A risk-based HSSE Management System
The HSSE Management System (HSSE MS) documents describe how your project will fulfill its obligations to protect the environment, employees and the public from potential impacts of its operations and activities. These documents describe the company structure, responsibilities, practices, procedures, processes, resources and expected behaviors needed to implement company policies and any associated objectives and targets. The primary purpose of these documents is to establish a safe workplace where risks to Contractor workers, Client staff, the general public and the environment will be eliminated or minimized - As Low As Reasonably Practical. (ALARP).
The full scope of HSSE MS documents can be impacted by external factors: Project financing; the country in which project is located; commitments to specific standards; national and regional Occupational, Health, Safety and Environmental legislation; national liability issues; and the background and experience of management staff.
What is safe?
When implementing an HSSE MS on a pipeline construction project, the Company/Client/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.
If you don´t know history you are doomed to repeat the mistakes of the past.
Knowledge of construction risks can only be acquired through lessons learned on the right of way. Lack of a comprehensive knowledge of pipeline construction risks during the engineering phase, well before the kick off of construction, when documents and contracts are drawn up, is the single most frequent cause of the failure of an HSSE management system. An HSSE manager and/or HSSE advisor who is experienced with pipeline construction and possesses a detailed knowledge of pipeline construction methodology is an essential member of the management team. Be wary of construction management who may claim to be experts in risk management. They have spent their careers focused on other issues and the extent of their HSSE knowledge is limited. Corporate HSSE managers are often recruited from operations, offshore, or other unrelated industries. Consequently those planning the HSSE project strategy often have little if any practical knowledge of industry specific lessons learned, the equipment capabilities and work methodology. Surprisingly, lessons learned from the right of way during the construction phase are never collated for future projects. This critical knowledge leaves the project in the hands of the HSSE contracted supervision, at the termination of their contract.
H&S vs. Environmental Management
Effective Health and Safety management is more difficult to assess than Environmental management because environmental issues for the most part are quantifiable and H & S issues are perceived as not quantifiable. Physical, biological, social, and archeological baselines are established in the EIA. Many environmental issues such as fauna groups, vegetation sampling points, numbers of bird, mammal, and reptile species, erosion & sediment control, noise and air pollution, vibration, hydrobiology, soil management and agrostology are physically measurable. This simplifies the task of environmental management. Getting Health & Safety management right is much more difficult, because such physical measurements are not available to tell you if a construction technique is safe or not. Consequently there are often disproportionate resources allocated to environment and social impacts, compared to Health and Safety project impacts. Best-practice baselines in safety are limited to regulatory compliance, due to lack of knowledge of lessons learned and a fear of liability. The good news is that practical experience and lessons learned can provide safety best-practice baselines to quantify the risks inherent in the work methodology.
Safety is an attitude and needs to be proactive not reactive.
Your challenge is to create a risk-based HSSE MS. The first priority in the development of an HSSE MS is to identify the risks your workforce will be facing. Knowledge of pipeline construction risks cannot be learned in a school, nor acquired after kick off with Job Safety Analysis´s (JSAs) or other on site risk assessment tools. Success is achieved by developing an HSSE Plan to mitigate specified historic industry risks, as opposed to starting empty-handed and developing a plan to identify the risks. The high risk activities (those activities that are associated with past industry accidents and losses) must be identified in your plan. Mitigation of these risks by the implementation of pipeline industry best-practices must be discussed with your Contractors at the project kickoff meeting(s). Your HSSE Plan should establish your own company´s interpretation of “accepted industry best practices”. Your HSSE Plan is your “top document” within your HSSE Management System, which is comprised of other plans, safe work practices and procedures, method statements, risk assessments, risk register(s) etc. This management concept has been used since the 1940s by following a simple process identified in the diagram below: The Deming Circle.
PLAN – refers to a written HSSE Management System. DO – refers to the implementation of the plans and procedures. CHECK – inspections and audits are conducted to assure compliance with the HSSE Management System documents. ACT – corrective actions are taken to close any gaps identified in the audits and inspections.
