
AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 2 of 44
TABLE OF CONTENTS
S/N DESCRIPTION PAGE

1.0 Introduction
4
2.0 SSHE POLICY 5-13
2.2 Health, Safety and Environment Policy
2.3 Smoking, Drugs and Alcohol Policy
2.4 Transport Policy
2.5 Community Relations Policy
2.6 Waste Management Policy
2.7 Personal Protective Equipment (PPE) Policy
2.8 Incident and Near Miss Reporting Policy
2.9 Malaria Control Policy
3.0 SAFETY MANAGEMENT SYSTEM 14-24

3.1 Management Commitment
3.2 Responsibilities
3.2.1
Country Manager
3.2.2
Business Development Manager
3.2.3
3.2.4 QHSE Coordinator
3.3 All Employees
3.4 Training
3.5 Subcontractor Management
3.63. Regulatory Compliance
63.6 Emergency Preparedness and Response
3.7 Risk Management
3.8 Safety Performance Measurement and Reporting
3.9
Incident Management
4.0 HSE TOOLS 25-30

4.1 SSHE Performance Measurement and Reporting
4.2 Gap Closure and Follow-up
4.3 Safety Team
4.4 Safety Alerts/Bulletin
4.5 Hazard Identification
4.6 Permit to Work System
4.7 Job Safety Analysis
4.8 Step Back 5x5
4.9 Loss Prevention Observation (LPO)
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5.0 HSE MEETINGS 31-34

5.1 Safety Meetings
5.2 Kickoff Meeting
5.3 Toolbox meeting
5.4 SSHE Drills
5.5 Safety Stand Down
6.0 SAFETY PROGRAMS 35-38
6.1 Behavior-Based Safety
6.2 Hand and Power Tools
6.3 Personal Protective Equipment
6.4 Housekeeping
6.5 Safety Inspections/Walkthroughs
6.6 Management of Change
7.0 OCCUPATIONAL HEALTH MANAGEMENT 39-40
7.1 Exposure Monitoring
7.2 Noise
7.3 Fitness to Work and Fit Testing
7.4 Fatigue Management
7.5 TB Program
8.0 ENVIRONMENTAL PROGRAM 41
8.1 Waste Management
8.2 Spill Management
9.0 Personnel Competency 42

10.0 SECURITY PROGRAM 43
10.1 Security Plan
10.2 Community Relations Plan
11.0 TOOLS AND EQUIPMENT 44
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1.0 Introduction
1.1 Introductory Statement
SERVICING & PROVING OF BULK OIL METER & CORIOLIS is to be carried out by
KENT GERMAN GLOBAL (KGG) LIMITED, within the contract specified
duration. This HSE plan covers the incident prevention programs to be
employed during the project execution. All employees will abide by all the
rules in this plan including those prescribed by the client
KGG LIMITED recognizes and places importance on safety in the execution of

her projects. To ensure and manage safety effectively in all ramifications, these
objectives shall be sustained:
 Meet all relevant regulatory and legislative requirements.
 Manage all risk associated with its activities to as low as reasonably
practicable (ALARP)
 Sustain management commitment to Health and safety of its personnel
and third parties.
 Increase the level of HSE awareness and competency amongst employees.
 Minimize the impact of its operations on the environment.
 Maintain harmonious relationship with its host community
 Recognize HSE management as a line responsibility.
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2.0 POLICY
2.1 CASHES POLICY
It is our policy to carry out our operations in such a way that health and
safety of our employees and others who may be affected are safeguarded.
Safety awareness is of utmost importance to every staff in our company;
Accident prevention by observing safety rules and by creating a safe work
environment and applying safe work methods is expected of all employees. It
is essential that every staff have clear understanding of the fight and safe
way to do his job. By so doing, we can save others and ourselves from
accidents and also keep at a minimum the impact of our activities on
the environment.
KGG management shall on a continuous basis, exercise the responsibility
for the removal or otherwise rendering harmless operational hazards
through training and motivation. We will comply with the client work rules
and statutory regulations.
We would re-emphasize that each employee, at every level, is responsible for
adopting a positive attitude towards safety. As a company, KGG accepts
both its legal and moral obligations towards its work force and will continue
to maintain, to the best of its ability a safe health working environment for
all its employees.
Our commitment is to ensure that we maintain safe system of work, provide
training where required and competent supervision. It is incumbent on line
management and supervision to ensure that all personnel are aware of, and
adhere to our safety rules and regulations. Conversely we expect that every
employee will report unsafe act or unsafe conditions to their supervisor.
------------------------------------
KENNETH ODIA
Country Manager (Nigeria)
Rev: 0.1 KGG/HSE/13/17/02
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2.2 HEALTH, SAFETY AND ENVIRONMENT POLICY
Kent German Global shall in the course of carrying out her operations
 Ensure that lives of personnel and assets are protected and
preserved
 Protect the environment.
 Manage HSE matters as any other critical business activity.
 Promote a culture in which all Kent German Global employees
Share this commitment,
Ensure Safety, Protection of Health, and Security of her workers,
third parties, and Facilities.
------------------------------------
KENNETH ODIA
Rev: 0.1 KGG/HSE/58/17/02
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2.3 SMOKING, DRUGS AND ALCOHOL POLICY
Having recognized smoking as injurious to health and a fire hazard, it shall be
Kent German Global policy to
 Strongly discourage smoking
 Prohibit smoking in our premises and work areas.
The abuse of drugs and alcohol can be injurious to health and impair
performance at work.
It is therefore strictly prohibited:
 For any employee to be at work when under the influence of drugs and
alcohol.
 For any employees to possess, use, distribute or sell alcohol or illegal
drugs on company business or work location.
 Drug abuse and self-medication is strongly discouraged
------------------------------------
KENNETH ODIA
Rev: 0.1 KGG/HSE/17/17/02
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2.4 TRANSPORT POLICY
Transportation is an essential part of this business. Therefore all forms of
journey
(Air, land or marine) shall be well planned, and materials handling
equipment used on company business shall comply with the company
standards and shall be operated by authorized personnel.
Kent German Global Shall ensure that transport activities are managed as
an integral part of day-to-day activities.
All forms of air, land and marine transport and material handling
equipment shall be registered and audited before use. All policies on
journey management shall apply
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KENNETH ODIA
Rev: 0.1 KGG/HSE/15/17/02
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2.5 COMMUNITY RELATIONS POLICY
In order to pursue mutually beneficial relations with host communities,

