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SEA HIBISCUS SDN BHD

Management System
Health, Safety, Security and Environment
Management System Manual

Alvin Yumpud
Roy @ Ambok
0 08/08/2019 1st Issue Document Pascal Hos
Sakka Patiroi
Hatta Mansor

Roy @ Ambok Alvin Yumpud


A 29/07/2019 First Draft Document Pascal Hos
Sakka Patiroi
Hatta Mansor
REV DATE DESCRIPTION ORIGINATOR REVIEWER APPROVER
IP Security Company Confidential Total number of Pages (including Cover sheet):
Company Originator Asset / Facility Functional Discipline Sub-Doc. Sequence- Rev
Doc. Type
Document Project Code Code Dept Type Sheet
Control No.
Document Title: HSSE MS
Document Number: SEAH-00-GEN-HSSE-MD-MAN-NA-0001
Revision: 0

DOCUMENT REVISION HISTORY


REVISION AUTHORISATION

Rev. Changed Changed


Date Endorsed Endorsed Approved
No. Section By

SUMMARY OF REVISIONS

Rev. No. Date By Description of Key Changes

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A. PROCESS SUMMARY

SEA Hibiscus (SEAH) Health, Safety, Security and Environment Management System (hereinafter also
referred to as HSSE Management System, abbreviated as HSSEMS) defines the Company’s HSSE policy,
strategic objectives, organisation and the arrangements which are necessary to manage the identified
health, safety and environmental risks associated with SEA Hibiscus activities.
The purpose of the HSSE Management System is to ensure that:

 The health, safety, security and environmental risks inherent in SEA Hibiscus operations have been
systematically identified;
 Arrangements are in place to control these risks and to deal with the consequences should the needs
arise; and
 The necessary information, training, auditing and improvement processes are in place to achieve these
objectives.

B. SCOPE

All requirements defined in this HSSE Management System shall apply equally for SEA Hibiscus operations,
including contractors engaged in work for the Company.

C. ROLES AND RESPONSIBILITIES

The owner of this HSSE Management System is SEA Hibiscus (SEAH) Chief Executive Officer. As the
owner, he is responsible for issuing the HSSEMS Manual under his signature and issuing clear directives
to the Custodian on HSSEMS changes.

The Custodian of the HSSE Management System Manual is the Head of Department, HSSE.

Reviews and amendments to the HSSE Management System Manual shall be approved by SEA Hibiscus,
HSSE Department.

D. HSSEMS MANUAL STRUCTURE

The HSSE Management System Manual comprises three (3) parts as follows. A brief summary of the
content of each part is as given below.

HSSE Management Syst em


Manual

Part 1 Part 2 Part 3


Management System Appendices Reference Documents
Elements and Standards

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D.1. PART 1: MANAGEMENT SYSTEM ELEMENTS

Describe SEA Hibiscus management system element, under the following headings:
 Leadership and Commitment;
 Policy and Strategic Objectives;
 Organisation, Resource, Competency and Documentation
 Suppliers and Contractors HSSE Management
 Hazard and Effects Management
 Planning and Procedures
 Implementation and Monitoring
 HSSE Assurance
 Management Review

D.2. PART 2: APPENDICES

Provide reference for typical HSSE hazards associated with SEAH Business and Organisation Charts:
 Typical HSSE hazards associated with SEA Hibiscus Business
 Organisation Charts

D.3. PART 3: REFERENCE DOCUMENTS AND STANDARDS

Provide a comprehensive list of documents and standards referred to in the preparation of Part 1 of the
HSSE Management System.

E. RECORD

The Head of Department, HSSE shall be responsible for maintaining the HSSE Management System Manual
and the associated health, safety and environmental procedures/guidelines.

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HSSE MANAGEMENT SYSTEM

MS Element MS Sub-Element

1. Leadership and 1.1 Leadership and Commitment


Commitment

2.1 SEAH HSSE Policy


2. Policy andStrategic
2.2 SEAH HSSE-related Policies
Objectives
2.3 HSSE Strategic Objectives

3.1 HSSE Governance


3.2 Roles, Responsibilities and Accountabilities
3. Organisation, &
3.3 Resources, Training and Competency
Resources
3.4 Communication Processes
3.5 Documentation

4.1 Hazard and Effects Management Process


4. Hazard and Effects 4.2 HSSE Risk Screening Criteria
managementsystem 4.3 Performance Criteria for Maintaining Controls
4.4 SEAH Risk Management Requirement

5.1 HSSE Plan


5.2 Asset Integrity
5. Planning and
Procedure 5.3 Procedures and Work Instructions
5.4 Management of Change
5.5 Crisis, Emergency and Contingency Planning

6.1 Performance Monitoring


6. Implementation and 6.2 Records
Monitoring 6.3 Non-compliance and Corrective Actions
6.4 Incident Investigation and Follow Up

7.1 HSSE Assurance Planning


7. Audit and Assurance 7.3 HSSE Management System Assurance
7.3 Technical HSSE Assurance
7.4 External HSSE Assurance

8. Management Review 8.1 Management Review

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HSSE MANAGEMENT SYSTEM

ELEMENT 1: LEADERSHIP AND COMMITMENT

1.1 LEADERSHIP AND COMMITMENT

1.1.1 Purpose

This Sub-Element defines SEA Hibiscus expectation, from leaders at all levels, for visible expression of
leadership and commitment that is consistent with the SEA Hibiscus aspiration to creating and sustaining
a culture that support the effective functioning of the HSSE Management System.

1.1.2 Scope

The leadership and commitment for HSSE, including the commitment to provide adequate resources on
health, safety, security and environment (HSSE) matters, is expected of all leaders throughout SEA Hibiscus
operations, including Contractors engaged in work for the Company.

1.1.3 Expectations

1.1.3.1 As a general guideline, the commitments expected from the various levels of leadership are as follows:-

1.1.3.1.1 Management (Chief Executive Officer, Chief Operation Officer, and Senior Managers)

Management shall provide strong, visible leadership and commitment, and ensure that this commitment
is translated into the necessary resources to develop, operate and maintain the HSSE Management System
and to accomplish the HSSE Policy and Strategic Objectives.

1.1.3.1.2 Line Management (Managers and Senior Executives)

Line Management shall provide strong, visible leadership and commitment, and ensure that full account
is taken of the HSSE policy requirements and shall provide support for actions taken to protect health,
safety, security and the environment within their sphere of influence.

1.1.3.1.3 All Employees

Employees at all levels in SEAH shall demonstrate their commitment to HSSE requirements and ensure
that these are given priority and not compromised in any activity.

1.1.3.1.4 Contractors

Contractors shall actively contribute to the creation and sustenance of a culture that support the HSSE
Management System through its policy, strategic objectives, initiatives and action plan.

1.1.3.2 Visibility

Leadership at all levels, including Contractors, is expected to demonstrate their visibility through:

(1) Communicating SEA Hibiscus HSSE Policy, objectives and requirement to other employees and
Contractors;
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(2) Actively participating in HSSE activities such as, but not limited to, site visits, trainings, audit/assurance,
workshops, campaigns and conferences; and

(3) Driving the process for HSSE excellence which provides a culture where employees and Contractors
are well informed and motivated towards improving HSSE performance.

1.1.3.3 Proactive In Target Setting

Leadership at all levels, including Contractors, is expected to demonstrate their proactiveness in target
setting through:

(1) Steering the development of leading and lagging HSSE key performance indicators and targets,
including improvement targets, in consultation with employees and Contractors; and

(2) Appraising employees performance against the agreed HSSE objectives and targets in Individual
Performance Contract (or equivalent) and reward accordingly.

1.1.3.4 Informed Involvement

Leadership at all levels, including Contractors, is expected to demonstrate their informed involvement
through:

(1) Making available the necessary information and resources for the development and review of the HSSE
Management System and its associated procedures, as part of continuous improvement process; and

(2) Steering the effective implementation of the HSSE Management System, including leading
improvement efforts, taking into consideration the priority areas and the status of follow up remedial
programmes.

1.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Records of site visits (HSSE and others);

(2) Minutes of HSSE-related meetings;

(3) Records on participation in HSSE-related activities e.g. incident investigation, HSSE meetings, HSSE
trainings/seminars/conferences, HSSE assurance/inspection, HSSE KPI setting, HSSE risk assessment,
etc.

(4) HSSE Strategies, Initiatives and Plan, including HSSE Management System Implementation Plan;

(5) HSSE KPI (both leading and lagging) and targets and record of reviews;

(6) Annual Individual Performance Contract (or equivalent) and record of appraisal; and

(7) HSSE awards and recognition programmes.

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HSSE MANAGEMENT SYSTEM

ELEMENT 2: POLICY AND STRATEGIC OBJECTIVES

2.1 SEA HIBISCUS HSSE POLICY

2.1.1 Purpose

SEA Hibiscus Health, Safety, Security and Environment Policy (hereinafter also referred to as SEA Hibiscus
HSSE Policy) provides the direction on how issues relating to health, safety, security and the environment
are to be managed and integrated into the overall business process throughout SEA Hibiscus.

2.1.2 Scope

SEA Hibiscus HSSE Policy shall apply throughout its operations, including Contractors engaged in work
for the Company.

2.1.3 Expectations

2.1.3.1 SEA Hibiscus HSSE Policy quoted hereunder, states as follows:

QUOTE
SEA Hibiscus is committed to Health, Safety, Security and Environment (HSSE) and shall take
reasonable and practicable steps to prevent and eliminate the risk of personal injury, occupational
illnesses and damage to properties. SEAH shall take proactive steps and measures in the
protection and the conservation of the environment.

In line with the Policy Statement on Health, Safety and Environment, SEA Hibiscus shall therefore:

Comply with HSSE legal requirements wherever we operate;


Implement effective risk control measures in all our activities; including operations covering
acquisition, exploration, development, production and abandonment, which will eliminate,
prevent or reduce risks to a level as low as reasonably practicable;

Build an effective and resilient HSSE Management System as an integral part of our business
philosophy and cultivate a desired HSSE Culture;

Provide competent workforce, adequate resources and organisation in all our activities in
ensuring a safe environment at the workplace;

Promote HSSE engagement between joint venture partners, regulatory authorities, Contractors
and key stakeholders;

Drive and promote continuous improvement in HSSE performance;

Establish effective crisis management and emergency response capabilities in all our operations

SEA Hibiscus requires all its employees, Contractors and others to strictly adhere to this policy at
all times. Joint venture partners are expected to implement an effective HSSE Management
System which is in line with industry best practices.
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2.1.3.2 SEA Hibiscus HSSE Policy shall be reviewed at least once in five years.

2.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of SEA Hibiscus HSSE Policy in English and Bahasa Melayu;

(2) Displayed conspicuously at strategic locations throughout workplaces;

(3) Records of policy revision including stakeholders review; and

(4) Evidence including records of dissemination and communication of the SEA Hibiscus HSSE Policy to all
employees and Contractors.

2.2 SEA Hibiscus HSSE-Related Policies

2.2.1 Purpose

SEA Hibiscus HSSE-related Policies (also referred to as daughter policies) are developed in line with
and to complement SEA Hibiscus HSSE Policy.

2.2.2 Scope

SEA Hibiscus HSSE-related Policies shall apply throughout SEA Hibiscus operations, including
Contractors engaged in work for the Company.

2.2.3 Expectations

The expectations of the following HSSE-related policies shall be complied with:

2.2.3.1 Stop Work Policy quoted hereunder, states as follows:

QUOTE
SEAH Management is committed to giving priority to Health, Safety, security and Environment
wherever endeavour to take every reasonable and practicable step to minimise or eliminate the
risk of injuries, health hazards, damage to properties or environment.

It is the SEAH policy that all employees including contractor staff, shall stop work when there is
an imminent and real threat which can physically endanger them and others or cause adverse
impact to environment.

This Stop Work Policy has the full support of Management. When there is doubt on whether work
should continue, employees including contractor staff, should promptly notify their immediate
supervisor for assessment of the hazardous condition.

2.2.3.2 Drug and Alcohol Policy quoted hereunder, states as follows:

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QUOTE
In accordance with Our Health, Safety, Security and Environment Policy, SEAH recognises that any
drug and alcohol abuse will affect the employees’ work performance and can be a threat to the
company’s operations. It is the company policy that its employees and workplaces are free from
drug and alcohol abuses in line with SEAH Code of Conduct and Discipline.

This policy shall be enforced through drug and alcohol-free programmes of prevention,
counselling and rehabilitation, as prescribed under SEAH Drug and Alcohol-Free Workplace
Programme. Employees who are found to be in contravention of the said shall be subjected to
disciplinary action.

The company requires all its employees, contractors and others to strictly adhere to this policy at
all times.

2.2.3.3 Environmental Objective Statement Policy quoted hereunder, states as follows:

QUOTE
In line with SEAH Health, Safety, Security and Environment Policy, SEAH, in undertaking the
exploration, development and production oil and gas, shall enhance its environmental
management through the following:

Identify and assess environmental risks/ impacts associated with business activities and provide
control measures to eliminate or minimizes the risks/ impact to a level as low as reasonable
practicable (ALARP).
Comply with applicable environmental legislation wherever we operate and other requirements
that SEAH subscribes to.

Establish and review environmental objectives and targets and monitor and analyse
environmental performance for continuous improvement.

Promote the use of environmentally friendly material, affective utilization of natural resources
and efficient work processes for the prevention of pollution.

Provide forum for employees, joint venture partners, contractors, and key stakeholders actively
participate in environmental programmes.

Undertake effective recovery and restoration measures to minimise the impact of environmental
incident.

Perform periodic and comprehensive environmental management assurance and implement


appropriate corrective action to eliminate non-conformances.