OHSAS 18001
HSSE Management Systems are and have been modeled after different Standards. In the 1990s the OHSAS 18001 model became the internationally accepted occupational health and safety management standard, which evolved from, expands on and is very similar to the Deming Circle.
Adherence to the OHSAS 18001 standard will not provide you assurance that all high risk construction activities will be identified, and controls implemented. The standard only assures that you have a written plan to identify risks. Whether or not it is implemented or effective is not evaluated within the certification process.
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. 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.
Pipeline construction work is fast paced, complex and dangerous, where workers are exposed to a menu of constantly changing, life threatening risks. Assurance that your Contractors are OHSAS 18001 certified can give corporate managers a false sense of security. Theoretically OHSAS 18001 is an excellent standard which if fully implemented within the contractor organization on a pipeline construction project, will provide as good a starting point for risk management as could be desired . The OHSAS 18001 standard requires planning for hazard identification, risk assessment and risk control. Certification to the OHSAS 18001 Standard is commonly assumed to include implementation, however 85% of companies are certified by certification bodies, only on the basis of a compliant, written HSSE Management system, without confirmation of an acceptable level of site implementation. The primary and critical issue of whether the management system is actually effective at identifying hazards and risks, is not evaluated within the terms of the standard. Consequently reliance on certification to this standard, can and often does cause disappointment for the Client. This disappointment manifests itself in the unexpected and poor safety culture of OHSAS 18001 certified Contractors. Additionally, within the framework of a lump sum contract, this is often the cause of the Client losing control of HSSE management on their own project. This can be prevented by an OHSAS 18001 implementation audit of shortlisted contractors, prior to contract award, which will provide corporate managers with the data they need to evaluate a potential contractor´s commitment to HSSE.
Knowledge of this commitment is critical for corporate managers in today´s recent history of catastrophic industrial accidents: Exxon Valdez oil spill, Texas City refinery explosion, Deep Water Horizon oil spill, Hungarian Ajka alumina chemical sludge spill, Fukushima nuclear disaster…. because the standard clearly places the organization´s top management as responsible and liable. At the start of a pipeline construction project, managers routinely commit to standards they don´t understand without any concept of how compliance with the specified standard will impact their schedule and costs.
Risk management on pipeline construction projects is an integral part of construction management and cannot be separated from it.
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 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 become mandatory in some countries. 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.
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 “town hall” meetings about introducing to the country new and high standards and strict compliance. Then, as the impact on schedule 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”.
Oil & Gas Companies financing their own projects, as part of an expansion, replacement or looping program are not bound by external 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 this 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.
In instances where a Company has financed an international project, the lenders will have many expectations outlined in an Environmental Impact Assessment (ESIA) 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 a core of construction staff and 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 as different as night and day, 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, often have volumes of HSSE Management Systems documents. The HSSE MS document map of some of these companies is so extensive, that much of the paperwork and processes serve no real purpose in identifying risks, or preventing accidents. Contracted construction 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 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.
If the project is financed by 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 environmental 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 will be responsible to develop Environmental, Social Implementation Plans (ESIPs), that require the approval of the Client.