Kent German Global shall:
 Establish and maintain close relationship with all segments of the host
communities to better understand their concerns, needs and aspirations.
 Respond to formal community request in an appropriate and timely
manner.
 Respect and preserve the customs, traditions and beliefs of the host
communities
 Maintain cordial relationship with host communities
 KENT GERMAN GLOBAL shall employ the services of local labour where
no technical expertise is required
 Organizes community Development programs for host communities.
 Assist host community in developmental projects.
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KENNETH ODIA
Rev: 0.1 KGG/HSE/20/17/02
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2.6 WASTE MANAGEMENT POLICY
Wastes are unavoidable materials resulting from an activity which has no
immediate economic demand and which must be disposed of.
It shall be the policy of Kent German Global to:
 Generate less waste through more efficient practices.
 Manage and dispose of such wastes in a statutory and environmentally
responsible manner.
 Minimize the potential to cause harm to human health and the
environment by handling waste materials generated in our operations
properly.
 Abide by all Statuary and legal requirements on waste management and
disposal –from Local, State and Federal authorities.
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KENNETH ODIA
Rev: 0.1 KGG/HSE/11/17/02
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2.7 PERSONAL PROTECTIVE EQUIPMENT (P.P.E) POLICY
It is the policy of KGG to provide relevant and high quality Personal

Protective Equipment: coveralls, safety shoes, hard hats, hand gloves etc for
all personnel engaged in her operations.
Continually, the management shall enforce the effective use and
maintenance of available Personal Protective Equipment, which entails
regular condition audits and replacement of defective ones.
Site(s) safety officers and supervisors shall continue to monitor
compliance with this policy.
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KENNETH ODIA
Rev: 0.1 KGG/HSE/09/17/02
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2.8 , INCIDENT AND NEAR MISS REPORTING POLICY
It is the Policy of KGG that all on-the-job incidents must be reported and
investigated. Accidents that must be reported include any incidents that
may cause minor or severe injuries or incidents that are results of
negligence or inadequate safety precautions. The victims may be employees
who were injured while performing their duties or other people that were on
company premises or vehicles.
Accidents must be reported as soon as possible to expedite investigation

and increase likelihood of important findings. The sooner the cause or
details of the accident are identified, the sooner the company can establish
preventative measures for the future.
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KENNETH ODIA
Rev: 0.1 KGG/HSE/59/17/02
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2.9 MALARIAL CONTROL POLICY
The KGG Malarial treatment policy aims to:
• Reduce morbidity,
• Halt the progression of uncomplicated disease into severe and potentially
fatal disease, and thereby reduce malaria mortality,
• Reduce the impact of placental malaria infection and maternal malaria-
associated anaemia through intermittent preventive treatment,
• Minimize the development of antimalarial drug resistance.
The KGG Antimalarial intervention strategy is in four key elements:
i. Personnel with malaria should have access to appropriate and adequate

treatment within 24 hours of the onset of symptoms
ii. Pregnant women particularly in their 1 and 2 pregnancies should
have access to effective antimalarial prophylaxis and treatment
iii. Insecticide treated nets and other materials should be available and
accessible to persons at risk of malaria.
iv. Epidemics of malaria should be recognized and steps initiated for their
containment within one week of their onset.
It is obvious that achieving the goal of this policy would require the
availability of appropriate antimalarial drugs and their proper management,
including storage and rational use.
KGG workforce shall be properly educated on malaria and its treatment;
thus, an effective monitoring and evaluation system shall be set up to
ensure that objectives are being properly pursued.
KENNETH ODIA
Rev: 0.1 KGG/HSE/60/17/02
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3.0 SAFETY MANAGEMENT SYSTEM
3.1 Management Commitment
It is generally believed that middle and low level managers, in particular,