2.2.3.4 SEA Hibiscus HSSE-related policies shall be written in an understandable language. The policies
shall be prominently displayed at strategic locations throughout work locations.

2.2.3.5 Line management shall explain the personal relevance of the HSSE- related policies to their
respective employees and Contractors, such that employees and Contractors are able to explain
their roles in fulfilling the requirements of the policies.

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2.2.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of SEA Hibiscus HSSE-related policies, including in English and Bahasa Melayu;

(2) Displayed conspicuously at strategic locations throughout workplaces; and

(3) Evidence, including records of dissemination and communication of the SEA Hibiscus HSSE-related
policies to all employees and Contractors.

2.3 HSSE Strategic Objectives

2.3.1 Purpose

SEA Hibiscus HSSE Strategic Objectives (also referred to as HSSE Strategies and Initiatives) provides
the standard framework on how the intent and objectives of SEAH HSSE Policy are to be implemented
throughout the Company.

2.3.2 Scope

SEA Hibiscus HSSE Strategic Objectives shall apply throughout its operations; and shall be the basis
for the development of Company HSSE Plan.

2.3.3 Expectations

2.3.3.1 SEA Hibiscus HSSE Strategic Objectives shall be developed to operationalise the intent and
objectives of SEA Hibiscus HSSE Policy. The HSSE Strategic Objectives shall address both long term
and short term HSSE strategies and initiatives, and aimed at enhancing the implementation of
SEA Hibiscus HSSEMS and continual improvement in HSSE performance.

2.3.3.2 SEA Hibiscus HSSE Strategic Objectives shall be in line with SEA Hibiscus HSSE Policies, and shall
be subjected to annual review as part of the Company business planning process.

2.3.3.3 SEA Hibiscus HSSE Strategic Objectives shall be communicated throughout its operations, and
shall be used as a basis in the development of Company HSSE Plan.

2.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of SEA Hibiscus HSSE Strategic Objectives, including records of annual review;

(2) Company HSSE Plan; and

(3) Records of dissemination on the SEA Hibiscus HSSE Strategic Objectives.

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HSSE MANAGEMENT SYSTEM

ELEMENT 3: ORGANISATION, RESOURCES, COMPETENCY AND DOCUMENTATION

3.1 HSSE GOVERNANCE

3.1.1 Purpose

This Sub-Element defines the governance and guiding principles with respect to delineation of HSSE roles,
responsibilities and accountabilities SEA Hibiscus.

3.1.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEA Hibiscus operations, including
Contractors engaged in work for the Company.

3.1.3 Expectations

3.1.3.1 SEA Hibiscus HSSE Department is the highest-level decision-making body on health, safety,
security and environmental matters for SEA Hibiscus operations. Apart from approving the
Company HSSE Policy and HSSE Strategic Objectives, the department maintains an overview of
the effectiveness of SEA Hibiscus HSSE Management System.

3.1.3.2 HSSE Advisors provide specialist HSSE advice on health, safety, security and environmental matters
to management and line management, in enabling the effective implementation of arrangements
specified in the HSSE Management System, including benchmarking to International and Industry
standards.

3.1.3.3 HSSE is a line responsibility. The Chief Executive Officer/Chief Operation Officer/Managers shall be
responsible in ensuring that the HSSE risks associated with the conduct of business activities are
managed to a level that is as low as reasonably practicable (ALARP), such that harm to people,
environment, asset and reputation are eliminated and/or minimised.

3.1.3.4 The Chief Executive Officer/Chief Operation Officer/Managers shall be responsible and accountable
for the HSSE performance associated with activities carried out by the SEAH. However, the followings
exceptions shall apply:

(1) For activities associated with exploration drilling, the HSSE performance shall be the responsibility
and accountability of the Chief Executive Officer/Chief Operation Officer;

(2) For activities associated with development drilling, the HSSE performance shall be the responsibility
and accountability of the Chief Operation Officer; and

(3) For activities associated with workover drilling, the HSSE performance shall be the responsibility and
accountability of the Head of Operation.

3.1.3.5 All Departments and Work Locations shall appoint an HSSE Focal Person, from among suitably
competent personnel within the Departments and Work Locations, to coordinate the implementation

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of the HSSE Management System, including the associated procedures and guidelines, within the
respective Department/Work Location.

3.1.3.6 The HSSE Focal Person shall work closely with the HSSE Department and shall have direct access to
the expertise, database and records within the HSSE Department.

3.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Minutes of respective HSSE Committee Meeting;

(2) Risk management records;

(3) Records associated with HSSE advisory roles, e.g. emails, meeting attendance records, etc; and

(4) Records associated with HSSE performance.

3.2 HSSE Roles, Responsibilities And Accountabilities

3.2.1 Purpose

This Sub-Element defines the HSSE roles, responsibilities and accountabilities of personnel, both SEA
Hibiscus and Contractors, in the implementation of HSSE Management System.

3.2.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEA Hibiscus operations, including
Contractors engaged in work for the Company.

3.2.3 Expectations

The HSSE roles, responsibilities and accountabilities of all personnel, both Company and Contractors, shall
be clearly defined in Position Description/Job Description. Additionally, specific annual HSSE objectives
and targets shall be incorporated as part of employees’ performance management system.

For the effective implementation of SEA Hibiscus HSSE Management System, the HSSE roles,
responsibilities and accountabilities of employees and Contractors are as outlined below:

3.2.3.1 Chief Executive Officer (CEO)

(1) The Chief Executive Officer (CEO) has the overall responsibility and accountability for HSSE throughout
SEA Hibiscus operations.

(2) He delegates the responsibility for the implementation of the HSSE Management System, via the
respective line management, to every employee working for SEA Hibiscus, according to the respective
employee’s area of responsibility and level of authority.

(3) He delegates the responsibility for advice on health, safety, security and environmental matters to
the Head of Department, HSSE.
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(4) He ultimately authorises the necessary resources to meet HSSE strategic objectives and targets
throughout SEA Hibiscus operations.

3.2.3.2 Head of Department/Managers

(1) Head of Department and Managers are responsible to the Chief Executive Officer (CEO) and shall have
the responsibility and accountability for the implementation of the HSSE Management System within
their respective Division.

(2) They are responsible and accountable for the provision of adequate resources, including competent
personnel, to implement the arrangements specified in the HSSE Management System within their
respective location.

(3) They, in turn, delegate the responsibility for the implementation of the HSSE Management System
in their respective location, including agreed HSSE objectives, plans and targets to the respective Head
of Department and Managers within the location.

(4) In addition, the Senior General Managers shall also meet the HSSE roles, responsibilities and
accountabilities as specified in their respective Job Description.

3.2.3.3 Head of Department, HSSE

(1) Head of Department, HSSE is responsible to the Chief Executive Officer (CEO), and shall have the
responsibility and accountability for the followings:

(a). Custodian of the HSSE Management System and "Management Representative" for all HSSE
matters;

(b). Management Representative for engagement and contact with SEA Hibiscus, regulatory
authorities and industry associations on all HSSE matters;

(c). Maintain an HSSE organisation appropriate for the purpose of providing adequate HSSE support
for the implementation of the HSSE Management System throughout SEA Hibiscus operations;

(d). Maintain an independent HSSE assurance programme to support the effective implementation
of the HSSE Management System throughout SEA Hibiscus operations; and

(e). Maintain an effective crisis management and emergency response capabilities throughout SEA
Hibiscus operations.

(2) In addition, the Head of Department, HSSE shall also meet the HSSE roles, responsibilities and
accountabilities as specified in his Job Description.

3.2.3.4 Head of Operations

(1) Head of Operation (HOO) shall have the responsibility and accountability for the implementation of
HSSE Management System in respective location.

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(2) He is responsible and accountable for the provision of adequate resources, including competent
personnel, to implement the arrangements specified in the HSSE Management System in respective
location.

(3) In the execution of HSSE-critical activities, he is responsible and accountable for the conduct of the
required HSSE risk assessment, including the identification and implementation of HSSE controls, such
that harm to people, environment, asset and reputation are eliminated and/or minimised.

(4) He is responsible and accountable for ensuring the technical and operational integrity of facilities and
equipment that SEA Hibiscus design, procure, fabricate, install, acquire, operate and maintain;
including facilities and equipment used by Contractors engaged in work for the Company.

(5) He, in turn, delegates the responsibility for the implementation of the HSSE Management System,
including agreed HSSE objectives, plans and targets to the respective Managers within the location.

(6) In addition, the Head of Operations (HOO) shall also meet the HSSE roles, responsibilities and
accountabilities as specified in his respective Job Description.

3.2.3.5 Offshore Installation Managers and Company Site Representative

(1) Offshore Installation Managers (OIM) and Company Site Representatives (CSR) shall have the
responsibility and accountability for the implementation of HSSE Management System, including the
associated procedures and guidelines, within their respective facility and worksite.

(2) They are responsible for ensuring that employees and Contractors personnel under their supervision
are fully competent to carry out tasks allocated to them, including emergency response preparedness
capabilities.

(3) In the execution of HSSE-critical activities, they are responsible and accountable for the conduct of
the required HSSE risk assessment, including the identification and implementation of HSSE controls,
such that harm to people, environment, asset and reputation are eliminated and/or minimised.

(4) They are responsible and accountable for ensuring the technical and operational integrity of facilities
and equipment within the respective facility/worksite, through execution of required maintenance
activities.

(5) They, in turn, delegate the responsibility for the implementation of the HSSE Management System in
their respective facility and worksite, including agreed HSSE objectives, plans and targets to the
respective Supervisors and Team Leaders within the facility and worksite.

(6) In addition, the Offshore Installation Managers and Company Site Representatives shall also meet the
HSSE roles, responsibilities and accountabilities as specified in their respective Job Description.

3.2.3.6 HSSE Managers

(1) HSSE Managers shall have the responsibility and accountability in driving the implementation of HSSE
Management System within their respective location.

(2) They are responsible and accountable for providing the required advice on HSSE, towards attaining
full compliance to the requirement of the HSSE Management System within their respective location.
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(3) They are responsible for engagement/contact on HSSE matters with regulatory authorities and
industry associations within their respective location.

(4) They are responsible for maintaining an HSSE assurance programme, including for Contractors, to
support the effective implementation of the HSSE Management System within the location.
(5) They are responsible for maintaining an effective crisis management and emergency response
capabilities within the location.

(6) HSSE Managers shall also meet the HSSE roles, responsibilities and accountabilities as specified in
their respective Job Description.

3.2.3.7 HSSE Advisor

(1) HSSE Advisor is an employee in line departments appointed to coordinate HSSE matters for their
respective Department/function. The appointment of HSSE Advisor shall be made in writing by the
Head of Department, HSSE.

(2) HSSE Advisor Person shall be responsible for the followings:


(a). Disseminating HSSE information within the respective Department/function;

(b). Coordinating the provision of HSSE advice to Department/function;

(c). Tracking to closure the implementation of HSSE Recommended Action Items for the
Department/function;

(d). Tracking the implementation of HSSE trainings for the Department/function;

(e). Compiling and submitting HSSE performance reports (e.g. incident report, manhours); and

(f). Coordinating and/or conducting HSSE briefing to new staff and transferees within the
Department

3.2.3.8 All employees and Contractors – General Duties

(1) All employees and Contractors shall work towards creating and sustaining a culture that support the
effective implementation of the HSSE Management System; and

(2) All employees and Contractors shall be responsible for the safety and health of themselves and of
other persons who may be affected by their acts or omissions at work.

3.2.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Organisation charts and job descriptions, or equivalent;

(2) Individual performance appraisal and;

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(3) Record on communication of roles and responsibilities, e.g. on delegating of responsibilities,


authorization papers, on liaison with relevant government regulatory authorities, on providing advice
on legal matters relating to HSSE Management System.

3.3 RESOURCES, TRAINING AND COMPETENCY

3.3.1 Purpose

This Sub-Element defines SEA Hibiscus requirement on human resources, including the required
competencies, aimed at ensuring the safe execution of business activities, such that harm to people, asset,
environment and reputation are eliminated and/or minimised.

3.3.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEA Hibiscus operations, including
Contractors engaged in work for the Company.

3.3.3 Expectations

3.3.3.1 Head of Operation/Managers of the respective location shall ensure that adequate number of
personnel is available to execute the required business activities, including the implementation of
arrangements specified in the HSSE Management System.

3.3.3.2 In manpower planning, the HSSE-related considerations shall include, amongst others, the followings:

(1) Complexity of facilities and equipment’s, including the associated safeguarding systems;

(2) Adequacy of personnel for normal plant operations and maintenance, as well as to cater for
roster/shift work, formal training, leave, plant emergencies, etc;

(3) The level of competency, both trades and HSSE competencies, of personnel; and

(4) Availability of personnel for HSSE risk management activities, including the monitoring and
implementation of identified risk controls and mitigations.

3.3.3.3 Head of Operation/Managers shall ensure that all employees within their respective location are
competent to perform the required accountabilities, as specified in their respective Job Description.

3.3.3.4 For Company employees, the competency requirements for the various skill groups shall be as
defined in SEA Hibiscus Human Resources Handbook. These requirements shall be fully complied with
to ensure personnel are competent in carrying out the respective job requirements.

3.3.3.5 For Contractors employees, the competency requirements shall be defined in their respective
Contractors HSSE Management System, and the requirements shall conform to the relevant
International and Industry Standards.

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3.3.3.6 Head of Operation/Managers shall ensure that all employees, including Contractors, within their
respective location attend the required HSSE trainings as specified in SEA Hibiscus Human Resources
Handbook.

