Health, Safety, Security & Environmental (HSSE)
Management Consulting Services for the Pipeline
Construction Industry
HSSE Management System (MS) Documents

Peter Kinsey

 
Pipeline Construction
Hazard Recognition & Risk Management

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HSSE Management System (MS) Documents

The number and type of documents comprising a project's HSSE Management System (HSSE MS) will depend on numerous factors: Project financing; the country in which project is located; commitments to specific standards; national Occupational, Health, Safety and Environmental legislation; national liability issues; the background and experience of management staff….

An HSSE Management System (HSSE MS) is comprised of many documents, which on different pipeline construction projects, serve different purposes. The primary purpose is to establish a safe workplace where risks to Contractor workers, Client staff, and the general public will be eliminated or minimized as far as is practical. The project HSSE Management System documents describe how the project will fulfill its obligations to protect the environment, employees and the public from potential impacts of its operations and activities. This is the basic function of the HSSE MS documents, which describe the company structure, responsibilities, practices, procedures, processes, resources and expected behaviors needed to implement company policies and any associated objectives and targets. This document system also provides the information and tools, management needs to identify, assess and control HSSE risks. Additionally there are other factors that come into play, which shape a project’s HSSE document map.

In instances where a Company has financed an international project, the lenders will have many expectations that will require the development of numerous, predominantly Environmental and Social documents within the HSSE MS. Oil & Gas Companies with experience managing international pipeline construction projects generally have an established Company Construction HSSE MS. Companies lacking an experienced construction team, often start a project with a severe handicap. Such companies may implement an existing company Operations HSSE MS to control the risks associated with the construction process, not recognizing that operational risks and construction risks are very different and must be managed using different methods. Additionally, a construction and HSSE management team with little or no practical knowledge of pipeline construction, may be recruited for the project, drawn from the company’s offshore exploration or refinery sectors.

International Oil & Gas companies, accustomed to working under International Financial Institution (IFI) standards, with head offices and operational practices originating in demographic regions with well established standards which are habitually complied with, have sophisticated HSSE Management Systems (HSSE MSs) with prolific paper trails. The HSSE MS document map of some companies is so extensive, that much of the paperwork becomes an end unto itself, and serves no real purpose in identifying risks, or preventing accidents. Contracted management staff who have worked for these Oil & Gas companies on other projects, may wrongly assume that this familiar HSSE MS is the pipeline industry standard. An HSSE MS comprised of many volumes of documents does not necessarily deliver a safer project. HSSE Management Systems have to be tailored to the requirements of the stakeholders, the safety culture of the national workforce and other variables, and may be different from project to project.

Oil & Gas Companies financing their own projects, as part of an expansion, replacement or looping program are not bound by all the above mentioned IFI standards and guidelines. Established Pipeline Operators, with long experience in expansion and looping construction, may have management staff with many years of on-site construction experience in all aspects of pipeline construction. These companies will possess a proven Construction Safe Operations Manual, which will be referenced within the contract, and so be contractually binding. All parties, Contractors included, will be accustomed to complying with the established construction practices in the manual. The Contractors working for these pipeline operators will have a Company Safety Manual, which establishes an HSSE Policy, and includes an inventory of Safe Work Practices and Procedures and specific Environmental Guidelines. On these types of projects industry standards are known and accepted. The HSSE MS documentation for this type of pipeline construction scenario will be limited and streamlined, and the work will be executed quickly and safely.

When implementing an HSSE MS on a pipeline construction project, the Company/Owner is repeatedly faced with the ambiguity inherent in the question: " Is it safe? " What is "safe" to one person, may represent "unacceptable risk" to another, depending on levels of experience and where that experience was accrued. Different project personnel will have different and conflicting answers to that simple question, often tempered by personal priorities. Environmental issues such as erosion & sediment control, noise pollution, vibration, air & water quality, soil… are physically measurable, which simplifies the task of environmental management. With respect to Health & Safety management, such physical measurements are not available to tell you if a construction technique is safe or not. Only practical experience can answer that question.

If the project is financed by an International Financial Institution (IFI) or other similar lender institution, there will be many conditions attached to the loans, which will include adherence to IFI environmental, safety and social standards, guidelines, and recommended practices (IFC EHS Guidelines). These IFI conditions will be incorporated into plans and procedures within a structured HSSE MS which provides assurance to the bank, that the project will be executed within the parameters of their established standards, and in so doing, address national socio-economic and cultural conditions. This HSSE MS provides an organized framework to address these conditions and to execute the project under an established set of HSSE controlling plans and procedures. There will be HSSE Management documents that define the overall commitments and principles under which the project will be executed such as:

  • Health, Safety, Security and Environmental Integrated Management System (HSSE IMS) Document or Manual.
  • Environmental Standards Document which summarizes the applicable national and international standards and guidelines and defines the project commitments.
  • Commitments Register that contains all the Project HSSE commitments, as derived from the ESIA Source Documents.

