Release Authorized by: / Danny Trahan, Safety Director / Manual Rev 4
HSE OFFICE, ENGINEERING & PROJECT/SITE ACTIVITIES
HSE OFFICE, ENGINEERING PROJECT/SITE ACTIVITIES
TABLE OF CONTENTS
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HSE OFFICE, ENGINEERING & PROJECT/SITE ACTIVITIES 1
PURPOSE 5
SCOPE 5
APPLICATION 5
DEFINITIONS 5
OBJECTIVES 5
1.0 USE OF CORPORATE PRACTICES 6
1.1 General 6
1.2 Deviations 6
A. Collaboration with Others 7
B. Seconded Employees 7
C. Contracts/Subcontracts 7
1.3 Exceptions 7
1.4 Legal Requirements 7
2.0 ZERO ACCIDENTSSM PROGRAM 8
3.0 SITE-SPECIFIC HSE DOCUMENTS 8
3.1 HSE Procedures 8
3.2 HSE Plan 8
3.3 HSE Manual 8
4.0 MAJOR PROGRAM ELEMENTS 8
4.1 General 8
4.2 Ratio of HSE Representatives to Project Field Employees 9
4.3 Project Requirements Checklist 9
4.4 Setting Program Goals and Objectives 9
4.5 Implementation 10
A. HSE Monitoring 10
B. Communications 10
4.6 Employee Involvement 10
4.7 Hazard/Risk Identification and Management 11
A. Methods of Hazard Identification 12
B. Systems Approach to Managing Hazards and Risks 12
C. Job Safety Analysis) 13
D. Safety Task Assignment 13
5.0 ROLES AND RESPONSIBILITIES 13
5.1 Project Director/Managing Director/General Manager 13
5.2 Project/Site Manager 14
5.3 Line Management 15
5.4 HSE Board 16
5.5 HSE Representative 17
5.6 HSE Employee/Craft Representative 18
5.7 All Personnel 18
5.8 Contractors 19
5.9 Administration Manager/Office HSE Coordinator 19
6.0 PROJECT STARTUP 20
7.0 ENVIRONMENTAL PLANNING 20
7.1 Water Quality 21
7.2 Air Quality, Including Dust, Emissions, and Odors 21
7.3 Noise and Vibration 21
7.4 Waste Management 21
7.5 Traffic Management 21
7.6 Contaminated Land 21
7.7 Public Relations and Liaison 22
7.8 Wildlife Flora and Fauna and Natural Features 22
7.9 Visual Intrusion, Signs, and Lighting 22
7.10 Archaeology 22
7.11 Worksite Housekeeping 22
8.0 MANAGEMENT OF CHANGE 23
9.0 TRAINING AND EDUCATION 23
9.1 Orientation 23
9.2 Training 23
9.3 Professional Credentialing 24
10.0 AUDITS 24
10.1 Planned Inspections 24
10.2 Project/Site Audits 25
11.0 CONTRACTOR SELECTION 25
12.0 ACCIDENTS AND INCIDENTS MANAGEMENT 25
12.1 Incident Investigation and Reporting 25
12.2 Critical Incident Management 26
12.3 Reporting 26
13.0 Substance Abuse Program 26
14.0 WORKERS’ COMPENSATION 26
15.0 PERFORMANCE INDICATORS 27
16.0 AWARDS PROGRAMS 27
17.0 OCCUPATIONAL HEALTH AND INJURY MANAGEMENT 28
18.0 Travel Safety 28
19.0 DISCIPLINARY ACTIONS 28
20.0 EMERGENCY PREPAREDNESS 28
21.0 MAINTENANCE, INSPECTION, TESTING, AND MODIFICATION 28
22.0 SITE ACCESS AND SECURITY 29
23.0 PERSONAL PROTECTIVE EQUIPMENT 29
24.0 VEHICLES AND MOBILE EQUIPMENT 29
25.0 OVERHEAD HIGH-VOLTAGE SERVICES 29
26.0 BURIED SERVICES 29
27.0 FALL PROTECTION 29
28.0 SCAFFOLDING 29
29.0 LADDERS 29
30.0 ELEVATED WORK PLATFORMS 29
31.0 SAFE WORK/ACT OBSERVATION 29
32.0 WORKING IN HEAT 30
33.0 MANUAL HANDLING 30