3.3.3.7 The HSSE trainings, categorised as Mandatory, Compulsory or Recommended Training, are intended
to provide the required HSSE competencies to enable safe execution of work activities.

3.3.3.8 In cases where there are legislative/regulatory competency requirements for any specific job
function, these requirements shall be fully complied with; including the requirement to demonstrate
competencies through formal assessment. These legislative/regulatory competency requirements, if
any, shall be clearly specified as part of the competency assurance system.

3.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Organisation Chart;

(2) Availability of competency assurance system;

(3) Documentations associated with both skill group and HSSE trainings, e.g. training plan, training
budget, training matrix, training records, etc; and

(4) Certificates of personnel holding specific job function that required certification.

3.4 COMMUNICATION PROCESSES

3.4.1 Purpose

This Sub-Element defines SEA Hibiscus requirements on HSSE communication process throughout its
operations, including Contractors.

3.4.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEA Hibiscus operations, including
Contractors engaged in work for the Company.

3.4.3 Expectations

HSSE Committees shall be established to steer and make decision on the implementation of the HSSE
Management System throughout SEA Hibiscus operations. The Term of Reference (TOR) of the various
HSSE Committees is as described below.

3.4.3.1 SEA Hibiscus Management HSSE Committee (SEAH HSSEC)

3.4.3.1.1. SEAH’s HSSE Committee (MHSSEC) is the highest-level decision-making body on health, safety,
security and environmental matters for SEA Hibiscus operations. Members of the Committee are as
follows:

Chairman: Chief Executive Officer


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Secretary: Head of HSSE


Members: Chief Operation Officer (COO)
Head of Operation (HOO)
Head of Projects & Engineering
Head of Contract & Procurement
Drilling Manager
Head of Human Resource
Head of Geoscience & Subsurface
Head of Legal

3.4.3.1.2. SEA Hibiscus Management HSSE Committee convenes on quarterly basis. The main roles and functions
of the Committee include, amongst others, the followings:

(1) Reviews the effectiveness and adequacy of the HSSE Management System and approves changes to
the HSSE Management System Manual;

(2) Approves Company’s long term and short term HSSE strategies, objectives and targets, including
annual HSSE Plan;

(3) Approves Company’s HSSE Standards/Manuals/ Procedures/Guidelines;

(4) Reviews Company’s HSSE performance;

(5) Reviews major assurance findings and set directives for development of intervention plan to enhance
compliance;

(6) Reviews major incidents and endorses the findings and recommendations arising from incident
investigation;

(7) Communicates with location HSSE Committees through exchange of minutes of meeting for
discussions at respective meetings; and

3.4.3.2 Location HSSE Committee

3.4.3.2.1. The Location HSSE Committee drives the implementation of requirements specified in the HSSE
Management System, including the associated procedures and guidelines, for the respective
facility/worksite. Members of the Committee are as follows:

Chairman: Person-In-Charge of Facility/ Worksite (OIM/ Plant Manager)


Secretary Nominated by Person-In-Charge/ HSSE Advisor
Representatives from employee
Representative from employer
Representatives from environment
Representative from health
Representative from Contractors
Representative from Caterer
Representative from Vessel

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3.4.3.2.2. Location HSSE Committee convenes on quarterly basis. The main roles and functions of the
Committee include, amongst others, the followings:

(1) Implement the requirement of the HSSE Management System, including the associated procedures
and guidelines;

(2) Review incidents/accidents at the respective facility/worksite and share lessons learnt;

(3) Review and monitor the implementation of facility/worksite;

(4) Discuss and provide solutions and/or directions to relevant HSSE issues and/or recommendations for
HSSE improvement that are within the limit of authority of Location HSSE Committee;

(5) Cascade management feedback and discussion arising from HSSE Committee minutes, relevant HSSE
issues, procedures, and policy matters;

(6) Review all action items arising from HSSE inspections, assurance, incident investigations, etc, and
track the implementation of the action items to completion;

(7) Carry out site inspection at least once a month to detect any unsafe conditions or unsafe practices;
and

(8) Promote enhancement of HSSE awareness through HSSE talks, HSSE publications, HSSE alerts, etc.

3.4.3.3 Other Communication Process

3.4.3.3.1. HSSE Meeting

The Person-in-Charge of all department/facility/worksite shall conduct an HSSE Meeting to provide


avenues for management personnel and employees, including Contractors, to discuss on HSSE matters, as
well as sharing of HSSE- related information, e.g. HSSE performance, incidents, lesson learnt, etc. For office
department, the meeting may be conducted in conjunction with the department meeting.

3.4.3.3.2. Contractors Management HSSE Meeting

The Contract Holders shall ensure that Contractors Management HSSE Meeting is held to provide avenues
for SEA Hibiscus and Contractors management personnel to discuss on HSSE matters, including HSSE
performance, related to the contracted works. The meeting shall be conducted on quarterly basis.

3.4.3.3.3. Engagement with Communities

Engagement with local communities which may be impacted by SEA Hibiscus business activities shall be
conducted to create awareness on Company’s operations, including the associated HSSE controls and
recovery measures. Where there are legislative requirements to conduct such engagements, these
requirements shall be fully complied with.

3.4.3.3.4. Daily Site Operations Meeting

The Person-in-Charge of all facility/worksite shall conduct daily site operations meeting to discuss daily
planned activities, as well as sharing of HSSE-related information, e.g. incidents, unsafe acts and unsafe
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conditions, lesson learnt, etc. Emphasis shall be given to potential impact of hazardous activities, including
concurrent activities, such that harm to people, environment, asset and reputation are eliminated and/or
minimised.

3.4.3.3.5. Pre-Job Meetings

Supervisors shall conduct pre-job meetings for all non-routine works, including those carried out by
Contractors. The meeting should address, amongst others, the procedure and work permit conditions for
the work.

3.4.3.3.6. Toolbox Meetings

Supervisors shall conduct daily toolbox meeting involving all personnel, both Company and Contractors,
covering planned topics, amongst others, the followings:

(1) Daily work programme including changes in work activities;

(2) Reminders on hazard as well as control measures associated with the work activities; and

(3) Incident reports and lesson learnt.

3.4.3.3.7. HSSE Induction

All new employees and transferees, including Contractors, shall be given a formal induction of the
facility/worksite, including familiarisation with emergency procedures.

3.4.3.3.8. HSSE alert, bulletin, newsletter, etc.

HSSE alert, bulletin, newsletter, etc, should be issued for communication of lesson-learnt arising from
incident, as well as other HSSE information.

3.4.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Appointment Letters for various HSSE committees’ members;

(2) Minutes of meetings of the various HSSE committees, working groups, etc; and

(3) Documentations related to other communication processes.

3.5 DOCUMENTATION & CONTROL

3.5.1 Purpose

This Sub-Element defines SEA Hibiscus requirements on documentation associated with the HSSE
Management System, including the management and control of such documentation.

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3.5.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations.

3.5.3 Expectations

3.5.3.1 HSSE Management System Manual

3.5.3.1.1. SEA Hibiscus HSSE Management System Manual shall apply throughout SEA Hibiscus operation; and
shall be made available and/or accessible for all employees, including Contractors.

3.5.3.1.2. Where required, including to cater for specific local requirement, local-specific HSSE Management
System Manual should be developed; and shall be made available and/or accessible for all employees
and Contractors within the location. Such document shall be in line with SEA Hibiscus HSSE
Management System.

3.5.3.2 HSSE Procedures and Guidelines

3.5.3.2.1. SEA Hibiscus HSSE Procedures and Guidelines shall apply throughout SEA Hibiscus operation; and shall
be made available and/or accessible for all employees, including Contractors.

3.5.3.2.2. Where required, including to cater for specific local requirement, local-specific HSSE Management
System Manual should be developed; and shall be made available and/or accessible for all employees
and Contractors within the location. Such document shall be in line with SEA Hibiscus HSSE
Management System.

3.5.3.3 Health, Safety and Environment (HSE) Case

3.5.3.3.1. HSE Case is essentially the HSSE Management System Manual for a specific facility and/or worksite. HSE
Case shall be developed for the following facilities and/or worksites throughout SEAH operations,
including Contractors:

(1) Onshore and Offshore Oil and Gas Plant/Platform; and

(2) Drilling Rigs.

3.5.3.3.2. The Head of Department/Operation/Managers of the respective location shall ensure that facility-
specific HSE Case or equivalent, are developed and in place for all HSE-critical facilities within the
respective location.

3.5.3.3.3. Where there is legislative requirement for facility-specific HSE Case, such requirement shall be fully
complied with including, amongst others, specific requirement with respect to content, title, etc., (e.g.
Control of Industrial Major Accident Hazard Report, Control of Major Accident Hazard Report).

3.5.3.3.4. The information contained in the HSE Case shall demonstrate, amongst others, the followings:

(1) The facility has an effective HSSE Management System;

(2) Any potential harm to people, environment, asset and reputation are eliminated and/or minimised
to a level that is as low as reasonably practicable (ALARP), through appropriate risk assessments; by
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evaluating the possible hazard and effects, including identification of controls and recovery barriers;
and

(3) The facility is fit and safe to be operated, and all controls and recovery barriers, including an
emergency response plan, are adequate to cater for any emergency.

3.5.3.3.5. As a minimum, SEA Hibiscus’ HSE Case shall conform to the requirement defined in Company’s
requirements. The main parts of an HSE Case shall be as follows:

Part 1 Part 2 Part 3 Part 4 Part 5


Introduction Facility Safety Formal Safety Reference and
Description Management Assessment supporting
System (SMS) Document
Description

(1) Part 1 is the Introduction to the HSE Case describes the purpose and objectives of the Safety Case and
the scope of its application. It indicates the contents of the HSE Case and describes the HSE Case
development. It also specifies the proposed facility Operator and the HSE Case custodian. The
Introduction describes the statutory requirements with which the HSE Case must comply and the
circumstances that require the HSE Case to be submitted

(2) Part 2, Facility Descriptions describes all of the systems and equipment that comprise facilities and
the normal production, operations and maintenance activities that are performed at, or near, the
facility

(3) Part 3, The Safety Management System (SMS) description provides a description of SEA Hibiscus
Health and Safety Security and Environment (HSSE) management process in place to identify and
manage the hazards and risks associated with the normal production, operations and maintenance
activities, including management of any changes. The SMS describes the organisational arrangements
and roles and responsibilities for both normal operations and for emergencies. It also provides
assurance that controls are maintained in accordance with defined Performance Standards and that
reviews are conducted as necessary and appropriate. The SMS is interchangeably referred to as SEA
Hibiscus HSSE Management System (HSSE-MS) and is a key system within SEA Hibiscus whose purpose
is to describe, in a systematic and structured manner, the activities, processes and procedures for the
successful implementation of the SEA Hibiscus HSSE Policy. The HSSE-MS provides the guidance and
tools for undertaking the management of all safety, occupational health and environmental hazards.
Development and use of a HSE Case is one process specified in the HSSE-MS and is the tool SEA
Hibiscus uses to manage those hazards classified as Major Accident Hazards (MAH). The HSE Case
should be considered as part of the overall HSSE-MS management of hazards.

(4) Part 4, The Formal Safety Assessment (FSA) describes the process undertaken to provide assurance in
the adequacy of both the design and the associated SMS to ensure that the risks to HSE Case - MAHs
are reduced to a level that is both tolerable and ALARP, in line with industry standard Risk Acceptance
criteria. The FSA also presents the MAH Control Datasheets and Bowtie diagrams for each MAH as
well as a matrix of Safety Critical Elements (SCE) versus the MAH to which they relate.

(5) Part 5 The References & Supporting Documents part of the HSE Case present the relevant drawings
and their associated references that support the HSE Case.

3.5.3.3.6. For the New Facilities, the requirements for the HSE Case shall be as follows:
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(1) The Head of Department/Operation/Managers shall be responsible in ensuring that all new facilities
shall each have a facility specific HSE Case or equivalent, and shall be developed in line with SEA
Hibiscus’ HSE Case requirements; and

(2) The HSE Case shall be developed during the project design stage. The document shall be amongst the
deliverables during the facility’s handover and shall be approved by the Head of
Department/Operation/Managers prior to facility’s start-up.

3.5.3.3.7. For the Existing and Acquired Facilities, the Head of Department/Operation/Managers shall be
responsible in ensuring that all existing onshore and offshore facilities shall each have a facility specific
HSE Case or equivalent.

3.5.3.3.8. For drilling rigs, the Manager shall be responsible in ensuring that all drilling rigs shall each have a rig
specific HSE Case or equivalent, and shall be developed in line with SEA Hibiscus’ HSE Case requirements
or International and/or Industry standards.

3.5.3.3.9. Document Management and Control

(1) A document management and control system shall be in place, in accordance with SEA Hibiscus
Documentation Management Procedure, to ensure the integrity and accuracy of the documents. This
shall include formal administration, custodianship and technical correctness.

(2) A document custodian shall be assigned to each document. The custodian may be selected amongst
the process owner who has direct responsibility for the processes or requirements being prescribed
in the respective document within SEAH.

(3) Each document shall be approved by the appropriate approval authority, as stipulated in the Limits
of Authority (LOA) Manual.

(4) All SEAH controlled documents shall be reviewed as and when required or at least once in every 5
years.

3.5.3.3.10. A tracking and monitoring system shall be developed to ensure effective implementation of the HSSE
Management System, including demonstration of full compliance to legislative requirements.

3.5.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of HSSE Management System Manual;

(2) Availability of HSSE procedure and guidelines, for SEAH;

(3) Availability of HSE Case or equivalent (e.g. CIMAH Report, etc), including the associated documents,
e.g. records of tracking of recommendations, etc;

(4) Document control system; and

(5) Records associated with tracking of HSSE Management System implementations.