influence safety at work as well as health and wellbeing of their
subordinates, we however at KGG believe the role of Chief Executive Officer
is crucial as well. Failure to include health and safety as a key business risk
in key decisions can have catastrophic results.
Senior managers give priority to health and safety at work and the extent to
which managers use their authority to promote compliance with
occupational health and safety rules and the respective policy within the
company motivates the individuals to orient their behavior on the standards
set by management.
Management is committed to:
 Worksite visits with the target to praise good occupational health and
safety approaches and to address unsafe behavior by encouraging
changes and looking at the causes for failure to follow the occupational
health and safety rules. These visits are also useful in providing
opportunities for employees to raise any health and safety issues.
 Regular attendance of health and safety meetings as well as regularly
including the health and safety representative in management meetings
 Starting with the topic occupational health and safety during team
meetings
 Active involvement in the investigation of accidents, near misses,
incidents and ill health
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3.2 Responsibilities
The safety requirements and critical activities in this plan shall be implemented
and supervised as described below.
3.2.1 Country Manager

 Directs and control all the activities of KENT GERMAN GLOBAL LIMITED
in accordance with the policies, strategies and objectives laid down;
 Supervises the company‟s organization and is responsible for appointing
and defining the tasks for the different functions;
 Implement the general policy laid down by the company in respect of
quality;
 Analyse quality cost in order to assess the adequacy and efficiency of the
company‟s quality management system and define the objective to be met
for continuous improvement.
In addition to these responsibilities he shall:
HSE Roles and Responsibility

 Overseas all HSE issues in the organization.
 Head investigation panel for middle level accident
 Provide budget for all HSE related requirements like PPE, Medicals and
Trainings.
 Administers consequence management for HSE violations.
 Initiates review panel report for HSE documentation
 Attend and chair monthly HSE meetings.
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3.2.2 Business Development Manager
 Assures and provides adequate resources and time to manage the

contract;
 Has an understanding of Client‟s guidelines for the monitoring of HSE in
contracts;
 Represents the company and maintains appropriate level of relationship
with the client representatives;
 Supervision and administration of all subcontracts;
 Define the objectives, identify the constraints and plan contract
activities;
 Define the contract organization structures;
 Supervise the application of the control system in order to ensure
achievement of time, cost and quality objectives;
 Ensures the periodic and final reporting of all activities;
.
3.2.3 QHSE COORDINATOR
The QHSE Coordinator shall be responsible for work carried out in accordance with
governing QHSE regulations and in-house standards.
His duties consist of, but not limited to:

 Preparation of HSE work plans and procedures;
 To make sure that all HSE precautionary measures are in place and also
to advise when necessary
 Be reasonable familiar with Client‟s HSE policies, document and
emergency procedures, particularly those relating to the work site, to
make sure that all HSE precautionary measures are in place and also to
advise when necessary;
 Liaison with HSE Personnel of the client in order to coordinate HSE of
Personnel and equipment;
 Collection and updating of statistical data relating to accident and
incident on site;
 Taken necessary step in order to ensure that all personnel comply with
HSE regulations
 Implement the quality assurance program;
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3.2.4 ALL EMPLOYEES
 Do nothing to endanger themselves or co-workers.

 Use the correct tools and equipment for all job.
 Keep tools in good condition.
 Use proper personal safety equipment provided at all times
 Spot and report all hazard
 Should be responsible for their own safety and the safety of others
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3.3 TRAINING
3.3.1 HSE Training
All staff carrying out specialized jobs shall have their certificates and full
awareness hazards related to their line of operation.
For example
Applicab
Evidence of Training (documentation

Description
on site)
le
Basic HSE  HSE Induction checklist & Attendance

Induction/Orientation
 Drill reports (man overboard, medevac,
Emergency Response
security, snake bite etc.)
PTW  PTW awareness training
Fall Protection Awareness training on work at height
 National Driving Licence/Defensive
Driver training/certification
driving awareness
PPE usage and  PPE training attendance list
maintenance
Hazard Identification and  Tool box talk, JHA and LFI cascade
Awareness
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3.4 Subcontractor Management
Subcontractors and subcontracting are not application for this project,

however, KENT GERMAN GLOBAL LIMITED has a documented policy
guideline that guides and controls the execution of all subcontracts within
the organization.
3.5 Regulatory Compliance
KGG LIMITED will ensure full compliance with all relevant legislation, both national and
International as well as industrial standard.
Below are examples of Nigerian National laws pertinent to “the Contract”
3.6.1 Health and Safety

