Saudi Aramco 7180 (5/89)

G.I. NUMBER Approved

6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 1 OF 7

CONTENT:
1 PURPOSE
2 SCOPE
3 COMPLIANCE REVIEW OBJECTIVES
4 RESPONSIBILITIES
5 SCHEDULING COMPLIANCE REVIEWS
6 COMPLIANCE REVIEW PROCEDURE
7 COMPLIANCE REVIEW REPORT
8 IMPLEMENTATION OF RECOMMENDATIONS

1.0 PURPOSE:
1.1 To provide guidelines relative to Saudi Aramco requirements to periodically conduct reviews
for compliance with the Company loss prevention policy statement per G.I. 5.002, "Loss
Prevention Policy Implementation", paragraph 4.13, and as detailed in the Corporate Loss
Prevention Manual, section 170, "Compliance Reviews".

2.0 SCOPE:
2.1 Compliance review program methodology and procedures.

2.2 Compliance review recommendations (implementation, status reporting and follow-up

requirements).

2.3 Procedures for non-compliance with recommendations.

2.4 Responsibilities of business lines, the Loss Prevention Department, the proponent department,
support departments and the compliance review chairman.

3.0 COMPLIANCE REVIEW OBJECTIVES:

3.1 To assess a department's loss prevention program, and to evaluate program implementation.

3.2 To emphasize parts of the loss prevention program that are working well.

3.3 To develop recommendations for loss prevention program improvements.

3.4 To assess equipment and material deficiencies and recommend corrective actions.

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 2 OF 7

3.5 To assess department and employee commitment to and participation in both Company and
departmental safety programs and recommend areas for improvement.

3.6 To review the implementation of recommendations made during previous compliance reviews.

3.7 To provide information to proponent management for improving the effectiveness of their loss
prevention program.

4.0 RESPONSIBILITIES:
4.1 Business Lines

4.1.1 Business line heads are responsible for nominating departments for compliance reviews,
as well as manager level employees (or above) to serve as chairmen for compliance
reviews. Business line heads will ensure that nominated chairmen are available full time
for the compliance reviews they chair.

4.2 Loss Prevention Department

4.2.1 The Loss Prevention Department shall be responsible for coordinating the compliance
review program. This coordination includes: scheduling the review; selection of the
review team chairman; identification of team members (from proponent, support and
Loss Prevention departments and in selected cases outside specialists groups) required
for each review; notifying the involved personnel; and preparation of review materials/
guidelines such as the format for the compliance review report and the interview
questionnaires.
4.2.2 The Loss Prevention Department shall be responsible for providing background
information on the proposed compliance review to the appointed chairman and team
members. The chairman and team members will also be briefed by Loss Prevention on
all aspects of the review (e.g. report format, categorization of recommendations as
"major", "moderate" or "minor" as outlined in paragraph 7.2).

4.3 Proponent Department

4.3.1 The proponent department will provide review team members (from within their
department) with appropriate qualifications and experience as recommended by the Loss
Prevention Department. One of these team members shall be appointed as secretary of
the review team. It is recommended that the secretary be an experienced engineer who
is familiar with the operations to be reviewed.
4.3.2 The proponent department will provide access to the review team to inspect it's facilities,
interview it's employees and review it's documents as requested by the compliance
review chairman.
4.3.3 The proponent department shall provide logistical support to the review team as
appropriate. This may include items such as housing, food or meal allowances, office
space, a full-time dedicated clerk, and security permits.

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 3 OF 7

4.3.4 The proponent department will implement (or resolve) and provide status reports on
review recommendations as outlined in section 8 of this G.I.

4.4 Support Departments

4.4.1 Support departments, such as those in the Engineering Organization, will provide
specialists to effectively support compliance reviews. Other organizations may also be
asked to provide specialists for compliance reviews and they should make every effort
to support these reviews.

4.5 Compliance Review Chairman

4.5.1 The chairman shall have complete procedural freedom (within the general guidelines
provided by Loss Prevention during briefings before the review) to direct the course of
the review. For example, he may assign specific tasks to the members of the review team
or divide the review team into groups in order to efficiently utilize the expertise of the
members available to him.
4.5.2 The chairman, with assistance from the team secretary, shall finalize the findings of the
review team by the end of the review period, in the report format provided by Loss
Prevention during briefings prior to the review, and obtain concurring signatures from
all review team members. Under exceptional circumstances he shall allow a review team
member to record dissents and deviations from the majority view when signing the
report.
4.5.3 The chairman shall be responsible for providing the review report to the proponent
department and other organizations as outlined in section 7 of this G.I.