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HSSE MANAGEMENT SYSTEM

ELEMENT 4: HAZARD AND EFFECTS MANAGEMENT

4.1 HAZARD AND EFFECTS MANAGEMENT PROCESS

4.1.1 Purpose

This Sub-Element defines SEA Hibiscus requirement in respect of managing HSSE risks to ensure that HSSE
risks associated with the Company’s activities, including Contractors, are as low as reasonably practicable
(ALARP).

4.1.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

4.1.3 Expectations

4.1.3.1 The hazard and effects management process for SEAH shall be in line with Company’s requirements.

4.1.3.2 Company’s hazard and effects management process is based on four (4) basic principles, as follows:

4.1.3.2.1 Identify hazard and effects;

4.1.3.2.2 Assess the risks posed by the hazard, in the event of hazard release;

4.1.3.2.3 Identify Control measures to eliminate and/or reduce the risks; and

4.1.3.2.4 Identify Recovery measures to mitigate and/or reduce the impact to people, asset, environment, and
reputation.

4.1.3.3 An overview of the risk management process is illustrated in the table below:

BASIC PRINCIPLE MAIN STEP/PROCESS BRIEF DESCRIPTION

IDENTIFY 1. Identify Hazard and Effects  What is the hazard?


 What could go wrong?

2. Establish Screening Criteria  Define the screening criteria.


 Define level of acceptable and
unacceptable risk.

ASSESS 3. Assess (evaluate) Hazard  How serious can it be?


and Effects
 How probable is it?

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BASIC PRINCIPLE MAIN STEP/PROCESS BRIEF DESCRIPTION

4. Document Significant
Hazard and Effects and
applicable Statutory
Requirement

5. Define detailed Objectives Refer SEAH ’s HSSE Key Performance


and Performance Criteria Indicators (KPI) as defined annually
by Managements Committee.

CONTROL 6. Identify, evaluate and  Prevent/Eliminatethe hazard:


implement Control
 Is there a better way?
Measures
 How to prevent it?

RECOVERY 7. Identify, evaluate and  Mitigate consequence:


implement Recovery
 How to limit the consequences?
Measures
 How to recover?
 How to restore?

4.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) HSSE risk management guidelines, e.g., for Environmental Impact Assessment (EIA), Health Impact
Assessment (HIA), Social Impact Assessment (SIA), Health Risk Assessment (HRA);

(2) HSSE risk management documents, e.g. Hazard and Effects Register (HER), Environmental Aspects and
Impacts Register, Health Risk Assessment Report, Matrix of Permitted Operations (MOPO); HSE
Case(s), CIMAH, HAZOP & HAZID Reports;

(3) Hazardous Area Classification Layout;

(4) Operational control procedures and work instructions; and

(5) Emergency Response Management Plan, including Oil Spill Response Plan.

4.2 HSSE RISK SCREENING CRITERIA

4.2.1 Purpose

This Sub-Element defines SEAH HSSE risk screening criteria to be applied in all hazard and effects
assessments carried out throughout Company operations, including Contractors.

4.2.2 Scope
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The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

4.2.3 Expectations

4.2.3.1 Risks posed by hazard associated with the conduct of activities throughout SEAH operations, including
Contractors, shall be managed to a level that is as low as reasonably practicable (ALARP).

4.2.3.2 For qualitative assessment, SEAH Risk Assessment Matrix (RAM) shall be used to assess the risks posed
by the hazard. The matrix is as shown in Figure 1 below.

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Consequences Probability
A (1) E (5)
B (2) C (3) D (4)
Severity People Asset Environment Reputation Very Almost
Unlikely Possible Likely
unlikely certain
Massive Effect Massive
Massive Damage Persistent severe international
CAPEX >USD 25 mil environmental damage consequence
5
Single fatality OPEX >USD 5 mi Tier 3 Oil Spill Response International public 5 10 15 20 25
Catastrophic
Production loss LOPC: Major release: attention. Extensive
>20% annual target equal to or above 100 adverse attention in
times Tier 1 Threshold international media
Major Effect
Severe environmental Major national
Major Damage
damage consequence
CAPEX USD 15-25
Tier 2 Oil Spill Response National public
4 mil
PTD, PPD LOPC: Major release: concern. 4 8 12 16 20
Major OPEX USD 2-5 mil
equal to or above 10 Extensive adverse
Production loss 10-
times Tier 1 Threshold attention in the
20% annual target
and below 100 times the national media
INTOLE RABLE
limit HIGH
Moderate localised
consequence
Moderate Effect
Moderate Damage National media
Limited environmental
Major injury or CAPEX USD 5-15 and/or regional
damage
3 health effect mil political attention
LOPC: Major release: 3 6 9 12 15
Moderate LWC or RWC, OPEX USD 1-2 mil resulting in
equal to or above Tier 1
>4 calendar days Production loss 5- negative
Threshold and below 10
10% annual target consequence on
times the limit
company
operations
Limited 2
Minor Effect consequence MEDIUM
Minor environmental Local medical
Minor injury or Minor Damage
damage, but no lasting and/or local
health effect CAPEX/OPEX >USD
2 effect political attention
LWC or RWC, 100k 4 6 8 10
Minor LOPC: Minor release: with potentially
<= 4 calendar Production loss 1-
equal to or above Tier 2 negative
days 5% annual target
and below Tier 1 consequence for
Threshold company
operations
Slight Effect
LOW
Slight Damage
Slight injury or Slight environmental Slight effect
CAPEX/OPEX <USD
1 health effect damage contained Local public
100k 1 2 3 4 5
Slight No Treatment within the premises. awareness but no
Production loss
Case or FAC LOPC: Slight release: discernible concern
<1% annual target
below Tier 2 Threshold
PTD: Permanent Has
Total Disability Never happened
Has
PPD: Partial heard within the
happened
Permanent Direct Cost: Cost of in last 5
Heard at the Op Has
Disability directly attributed LOPC: Material Release the last years in
of Co once happened
LWC Lost to the incident, Threshold Quantities per 100 the O&G
within per year more
Workday Case excluded indirect API Recommended See explanation years in or Group
Notes: the last than once
RWC: Restricted costs Practice 754 table O&G of
10 Op Co = per year
Work Case Companies
years in Operating at the Op
FAC: First Aid See explanation See explanation tables O&G =
O&G Company, Co
Case table. Oil & Group =
eg AOC,
Gas HPB
SEAH
See explanation Industry including
table all Op Co

Figure 1: SEAH Risk Assessment Matrix

L Low Risk Manage for Continuous Improvement


M Medium Incorporate Risk Reduction Measures
H High Intolerable

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Consequences
Risk Rating Intervention
Risk is not tolerable
- Mitigate the Risk by incorporation of control and recovery action(s) to reduce
the Risk rating to HIGH or below
INTOLERABLE
16-25 Incidents and Assurance findings/reports reportable to Group CEO
Incident investigation led by Op Co CEO or delegate
Hi Po incident investigation led by Op Co L2
Risk is tolerable if supported by ALARP demonstration
- Undertake risk reduction by applying appropriate control and recovery barriers
HIGH - Review and approval of ALARP demonstration by Op Co L3
9-15
Incidents and Assurance findings/reports reportable to Op Co CEO
Incident investigation led by Op Co L3
Risk is tolerable if supported by ALARP demonstration
- Undertake control evaluation
- Review and approval of ALARP demonstration by HOD/ Op Co L4
MEDIUM
- Monitor using procedure or appropriate internal control
4-8
Incidents and Assurance findings/reports reportable to Op Co L3
Incident investigation led by Op Co L4
Risk is tolerable
LOW
- Monitor at operational level using procedure/appropriate internal control
1-3 - Take corrective action according to availability of resources

Figure 2: Risk Rating and Required Intervention

4.2.3.3 The definition of the various consequences in terms of harm to people, asset, environment and
reputation as shown in SEAH Risk Assessment Matrix are as follows:

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People
Consequences
Severity People
Single Fatality
- Fatality due to injury or occupational illness
5
- Occupational illnesses including cancer with irreversible health effect which
Catastrophic
result in Permanent Total Disability such as asbestosis, silicosis and heart or
kidney failure due to chemical exposure
Permanent Total Disability or Permanent Partial Disability
- Injury which result in Permanent Total Disability or Permanent Partial Disability
- Occupational illness including cancer with irreversible health effect which result
in Permanent Total Disability such as asbestosis, silicosis and heart or kidney
4
failure due to chemical exposure
Major
- Occupational illnesses with irreversible health effects which result in
Permanent Partial Disability such as occupational noise induced hearing loss,
chronic back disorder or repetitive strain injury
- Mental illness due to stress with irreversible health effects
Major injury or health effect
3 - Lost Workday Case or Restricted Work case, where the duration exceeds 4
Moderate calendar days
- Mental illness due to stress with reversible health effects
Minor injury or health effect
- Lost Workday Case or Restricted Work Case, where the duration equals or less
than 4 calendar days
2
- Occupational Illnesses with reversible health effects such as food poisoning and
Minor
acute dermatitis
- Positive biological/ biological effect monitoring result without permanent effect
to health
Slight injury or health effect
1 - No Treatment Case or First Aid Case
Slight - Illnesses that result in noticeable discomfort, minor irritation or transient
effects that are reversible after exposure stops
PTD: Permanent Total Disability
PPD: Partial Permanent Disability
Notes: LWC: Lost Workday Case
RWC: Restricted Work Case
FAC: First Aid Case

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Asset
Consequences
Severity Asset
Massive Damage
5
- CAPEX >USD 25 mil, OPEX >USD 5 mil
Catastrophic
- Production loss >12 weeks or >20%
Major Damage
4
- CAPEX >USD 15 mil, OPEX >USD 2 mil
Major
- Production loss >4 weeks or >10%
Major injury or health effect
3
- CAPEX >USD 5 mil, OPEX >USD 1 mil
Moderate
- Production loss >1 week or >5%
Minor injury or health effect
2
- CAPEX/OPEX >USD 100 k
Minor
- Production loss >1 day or >1%
Slight injury or health effect
1
- CAPEX/OPEX <USD 100 k
Slight
- Production loss <1 day or <1%
Direct Cost: Cost directly attributed to the fire and/or explosion, such as the
replacement value of equipment lost, product loss, cost of repairs, clean up,
emergency response and/or fines. Direct cost does not include indirect costs, such
as business opportunity losses, loss of profits due to equipment outages, cost of
Notes: obtaining or operating temporary facilities or cost of obtaining replacement
products to meet customer demand.

Group reporting will be based in the USD values. Op Co may use local currency
rounded to the nearest equivalence for business planning and regulatory reporting.

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Environment
Consequences
Severity Environment
Massive Effect
- Persistent severe environmental damage what will lead to loss of natural
resources over a wide area
5
- Release or non-compliance to regulatory limits over designated areas of
Catastrophic
ecological importance or an extensive area
- Requirements for Tier 3 oil spill emergency response
- LOPC: Major release: equal to or above 100 times Tier 1 Threshold
Major Effect
- Severe environmental damage that will require extensive measures to restore
beneficial uses of the environment
- Release or non0compliance to regulatory limits which results in significant
4
disruption of or impairment to beneficial uses of the environment and/or to
Major
public receptors
- Requirement for Tier 2 oil spill emergency response
- LOPC: Major release: equal to or above 10 times Tier 1 Threshold and below
100 times the limit
Moderate Effect
- Non-compliance to regulatory limits; Not resulting in consequences described
in RAM 4/5
- Limited environmental damage that will persist or require cleaning up
3
- LOPC: Major release: equal to or above Tier 1 Threshold and below 10 times the
Moderate
limit
- Natural gas, Methane, Ethane, Propane, Butane, LPC, LNG = 500 kg
- Petrol, Gasoline, Methanol, above 15 API Gravity Crude oil = 1000 kg or 7 bbl
- Diesel, below 15 API Gravity Crude oil = 2000 kg or 14 bbl
Minor Effect
- Breach of prescribed Op Co/ Other standard limits, if any; Not resulting in
consequences described in RAM 4/5
- Minor environmental damage, but no lasting effect
2
- LOPC: Major release: equal to or above Tier 2 Threshold and below Tier 1
Minor
Threshold
- Natural gas, Methane, Ethane, Propane, Butane, LPC, LNG = 50 kg
- Petrol, Gasoline, Methanol, above 15 API Gravity Crude oil = 100 kg or 1 bbl
- Diesel, below 15 API Gravity Crude oil = 1000 kg or 10 bbl
Slight Effect
1
- Slight environmental damage contained within the premises
Slight
- LOPC: Slight release: below Tier 2 Threshold

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- Release – Includes gaseous release into the atmosphere, and/r spill onto or into
soil and/or water
- Material Release Threshold Quantities per API Recommended Practice 754
- Use barrels (bbl) for liquids, or kilograms (kg) for gases or solids. Conversion
between barrels and litres for liquids: 1 bbl =- 159 litres
- Non-compliance to regulatory standards/limits, with respect to but not limited
to air emission, effluent discharge, boundary noise, objectionable odour, heat
or vibration. Where host country regulatory requirements are not available,
then Op Co standards/limits will apply, if available.

