GR09 : Health and Safety in

Industrial Projects
GHSD-GOV-PPT-0014
REV 00
24.04.2023

RESTRICTED INTERNAL SECRET

Agenda

Revision of GR09
1
Overview GR09
2
H&S in Industrial Projects - Requirements
3
Implementation
4
One Page Summary Slide
5
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 Health and Safety in Industrial Projects
Revision of GR09 

This summary presentation is to assist in summarising the principles of GR09 and suggestions for the
deployment. Individuals are required to revert to the original text for developing their own procedure.

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Revision of GR09: WHY ?

To reinforce the management of H&S through the life cycle of projects

To reinforce the Roles and Responsibilities of the Business development Managers and
the Project Managers
To separate out the H&S due diligence approach associated with Mergers and
Acquisitions. This is now strengthened and incorporated in the new GR12

The BD and PM departments have a key role in the implementation of GR09

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Overview of GR09 

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GR09 Health and Safety in Industrial Projects - Objective

GR09 sets out the minimum requirements related to occupational

health & safety (H&S) and process safety that must be complied
with by all ENGIE entities for Industrial Projects.

The aim is to support the prevention of accidents as far upstream as

possible, to avert physical harm to employees of the Group ,
contractors or third parties, as well as material damages.

This goal goes beyond the project timeline as it looks also to deliver
an installation that is intrinsically safe during its entire life cycle.

GR09 is the overarching rule on H&S in Industrial Projects. It is

supported by DOP 25 H&S Risk Management Standard for
Industrial Projects.
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Règles Groupe ENGIE (sharepoint.com)
GR09 Health and Safety in Industrial Projects – Scope

This GR09 applies to the CAPEX projects where ENGIE acts as Owner, and Installation Projects
where ENGIE acts as Contractor, and has an operational control or is the leader in H&S matters.
It includes the following types of projects:
• Green Field Projects (including pilots) ;
• Brown Field /Revamping Projects ;
• Decommissioning & Dismantling Projects.

Projects where Engie is in Partnership

Where ownership is shared with partners, the applicable H&S framework will be identified in the
shareholder’s agreement, consortium agreement or joint development agreement.
That framework shall be compliant with Group H&S Rules and ENGIE life-saving rules.

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GR09 Health & Safety in Industrial Projects – Roles & Responsibilities

There are a number of roles in projects – all of whom have an individual responsible for H&S. the following is a non-
exhaustive list of roles:
• Owner’s Representative : has the final accountability for project health & safety management
• Business Developer
• Project Manager
• Technical Project manager
• Construction Manager
• Commissioning Manager
• O&M Expert or representative
• Health & Safety Expert
• Process Safety Engineer
• H&S Site Supervisor

The specific detailed H&S responsibilities of each role are detailed in Annex 2 of the GR
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H&S in Industrial Projects:
Requirements

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GR09 Health & Safety in Industrial Projects – Project Lifecycle

The typical project lifecycle can be represented by the following diagram:

An H&S management system, including risk assessment, shall be defined and

implemented throughout the full project lifecycle being under the
accountability of the BD and subsequent PM.
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GR09 – Business Development - Initiate

Ensure that an H&S Expert is involved / consulted from the outset.

Draft Project Plan referring to GR09 and DOP25 H&S Management in Industrial Projects.
Development Committee (DevCo) requirements :
Short generic description of main H&S aspects for project and technology
Highlight of the main H&S risks and challenges of the Project.
Links to the required H&S documents (mandatory requirements – refer to slide x).
Investment Committee (InvestCo)
H&S Project Review prior to Comité de la Stratégie, des Investissements et des Technologies (CSIT) or also when deemed
required (multi GBU project / high risk process or new technology etc). Review to include:
• H&S Management Plan
• Risk Assessment taking into account layout / applicable site / location
• Permitting and Regulatory aspects
• Compliance with specific safety requirements e.g. of insurer requirements such as compliance to NFPA standards
• Project Team Book (PTB) to include full chapter on H&S with detailed description on risks and their controls and further studies /
activities that will be required during subsequent phases
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Independent H&S Expert (i.e. not involved directly with the project) to attend
GR09 – Request For Proposal (RFP)

Nominated H&S Expert assigned to the project shall be consulted to define:

• The list of H&S activities and deliverables required to execute the requirements of the
contract.
• H&S deliverables that will need to be submitted within the technical proposal, demonstrating
the Contractor’s capacities to execute the work.
• The minimum H&S requirements as aligned with the Preliminary H&S Management Plan.
• H&S oversight required for the project.