There will be Client Management Plans which define procedures for which the Client is responsible and Contractor Management Plans (CMPs) for which the Contractor is responsible. Commitments from the commitments register will be transformed into Contractor actions within the CMPs. These CMPs become contractual requirements. Contractors are required to prepare compliant Plans and Procedures which will be consistent with Client Management Plans.

The Contractor is responsible for Environmental, Social Implementation Plans (ESIPs), that require the approval of the Client. At the construction kick-off meeting, high risk activities will be defined for which the Contractor will be required to develop Method Statements with accompanying risk assessments and/or plans, safe work practices and procedures.

The Client develops an HSSE Management System well before the tender invitations, which after contract award, the Contractor’s HSSE Management System will be expected to mirror.

Examples of these Plans and Procedures are listed in the table below:

Project Execution PlanHSSE Field Manual
Pipeline SIMOPS ManualContractor Health and Safety Performance Pre-Hire Evaluation
Ecological Management PlanHydrotest Contractor Management Plan (CMP)
Bio-restoration PlanErosion Control and Reinstatement CMP
Land Acquisition and Compensation PlanWaste Management CMP
Grievance ProcedurePipeline Footprint CMP
Cultural Heritage Framework DocumentPollution Prevention CMP
Assessment, Assurance & Improvement PlanCompliance Monitoring Plan
Management of Change (MoC) ProcedureCultural Heritage CMP
Security PlanCommunity Liaison and Consultation CMP
Community Health PlanCommunity Safety and Transportation CMP
Hazard Identification, Risk Assessment and ManagementCommunity and Stakeholders Awareness
Health and Safety Management PlanHSSE Policy Statements
HSSE Training PlanOrganizational structure
Transportation & Vehicle Management PlanEnvironmental and Social Action Plan (ESAP)
Contingency PlanBiodiversity Action Plan.
Human and Financial/Operational ResourcesEnvironmental and Social Impact Assessment (ESIA)
Management Review PlanEmployee Development & Performance Plans and Programs
Records and Record Management PlanEnvironment and Social Management Plan Framework Documents
Monitoring and Measurement PlanCommunication and Consultation Plan
Performance Indicator PlanLegal and Regulatory Compliance Plan
HSSE Targets and ObjectivesHSSE Management and Review
HSSE Training Plan & MatrixCommunity Safety Transport Plan
HSSE Action Tracking PlanNon Conformance and Corrective Action Procedure
Incident Analysis and PreventionAssessment, Assurance and Improvement
Working with Contractors and OthersFacilities Design and Construction
People, Training and BehaviorsOperations and Maintenance Plan
Leadership and AccountabilityCrisis and Emergency Management
Project Execution PlanHSSE Measures KPIs

HSSE Management is all about identifying hazards, managing risks, and regulatory compliance. Success is achieved by establishing and enforcing safe work practices and procedures and molding behaviors within the workforce. Safety is an attitude and needs to be proactive not reactive.

On a pipeline construction project risks fall into two categories: Transportation Risks and Work Phase Risks.

  1. Transportation accidents constitute the highest proportion of HSSE lagging indicators, which can quickly drag down your incident frequency statistics. In areas that have extremely rugged terrain, poor road maintenance, and zero safe driving culture, the project’s Transportation Management Plan becomes a project HSSE document critical in delivering target HSSE goals.
  2. Work Phase Risks are known. The Pipeline Construction Industry is more than 60 years old. The equipment and methodology have not changed a great deal over time. Many lessons have been learned. Application of these lessons learned through seamless on site supervision will deliver project target HSSE goals.

Some countries have highly developed national Occupational Health and Safety (OH&S) legislation, including stringent due diligence legislation, which assigns accountability and culpability following accidents. These countries have a highly trained and skilled itinerant workforce which follows the pipeline work from place to place, often crossing national boundaries. Here an extensive Craft Training Plan may not be necessary. In these countries a simple requirement for compliance with the national regulatory requirements will mitigate a lot, but not all risks. Rules and regulations may exist, but people the world over, inherently do not like to obey rules. In these countries the importance of the Motivation and Incentives Plan may take on more significance. In other countries that have only token or poorly developed OH &S national legislation, more extensive plans and procedures may need to be considered to effectively control risks.