 Labour Act, 1971
 Workmens Compensation Act, 1987
 Factories Act, 1987
 Trade Disputes Act, 1976
 Trade Unions Act, 1973
 Petroleum Regulations, 1967
 Mineral Oils (Safety) Regulations, 1963
 Gas Industry in Nigeria, Draft Regulations, 1989
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3.6 Emergency Preparedness and Response
Due to the nature of the project, there may be emergency situations, which could require
contingency planning, these include but not limited to:
 Fire incidence
 Medical emergency
 Security emergency
In the event of an emergency, a distinct site alarm will be sounded and all
workers must promptly move to the muster point. In the event of security, every
personnel are expected to take cover in the nearest safe haven or as would be
directed by Client‟s site emergency response procedure. The type of alarm and
position of the muster point will form part of the site induction.
3.6.1 Medivac
Medivac is the procedure used to transport victims of serious accidents or
sickness at the work sites or Yard/Accommodation areas. The related action
plans shall be posted in notice boards at the worksite, accommodation areas and
on vehicles. All employees shall be instructed with regard to Medivac condition
during HSE meetings and training sessions.
The communication system for Medivac cases will be by either radio or telephone
communications from site. As a minimum, the person communicating the
information should provide the following details (be brief, to the point, calm and
polite):
 Location of injured party

 Nature of illness or injury
 Cause of the illness or injury
 Name of injured or ill person
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 Condition of injured (unconscious, stretcher case, walking)

 Status of medical attention given on site
This information will be passed on to the Country Manager to enable him to make
contact with the client to initiate medevac arrangements
3.6.2 Fires
All personnel will be trained on Basic awareness for fire prevention. However, in
the event of a fire outbreak the initial steps are to raise the alarm and assess the
situation. The second step is to determine if the fire can be controlled using
equipment available (Fire extinguisher). If this is not possible personnel are
advised not to expose themselves to any risk of personal injury
.
3.7 Risk Management
The contract activity has the potential to create many risks. Care in managing
these risks protects both KGG and Client from loss.
All potential hazards related to “the Contract” will be identified and all related
risks analyzed. Job Safety Analysis will be prepared for each project task. KGG
will use the CLIENT Standards and Guidelines as a starting point for the Hazard
and Effect Management Process (HEMP) on “the Contract”. Additional hazards
may be identified as a result of:
 Experience from previous contracts

 Checklists developed from previous experience
 New legislation
 Revisions or changes to Codes and Standards
 Incident investigations and Near Miss reports
 Scheduled HSE Reviews
 Newly identified „Industry Best Practices‟
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All Supervisors and their subordinates have the duty to exercise continuous
control over potential hazards that may rise during the performance of daily
activities. Identified hazards and preventive measures shall be a topic of
discussion during the daily Toolbox meetings. All personnel shall report new
hazards and risks to their Supervisor who shall introduce immediate corrective
actions to eliminate the condition.
3.8 Safety Performance Measurement and Reporting

Safety performance measurements and reporting are essential requirement of HSE
management systems. It ensures the adequacy of the systems against established
requirements. KGG HSE system will be aligned to that of CLIENT in order to have
a common approach to HSE management and reporting. KGG will report to
CLIENT its safety performance in accordance with all CLIENT reporting criteria
and internally we will report using the guidelines contained in HSEMS.
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3.8.1 HSE Performance Monitoring Indicator
S/N Leading Indicators Plan Actual Lagging Indicators Plan Actual

1 Premob activities 100 Exposure Hours 8hrs
2 Adequate controls for 100% Fatalities 0
key hazards
3 Mobilization Activities 1/project Lost time Injuries 0
4 Management Field 1/Quarter High Risk Incidents 0
inspections
5 HSE 2/Annum Unsafe acts/unsafe 10/month
Audits/Inspections conditions
6 2/Quarter Community 0
Emergency Drills
Disturbance
7
Compliance to work 100% Man over board
procedures incidents 0
8 HSE Meetings 1/month Security incidents 0

9 Stop work exercised 100% Waste Generated 30kg/Month
3.9 Incident Management
It is our policy at KGG that all incidents must be reported and investigated thereby
identifying, analyzing, and correcting hazards to prevent a future re-occurrence.
3.10.1 Reporting Method

Accidents, injuries, illnesses and near misses are to be reported to the safety officer
3.10.2 Report Timing

All incident reports must be submitted within 24 hours of the incident. If full details of
the incident, injury, investigation and corrective actions are not available within this
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timeframe, the essential details of the incident or injury as they are known should be
submitted initially. Additional information, including details of supervisor investigation
and corrective actions, should be submitted via email to Country Manager
as soon as possible (within one week).
3.10.3 Accident Investigation

Reported accidents and incidents should be promptly investigated by the immediate
supervisor of the injured or ill person, or by the person in charge of the area where the
incident occurred. The investigation should identify the causes of the accident and assess
any hazards that need to be controlled. Supervisors should discuss the incident with
relevant staff and decide on suitable risk controls to be implemented. The investigation
and corrective actions are to be summarized in the Incident Report.
3.10.4 Importance Of Reporting