The process of the pre-qualification, section and management of Contractors is detailed in

GR02 and shall be complied with

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GR09 – Project Exécution – Design

Project H&S Expert to be appointed by Project Manager no later than the start of the design phase.
ENGIE H&S Line (Entity / country or GBU shall approve the Project H&S Expert selection.
If the H&S Expert is not an ENGIE employee, he/she shall be trained to know, understand and apply
ENGIE H&S requirements and demonstrate acquired knowledge.
The H&S Expert may cover both the Occupational H&S role and the design process safety role,
depending on expertise and competencies.
Design – Basic Design / FEED (Front End Engineering Design) onwards
Active management of:
• Process safety risk studies
• Safety Reviews
• Risk evaluations based on ALARP (A Low As Reasonably Practicable) principle
• Occupational risk reviews and plans for construction, commissioning, operation and maintenance
Refer to GR09 and DOP25 for details
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GR09 – Project Exécution – Build

Build
Project Contractor H&S Manager shall be approved by ENGIE prior to his mobilization (Refer to GR02).
Contractor shall mobilize appropriately qualified and competent H&S personnel taking into recognition
the risks profile of the activities and site.
KPIs in line with the Group KPIs shall be put in place
Inductions / Onboarding are a mandatory requirement
Review and (if contractually required) approval of the following documents prior to mobilization on site:
• The H&S Management Plan. Typical Content / template is in ANNEX 4.
• The safety or risk register.
• The risk assessments associated with the method statements.
• Emergency Response Plan
Refer to GR02 for further details

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GR09 – Project Exécution – Test and Commissioning

Test and Commissioning / Start Up

Project Manager or Commissioning Manager by delegation will ensure that risks arising from
commissioning and/or start-up are systematically identified, assessed and managed and that there is a
systematic process to verify that the plant or installations and equipment are in a safe condition, and that
personnel are appropriately prepared before commissioning/start-up.
Essential documents/activites include, but are not limited to:
• Commissioning Plan including H&S requirements.
• Risk Assessments.
• Permit to Work System.
• Safety Functions testing plan
• Emergency Response Plan

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GR09 – Project Exécution – End/Completion

End (Completion)
Safety file including the key documentation (e.g. test reports, commissioning documents, certificates, required
licenses, operation and maintenance manuals, plans and diagrams as built) must be created prior to handover to
operations.

It is mandatory for a Safety Critical Elements Register to be developed during the Execution phase and handed over
into the Operations Phase.

A final safety review must be performed by the project management team, including the O&M team and involving
the H&S Expert before the official handover

REX
A REX process including H&S matters shall be organized before the project closure by the project management team.
This return of experience should be used to feed H&S management plans/requirements of future projects.

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GR09 Health & Safety in Industrial Projects – Overview

The following is an
overview of the key
studies and activities.
Those in red are
mandatory for every
project.

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GR09 – Decommissioning and Dismantling

The H&S approach to Decommissioning and Dismantling Projects is identical to New Build Projects but
with particular additional attention being given to:

• Opening of equipment in terms of environmental impact and occupational exposure

• Non-availability / removal of safety barriers
• Risks associated with removal/demolition of equipment / piping
• Hierarchy Waste Management Analysis of all materials (reuse / recycle / revalorization / treatment
/ disposal

In the event of brown field projects / ties ins, a SIMOPs risk assessment shall be undertaken. The resident
operational personnel, key project roles and Contractors shall participate in the review.