The Client develops the 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 Plan | HSSE Field Manual | | Pipeline SIMOPS Manual | Contractor Health and Safety Performance Pre-Hire Evaluation | | Ecological Management Plan | Hydrotest Contractor Management Plan (CMP) | | Bio-restoration Plan | Erosion Control and Reinstatement CMP | | Land Acquisition and Compensation Plan | Waste Management CMP | | Grievance Procedure | Pipeline Footprint CMP | | Cultural Heritage Framework Document | Pollution Prevention CMP | | Assessment , Assurance & Improvement Plan | Compliance Monitoring Plan | | Management of Change (MoC) Procedure | Cultural Heritage CMP | | Security Plan | Community Liaison and Consultation CMP | | Community Health Plan | Community Safety and Transportation CMP | | Hazard Identification, Risk Assessment and Management | Community and Stakeholders Awareness | | Health and Safety Management Plan | Organizational structure | | HSSE Training Plan | HSSE Policy Statements | | Transportation & Vehicle Management Plan | Environmental and Social Action Plan (ESAP) | | Contingency Plan | Biodiversity Action Plan. | | Human and Financial/Operational Resources | Environmental and Social Impact Assessment (ESIA) | | Management Review Plan | Employee Development & Performance Plans and Programs | | Records and Record Management Plan | Environment and Social Management Plan Framework Documents | | Monitoring and Measurement Plan | Communication and Consultation Plan | | Performance Indicator Plan | Legal and Regulatory Compliance Plan | | HSSE Targets and Objectives | HSSE Management and Review | | HSSE Training Plan & Matrix | Community Safety Transport Plan | | HSSE Action Tracking Plan | Non Conformance and Corrective Action Procedure | | Incident Analysis and Prevention | Assessment, Assurance and Improvement | | Working with Contractors and Others | Facilities Design and Construction | | People, Training and Behaviors | Operations and Maintenance Plan | | Leadership and Accountability | Crisis and Emergency Management | | Project Execution Plan | HSSE Measures KPIs | |
At a construction kick-off, HAZCON/HAZID, joint risk assessment or other similar initial 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.
On a pipeline construction project risks fall into two categories: Transportation Risks and Work Phase Risks.
- Transportation accidents constitute the highest proportion of HSSE lagging indicators, which can quickly drag down your incident frequency statistics. In countries/regions 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.
- 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. If your project team does not have access to a database of these lessons learned, you would be well advised to bring in an external advisor to enhance your HAZCON risk assessment sessions and provide mentoring for your HSSE staff.
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.
Money Talks
On all projects, locking the Contractor into written detailed HSSE commitments, identified in a contractually binding commitments register, HSSE plans, procedures, and other HSSE documents, is an effective and essential means of delivering an accident free project. Contractually binding documents which identify specific project HSSE standards, objectives, expectations, penalties for non-compliance and rewards for exceptional performance, 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 management will not follow the established plan as closely as they will with monetary penalties attached to non-compliance. These financial incentives ensure that your Contractors allocate sufficient resources to ensure their front line supervision, the right of way foreman, embrace the requirements in your HSSE plans and procedures. The success of your HSSE MS hinges almost entirely on these foreman, many of whom will be, if not illiterate, severely challenged with the volumes of documents. If the Contractor foremen do not buy into the HSSE MS, accidents and losses will occur.
During the selection and preparation of documents, ensuring that the myriad of known risks are controlled through HSSE MS 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. For this reason many project contracts do not contain sufficient Client specified and mandated 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. The larger the percentage of hold back, the better will be the Contractor´s HSSE performance. Additionally, during the engineering phase of the project, early HSSE input into the tender offering, and contractually binding project documents such as the project execution plan, pipeline specifications and other critical project execution documents is essential to ensure that risks will be managed during execution.
Accidents predict injuries
Client project management staff, including HSSE management, may have limited knowledge of the actual work methodology and less knowledge of the pipeline construction industry´s, historic and reoccurring accidents and their causes. If management staff do not have the accrued experience and knowledge of lessons learned, and are not familiar with how the work is executed, they will inevitably be the weak link in your management team, and will need external support. Often this lack of experience in pipeline construction is a consequence of project HR recruitment policies. Industry specific experience takes second place to academic and engineering credentials on recruiting agency internet sites and job application forms, when sourcing HSSE management staff for international projects. HSSE is identified as an “expertise” or “discipline”. The HSSE “discipline” is knowledge of a simple generic system, which cannot be expected to be effective without a parallel knowledge of the complex specific industry sector practices, hazards, risks and lessons learned, to which it is applied. Additionally recruiters may place a priority on their own financial margins, thereby not delivering the CVs of best qualified candidates for the Client to review.
The experience depicted in the many photographs found on this website cannot be gained 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.