Beneficial Uses
- Means uses of the environment or any element or segment of the environment
that is conductive to public health, welfare or safety and which requires
protection from the effects of wastes, discharges, emissions and deposits
Covers the uses of land, water and/or other natural resources including but not
limited to:
- Agriculture/aquaculture – Farming, horticulture and commercial production of
aquatic animals;
- Public water supply – Source water for community, or individual water supply
systems, including, but not limited to, drinking water supply delivered through
community water supply systems;
- Industrial water supply – Water for industry, including secondary industry and
a mining or petroleum activity, and for other industry uses
- Wildlife habitat in areas of ecological importance – Support wildlife habitat and
Notes: ecosystems including, but not limited to, the survival and enhancement of plant
and animal species in areas of ecological importance;
- Recreation – Parks, green areas and water bodies used for sports, boating,
recreational fishing, swimming and other social activities;
- Culture, religion and heritage – Areas with high archaeological and historical
value, aboriginal/native traditional or customary land, burial grounds, houses
of worship or land reserved for spiritual/religious activities.

Designated
- Means listed, gazette, recognised, identified or protected by law or by relevant
authorities

Public receptors
- Include offsite residences, institutions (e.g. schools, hospitals), industrial,
commercial, and office buildings, parks or recreational areas where members
of the public could potentially be or are exposed to environmental pollutants;
Disruption to public receptors
- May include disruption or interruption resulting in community evacuation, or
injury or illness from exposure to environmental pollutants

Area of ecological importance


- Means clearly defined geographical space, recognised, dedicated and managed,
through legal or other effective means, to achieve the long-term conservation
of nature with associated ecosystem services and cultural values
This may include:

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Consequences
- National and State parks, nature reserves or conservation areas (e.g. wildlife
reserves, sanctuaries, marine parks, and forest reserves);
- UNESCO Biosphere Reserve and Heritage Site
- Areas with restricted range or endemic species, and migratory and
congregatory species
- Wetlands that have been designated or recognised as being regional, national
and international importance

Rare, endangered, threatened and endemic species


- Includes listed species, for example, according to IUCN Red List of Threatened
Species (critically endangered or endangered species or vulnerable), or
protected under statutory act

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Environment – Lost Of Primary Containment (LOPC)


Threshold
Threshold Quantity Threshold Quantity
Release Material Hazard Classification a, c, d
(outdoor release) (indoor b release)
Category
1 TIH Zone A Materials 5 kg (11 lb) 2.6 kg (5.5 lb)
2 TIH Zone B Materials 25 kg (55 lb) 12.5 kg (27.5 lb)
3 TIH Zone C Materials 100 kg (220 lb) 50 kg (110 lb)
4 TIH Zone D Materials 200 kg (440 lb) 100 kg (220 lb)
Flammable Gases

or

Liquids with Initial Boiling Point ≤ 35 °C (95 °F) and Flash Point
5 500 kg (1100 lb) 250 kg (550 lb)
<23 °C (73 °F)

or

Other Packing Group I Materials excluding strong acids/bases


Liquids with Flash Point ≥ 35 °C (95 °F) and Flash Point < 23 °C
(73 °F) 1000 kg (2200 lb) 500 kg (1100 lb)

6 or or or

Other Packing Group II Materials excluding moderate 7 bbl 3.5 bbl


acids/bases
Liquids with Flash Point ≥ 23 °C (73 °F) and ≤ 60 °C (140 °F)

or

Liquids with Flash Point >60 °C (140 °F) released at a


2000 kg (4400 lb) 1000 kg (2200 lb)
temperature at or above Flash Point
7 or or
or
14 bbl 7 bbl
strong acids/bases

or

Other Packing Group III Materials


It is recognised that threshold quantities given in kg and lob or in lb and bbl are not exactly equivalent. Companies should select
on e of the pair and use it consistently for all recordkeeping activities.
a.
Many materials exhibit more than one hazard. Correct placement in Hazard Zone or Packing Group shall follow the rules
of DOT 49 CFR 173.2a[14] or UN Recommendations on the Transportation of Dangerous Goods, Section 2[10]. See Annex B.
b.
A structure composed of four complete (floor to ceiling) walls, floor, and roof.
c.
For solutions not listed on the UNDG, the anhydrous component shall determine the TIH zone or Packing Group
classification. The threshold quantity of the solution shall be back calculated based on the threshold quantity of the dry
component weight.
d.
For mixtures where the UNDG classification is unknown, the fraction of threshold quantity release for each component
may be calculated. If the sum of the fractions is equal to or greater than 100%, the mixture exceeds the threshold quantity.
Where there are clear and independent toxic and flammable consequences associated with the mixture, the toxic and
flammable hazards are calculated independently. See Annex A, Examples 28, 29, and 30.

Natural gas, methane, Ethane, Propane, Butane, LPH, LNG = 500 kg


Petrol, Gasoline, Methanol, above 15 API Gravity Crude oil = 1000 kg or 7 bbl
Diesel, below 15 API Gravity Crude oil = 2000 kg or 14 bbl

Table 1: Tier 1 Material Release Threshold Quantities

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Threshold
Threshold Quantity Threshold Quantity
Release Material Hazard Classification a, c, d
(outdoor release) (indoor b release)
Category
1 TIH Zone A Materials 5 kg (11 lb) 2.6 kg (5.5 lb)
2 TIH Zone B Materials 25 kg (55 lb) 12.5 kg (27.5 lb)
3 TIH Zone C Materials 100 kg (220 lb) 50 kg (110 lb)
4 TIH Zone D Materials 200 kg (440 lb) 100 kg (220 lb)
Flammable Gases

or

Liquids with Initial Boiling Point ≤ 35 °C (95 °F) and Flash Point
5 500 kg (1100 lb) 250 kg (550 lb)
<23 °C (73 °F)

or

Other Packing Group I Materials excluding strong acids/bases


Liquids with Flash Point ≥ 35 °C (95 °F) and Flash Point < 23 °C
(73 °F)

or 1000 kg (2200 lb) 500 kg (1100 lb)

6 Other Packing Group II Materials excluding moderate or or


acids/bases
7 bbl 3.5 bbl
or

Strong acids and bases


Liquids with Flash Point > 60 °C (140 °F) released at a
2000 kg (4400 lb) 1000 kg (2200 lb)
temperature below Flash Point
7 or or
or
14 bbl 7 bbl
Moderate acids/bases
In order to simplify determination of reporting thresholds for Tier 2, Categories 6 and 7 in Tier 1 have been combined into one
category in Tier 2 (Category 6). The simplification is intended to provide less complicated requirements for those events with
lesser consequences.

It is recognised that threshold quantities given in kg and lb and bbl are not exactly equivalent. Companies should select one of
the pair and use it consistently for all recordkeeping activities.
a.
Many materials exhibit more than one hazard. Correct placement in Hazard Zone or Packing Group shall follow the rules
of DOT 49 CFR 173.2a[14] or UN Recommendations on the Transportation of Dangerous Goods, Section 2[10]. See Annex B.
b.
A structure composed of four complete (floor to ceiling) walls, floor, and roof.
c.
For solutions not listed on the UNDG, the anhydrous component shall determine the TIH zone or Packing Group
classification. The threshold quantity of the solution shall be back calculated based on the threshold quantity of the dry
component weight.
d.
For mixtures where the UNDG classification is unknown, the fraction of threshold quantity release for each component
may be calculated. If the sum of the fractions is equal to or greater than 100%, the mixture exceeds the threshold quantity.
Where there are clear and independent toxic and flammable consequences associated with the mixture, the toxic and
flammable hazards are calculated independently. See Annex A, Examples 28, 29, and 30.

Natural gas, methane, Ethane, Propane, Butane, LPH, LNG = 50 kg


Petrol, Gasoline, Methanol, above 15 API Gravity Crude oil = 100 kg or 1 bbl
Diesel, below 15 API Gravity Crude oil = 1000 kg or 10 bbl

Table 2: Tier 2 Material Release Threshold Quantities

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Reputation
Consequences
Severity Asset
Massive international consequence
- Persistent, severe impact on livelihood, social and cultural assets, community
security, community health, vulnerable or indigenous peoples and/or human rights
infringements
5 - Impact may affect a large geographic area or population
Catastrophic - Mitigation is complex or protracted, and of limited effectiveness
- High level of concern and action(s) by governments and/or by international NGOs
- International public attention. Extensive adverse attention in international media
- National/international policies with potentially severe consequences on access to
new areas, grants/renewal of licenses and/or tax legislation
Major national consequence
- Persistent effects on livelihood and/or social and cultural assets, community health
- Effects on community security, vulnerable or indigenous peoples and/or human
rights infringements, that are serious and/or at a community level
- Mitigation is complex or protracted
4 - Impact on local and national stakeholder relations
Major - National government and/or NGO involvement with potential for international
NGO action
- National public concern. Extensive adverse attention in the national media
- Regional/national policies with potentially restrictive measures and/or
consequences on grant/renewal of licenses
- Mobilisation of pressure or action groups
Moderate localised consequence
- Persistent nuisance
- Effects on livelihood and/or social and cultural assets, community health
- Limited observable effects on community security, vulnerable or indigenous
peoples
3
- Local or Regional public concern
Moderate
- Local stakeholders, e.g. community, NGO, Industry and government, are aware
- Extensive adverse attention in local media
- National media and/or regional political attention resulting in negative
consequence on company operations
- Adverse stance of local government and/or action groups
Limited consequence
- Limited short-term nuisance
- Limited effects on livelihood and/or social or cultural assets, community health
2 - No observable adverse effect on community security, vulnerable or indigenous
Minor peoples
- Local public concern or complaints
- Local media and/or local political attention with potentially negative consequence
for company operations

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Consequences
Slight effect
- Infrequent slight nuisance. (Nuisance to include interference with reasonable
comforts and enjoyments in life, general inconvenience relating to day to da
1
activities or enjoyment of land)
Slight
- No observable adverse or perceived effect on livelihood, social and cultural assets,
community security, community health, vulnerable or indigenous peoples
- Local public awareness but no discernible concern

4.2.3.4 To eliminate and/or minimise risks to a level that is as low as reasonably practicable (ALARP), the ALARP
Principle shall be adhered to.

4.2.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Qualitative Risk Assessment report;

(2) Quantitative Risk Assessment report;

(3) HSE Case, or equivalent; and

(4) Risk management records, e.g. Hazard and Effects Register (HER), Environmental Aspects and Impacts
Register, Health Risk Assessment (HRA) reports, etc.

4.3 PERFORMANCE CRITERIA FOR MAINTAINING CONTROLS

4.3.1 Purpose

This Sub-Element defines SEAH requirement for the establishment of performance criterion and standards
to ensure the effectiveness of risk reduction and mitigation measures (i.e. control and recovery barriers)
identified in hazard and effects management process.

4.3.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

4.3.3 Expectations

4.3.3.1 SEAH shall implement systems to ensure the integrity of HSSE controls identified in hazard and effects
management process; e.g. maintenance management system, procurement management system,
action item tracking system, etc.

4.3.3.2 Key Performance Indicators (KPI) required to ensure the continued integrity of HSSE controls (control
and recovery barriers) shall be established and tracked accordingly.

4.3.3.3 The Key Performance Indicators (KPI) and Targets shall conform to the relevant legislations, SEA
Hibiscus requirements, including benchmarking to International and/or Industry Standards.
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4.3.3.4 Accountable parties shall be identified to ensure effective implementation of the identified Key
Performance Indicators (KPI); including incorporation of selected Key Performance Indicators (KPI) as
part of employees’ performance management system.

4.3.3.5 The actual performance in undertaking activities required to maintain integrity of HSSE controls shall
be documented and trended against the defined performance standards. Examples of activities
required to maintain HSSE controls include, amongst others, emergency shutdown (ESD) function test,
emergency drill, testing and maintenance of lifeboats, lifesaving equipment, shutdown systems,
firewater pumps, oil spill equipment, etc.

4.3.3.6 The actual performance of equipment identified as HSSE controls shall be documented and trended
against the design performance standards. Examples of equipment performance include, amongst
others, firewater pump’s flow rate at defined pressure, shutdown valves’ closing time and leak/passing
rate, blowdown valves’ opening time, etc.

4.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of systems to ensure integrity of HSSE controls, e.g. maintenance management system,
procurement management system, etc;

(2) Set of performance criteria;

(3) Maintenance and inspection records, schedule and backlog, including records related to actual
performance of equipment and monitoring activities, e.g. lifesaving inspection records, emergency
shutdown (ESD) test records, firewater pump test records, etc; and

(4) Individual performance target incorporating selected Key Performance Indicators (KPI).

4.4 SEA HIBISCUS RISK MANAGEMENT REQUIREMENT

4.4.1 Purpose

This Sub-Element defines SEAH requirement for the conduct of structured HSSE risk assessment, including
the identification and implementation of identified HSSE controls, for all activities spanning the entire
asset lifecycle of SEAH.

4.4.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

4.4.3 Expectation

4.4.3.1 Acquisition Phase

4.4.3.1.1 For block bidding and acquisition, the Head of Departments/Operations/Manager’s shall ensure that,
as part of the Risk Assessment, an assessment of HSSE risk is carried out.
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4.4.3.2 Exploration and Appraisal Phase

4.4.3.2.1 Prior to commencement of survey and seismic activities, the Head of


Departments/Operations/Manager’s shall ensure that the appropriate HSSE risk assessments are
carried out. As part of the risk assessment, HSSE controls shall be identified for implementation such
that harm to people, asset, environment, and reputation are eliminated and/or minimised.

4.4.3.2.2 For survey and seismic activities, the following HSSE risk assessments, amongst others, shall be carried
out:

(1) Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA);

(2) Activities HSSE Risk Assessment, either quantitative, semi-quantitative and/or qualitative assessment
of specific health, safety and environmental risk, as necessary, e.g. Health Risk Assessment (HRA); and

(3) Job Hazard Analysis (JHA).