34.0 WORKING ALONE 30
35.0 FLOOR GRATING REMOVAL 30
36.0 WORKING ON ROOFS 30
37.0 CRANES AND LIFTING EQUIPMENT 30
38.0 TRAFFIC MANAGEMENT 30
39.0 LOADING, TRANSPORT, AND UNLOADING MATERIALS 30
40.0 HSE HANDOVER 30
41.0 PRESSURIZED EQUIPMENT 30
42.0 EARTHWORK, CONCRETE, AND MASONRY 30
43.0 DRILL AND BLAST OPERATIONS 30
44.0 FIBROUS MATERIALS 31
45.0 RAILROAD SAFETY 31
46.0 MARINE OPERATIONS 31
47.0 CONFINED SPACE ENTRY 31
48.0 ABRASIVE BLASTING 31
49.0 FIRST LINE BREAKS 31
50.0 TANK AND PIPING SYSTEM 31
51.0 SHOP EQUIPMENT AND FACILITIES 31
52.0 HIGH-PRESSURE WATER CLEANING 31
53.0 LAWN EQUIPMENT AND CHAIN SAWS 31
54.0 HOT TAPPING 31
55.0 EATING AND SANITATION FACILITIES 32
56.0 HAND AND PORTABLE POWER TOOLS (INCLUDING POWDER-ACTUATED TOOLS) 32
57.0 MIER AND MSISR REPORTING 32
58.0 RADIATION 32
59.0 EXPOSURE TO HAZARDOUS CHEMICALS/AGENTS 32
60.0 PROCESS SAFETY MANAGEMENT 32
61.0 STEEL ERECTION 32
62.0 HAZARD COMMUNICATIONS 32
63.0 HAZARDOUS ENERGY CONTROL 32
64.0 HOT WORK (WELDING, CUTTING, BURNING) 32
65.0 HAZARDOUS MATERIALS 32
66.0 ELECTRICAL WORK SAFETY 33
67.0 PROJECT CLOSEOUT 33
68.0 HSE ENGINEERING 33
69.0 RECORDS 33
70.0 REFERENCES 33
PURPOSE
This practice identifies and presents in some detail the strategies for executing the Health, Safety, and Environmental (HSE) requirements that are common to office, engineering, and project/site (field) activities.
SCOPE
This practice includes references to over 50 processes and activities common to projects, engineering, and offices worldwide, including the 12 high-impact injury reduction techniques of the ZERO ACCIDENTS SM Program.
APPLICATION
This practice applies to work activities and employees under the control of P2S and its contractors.
DEFINITIONS
ZERO ACCIDENTSSM Program – 12 high-impact injury reduction techniques that have consistently shown exceptional results when fully embraced, implemented, and audited by projects and offices. The 12 techniques are:
- Contractor Management
- Pre-Project HSE
- HSE Education and Orientation
- New Employee Development
- HSE Awareness Program
- Substance Abuse Program
- Recognition and Rewards
- Incident Reporting and Investigation
- Pre-Task Planning
- Management in Action
- Audit/Assessments
- Use of Networking and Resources
OBJECTIVES
The practices are written to be in compliance with the U.S. Occupational Safety and Health (OSHA) standards and regional regulatory requirements. Where an OSHA standard has not been promulgated, the practices are written to be commensurate with recognized health, safety, and environmental (HSE) management programs, such as the Voluntary Protection Program, International Organization for Standardization (ISO)14001, and Occupational Health and Safety Advisory Services’18002. Best management practices and incountry requirements from countries around the world have also been included where applicable.