You cannot hammer a nail on the internet
After contract award and before the start of construction, the Client will require the Contractor to:
- Break down and itemize the scope of the work.
- Systematically identify associated hazards and risks for each phase of the work.
- Generate a list of all high risk construction activities.
- 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.
- Document these controls in plans and procedures.
- 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:
| Transportation | Legal and Regulatory Compliance | | Leadership and Accountability | HSSE Policy and Management System | | HSSE Management | People, Training and Behaviors | | Hazard Identification, Risk Assessment and Management | Incident Reporting, Analysis and Prevention | | Environmental Management | Pollution Prevention – Air, Noise, Vibration, Water & Soil | | Construction Constraints to Minimise Environmental Impact | Specific Environmental Requirements for Temporary Facilities, Vehicles and Equipment | | Noise Limits Management | Contaminated Land and Biological Hazards | | Emergency Response | Security | | Audits and Inspections | Targets and Objectives | | Training Plan | Motivation and Incentives | | Lifting / Hoisting | Ground Disturbance | | Respiratory Protection | Substances Hazardous to Health | | Health | Vehicle and Equipment Management | | Craft Training | Operators Training and Competency Assurance | | Communication | Waste Management | | Electrical Hazards | Confined Space Management | | Permit to Work | Explosives Management | | Health, First Aid and Medical Treatment | Thermal Stress | | Manual Handling | Food Handling, Storage and Personal Hygiene | | Orientation and Training | Medical Services | | Job Hazard Analyses | Subcontractor Management | | Reports and Records | Designation 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 Entry | Pipe and Materials Handling | | Moving Equipment Under and Working in Proximity to Overhead Power Lines | Use of Heavy Equipment in Proximity to Buried Pressurized Pipelines | | Pipe Hauling, Stringing, Stockpiling, Loading & Offloading | Locating, Day Lighting & Excavating Buried Utilities | | Transportation of Dangerous Goods | Abrasive Blasting | | Tool Maintenance and Inspection | External Pipe Coating Application | | Lower-in | Use of High or Low Voltage Holiday Detectors | | Hydro Test | Propane Management | | Winching | Towing | | Working Alone | Handling Fiber Optic Cable | | X-Ray – Radiographic Inspection | Storage of X-Ray Source | | Electric Water Pumps – Setup and Use | Traffic Management on Public Roads | | Chainsaw use | Hauling Equipment on Public Roads | | Hydrotest water filtering | Spill Response | | Spill Containment | Stream and Water Body Crossings and Sedimentation Control | | Topsoil Separation | Slope Stability and Erosion | | Drainage Management | Improvised sorbent booms | | Diversion Berm Configurations | ROW Two-Toning | | Construction De-Watering Discharges | Washing Restrictions | | Fuel and Chemical Storage and Handling | Water Crossings | | Emergencies and Evacuation | Respiratory Protection | | Blood borne Pathogens | Personal Protective Equipment PPE | | Hazard Communication | Non Destructive Testing | | Housekeeping | Fire Prevention | | Floor and Wall Openings | Scaffolding | | Heat and Cold Stress | Hearing Conservation | | Air Sampling & Monitoring | Barricades | | Excavation and Trenching | Confined or Enclosed Spaces | | Hazardous Work Permit | Portable Ladders | | Compressed Gas Cylinders | Electrical Equipment | | Safety Watches | Asbestos Hazards | | Radiation Protection | Medical Surveillance | | Drinking Water and Ice | Night Work | | Railroad Crossings | Road Crossings | | Side boom, Crane and Material Handling | Fire Prevention and Protection | | Smoking Regulations | Rigging | | Emergency Flushing of Eyes and/or Body | Office HSSE | | Fiber Optic Hazard Recognition | Lasers | | Washing Facilities | Lunch Rooms | | Concrete Products | Saws | | Jacks, Rollers and Related Devices | Pile Driving and Dredging | | Transportation of Workers | Exits | | Flag persons | Propane LPG | | Rollover Protective Structures (ROPS) | Root Cause Analysis | | Occupational Health Records | Government 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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