4.4.3.2.3 For exploration drilling activities, the following HSSE risk assessments, amongst others, shall be carried
out:

(1) Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA);

(2) Process Hazard Analysis (PHA), e.g. assessment of process/sub-surface drilling risk as part of
developing drilling programme;

(3) Activities HSSE Risk Assessment, either quantitative, semi-quantitative and/or qualitative assessment
of specific health, safety and environmental risk, as necessary, e.g. Health Risk Assessment (HRA); and

(4) Job Hazard Analysis (JHA).

4.4.3.2.4 In cases where Project Risk Assessment (PRA) is required, the scope of the assessment shall cover a
thorough evaluation of the HSSE risks associated with exploration activities.

4.4.3.2.5 Where required by legislation, the risk assessment reports (e.g. Environmental Impact Assessment
Report) shall be submitted for approval by the relevant regulatory authorities.

4.4.3.3 Development Phase

4.4.3.3.1 Prior to commencement of the various stages of development phase, the Head of
Departments/Operations/Manager’s shall ensure that the appropriate HSSE risk assessments are
carried out. As part of the risk assessment, HSSE controls shall be identified for implementation such
that harm to people, environment, asset and reputation are eliminated and/or minimised.

4.4.3.3.2 During the various stages of development phase, the required HSSE risk assessments are specified.

4.4.3.3.3 Conceptual Design

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As a minimum, the following HSSE risk assessments, amongst others, shall be carried out:

4.4.3.3.3.1 Conceptual Hazard and Operability Studies (HAZOP) or Hazard Identification (HAZID).

4.4.3.3.4 Detailed Design

4.4.3.3.4.1 As a minimum, the following HSSE risk assessments, amongst others, shall be carried out:

(a). Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA);

(b). Process Hazard Analysis (PHA), e.g. Hazard and Operability Studies (HAZOP), Instrumented Protective
Function (IPF) studies, Layers of Protection Analysis (LOPA), etc;

(c). Major hazard assessments e.g. Quantitative Risk Assessment (QRA) including other specialised
studies, e.g. Gas Plume Assessment, Blast and Thermal Radiation Assessment, Emergency System
Survivability Analysis (ESSA) and Emergency, Temporary Refuge, Evacuation and Rescue Analysis
(ETRERA);

(d). Ergonomics/Human Factor Engineering Assessment; and

(e). Failure Mode and Effect Analysis (FMEA) and Failure Mode, Effect and Criticality Assessment (FMECA).

4.4.3.3.4.2 The Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA) should be developed as early as possible during the design stage, and it should
cater for all on-site activities associated with the field development, including for drilling activities.

4.4.3.3.4.3 Where required by legislation, the risk assessment reports (e.g. Environmental Impact Assessment
Report) shall be submitted for approval by the relevant regulatory authorities.

4.4.3.3.5 Fabrication/Construction, Installation, Hook-up and Commissioning

As a minimum, the following HSSE risk assessments, amongst others, shall be carried out:

(a). Activities HSSE Risk Assessment, either quantitative, semi-quantitative and/or qualitative assessment
of specific health, safety and environmental risk, as necessary, e.g. Health Risk Assessment (HRA);

(b). Job Hazard Analysis (JHA); and

(c). Pre-Start Up Review/Audit (Pre-Activity Safety Review).

4.4.3.3.6 Development Drilling

4.4.3.3.6.1 As a minimum, the following HSSE risk assessments, amongst others, shall be carried out:

(a). Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA);

(b). Process Hazard Analysis (PHA), e.g. assessment of process/sub- surface drilling risk as part of
developing drilling programme;
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(c). Activities HSSE Risk Assessment, either quantitative, semi- quantitative and/or qualitative assessment
of specific health, safety and environmental risk, as necessary, e.g. Health Risk Assessment (HRA); and

(d). Job Hazard Analysis (JHA).

4.4.3.3.6.2 Where required by legislation, the risk assessment reports (e.g. Environmental Impact Assessment
Report) shall be submitted for approval by the relevant regulatory authorities.

4.4.3.3.7 In cases where Project Risk Assessment (PRA) is required, the scope of the assessment shall cover a
thorough evaluation of the HSSE risks associated with development activities.

4.4.3.4 Production and Maintenance Phase

4.4.3.4.1 During production and maintenance phase, the Head of Departments/Operations/Manager’s shall
ensure that the appropriate HSSE risk assessments are carried out. As part of the risk assessment, HSSE
controls shall be identified for implementation such that harm to people, environment, asset and
reputation are eliminated and/or minimised.

4.4.3.4.2 During production and maintenance phase, the following HSSE risk assessments, amongst others, shall
be carried out:

4.4.3.4.2.1 Facility HSSE Risk Assessment

4.4.3.4.2.1.1 Process Hazard Analysis (PHA), e.g. Hazard and Operability Studies (HAZOP), Instrumented
Protective Function (IPF), Layers of Protection Analysis (LOPA), etc; and

4.4.3.4.2.1.2 Major hazard assessments e.g. Quantitative Risk Assessment (QRA) including other specialised
studies, e.g. Gas Plume Assessment, Blast and Thermal Radiation Assessment, Emergency System
Survivability Analysis (ESSA) and Emergency, Temporary Refuge, Evacuation and Rescue Analysis
(ETRERA).

Process Hazard Analysis (PHA) shall be carried out at least once in every five years.

Where required by legislation, the risk assessment reports shall be submitted for approval by the relevant
regulatory authorities.

4.4.3.4.2.2 Activity HSSE Risk Assessment

4.4.3.4.2.2.1 Activities HSSE Risk Assessment, either quantitative, semi- quantitative and/or qualitative
assessment of specific health, safety and environmental risk, as necessary, e.g. Health Risk
Assessment (HRA)

4.4.3.4.2.2.2 Job Hazard Analysis (JHA);

4.4.3.4.2.2.3 Pre-Start up Review (PSR); and

4.4.3.4.2.2.4 HSSE risk assessment associated with simultaneous activities.

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Where required by legislation, the risk assessment reports shall be submitted for approval by the
relevant regulatory authorities.

4.4.3.4.3 For any process-related activities (e.g. plant shutdown, start-up and/or major maintenance activities),
the required Pre-Start up Review shall be carried out in line with the requirements stipulated in SEAH
Pre-Start up Review Guideline.

4.4.3.4.4 Prior to commencement of simultaneous operations (e.g. simultaneous production and drilling,
simultaneous production and construction/commissioning, simultaneous production and major
maintenance), the required Pre-Start up Review shall be carried out in line with requirements stipulated
in SEAH Pre-Start up Review Guideline.

4.4.3.5 Decommissioning and Abandonment Phase

4.4.3.5.1 Prior to decommissioning and/or abandoning any facility, the Head of


Departments/Operations/Manager’s shall ensure that the appropriate HSSE risk assessments are
carried out. As part of the risk assessment, HSSE controls shall be identified for implementation such
that harm to people, environment, asset and reputation are eliminated and/or minimised.

4.4.3.5.2 As a minimum requirement, the following HSSE risk assessments shall be carried out:

(a). Environmental Impact Assessment (EIA), including Social Impact Assessment (SIA) and/or Health
Impact Assessment (HIA);

(b). Major hazard assessments e.g. QRA covering the major hazard associated with the decommissioning
and abandonment of facility;

(c). Pre-Start up Review (PSR);

(d). Activities HSSE Risk Assessment, either quantitative, semi-quantitative and/or qualitative assessment
of specific health, safety and environmental risk, as necessary, e.g. Health Risk Assessment (HRA); and

(e). Job Hazard Analysis (JHA).

4.4.3.5.3 In cases where Project Risk Assessment (PRA) is required, the scope of the assessment shall cover a
thorough evaluation of the HSSE risks associated with decommissioning and abandonment activities.

4.4.3.5.4 Where required by legislation, the risk assessment reports (e.g. Environmental Impact Assessment
Report) shall be submitted for approval by the relevant regulatory authorities.

4.4.3.6 The risk management requirement in Operations lifecycle can be summarised as follows:

PHASE OPERATIONS STAGE HSSE RISK ASSESSMENT


 CRA
Acquisition Business Development  HSSE Due Diligence for asset acquisition
and/or asset takeover

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PHASE OPERATIONS STAGE HSSE RISK ASSESSMENT


 EIA, including SIA and/or HIA
Survey and seismic  Activities HSSE Risk Assessment
 JHA
Exploration &
 EIA, including SIA and/or HIA
Appraisal
 PHA
Exploration Drilling
 Activities HSSE RiskAssessment
 JHA
Conceptual Design  ConceptualHAZOP/HAZID
 EIA, including SIA and/or HIA
 PHA
 Major hazard assessment
Detailed Design
 Ergonomics/ Human Factor Engineering
Assessment
 FMEA/ FMECA
Development
Fabrication/Construction,  Activities HSSE RiskAssessment
Installation, Hook-up and  JHA
Commissioning  PSR
 EIA, including SIA and/or HIA
 PHA
Development Drilling
 Activities HSSE Risk Assessment
 JHA
Facility Risk Assessment:
 PHA
 Major Hazard assessment
Activities Risk Assessment:
Production and For normal and
Maintenance simultaneous operations  Activities HSSE Risk Assessment
 JHA
 PSR
 HSSE risk assessment related to
simultaneous operations
 EIA, including SIA and/or HIA

Decommissioning  Major Hazard assessment


and -  PSR
Abandonment  Activities HSSE Risk Assessment
 JHA

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4.4.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) HSSE risk assessment report/records associated with acquisition activities, e.g. Risk Assessment
Report, etc;

(2) HSSE risk assessment report/records associated with exploration activities, e.g. Hazard and Effects
Register, Project Risk Assessment Report, Health Risk Assessment Report, Environmental Impact
Assessment, etc;

(3) HSSE risk assessment report/records associated with development activities, e.g. Hazard and Effects
Register, Project Risk Assessment Report, Health Risk Assessment Report, Environmental Impact
Assessment, etc;

(4) HSSE risk assessment report/records associated with production and maintenance activities, e.g.
Hazard and Effects Register, Process Hazard Analysis Reports, Chemical Health Risk Assessment
Report, etc; and

(5) HSSE risk assessment report/records associated with decommissioning and abandonment activities,
e.g. Project Risk Assessment, Hazard and Effects Register, Process Hazard Analysis Reports,
Environmental Impact Assessment Report, Chemical Health Risk Assessment Report, etc.

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HSSE MANAGEMENT SYSTEM

ELEMENT 5: PLANNING AND PROCEDURES

5.1 HSSE PLAN

5.1.1 Purpose

This Sub-Element defines SEAH requirement for the development of HSSE Plan in line with the Company’s
HSSE Strategies and Initiatives.

5.1.2 Scope

The requirement defined in this Sub-Element shall apply throughout SEAH operations.

5.1.3 Expectations

5.1.3.1 SEAH HSSE Plan

5.1.3.2.1 The Head of Department, HSSE shall develop SEAH HSSE Plan, incorporating corporate level action
items aimed at achieving the strategic objectives stipulated in SEAH HSSE Strategies and Initiatives.

5.1.3.2.2 The HSSE Plan shall be approved by SEAH HSSE Committee and signed by the Chief Executive Officer.

5.1.3.2 In cases where the location Annual HSSE Plan have not addressed project related HSSE activities, the
Project HSSE Plan shall be developed accordingly. The responsibility to develop and track the
implementation of the Project HSSE Plan is vested with the respective Managers/Contract
Owner/Contract Holder.

5.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Approved HSSE Plans;

(2) Relevant reports e.g. HSSE Plan implementation tracking, status of implementation report, etc; and

(3) Records of dissemination and/or communication e.g. minutes of meeting, distribution list, etc.

5.2 ASSET INTEGRITY

5.2.1 Purpose

This Sub-Element defines SEAH requirement in ensuring the technical and operational integrity of asset
(facilities and equipment) that SEAH design, procure, fabricate, install, acquire, operate and maintain;
including the requirement in respect of testing, inspection and monitoring of these facilities and
equipment.

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5.2.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

5.2.3 Expectations

5.2.3.1 SEAH shall have in place the required reliability and integrity management system to ensure the
technical and operational integrity of assets (facilities and equipment).

5.2.3.2 The requirement for technical and operational integrity of facilities and equipment shall span from
design, procurement, fabrication, installation, operations and maintenance to eventual abandonment.

5.2.3.3 All personnel who perform activities related to asset integrity are required to have the appropriate
competency in undertaking these activities.

5.2.3.4 Operations and Maintenance of Asset

5.1.3.2.1 During the operations and maintenance phase, the Head of Operation/Manager’s shall ensure that all
required technical and operational integrity requirements are complied with, conforming to SEAH
requirements.

5.1.3.2.2 The reliability and integrity management system, including maintenance management system, shall be
in place and fully functional in ensuring the continued technical and operational integrity of asset
(facilities and equipment).

5.2.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of reliability and integrity management system, including maintenance management
system;

(2) Maintenance and inspection records; and Training records of personnel.

5.3 PROCEDURES AND WORK INSTRUCTIONS

5.3.1 Purpose

This Sub-Element defines SEAH requirements for written procedures and work instructions for all HSSE-
critical activities carried out throughout SEAH.

5.3.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

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5.3.3 Expectation

5.3.3.1 Procedures and Work Instructions

5.3.3.1.1 The Head of Operation/Managers shall ensure that written procedures and work instructions are
available for all HSSE-critical activities within the location.

5.3.3.1.2 The requirements for written procedures and work instructions are applicable for all HSSE-critical
activities, spanning the entire SEAH ’s asset life cycle, including the associated support activities such
as Procurement and Logistics, Human Resources, Financial Services, Information Management, etc.