P2S’s objectives in implementing the P2S HSE Policy and Management System are to:
· Require personal responsibility and accountability for HSE management.
· Incorporate the highest recognized HSE standards into engineering, design, and work processes implemented at all of P2S-managed workplaces.
· Adopt other recognized standards and relevant statutory provisions, as the basis upon which P2S develops its own high standards.
· Provide effective training, efficient communication, and continuous performance review within the HSE Management System.
· Establish and monitor HSE performance targets for P2S’s workplaces, by the use of audits; toolbox meetings; Job Safety Analyses (JSAs), Form 000.653.F0100 and Safety Task Assignments (STAs), Form 000.653.F0101; and project targets (refer to Section13.0 of this practice).
1.0 USE OF CORPORATE PRACTICES
1.1 General
The P2S corporate HSE Management System provides an integrated tool—a set of “requirements documents”— to execute the company’s commitment to continually improving HSE performance.
The requirements documents that make up the HSE Management System are called “practices” and provide minimum HSE-related requirements, as well as how these requirements will be met.
Note: The practices contain excerpts from, and references to, numerous regulations, codes, and standards. The practices do not state the requirements of these regulations, codes, and standards in their entirety. Persons or organizations using these practices must familiarize themselves with such regulations, codes, and standards as appropriate.
These practices apply worldwide to P2S activities and recognize P2S's responsibility to meet––or wherever practical surpass––the relevant statutory requirements, codes of practice, guidance notes, and industry codes and standards. The corporate documents must be used to develop office and project/site-specific HSE procedures and plans, as well as flowed down to contractors for them to either adopt or develop and implement an “equal” HSE Management System.
This approach provides consistency and control in the management of HSE risks. Specific office and project/site procedures and plans may be more stringent than the corporate practices. The more stringent of comparable requirements documents will be used.
It is recognized that there are different requirements and different responsibilities at various locations and/or activities of the corporation. Therefore, specific corporate HSE practices have been developed for office HSE and engineering HSE, as well as those pertaining to project/site (field) HSE operations.
1.2 Deviations
It is understood that there may be valid reasons for deviations to be requested/granted to the corporate HSE Management System practices, as driven by different contract and/or incountry requirements at the project level. Where P2S HSE Management System practices relate to work functions that are not in the direct work scope or area of responsibility, those HSE Management System practices need not be implemented; thus, no request for deviation is required.
However, where HSE Management System practices do relate to the direct work scope and cannot be used, deviations from the P2S HSE Management System practices must be submitted to, and approved by, the Business Unit HSE “lead.” This is accomplished by completing the HSE Management System Compliance and Equivalency (Form 000.653.F0270) and submitting it for approval. When granting deviations, consideration should be given to the impact on client requirements, and contractual and regulatory compliance.
A. Collaboration with Others
When P2S is engaged in collaboration with other parties, such as joint ventures, partnerships, limited liability companies, or alliances, the extent to which the HSE Management System will be applied will be based on written agreement between the collaborating parties.
B. Seconded Employees
When P2S employees work under the managerial control of another organization, such as in supplemental labor arrangements (employees loaned to client organizations), their work may be performed in accordance with the HSE management system of that organization, provided that Form 000.653.F0270 is completed indicating the arrangement, and approved by the Regional Safety Manager.
C. Contracts/Subcontracts
The P2S HSE Management System practices are used unless a project develops its own equally robust procedures.
When a request for proposal is prepared, Practice 000.653.0010, Health, Safety, Environmental Management System – Table of Contents, is appended to the contract. If the successful bidder (contractor) elects to use P2S’s HSE Management System, as indicated at the time of bid, this is noted on the first page of the appendix. If the successful bidder (contractor) elects not to use P2S’s HSE Management System, as indicated at the time of the bid, this is also noted on the appendix.