5.0 SCHEDULING COMPLIANCE REVIEWS:

5.1 Each year, in the fourth quarter, the Loss Prevention Department shall request business line
heads to nominate departments from their respective business lines for the forthcoming
compliance review program. Business line heads will also be asked to provide nominees to
serve as chairmen for the upcoming program.

5.2 The Loss Prevention Department will review responses from business lines and compile the
final list of departments to be reviewed in the following year. Since the number of reviews is
limited, selection shall be based on such factors as criticality of operation, time since the last
review, and safety performance.

5.3 Based on nominations provided by business lines, the Loss Prevention Department will select
chairmen and confirm these selections with the management of the nominated persons. Where
possible, the chairman and the department to be reviewed should be from separate business
lines.

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 4 OF 7

5.4 Dates for compliance reviews will be finalized and published by the Loss Prevention
Department as soon as practical after response from business lines has been received.

5.5 Depending on the function of the department to be reviewed, the Loss Prevention Department
will request other departments in the Company, or outside consultants, to provide support staff
for each review as appropriate. These requests shall be made as soon as practical after the
compliance review schedule is finalized.

5.6 Operating and support departments with significant exposure should be reviewed at intervals of
three to five years. A department may be reviewed at more frequent intervals, if warranted and
agreed to by the Loss Prevention Department and the management of the department involved.

6.0 COMPLIANCE REVIEW PROCEDURE:

6.1 Following discussions on the proposed review with the management of the department or
organization being reviewed, the review team will convene on site. The review team members
shall assess that the department concerned has an up-to-date loss prevention program document
consistent with the requirements of the Corporate Loss Prevention Manual. The compliance
review team will evaluate the implementation of the department's program by assessing selected
items such as the following (other items may also be appropriate):

6.1.1 Control of responsibility/accountability for meeting Saudi Aramco's loss prevention

policy.
6.1.2 Operator or craftsman knowledge and training.
6.1.3 Implementation of safe work procedures (e.g. work permits, and operating instructions).
6.1.4 Disaster/emergency plans and employee preparedness.
6.1.5 The loss prevention program (including but not limited to safe operations committee(s),
unit safety meetings).
6.1.6 Work order systems, maintenance and engineering support.
6.1.7 Implementation (or resolution) of previous compliance review recommendations.
6.1.8 Communication of fire and safety concerns to all department personnel.
6.1.9 Safety administration of contractors.
6.1.10 Major hardware or design deficiencies.

6.2 To assess the items listed in section 6.1, the review shall consist of a detailed look into all areas
of loss prevention activity. Key people shall be interviewed, records and files reviewed,
procedures investigated, and key meetings shall be attended, if practical. In conducting the

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 5 OF 7

review, checklists should be used as a reminder of things to look for, talk about, and/or review.
Such checklists will be provided by the Loss Prevention Department representatives.

6.2.1 As a minimum, the following shall be interviewed: department manager, superintendents

of operations, engineering and maintenance, and a random selection of supervisors and
employees. Both new and old supervisors and employees shall be included. In most
cases, 10-15% of the employee population should be interviewed.
6.2.2 A safe operations committee meeting should be attended if possible. Particular attention
shall be paid to the make-up of the committee, content of the meeting, freedom of
exchange of comments, follow-up action on outstanding items and minutes of the
meeting, including distribution and publicity of accomplishments.
6.2.3 Attendance at a regular safety meeting is important to determine both the quality and
effectiveness of the material used and the ability of supervisors to get their message
across. If time permits, several meetings should be observed. Particular attention shall
be paid to the amount of preparation, visual aids used, subject matter, and both the
attentiveness and participation of employees.
6.2.4 Files relating to safety, fire, and other loss prevention matters shall be reviewed and the
following critical elements of the department loss control program shall be addressed:
management directives and statement of policies; safety meeting schedules; safety
suggestions, recommendations and pertinent follow-up activity; industrial hygiene
surveys; health and medical surveys; safety awards; statistics; inspection reports; letters
to supervisors and employees regarding rules, policies, and loss prevention matters; new
employee orientation/training; previous compliance review reports and follow-up work;
safety training; special medical tests; and investigations of accidents, fires and near
misses.
6.2.5 Accident logs and reports shall be checked to make certain that all reports are properly
completed. Particular attention needs to be paid to evidence of investigation, selection
of "cause and correction", and the length of time before reports are submitted and
distributed. Spot-checking proposed corrections and discussion with injured employees
will indicate management's effectiveness in preventing recurrences.
6.2.6 A spot check of written procedures is necessary to determine that hazardous operations
(e.g. tank entry, hot work, lockout/tag) are well defined; that safety equipment is properly
serviced and maintained; that work permit procedures are complied with; and that
personnel are properly trained and certified as required.
6.2.7 An inspection of facilities as appropriate to the department being reviewed shall be
conducted. Pertinent items to observe are: housekeeping; equipment guarding; dust,
fume and noise levels and controls; personal protective equipment; fire protection
equipment; flammable liquid storage; safety showers and eye wash stations; emergency
equipment; safety valves; mobile equipment, including hoisting devices; safety signs;
hazardous waste disposal; and field verification of implementation of a sample of
previous compliance review recommendations. Whenever, during the course of an
inspection, a serious hazard to life or property is identified, review team members should
report these hazards to the responsible supervisor for immediate control.