5.3.3.1.3 Written procedures and work instructions shall contain, as minimum, the followings;

5.3.3.1.3.1 Description of normal steps required in executing the task, as well as actions to be taken to cater for
any abnormal and emergency situations that may arise during the execution of the task;

5.3.3.1.3.2 Tasks to be completed, methods and/or tools to be used, data to be recorded, operating conditions to
be maintained, samples to be collected; and

5.3.3.1.3.3 HSSE control and recovery measures (identified in the activity/task risk assessment) required to ensure
safe execution of task, such that harm to people, environment, asset and reputation are eliminated
and/or minimised.

5.3.3.1.4 Training shall be conducted to ensure personnel are aware of the existence of procedures and work
instructions, understand their applicability and are competent to apply their requirements.

5.3.3.1.5 Procedures and work instructions shall be maintained as a controlled document. Any changes to
procedures and work instructions shall be managed in accordance with the management of change
process.

5.3.3.1.6 Procedures and work instructions shall be reviewed and revised as and when required, e.g. to
incorporate lesson learnt from incident investigation, reviews, studies, audits, etc; or at least once in
every three years.

5.3.3.2 Operating Manual

5.3.3.2.1 The Head of Operation/Managers shall ensure that plant operating manuals are available for all
facilities/worksites within the respective location.

5.3.3.2.2 The information contained in the Operating Manual shall include, amongst others, the followings:

5.3.3.2.2.1 Description of the facility;

5.3.3.2.2.2 Plant and equipment layout;

5.3.3.2.2.3 Start-up, normal operation and shutdown procedures;

5.3.3.2.2.4 Description of utilities system, including design information;

5.3.3.2.2.5 Description of process facilities, including design information;


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5.3.3.2.2.6 Description of control and instrumentation, including trip and interlocks; and

5.3.3.2.2.7 Description of safety systems e.g. fire and gas detection system, fire protection system, hazardous area
classification, etc.

5.3.3.2.3 All operations and maintenance personnel identified to work at the facility, including Contractors, shall
be trained and competent to operate the facility in accordance with the Operating Manual.

5.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of approved written procedures and work instructions for all HSSE-critical activities;

(2) Records related to communication and/or training to relevant personnel

(3) Records related to procedures and work instructions revision.

5.4 MANAGEMENT OF CHANGE

5.4.1 Purpose

This Sub-Element defines SEAH requirement for the effective management and control of changes
associated with Company business, with a view to preventing adverse HSSE impact.

5.4.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

5.4.3 Expectations

5.4.3.1 The Head of Department/Operation/Manager’s shall ensure that an effective management of change
system, including the associated procedures and guidelines, are developed and implemented to
manage and control changes within their respective location.

5.4.3.2 The type of changes that need to be controlled within the location shall be identified; the key
consideration being all changes that may have adverse HSSE impact. The various types of changes may
include, amongst others, the followings:

(1) Changes in approved design of facilities and equipment;

(2) Changes in approved operating and maintenance philosophy;

(3) Changes in plant and equipment;

(4) Changes in operating parameters;

(5) Changes in chemicals and/or hazardous materials;


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(6) Changes in approved procedures and work instructions;

(7) Changes in personnel occupying HSSE-critical positions; and

(8) Bypass of safety-critical equipment.

5.4.3.3 Guidelines on the nature of changes (e.g. normal, emergency and urgent changes), duration of changes
(permanent or temporary), documentations, tracking system, etc., shall also be specified.

5.4.3.4 The requirement on risk assessment shall be clearly specified. The risk attributed to the change shall
be assessed and additional or alternative HSSE controls, including mitigation, shall be identified such
that risk posed by the change remains as low as reasonably practicable (ALARP).

5.4.3.5 The requirement for technical endorsement and approval authorities shall also be clearly specified,
aligning the level of technical and approval authorities to the level of HSSE risk attributed to the
proposed change. Additionally, for extension of temporary changes, the requirement for higher level
technical endorsement and approval authorities shall also be clearly specified.

5.4.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of Management of Change procedures; types, nature and duration of changes clearly
defined.

(2) Documentation associated with Management of Change, e.g. MOC forms, risk assessment, tracking
of MOC, minute of meeting, training records, etc.

5.5 CRISIS, EMERGENCY AND CONTINGENCY PLANNING

5.5.1 Purpose

This Sub-Element defines SEAH requirement for an effective crisis and emergency management system,
including the associated plans and procedures, to manage incidents that may arise out of or in the course
of SEAH ’s activities.

5.5.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

5.5.3 Expectations

5.5.3.1 Head of Department, HSSE shall define the Crisis and Emergency Management System for SEAH
operations, including for Contractors engaged in work for the Company. The system shall define,
amongst others, the followings:

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(1) Crisis, emergency management and emergency response organisation, clearly defining roles and
responsibilities of team members;

(2) Procedures for managing and/or responding to crisis and emergencies, including contingency plans;

(3) Resources required for managing and/or responding to crisis and emergencies, including
arrangements for mobilising third party resources; and

(4) Competency requirement, including training and exercises to maintain crisis and emergency
preparedness.

5.5.3.2 SEAH Crisis and Emergency Management System shall conform to the relevant legislative requirements,
International Standards and/or Industry Standards.

5.5.3.3 SEAH Incident Management Organisation

5.5.3.3.1 The Head of Department, HSSE shall establish the SEAH Emergency Management Organisation to
manage crisis and emergency that may arise out of or in the course of SEAH business, including for
Contractors engaged in work for the Company.

5.5.3.3.2 The SEAH Incident Management Team steward the overall management of crisis and emergency
throughout SEAH operations, providing the required resources and technical support to the location.

5.5.3.3.3 The Incident Management Team shall comprise an Incident Commander, appointed from amongst the
Managers, as well as the required numbers of team members from amongst the relevant business
functions in SEAH.

5.5.3.3.4 The Incident Management Team shall be provided with adequate resources, information, procedures
and guidelines, including contingency plans, to ensure the effective management of crisis and
emergency throughout SEAH operations.

5.5.3.3.5 To complement the effective functioning of the Incident Management Team, the Incident Commander
(IC) may mobilise additional personnel and/or team (e.g. Technical Support Team, HR Support Team,
etc) to support the crisis and emergency management effort.

5.5.3.3.6 To ensure and maintain crisis and emergency management preparedness, the Incident Management
Team shall be provided with the required trainings and exercises.

5.5.3.4 Site Emergency Controller Team

5.5.3.5 The Offshore Installation Manager/Manager’s the respective location shall establish the Site Emergency
Controller Team to respond to emergency that may occur at the facility.

5.5.3.6 The Site Emergency Controller Team responds to all emergencies occurring on the facility. In cases
where additional resources and technical support are required, these shall be mobilised by the Incident
Management Team.

5.5.3.7 The Site Emergency Controller Team shall comprise an On-Scene Commander, who is the Person-in-
Charge of the facility, as well as the required numbers of team members from amongst the personnel
on the facility.
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5.5.3.8 The Site Emergency Controller Team shall be provided with adequate resources, information,
procedures and guidelines, including contingency plans, to ensure the effective response to all
emergencies on the facility.

5.5.3.9 To ensure and maintain emergency response preparedness, the Site Emergency Controller Team shall
be provided with the required trainings and exercises.

5.5.3.10 Contingency Plan

5.5.3.10.1 The Head of Department, HSSE and the Head of Operations shall develop the required Contingency
Plans, as necessary, to cater for major emergencies that may occur within their respective location. This
may include, amongst others, the following contingency plans:

5.5.3.10.1.1 Business Continuity Plan;

5.5.3.10.1.2 Oil Spill Contingency Plan;

5.5.3.10.1.3 Medical Evacuation Plan;

5.5.3.10.1.4 Natural Disaster Contingency Plan;

5.5.3.10.1.5 Inclement (Severe) Weather Contingency Plan;

5.5.3.10.1.6 Search and Rescue Plan;

5.5.3.10.1.7 Facility Abandonment and Evacuation Plan;

5.5.3.10.1.8 Influenza Pandemic Preparedness Plan; and

5.5.3.10.1.9 Security Risk and Evacuation Plan.

5.5.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Availability of SEAH Emergency Management Plan, Facility Emergency Response Plan and the required
contingency plans; and

(2) Relevant documents associated with emergency management and/or response, e.g. emergencies
logbook, records of emergency exercise/drill, duty roster, appointment of respective emergency
management and/or response team, training records, list of relevant external parties’ directory, etc.

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HSSE MANAGEMENT SYSTEM

ELEMENT 6: IMPLEMENTATION AND MONITORING

6.1 PERFORMANCE MONITORING

6.1.1 Purpose

This Sub-Element defines SEAH requirement on the establishment of key HSSE performance indicators,
aimed at ensuring full conformance to the requirement of the SEAH HSSE Management System, and the
associated procedures and guidelines.

6.1.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

6.1.3 Expectations

6.1.3.1 SEAH Management HSSE Committee shall establish for implementation throughout SEAH operations,
including Contractors, the relevant corporate-level HASE-related key performance indicators (KPI),
both leading and lagging, to monitor compliance to the requirements of the HSSE Management System.

6.1.3.2 The location HSSE Committee shall establish for implementation, the relevant HSSE-related key
performance indicators (KPI), both leading and lagging, to monitor compliance to the requirements of
the HSSE Management System within the respective location including Contractors.

6.1.3.3 The location HSSE Committee shall also establish for implementation, the relevant facility/worksite-
level HSSE-related key performance indicators (KPI), both leading and lagging, to monitor compliance
to the requirements of the HSSE Management System for facilities/worksites.

6.1.3.4 The respective HSSE Committees shall also define the targets and/or limits for the identified HSSE-
related key performance indicators (KPI), taking into consideration the needs for challenging targets
benchmarked to International and/or Industry Standards, as part of continuous improvement process.

6.1.3.5 Additionally, the appropriate leading HSSE-related key performance indicators (KPI) and agreed target
shall be identified and assigned to individuals as part of employees’ performance management system.

6.1.3.6 Examples of key performance indicators (KPI) at Corporate and Facility/Worksite level, amongst others,
are as follows:

Leading Lagging
Corporate  HSSE Plan Implementation  Total Recordable
 Conduct of HSSEMS Occupational Illness
Assurance Frequency (TROIF)
 Total Reportable Case
Frequency (TRCF)
 Oil Spill Index (OSI)

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Leading Lagging
Location  Management Operation Visit  HSSEMS Implementation
(MOV)  Number of
 Drug and Alcohol Testing Temporary MOC
 HSSE Policy  Lost Time Injury
Communication Frequency (LTIF)
Programme  Total Reportable Case
 Tracking of the Frequency (TRCF)
implementation HSSE  Maintenance Backlog
Recommended Action Items or percentage of
 Completeness ofMOCRisk corrective maintenance
Assessment versus planned
 Waste Minimisation maintenance
Programme  Availability of
 Frequency ofHygiene lifesaving appliances
Inspection  Audiometric Testing
 Validity of equipment Programme
testing/certification (e.g. crane,  Fire IncidentFrequency
pressure vessel, pressure relief (FIF)
valves, etc)  Effluent Discharge
 Tracking of the Quality (EDQ)
implementation HSSE  PTW Compliance Audit
Recommended Action Items  Number of Near Misses
 As-Builtness of HSE Case, CIMAH  Number of NoiseInduced
Report, Process Safety Hearing Loss
Information (PSI), ERP, etc.
 Conduct of Tier 1 HSSEMS
Assurance
 Healthsurveillance
programmes

6.1.3.7 SEAH shall also develop and implement an effective tracking system to monitor compliance to the
established HSSE-related key performance indicators and targets, including reporting to the respective
HSSE Committees.

6.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Approved HSSE KPI and performance targets;

(2) Relevant progress reports e.g. HSSE plan implementation, HSSE Recommended Action Items status,
training plan implementation, HSSE quarterly/monthly performance reports, etc;

(3) Monitoring reports e.g. Quarterly Environmental Monitoring Report, Health Surveillance Report, etc;

(4) Minutes of meetings of respective HSSE Committee;

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(5) Inspection/assurance reports e.g. Hygiene Inspection, etc; and

(6) Staff performance records.

6.2 RECORDS

6.2.1 Purpose

This Sub-Element defines SEAH requirement for safe-keeping, maintenance and retention of records to
demonstrate compliance to the requirements of the HSSE Management System and the associated
procedures and guidelines.

6.2.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

6.2.3 Expectations

6.2.3.1 Head of Department, HSSE shall maintain, on behalf of SEAH ’s Chief Executive Officer, the required
corporate level HSSE-related records.

6.2.3.2 Head of Department/Operation/Manager of the respective location shall maintain the required records
for their respective location.

6.2.3.3 The respective Head of Department/Operation/Manager shall identify the required records. A system
of records inventory shall be developed and maintained, taking into consideration aspect of records
security and accessibility.

6.2.3.4 Records that are required to be maintained shall include, but not limited to, the followings:

6.2.3.4.1 HSSE Policy and HSSE-related policies;

6.2.3.4.2 Job Description;

6.2.3.4.3 Employees Training records;

6.2.3.4.4 Employees Medical records;

6.2.3.4.5 Contract, including Invitation to Bid documents;

6.2.3.4.6 Minutes of Meeting of HSSE committees;

6.2.3.4.7 HSSE Risk Assessment records;

6.2.3.4.8 Health Surveillance and Monitoring records;

6.2.3.4.9 Permit to Work documentations, including the Associated certificates;

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6.2.3.4.10 Records relating to Asset Integrity, including Maintenance and Inspection records;

6.2.3.4.11 Management of Change documentation;

6.2.3.4.12 Records on Non-compliance;

6.2.3.4.13 Incident Investigation reports;

6.2.3.4.14 Evidence of HSSE Recommended Action Item (HSSERAI) closure;

6.2.3.4.15 HSSE Assurance reports; and

6.2.3.4.16 Management Review records.

6.2.3.5 The required records shall be kept and maintained, including archiving, by the respective location for a
minimum period of seven (7) years. Additionally, all health-related records shall be kept and
maintained, including archiving, for a period of thirty (30) years.