Therefore, it is important to determine the HSE Management System program that will be used on a project before initiating work.
1.3 Exceptions
In an unusual circumstance where asafety requirement in any practice is not feasible, inappropriate for the specific and unique situation, or presents agreater risk to the employee, awritten justification for exception to the requirement is submitted for approval to the immediate manager/supervisor and HSE Representative. A written justification from a subcontractor requires additional approval of the assigned buyer’s technical representative. Once approved, the exception/justification is included in the Job Safety Analysis (JSA)/Safety Task Assignment (STA) and all affected employees are informed during apre-job briefing. The pre-job briefing is documented in accordance with Practice 000.653.1304.
1.4 Legal Requirements
Each user needs to verify that pertinent legislative and corporate governance requirements, including contract requirements, are met in each specific office or project/site-specific procedure.
2.0 ZERO ACCIDENTSSM PROGRAM
Although they have been around for a while, the high impact ZERO ACCIDENTS reduction techniques continue to show results when used on jobsites. P2S HSE believes these techniques are the basis of a good HSE program, and every project will benefit from implementing them. This program of incident reduction techniques has helped P2S raise the level of expectation for HSE performance and provided the tools for us to make it happen.
P2S Corporate HSE audits (refer to Forms 000.653.F0272 and .F0950) measure how effectively projects and offices execute the ZERO ACCIDENTS techniques. If projects or offices are not adhering to this program, they will not perform well on their audits. Additionally, projects applying for ZERO Accidents awards (One-Star through Five-Star awards) are audited against these techniques.
3.0 SITE-SPECIFIC HSE DOCUMENTS
Procedures and plans are the implementation documents developed at the project level. Client procedures and plans may be substituted or tailored for a particular project if these meet or exceed P2S requirements and are required by the client. Where new or improved procedures have been developed, these should be forwarded to the P2S HSE Board to be considered for future inclusion in the corporate HSE Management System practices.
3.1 HSE Procedures
The site-specific HSE procedures supplement the PPM and describe in detail the HSE and security requirements to be used at the project site.
3.2 HSE Plan
A site-specific HSE “plan” is an overview of how the HSE program and procedures will be implemented. HSE plans are typically 50 pages or less. Modification of Practice 000.653.0020, Health, Safety, and Environmental Management System – Execution, is the preferred method to develop the site-specific HSE plan. However, the HSE section of the Project Execution Plan (PEP) can be considered the site-specific HSE plan.
3.3 HSE Manual
Together, these 2 documents comprise the site HSE manual.
4.0 MAJOR PROGRAM ELEMENTS
4.1 General
HSE incident prevention is a primary responsibility of all levels of the organization. Each manager is directed to use maximum initiative in communication, training, motivation, and monitoring techniques to apply every reasonable precaution to prevent incidents. Each employee is expected to take appropriate steps to eliminate incidents in the workplace.
HSE, as a professional staff function at the project/site level, will directly assist management in the execution of the HSE Management System at the business unit, business line, regional, and project/site level. Each person responsible for the HSE function must exhibit a high degree of professional competency, personal initiative, and effective communication skills in performing his/her duties. Project/Site HSE Representatives will be responsible for consulting with management in all matters affecting the environment and the health and safety of employees, contractor personnel, clients, and the community. Incident prevention responsibilities of managers cannot be delegated.
4.2 Ratio of HSE Representatives to Project Field Employees
The ratio of P2S HSE representatives will be specified by the Business Unite HSE Lead. However, as a general guide, the following will be used for planning purposes:
· When the onsite employee total equals or exceeds 25 employees, a P2S HSE Representative will be dedicated full-time to the responsibilities of the onsite HSE Representative; when the onsite employee total equals or exceeds 50 employees, the HSE Representative will be an HSE professional.
Note: “Onsite employee total” includes employees of P2S, contractors, and sub/lower-tier contractors working full- or part-time on the P2S-managed project site(s).