The reporting of incidents is essential for the identification of hazards in the workplace.
This should prompt remedial action to address the identified hazards and prevent any
recurrence of the incident.
"Near misses", incidents with potential for injury or damage should also be reported and
investigated. These incidents often serve as warnings that more serious consequences
could have resulted. Preventing recurrence is therefore still important.
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4.0 SSHE TOOLS
4.1 SSHE Performance Measurement and Reporting/KPI
Safety performance measurements and reporting are essential requirement of HSE

management systems. It ensures the adequacy of the systems against established
requirements. KGG HSE system will be aligned to that of CLIENT in order to have
a common approach to HSE management and reporting. KGG will report to
CLIENT its safety performance in accordance with all CLIENT reporting criteria
and internally we will report using the guidelines contained in HSEMS.
4.1.1 Measurement
The HSE performance shall be measured by means of the following leading and
lagging indicators as stated in table 3.9.1
4.2 Gap closure and follow-up
Scheduled internal audits and inspections would be undertaken during the course of this
contract execution; we are not unaware of Client‟s scheduled audit and inspection as well.
It is KGG standard that all identified gaps or non-conformance during these audits and
inspection should be closed out within the timeframe as specified in the Audit Report.
4.3 Safety Team
Our Health and Safety Committee (Safety team) meets every 2nd and 4th Monday of every
month with the sole objective to deliberate extensively on all issues related to Safety of
KGG and that of her Client where operation is ongoing. The standard remains the same in
this contract, all decision taken by our safety team to promote the health and safety of all
our personnel and client for the purpose of achieving GOAL ZERO would be communicated
through KGG site representative.
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4.4 Safety Alerts/bulletins
Safety alerts are issued when there is a specific safety issue that without immediate action
being taken could result in a serious or fatal injury. When dangerous equipment,
processes, procedures or substances are identified during risk assessment or after an
investigation, KENT GERMAN GLOBAL LIMITED will notify users and other stakeholders of
the danger. KGG will also notify users of the steps that need to be taken to rectify the fault
or protect people against it. We also ensure we cascade LFI (Learning from Incidence) to
our workforce from time to time. Safety alert is considered as one of the ways to achieving
GOAL ZERO.
4.5 Hazard Identification
Hazard is anything that has potential to cause injury, illness, equipment damage,
reputational damage and even fatality. KGG will ensure all hazards associated to
our operation will be identified, the associated risk will be assessed, and all
necessary control measures would be put in place to ensure ZERO incidents
during the execution of this project.
Below are some of the major hazards and controls procedure vis a vis work
instruction
Controls (standard,
Risk level procedure work
HAZARDS/RISK (L,M,H) instruction)
Mobilization (Transportation JHA Document, Journey
from KGG to Client facility) H Management plan
Pre-task investigation JHA Document, Work

activities (arrangement of M procedure, PTW
equipment & data collection)
JHA Document, Work

Equipment Lifting and set H procedure, PTW
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up
JHA Document, Work

Pressurization of Equipment H procedure, PTW
Venting JHA Document, Work

M procedure, PTW
Disconnections and M JHA Document, Work

housekeeping procedure, PTW
SEVERITY
1 2 3 4 5
LIKELIHOOD
2 4 6 8 10
3 6 9 12 15
4 8 15 16 20
5 10 18 20 25
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4.6 Permit to Work System
A permit to work (PTW) is a document signed by an authorised person(s) stating that a

non-routine job can be carried out under prescribed precaution. This must be obtained
before such operation could commence. The CLIENT “Work Permit” system shall be
applied on “the Contract”. The CLIENT “Work Permit” shall specify the condition under
which the works can be undertaken, with particular emphasis on the precautions to be
implemented. All personnel using the Permit to Work system or other controlling system
shall be trained by CLIENT prior to being authorized to use the system.
4.7 Job Safety Analysis
A job safety analysis (JSA) is a procedure which helps integrate accepted safety and
health principles and practices into a particular task or job operation. In JSA, each basic
step of the job is to identify potential hazards and to recommend the safest way to do the
job.
Below are the four basic steps we would deploy in conduction our JSA:
 Selecting the job to be analyzed

 Breaking the job down into a sequence of steps
 Identifying potential hazards
 Determining preventive measures to overcome these hazards
JSA will form part of the attachment to raise Permit to Work (PTW).
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4.8 Step Back 5x5
Whenever the activity involves appreciable risks or there is a change in work

condition/environment, move back 5 paces and invest 5 minutes to
 Observe the work area and surroundings

 Step through the job in your mind
 Think about what else is happening in the area- consider any possible change
 Identify and consider the hazards during the job
 Think what else can be done if something goes wrong
We would always ensure we apply 5x5 to all completed job to know if a new
hazard has been created.
4.9 Loss Prevention Observation (LPO)
LPO is a systematic method for observing a work process and determining if the job or
task is being performed according to standards (safety, quality, efficiency); making
recommendations to eliminate any discrepancies. The LPO evaluates both the activities
performed by the workers and the workplace conditions. The overall objective of the LPO
is to help maximize the efficiency (safety, quality, costs) of each task. This objective is
reached by elimination of losses or the respective costs that are associated with such
adverse events as personal injuries, equipment damage, and operational inefficiencies.
Below are steps involved in the development and use of loss prevention observation:
 Identification of target areas