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GR09 – Specificities for small projects, installation projects,
service contracts, including facilitity management contracts

Some of the requirements of the present Group Rule may not be fully applicable to or difficult to
abide by for ENGIE when working as a Contractor providing services or performing facility
management.

The H&S supervision & Staffing strategy can be adapted to this kind of projects. This strategy must
be validated by the highest level of the entity H&S line.

Notwithstanding the above, the principles to be respected for a services or FM contract remain
the same and mitigating actions need to be put in place whenever necessary. In particular:
• A H&S Plan (or similar) shall specify and quantify supervision of the works tailored to the
works to be performed and its risks.
• The health and safety conditions adopted to perform the service(s) shall be clearly stated
in the contract, as well as the role of each of the parties in the event of an accident.

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GR09 – Assurance Activities

A number of assurance activities will be required through the life cycle of the project. These shall include
but not be limited to:

• Cold eye reviews (design/construction/Pre-startup/Operation readiness)

• Inspections / safety walk-throughs
• Self-Assessments
• Audits – both of the Project itself and of the Contractors
• Deep Dive Reviews of specific areas of concern

All assurance activities will be planned and executed, if necessary, on a risk based approach.

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H&S in Industrial Projects

Implementation

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GR09 H&S in Industrial Projects– Implementation

For all new projects post date of issue of GR:

3 months to implement. Any project post the 3 month period shall implement from
the outset of the project.

For all existing projects at date of issue:

6 month implementation period during which projects must undertake the following:
• Self assessment to benchmark where the gaps may have been / are to incorporate the
H&S requirements in their project
• Safety Review by independent H&S Expert (a competent H&S individual that has not
been directly involved in the project)

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GR09: H&S in Industrial Projects– Support Materials

Powerpoint: Support for implementation consisting of overview of GR02

Powerpoint: Management Summary

Excel File: Self Assessment Questionnaire

BD / PM check lists

H&S Plan Template

Other support materials are available through GR02 and GR04. All are available in the GHSD Sharepoint.
Training package for PM / BD to be available September 2023

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GR09 Health and Safety in
Industrial Projects

One Page Summary Slide

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GR09 H&S in Industrial Projects

Objective: Why: Responsibilities:

GR09 sets out the minimum requirements related to • To reinforce the management of H&S Owner: BD / PM
occupational health & safety (H&S) and process safety throughout the project life cycle. Custodian: H&S Line
for all Industrial Projects. • Requirement for earlier intervention in H&S Oversight: Projects Dept. and Regional /
Aim is to design/construct installations to prevent matters in project development. Country / Entity HSE Managers
accidents. I.e. the scope covers the project timeline but • Some incidents could have been prevented or
looks beyond it to deliver an installation that is probability of them occurring reduced if safer Key Dates :
intrinsically safe throughout its life cycle. design hence more emphasis on upstream Issue: 9.05.2023
studies / reviews Implementation: 3 months from issue date
Key Points • Reinforcement of roles and responsibilities of of the GR for new projects. All new projects
BD / PM post this date to implement immediately.
1. H&S Expert involved from outset (Define phase)
Existing projects: 6 months implementation
2. Specific H&S accountabilities for BD and PM role
period
3. Emphasis on requirement of specific Process
Safety role
Materials
4. Periodic reviews by H&S Expert independent of
• GR09
the project
• Powerpoint Support Document
5. Key mandatory deliverables / activities (denoted in
red in the picture) • One Page Management Summary
6. Concept of designing to the ALARP Principle • Excel Self Assessment
(Reducing the risks to As Low As Reasonably • PM / BD Check list
Practicable) • H&S Plan template
To note: H&S with respect t o Mergers and Acquisitions is GR02 and GR04 materials
now the subject of its own GR: GR12
Direction Santé & Sécurité Groupe - GR09 - Tous les docu
ments (sharepoint.com)

Implementation:
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Existing Projects to undertake Self assessment and independent Safety Review.