On all projects, locking the Contractor into a written detailed HSSE commitments identified in contractually binding plans, procedures and other documents is an effective means of delivering an accident free project. Contractually binding documents which identify specific project HSSE standards, objectives, expectations and penalties for non-compliance provide the assurance that all Health, Safety and Environmental hazards and risks will be identified and controlled and the work performed in a manner that will not pollute the environment, nor expose the workers and general public to risks. Without penalties for non compliance, the Contractor may not follow the established plan as closely as with monetary penalties attached to non-compliance. However, during the selection and preparation of documents, ensuring that the myriad of known risks are controlled through HSMS documentation, must be balanced against a clear liability associated with giving direct instructions to the Contractor of how to execute the work.

Perceived liability can play a significant part in steering the HSSE planning of many projects and for this reason many project contracts do not contain sufficient Client specified HSSE requirements. Withholding a percentage of payments for poor HSSE performance, as measured by periodic project key performance indicator audits, is a common and effective method to assure Contractor compliance. Additionally, during the technical planning of the project, early input into the tender offering, project execution plan, pipeline specifications and other critical project execution documents is essential to ensure that risks will be managed during execution.

Client project management staff, including HSSE management, may have limited knowledge of the actual work methodology and less knowledge of the pipeline construction industry, historic and reoccurring accidents and their causes. Accidents predict injuries. If an HSSE staff do not have the experience and knowledge of lessons learned, and are not familiar with how the work is executed, they may be a weak link in your management team. Management must ensure that lack of experience in pipeline construction is not a consequence of project HR recruitment policies. Recruiting agencies, when sourcing HSSE management staff for international projects, invariably place a prerequisite for qualification and selection on academic credentials. Unfortunately the experience depicted in the many photographs found on this website cannot be gained from theory alone or directly from engineering textbooks. Nor can you learn from a textbook how to talk to, engage and gain the respect of the men and women in the industry’s workforce. Without this ability to discuss the work processes in a knowledgeable manner and thereby engage the workers, your HSSE management will be ineffective. Safety cannot be managed on a computer screen from a distance. It must be managed primarily onsite, at ground level, through interaction with the workforce.

Standards are accepted specifications which define methods, processes and practices. Experience has shown that compliance with a standard will never guarantee a total satisfactory performance. Accidents continue to happen. In many cases pipelines were constructed faster and just as safely, before the formulation of many of today’s accepted industry HSSE standards. Compliance with a standard may require substantial additional internal and external resources to develop additional HSSE documents, and implement compliance assurance auditing. All this can be expensive to implement and maintain. Some standards are referenced in legislation and have now in some countries become mandatory. Standards can be used in litigations as "accepted industry practices", incurring liability if not all aspects of the standard have been implemented. Consequently there is a liability associated with integrating Standards into your HSSE MS. Risk management on pipeline construction projects is an integral part of construction management, cannot be separated from it and cannot be entirely standardized.

There are many recognized standards: ANSI, ASME, OSHA, OHSAS 18001, UNE 81902, SA 8000, NFPA, DOT, BSI, CDM Regulations, DNV, SCC, TÜV, EU, ILO-OSH, ISO 14001, , ISO 9001… Frequently, project management commits to compliance with complex standards, such as OSHA without a full understanding of how such compliance will impact the project. The project starts off with high-profile declarations at public meetings about introducing to the country new and high standards and strict compliance. Then, as the impacts and costs of compliance become known, management surreptitiously backs off from their initial enthusiasm and their commitment to compliance is diluted into declarations of using OSHA or other standards as "guidelines for improvement".

Alignment with OHSAS 18001, although not universally adopted, is more often than not, a project expectation, now that more than forty countries have adopted it as a standard. OHSAS 18001 is a generic standard, against which any enterprises’ Occupational Health and Safety Management System (OH&S MS) can be assessed and certified. It was developed in the 1990s and officially released in April 1999. Pipeline construction work is fast paced, complex and dangerous, where workers are exposed to a menu of constantly changing, life threatening risks. The elements of the 18001 standard: Continual Improvement; Management Review; OH&S Policy; Planning; Checking and Corrective Action; Implementation and Operation…are a good starting point. Because of acceptance of this standard, today most HSSE Management Systems are very similar in scope.

After contract award and before the start of construction, the Client will require the Contractor to:

  1. Break down and itemize the scope of the work.
  2. Systematically identify associated hazards and risks for each phase of the work.
  3. Generate a list of all high risk construction activities.
  4. Assess risks associated with each activity and develop controls to eliminate or reduce risks to a tolerable and as low as reasonable and practical level.
  5. Document these controls in plans and procedures.
  6. Provide a list of these HSSE document deliverables.

At the kick-off meeting, Client and Contractor will agree to the list of deliverables.