 Development of LPO form
 Selection and training of observers
 Conducting the LPO
 Discussion of Results
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 Implementation of recommendations
 Verification and Validation
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5.0 SSHE Meetings
5.1 Safety Meetings
A safety meeting is an opportunity to discuss a specific safety and health topic in

an informal setting. It's intended to be participatory, encouraging questions and
discussion and drawing on workers' experience. It's not a lecture and there are no
tests.
The safety meeting will be short and it can be part of an existing staff or crew
meeting. Below should be taken into consideration during safety meeting
 Does this topic relate to your workplace? If not, choose another topic.
 Look up your company rules or policies about this topic.
 Find out about any accidents investigation report or learning from
incident related to this topic.
 Do not hand out copies of the Safety Tip until after the meeting. You
want workers to contribute their own ideas, not read off the sheet.
5.2 Kickoff Meeting
Kickoff meeting is the first meeting between KGG and the Client. This meeting would
follow definition of the base elements for the project and other project planning activities.
This meeting introduces the members of the project team (KGG) and the client and
provides the opportunity to discuss the role of team member. The process to be followed
is explained so as to maintain quality standards of the organization. Clarity is given by
the project lead if there exist any ambiguity in the process implementation.
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5.3 Toolbox Meeting
Every morning before start of work a safety Toolbox talk session will be held by
the Supervisor with the crew to instruct and discuss:
 Work activity of the day.

 Work procedures.
 Safety instructions for using equipment and tools.
 Particular hazardous conditions and precautions to be taken, for the
work activities.
 LFI‟s
5.4 SSHE Drills
KGG considers it a good idea to hold practice drills as often as necessary to test
employee emergency preparedness. After each drill, gather management and
employees to evaluate the effectiveness of the drill. Identify the strengths and
weaknesses of your plan and work to improve it.
5.4.1 Emergency Drill Objectives
 Giving employees an opportunity to practice emergency procedures in

a simulated but safe environment
 Determining if employees understand and can carry out emergency
duties
 Evaluating effectiveness of evacuation procedures and determining
necessary changes or adjustments to procedures to improve
performance
5.4.2 Drill Frequency
How often drill is conducted during this project is subject to the existing plan of
the Client, however KGG would ensure emergency response procedure forms part
of the induction programme of her employees.
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5.5 Safety Stand Down
Safety stand down meetings take time out of the work day to address important safety
issues. Shutting down the entire operation to focus on safety emphasizes its importance to
the whole company. Discussing these matters as a group also gives our employees an
opportunity to ask questions about material or process they may not understand.
KGG believes that the success of any safety meeting depends on its preparation, therefore
we would ensure all safety meetings, including Safety Stand Down is well planned and
topic would be chosen to address the current Health and safety priority of our operation.
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6.0 SAFETY PROGRAMS
6.1 Behavior-Based Safety
Behavioral Based Safety is an approach to safety that focuses on workers'

behavior as the cause of most work-related injuries and illnesses. The initiatives
have a proactive focus, encouraging individuals and their work groups to consider
the potential for incident involvement, (accidents) and to assess their own
behavior.
We would ensure twice in a year all personnel participate in a Behavior-Based

Safety program one which:
 Is based on solid principles about engaging, motivating, assisting,

reinforcing, and sustaining safe behaviors.
• Takes a systematic approach, examining the motivation underlying
behaviors, in order to increase safe behavior.
 Is an ongoing effort; not „once-off‟ provisions, but a new way of working
that the safety leader must continually promote for sustainable, positive
results.
• Takes time to achieve; however, results can be observed immediately due
to the nature of measurement involved.
• Emphasizes increasing safe behaviors rather than focusing on length of
time without injury. BBS programmes do not depend solely on „lagging
indicators‟ (after the fact), and instead shift the focus to „leading
indicators‟ (preventative).
• Is not a substitute for an already existing comprehensive health and
safety programme; it is a supplementary tool that will enhance the effect
of already existing practices, and will allow for an objective measurement
system.
• Aims to understand causes of incidents and near misses and correct them
through the behavior of relevant people. For example, reducing hazards
often requires behavior change of managers and frontline workers.
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6.2 Hand and Power Tools
It is a known fact that hand and power tools are major source of hazard in a workplace,
KGG however affirms that for effective prevention of incident resulting from hand and
power tools, the below precautionary measures would be taken:
 Keep all tools in good condition with regular maintenance

 Use the right tools for the job
 Examine each tool for damage before use and do not use damaged tools
 Operate tools according to the manufacturers' instructions and In line with
available risk assessment
 Provide and use properly the right personal protective equipment
 Maintain close supervision
6.3 Personal Protective Equipment
PPE is equipment that will protect the user against health or safety risks at work. Below
Personal Protective Equipment would be provided for the contract
 Coverall
 Safety Helmet
 Safety Shoe
 Hand glove
 Safety goggle
 Nose mask
 Ear muff
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6.3.1 Matching PPE with Activities
S/N HAZARD/RISK TYPE OF WORK PPE