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 6 OF 7

6.3 Security and environmental assessments are beyond the scope of these compliance reviews.
However, since the liaison of plant operations with security personnel is important during
emergencies, the review shall confirm how a plant's emergency response plan interfaces with
plant security.

6.4 Where possible, the review team shall hold a simulated fire or disaster drill to assess response
capability and emergency control systems. This drill will need to be closely coordinated with
operations and other relevant departments. The nature of the drill will depend on the
department being reviewed.

7.0 COMPLIANCE REVIEW REPORT:

7.1 The review team will compile the report from joint and individual assessments. The report will
consist of an evaluation of the reviewed department's loss prevention program and an
assessment of its implementation. Individual items considered in the review with support
findings will be included. The review report will be in the format provided by the Loss
Prevention Department during pre-review briefings.

7.2 The review recommendations shall be divided into "major", "moderate" and "minor" categories.
Generally, "major" recommendations will be those safety hazards which cite non-compliance
with Saudi Aramco G.I.s, standards, plant operating instruction manuals or the department loss
prevention program. However, the team has the prerogative of making other recommendations
if they feel it is warranted or if time prohibits a thorough comparison with "applicable"
standards.

7.3 All "major" and "moderate" recommendations shall be numbered and listed in the
"Recommendations" section of the report. An appendix to the report will include "minor"
recommendations and "punch list" items needing correction (i.e. housekeeping items, etc.).

7.4 A draft list of "major" recommendations shall be provided to the proponent department's
management for preliminary review.

7.5 The report will be addressed to the proponent department's manager, and "major"
recommendations will be discussed with the proponent department's management on the last
day of the review. The superintendent of the area Loss Prevention division shall be invited to
this review meeting.

7.6 Copies of the report will be provided to satisfy the reviewed department manager's distribution
requirements. Additionally, one copy of the report shall be provided to the Manager, Loss
Prevention Department, one copy to the area Loss Prevention superintendent, and one copy to
the administrative area head of the department being reviewed. The compliance review team
members shall be provided copies of the report upon request.

* CHANGE ** ADDITION NEW INSTRUCTION X COMPLETE REVISION 7

Saudi Aramco 7180 (5/89)
G.I. NUMBER Approved
6.006
SAUDI ARABIAN OIL COMPANY (Saudi Aramco)
GENERAL INSTRUCTION MANUAL ISSUE DATE REPLACES
ISSUING ORG. LOSS PREVENTION DEPARTMENT 6/8/1993 NEW
SUBJECT: LOSS PREVENTION COMPLIANCE REVIEWS APPROVAL PAGE NUMBER
AIN 7 OF 7

8.0 IMPLEMENTATION OF RECOMMENDATIONS:

8.1 Upon receipt of the review report the proponent department manager shall develop an action
plan for the implementation of recommendations. The implementation shall be completed
expeditiously, and all "major" recommendations shall have estimated dates for completion.

8.2 The proponent department will track the implementation (or resolution) of all recommendations.

8.3 The proponent department will provide status reports of the "major" recommendations to the
superintendent of the area Loss Prevention division every quarter until implemented or
otherwise resolved. These status reports may be in the form of minutes from SOC meetings in
which the recommendations are tracked, or they may be in a separate format.

8.4 Field verification of a sample of implemented compliance review recommendations (as reported
by proponent departments) will be formally done as part of the department's next compliance
review.

8.5 If the proponent department disagrees with or is unable to comply with a "major"
recommendation, a non-compliance letter shall be obtained from the proponent department's
administrative area head. This letter should state the justification for non-compliance. A copy
of this letter shall be forwarded to the Manager, Loss Prevention Department. If non-
compliance with Saudi Aramco engineering standards is involved it must be processed by
utilizing the waiver form SA-6409 (as outlined in Saudi Aramco Engineering Procedure 302).

Recommended:
Manager
Loss Prevention Department

Concurred:
Executive Director
Safety And Industrial Security

Approved:
President And Chief Executive Officer

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