Typical Contractor HSSE Documentation Deliverables (not limited to the following):

  • Project baseline HSSE plans:

TransportationLegal and Regulatory Compliance
Leadership and AccountabilityHSSE Policy and Management System
HSSE ManagementPeople, Training and Behaviors
Hazard Identification, Risk Assessment and ManagementIncident Reporting, Analysis and Prevention
Environmental ManagementPollution Prevention – Air, Noise, Vibration, Water & Soil
Construction Constraints to Minimise Environmental ImpactSpecific Environmental Requirements for Temporary Facilities, Vehicles and Equipment
Noise Limits ManagementContaminated Land and Biological Hazards
Emergency ResponseSecurity
Audits and InspectionsTargets and Objectives
Training PlanMotivation and Incentives
Lifting / HoistingGround Disturbance
Respiratory ProtectionSubstances Hazardous to Health
HealthVehicle and Equipment Management
Craft TrainingOperators Training and Competency Assurance
CommunicationWaste Management
Electrical HazardsConfined Space Management
Permit to WorkExplosives Management
Health, First Aid and Medical TreatmentThermal Stress
Manual HandlingFood Handling, Storage and Personal Hygiene
Orientation and TrainingMedical Services
Job Hazard AnalysesSubcontractor Management
Reports and RecordsDesignation and Training of HSSE Representatives
  • Project Safe Work Practices and Procedures for each of 30 – 200 High Risk Activities, depending on the complexity of project

Confined Space – Pipe EntryPipe and Materials Handling
Moving Equipment Under and Working in Proximity to Overhead Power LinesUse of Heavy Equipment in Proximity to Buried Pressurized Pipelines
Pipe Hauling, Stringing, Stockpiling, Loading & OffloadingLocating, Day Lighting & Excavating Buried Utilities
Transportation of Dangerous GoodsAbrasive Blasting
Tool Maintenance and InspectionExternal Pipe Coating Application
Lower-inUse of High or Low Voltage Holiday Detectors
Hydro TestPropane Management
WinchingTowing
Working AloneHandling Fiber Optic Cable
X-Ray – Radiographic InspectionStorage of X-Ray Source
Electric Water Pumps – Setup and UseTraffic Management on Public Roads
Chainsaw useHauling Equipment on Public Roads
Hydrotest water filteringSpill Response
Spill ContainmentStream and Water Body Crossings and Sedimentation Control
Topsoil SeparationSlope Stability and Erosion
Drainage ManagementImprovised sorbent booms
Diversion Berm ConfigurationsROW Two-Toning
Construction De-Watering DischargesWashing Restrictions
Fuel and Chemical Storage and HandlingWater Crossings
Emergencies and EvacuationRespiratory Protection
Blood borne PathogensPersonal Protective Equipment PPE
Hazard CommunicationNon Destructive Testing
HousekeepingFire Prevention
Floor and Wall OpeningsScaffolding
Heat and Cold StressHearing Conservation
Air Sampling & MonitoringBarricades
Excavation and TrenchingConfined or Enclosed Spaces
Hazardous Work PermitPortable Ladders
Compressed Gas CylindersElectrical Equipment
Safety WatchesAsbestos Hazards
Radiation ProtectionMedical Surveillance
Drinking Water and IceNight Work
Railroad CrossingsRoad Crossings
Side boom, Crane and Material HandlingFire Prevention and Protection
Smoking RegulationsRigging
Emergency Flushing of Eyes and/or BodyOffice HSSE
Fiber Optic Hazard RecognitionLasers
Washing FacilitiesLunch Rooms
Concrete ProductsSaws
Jacks, Rollers and Related DevicesPile Driving and Dredging
Transportation of WorkersExits
Flag personsPropane LPG
Rollover Protective Structures (ROPS)Root Cause Analysis
Occupational Health RecordsGovernment Agency Inspections
  • Method Statements
  • Completed risk assessments
  • Minutes of job hazard Analyses
  • Minutes of toolbox talks
  • Minutes of all HSSE meetings
  • Completed HSSE compliance assurance inspections
  • Internal HSSE audits
  • External audit reports
  • Vehicle and Equipment monitoring, maintenance and repair documentation
  • HSSE and technical Certifications required by the Authorities Having Jurisdiction
  • Weekly /Monthly HSSE reports
  • Training records
  • Competency assurance records
  • Reports of progress towards meeting objectives and targets
  • Non-conformance and corrective actions reports
  • Incident, Accident, Near Miss and investigation reports
  • First Aid Records
  • Accident/Incident investigations
  • Spill reports
  • Loss Prevention records
  • Key Performance indicator records

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