1 Head Injury FALLING & FLYING Safety Helmet
PARTICLES OBJECTS
2 Eye And Face Bolting & unbolting,
Injury Flogging, tougueing Safety Glasses
3 Hand Injuries Handling Tools,
Equipment and Material Hand Gloves
4
Dust House Keeping Nose Mask
5
Stain, Dirty Cloths
And Body Injury All operation Cover All
6 Equipment and materials Safety Shoes
Leg Injury
7 Noise from venting and
Ear Injury compressor Ear Muff
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6.4 Housekeeping
Housekeeping is the act of keeping the working environment cleared of all unnecessary
material, thereby providing a first-line of defence against accidents and injuries. KGG will
ensure:
 That suitable arrangements, are in place to maintain site tidiness to a high standard
 Appropriate disposal of waste material including arrangements for specialised or

hazardous waste
 That waste material removed from site is reaching the Client appointed area or
incineration facility, and is not being 'fly tipped' or causing environmental damage
 Removal of all unnecessary tools and equipment from the work site and return them
to toolbox appropriately
 Immediate reporting to Client site supervisor or HSE staff about any anomalies,
leaking, etc.
6.5 Safety Inspections/walkthroughs
Safety inspections do not safe lives or injuries; they do give us the opportunity to
identify and mitigate hazards. In addition to the continuous monitoring of “the
Contract” by the HSE staff, the Contract HSE Manager shall perform a formal
inspection of the site at least once every quarter to identify and correct any
hazardous conditions. Written records of all of the above shall be maintained and
where required for audit purposes submitted to Client.
Auditing shall be performed with the use of standard checklists and Audit
reports. Reports shall define recommendations for corrective actions for non-
conforming items.
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KGG shall allow CLIENT access at any time to premises, plant, equipment, personnel and
records when requested, to enable CLIENT to inspect or audit any aspect of “the Contract”
relevant to HSE and the work environment.
6.6 Management of Change
KENT GERMAN GLOBAL LIMITED has a robust change control process in place.
This document describes the process that is to be used for requesting and
managing changes to work products created or maintained in KGG. This process
will facilitate communication about requested changes on the course of execution
of KGG‟ projects, provide a common process for resolving requested changes and
Reported problems, and reduce the uncertainty around the existence, state, and
outcome of a change that has been requested in a work product.
Any staff of KGG can submit the following types of issues to the change control
system:
 Requests for requirements changes (additions, deletions, modifications,

deferrals) in the process and procedures
 Reports of problems occurring from any activity on site
 Requests for enhancements in current process
 Requests for any new development in projects
N/B All changes must be routed through KGG change control procedure and
must be authorised by the change control focal point after due consultation
with the Client’s department in charge.
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7.0 Occupational Health Management
7.1 Exposure monitoring
Exposure monitoring is the process of estimating or measuring the magnitude, frequency

and duration of exposure to chemical, physical and biological agents for a group of
workers. Monitoring generally consists of collecting direct measurements or samples to be
analyzed by a laboratory to determine the exposure of a worker to an agent (e.g. solvent,
dust). Exposure assessments must be carefully planned and executed to assure accurate
estimations of worker exposure. At KGG, all employee exposure is monitor by carrying of
effective health surveillance through our retainer Clinic. We monitor to:
 Help secure the right control

 To be sure exposure limit to hazardous substance is not exceeded
7.2 Noise
Noise presents one of the major hazards in our operation; KGG is determined none of her
employed would experience hearing loss as a result of operation. It is on this conviction
that we ensure necessary precautions must be in place to mitigate noise hazard. The
noise Hazard Assessment and control program ensures KGG personnel are protected
from noise hazards by:
 Evaluating potential noise hazards
 Implementing noise-reduction controls and providing hearing protection
 Performing periodic hearing examinations
 Providing hearing-protection training
 Identifying high-noise areas with signage
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7.3 Fitness for Work & Fit Testing
Medical fitness of workers will be carried out as part of the pre-mobilization activities
before mobilization to site. The medical fitness certificate will be at site as part of pre-
mobilization document package. The period of validity of fitness to work certificate is
subject to medical report.
7.4 Fatigue Management
Fatigue is more than simply feeling tired or drowsy. It is caused by prolonged periods
of physical and/or mental exertion without enough time to rest and recover; this has
been identified to be a root cause of major incident at workplace. For this reason
KGG limits overtime to ensure staffs are getting sufficient breaks between shifts;
encourages short naps of up to 15 to 20 minutes during the shift if it fits in with the type of work that
is being done.
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8.0 Environmental Program
8.1 Waste Management
KENT GERMAN GLOBA LIMITED is committed to sustainable development and

environmental protection. Integrated waste management is an integral part of our
business operations.
Waste management procedures shall be activated and we shall maintain effective
waste segregation.
The principle of the 4 R‟s waste management will be enforced i.e.:

Reduce, Reuse, Recycle, Recover
Monitoring and Restoration:
Waste such as solid waste, liquid waste will be track, collected and evacuated to
Client approved dump site in line with waste management manual.
8.2 Spill Management
The target for this contract is to achieve GOAL ZERO which no incident, accident
and no leak (spill), however should anything like spill occurred during the course
of our operation the steps below are to be taken into consideration except the
Client has a contrary procedure which would be expected to form par of induction
program
1. Be safe ( get the right safety equipment before you act)

2. Stop the source (turn off the tap or valve, plug the leak)
3. Confine the spill with sandbags or booms
4. Notify (Tell your supervisor or Client Site Supervisor)
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9.0 Personnel Competency
KGG recognizes the hazardous nature of her operations; we have however made it a point
of duty to ensure all our personnel have the necessary competency to deliver a quality job
without undermining safety standard. All personnel that would be deployed for the
contract possess requisite knowledge on:
 Hazard Identification
 Awareness on fire prevention
 Safe handling of equipment and tools
 Risk assessment & Job Safety Analysis
 Basic Offshore Safety Induction and Emergency Training
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10.0 Security Program
10.1 Security Plan
KGG will latch on to the existing Client‟s Security Plan. All workers will familiarize
themselves with the security plan, it will form part of the HSE induction/kickoff
meeting. In the event of threats from community or armed attack, employees will
follow the instructions in the security Plan.
10.2 Community Relations Plan
In order to pursue mutually beneficial relations with host communities, KENT

GERMAN GLOBAL LIMITED shall
 Establish and maintain close relationships with all segments of the

local population to better understand their concerns, needs and
aspirations
 Continuously assess and abate the social and economic impact of all
business activities and take needed preventive or mitigating measures
 Respond to formal community request in an appropriate and timely

manner
 Bring relevant issues affecting host communities to the attention of

appropriate authorities and other bodies that can be of assistance
 Manage the settlement of compensation for land acquired for

company operations and damages in a demonstrably fair, accountable
and transparent manner and in accordance with statutory provisions
and approved procedures.
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11.0 Tools & Equipment
All tools and equipment shall be of good standard. They must be properly maintained so
that workers are not endangered. We would ensure preventive maintenance of equipment
is carried out as scheduled to keep them in a safe, usable condition, limit downtime and
extend productivity. For effective maintenance of equipment, KGG would
 Ensure maintenance is performed as required

 Ensure that the person(s) performing the maintenance are competent
 Retain records of maintenance/service conducted
 Set up a system for removal and tagging of damaged or defective tools and
equipment.
44

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KGG

KENT GERMAN GLOBAL (KGG) LTD

FOR: SERVICING & PROVING OF BULK OIL METER & CORIOLIS

CLIENT: SHELL PETROLEUM DEVELOPMENT COMPANY OF NIGERIA

OUR REF: KGG/SPDC/HSSE/001/21

HSE, SECURITY PLAN & POLICIES

ACTION NAME DESIGNATION SIGNATURE

Reviewed By V.Onofua BDM

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 2 of 44

S/N DESCRIPTION PAGE

3.0 SAFETY MANAGEMENT SYSTEM 14-24

4.0 HSE TOOLS 25-30

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 3 of 44

5.0 HSE MEETINGS 31-34

9.0 Personnel Competency 42

11.0 TOOLS AND EQUIPMENT 44

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 4 of 44

1.1 Introductory Statement

KGG LIMITED recognizes and places importance on safety in the execution of

 Meet all relevant regulatory and legislative requirements.

 Manage all risk associated with its activities to as low as reasonably

 Sustain management commitment to Health and safety of its personnel

and third parties.

 Increase the level of HSE awareness and competency amongst employees.

 Minimize the impact of its operations on the environment.

 Maintain harmonious relationship with its host community

 Recognize HSE management as a line responsibility.

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 5 of 44

2.1 CASHES POLICY

Rev: 0.1 KGG/HSE/13/17/02

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 6 of 44

2.2 HEALTH, SAFETY AND ENVIRONMENT POLICY

 Ensure that lives of personnel and assets are protected and

 Protect the environment.

 Manage HSE matters as any other critical business activity.

 Promote a culture in which all Kent German Global employees

Share this commitment,

Ensure Safety, Protection of Health, and Security of her workers,

third parties, and Facilities.

Rev: 0.1 KGG/HSE/58/17/02

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 7 of 44

2.3 SMOKING, DRUGS AND ALCOHOL POLICY

Having recognized smoking as injurious to health and a fire hazard, it shall be

Kent German Global policy to

 Strongly discourage smoking

 Prohibit smoking in our premises and work areas.

It is therefore strictly prohibited:

 For any employees to possess, use, distribute or sell alcohol or illegal

drugs on company business or work location.

 Drug abuse and self-medication is strongly discouraged

AUTHORS MOSES E. , V.ONOFUA, K.ODIA PAGE 8 of 44

2.4 TRANSPORT POLICY

Transportation is an essential part of this business. Therefore all forms of

(Air, land or marine) shall be well planned, and materials handling

equipment used on company business shall comply with the company

standards and shall be operated by authorized personnel.

an integral part of day-to-day activities.

equipment shall be registered and audited before use. All policies on