6.2.3.6 Where there are legislative and/or contractual requirements for record keeping, such requirements
shall be fully complied with.

6.2.4 Verification

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Records management system, including completeness of inventory of records; and

(2) Availability and accessibility of records.

6.3 NON-COMPLIANCE AND CORRECTIVE ACTIONS

6.3.1 Purpose

This Sub-element defines SEAH requirement relating to the management of non-compliance to the
requirements of SEAH ’s HSSE Management System, including the associated procedures and guidelines.

6.3.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

6.3.3 Expectations

6.3.3.1 Head of Department/Operation/Manager of the respective location ensure, in the conduct of SEAH
business activities, the requirements of all applicable HSSE-related legislations and SEAH HSSE
Management System are fully complied with.

6.3.3.2 In the event of non-compliance to legislative requirements, the Head of


Department/Operation/Manager of the respective location shall, in consultation with the Head of
Department, HSSE and Legal Services, notify the relevant regulatory authorities.
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6.3.3.3 As part of managing non-compliance to legislative requirements, the Head of


Department/Operation/Manager of the respective location shall:

6.3.3.3.1 Determine the nature and causes giving rise to the non-compliance;

6.3.3.3.2 Assess the HSSE risk posed by the non-compliance, including identifying the required mitigations;

6.3.3.3.3 Develop Action Plan, including incorporation of conditions, if any, set by the relevant regulatory
authorities; and

6.3.3.3.4 Implement Action Plan, including communication of requirements to relevant personnel.

6.3.3.4 In the event of significant non-compliance to SEAH HSSE Management System, including the associated
procedures and guidelines, the Head of Department/Operation/Manager of the respective location
shall:

6.3.3.4.1 Determine the nature and causes giving rise to the non-compliance;

6.3.3.4.2 Assess the HSSE risk posed by the non-compliance, including identifying the required mitigations;

6.3.3.4.3 Develop Action Plan; and

6.3.3.4.4 Implement Action Plan, including communication of requirements to relevant personnel.

Significant Non-Compliance: Those non-compliances that posed high risk to people, asset, environment,
and reputation incidents.

6.3.3.5 Significant non-compliance to SEAH HSSE Management System shall be managed through the
management of change (MOC) process. The non- compliance/change management shall be reviewed
and approved by the SEAH Management Steering Committee.

6.3.3.6 The Head of Department/Operation/Manager of the respective location, as well as Department HSSE,
shall maintain an inventory of non-compliances for their respective location.

6.3.3.7 All non-compliances to legislative requirements shall be reported to SEAH HSSE Committee.
Additionally, significant non-compliances to SEAH HSSE Management System shall be reported to the
respective location HSSE Committee.

6.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) HSSE Legal Register, including non-compliance records;

(2) Inventory of significant non-compliance to HSSE Management System, including action plan to attain
compliance;

(3) Records of communication with relevant regulatory authorities, including approval for non-
conformance;
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(4) Records of tracking of the implementation of action plan; and

(5) Minutes of meeting of HSSE Committees.

6.4 INCIDENT INVESTIGATION, REPORTING AND FOLLOW-UP

6.4.1 Purpose

This Sub-Element defines SEAH requirement for the investigation, notification and reporting of incidents
that may arise out of and in the course of SEAH activities, including for activities carried out by Contractors
engaged in work for the Company.

6.4.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

6.4.3 Expectations

6.4.3.1 Head of Department, HSSE shall develop and maintain SEAH Incident Investigation and Reporting
System covering, amongst others:

6.4.3.1.1 Procedures on incident investigation, notification and reporting; and

6.4.3.1.2 Database for incidents, including system for tracking to closure of action items arising from incident
investigation.

6.4.3.2 SEAH Incident Investigation and Reporting Procedure shall conform to the requirement of the relevant
legislation as well as SEAH Standards.

6.4.3.3 For specific legislative requirements, if any, Head of Department/Operation/Manager of the respective
location shall develop and maintain additional procedures, in line with SEAH Incident Investigation and
Reporting Procedures, to cater for these requirements.

6.4.3.4 All incidents shall be investigated to identify the root causes such that preventive measures can be
implemented to prevent recurrence.

6.4.3.5 Head of Department/Managers, HSSE of the respective location shall disseminate throughout SEAH the
lesson-learnt from incidents, in particular those that have lateral applications, such that the required
HSSE controls can be implemented to prevent occurrence of similar incident.

6.4.3.6 For major and high potential incidents, lesson-learnt from the incident shall be reviewed by the
respective Head of Operation/location HSSE Committee, and where required, SEAH Management HSSE
Committee.

6.4.3.7 Any incident arising out of or in connection with work that cause i.e. Fatality or Serious bodily injury (1st
Schedule – NADOPOD Regulations 2004) or Dangerous occurrence (2nd Schedule NADOPOD Regulations
2004) shall be reported to Department of Occupational Safety and Health (DOSH)

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Document Number: SEAH-00-GEN-HSSE-MD-MAN-NA-0001
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6.4.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Incident investigation reports;

(2) Records associated with the status of implementation of action items arising from incident
investigation reports e.g. Closing report, performance reporting, etc;

(3) Evidence of dissemination and/or communication of lesson learnt and alert; and

(4) Training records.

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Revision: 0

HSSE MANAGEMENT SYSTEM

ELEMENT 7: AUDIT AND ASSURANCE

7.1 HSSE ASSURANCE PLANNING

7.1.1 Purpose

This Sub-Element defines SEAH requirement in respect of HSSE audits, to provide assurance to senior and
line management that HSSE controls are in place, and that the HSSE Management System is effectively
implemented and maintained.

7.1.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

7.1.3 Expectations

7.1.3.1 SEAH 's HSSE Assurance Guideline provides detail guidelines on the implementation of HSSE assurance
programmes throughout SEAH operations, including Contractors.

7.1.3.2 Head of Department, HSSE shall develop SEAH HSSE Assurance Plan. The plan shall cater for both long
term and short-term assurance activities (Four-plus-One Years HSSE Assurance Plan), and shall identify
all required HSSE assurance activities, including for Contractors.

7.1.3.3 Head of Department/Operation/Manager of the respective location develop an annual HSSE Assurance
Plan for their respective location. The plan shall identify all required HSSE assurance activities within
the location, including for Contractors.

7.1.3.4 SEAH shall provide adequate number of competent personnel to implement the required HSSE
assurance programmes.

7.1.3.5 An effective tracking system shall be in place to track to closure action items/recommendations arising
from HSSE assurance.

7.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) HSSE Assurance Plan;

(2) HSSE training records of personnel involved in HSSE assurance;

(3) Availability of effective tracking system; and

(4) Records associated with HSSE assurance, e.g. Term of Reference, status of implementation of HSSE
assurance recommendations, evidence of communication of findings, etc.

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7.2 HSSE MANAGEMENT SYSTEM ASSURANC

7.2.1 Purpose

This Sub-Element defines SEAH ’s requirement in respect of HSSE Management System Assurance for the
purpose of:

(1) Assessing the adequacy of HSSE Management System;

(2) Verifying the compliance to HSSE Management System requirements; and

(3) Identifying gaps in the implementation of the HSSE Management System such that appropriate
intervention plan can be developed, to enhance compliance as part of continual improvement
process.

7.2.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

7.2.3 Expectations

7.2.3.1 SEAH HSSE Assurance Plan, as well as the respective location HSSE Assurance Plan shall be developed
for implementation. The assurance exercise shall be carried out in accordance with SEAH HSSE
Assurance Guidelines.

7.2.3.2 Tier 1 HSSE Management System Assurance

7.2.3.2.1 Each department and/or facility shall carry out Tier 1 HSSE Management System assurance to assess
compliance to the requirements of the HSSE Management System and the associated procedures and
guidelines.

7.2.3.2.2 Gaps identified during the Tier 1 HSSE Management System assurance, if any, shall form the basis for
the development of appropriate intervention plan to enhance compliance to the HSSE Management
System.

7.2.3.2.3 The frequency of Tier 1 HSSE Management System assurance shall be as stipulated in the respective
location HSSE Assurance Plan.

7.2.3.2.4 Tier 1 HSSE Management System assurance shall be led by the Person-in- Charge of the department
and/or facility and team members selected among the personnel working in the department and/or
facility.

7.2.3.2.5 The implementation of recommendations arising from Tier 1 HSSE Management System assurances
shall be monitored by the respective location’s HSSE Committee until completion.

7.2.3.3 Tier 2 HSSE Management System Assurance

7.2.3.3.1 Location shall be subjected to Tier 2 HSSE Management System assurance to assess compliance to the
requirements of the HSSE Management System and the associated procedures and guidelines.
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7.2.3.3.2 Gaps identified during the Tier 2 HSSE Management System assurance, if any, shall form the basis for
the development of appropriate intervention plan to enhance compliance to the HSSE Management
System.

7.2.3.3.3 The frequency of Tier 2 HSSE Management System assurance shall be as stipulated in SEAH HSSE
Assurance Plan.

7.2.3.3.4 Tier 2 HSSE Management System Assurance team shall comprise, as a minimum, the following:

7.1.3.3.4.1 Assurance Team Leader shall be at least a Head of Department; and

7.1.3.3.4.2 The Assurance Team shall comprise members from relevant disciplines and/or functions within SEAH.

7.2.3.3.5 The implementation of recommendations arising from Tier 2 HSSE Management System assurances
shall be monitored by SEAH Management HSSE Committee, as well as the respective location’s HSSE
Committee until completion.

7.2.3.4 Tier 3 HSSE Management System Assurance

7.2.3.4.1 The purpose of Tier 3 HSSE Management System assurance is to assess the adequacy, as well as
effectiveness of implementation, of SEAH HSSE Management System and the associated procedures
and guidelines.

7.2.3.4.2 Each location shall be subjected to Tier 3 HSSE Management System assurance at least once in five
years.

7.2.3.4.3 The implementation of recommendations arising from Tier 3 HSSE Management System assurances
shall be monitored by SEAH HSSE Committee, as well as the respective location’s HSSE Committee until
completion.

7.2.3.5 Contractors’ HSSE Management System Assurance

7.2.3.5.1 SEAH Department HSSE shall carry out assurance on the adequacy, as well as effectiveness of
implementation, of Contractor HSSE Management System; and in cases where the HSSE Management
System is not formalized, an assessment of the adequacy of procedures and practices used by the
Contractors to manage HSSE.

7.2.3.5.2 The primary standard for Contractors HSSE Management System Assurance shall be the respective
Contractors’ HSSE Management System. Additionally, SEAH ’s HSSE Management System, as well as
International and/or Industry Standards on HSSE management should be used as secondary assurance
standards.

7.2.3.5.3 The scope for Contractors’ HSSE Management System Assurance shall cover the whole Contractors’
business activities associated with SEAH.

7.2.3.5.4 System assurance on Contractors HSSE Management System team shall comprise, as a minimum, the
following:

7.2.3.5.4.1 Assurance Team Leader shall be a Manager or Lead; and


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7.2.3.5.4.2 The Assurance Team members shall comprise members from relevant disciplines and/or functions
within SEAH.

7.2.3.5.5 Gaps identified during the compliance assurance on Contractors HSSE Management System, if any, shall
form the basis for the development of appropriate intervention plan to enhance compliance to the
respective Contractors HSSE Management System.

7.2.3.5.6 The implementation of recommendations arising from compliance assurance on Contractors HSSE
Management System shall be monitored by the respective location’s HSSE Committee until completion.

7.2.3.5.7 Apart from SEAH-led HSSE Management System assurance, Contractors shall develop their respective
HSSE Assurance Plan and carry out the required HSSE assurance, including assurance carried out by
external auditors and certification bodies.

7.2.3.5.8 SEAH Contract Holder shall ensure that the senior management personnel of Contractors participate in
SEAH -led HSSE assurance.

7.2.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) SEAH HSSE Assurance Plan;

(2) HSSE Management System Assurance reports;

(3) HSSE Plan incorporating gaps identified from both Tier 1 and Tier 2 HSSE-MS Assurance; and

(4) Records associated with HSSE assurance, e.g. status of implementation of HSSE assurance
recommendations, evidence of close out, minutes of meeting, etc.

7.3 TECHNICAL HSSE ASSURANCE

7.3.1 Purpose

This Sub-Element defines SEAH requirement in respect of Technical HSSE Assurance, to provide assurance
that the integrity of facilities and/or activities conform to SEAH HSSE Management System, SEAH HSSE-
related technical standards, as well as SEAH Technical Standards.

7.3.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

7.3.3 Expectations

7.3.3.1 Head of Department, HSSE shall develop SEAH HSSE Assurance Plan for implementation throughout
SEAH operations.

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7.3.3.2 As general guideline, the following technical HSSE assurance, amongst others, shall be carried out
within SEAH operations, including Contractors:

7.3.3.2.1 HSSE Legal Compliance Assurance;

7.3.3.2.2 Noise and Chemical Management Assurance;

7.3.3.2.3 Fire Safety Review/ Emergency Mitigation Facilities Review;

7.3.3.2.4 Aviation and/or Marine Safety Assurance;

7.3.3.2.5 Produced Water Treatment System Assurance;

7.3.3.2.6 Scheduled Waste Management Assurance;

7.3.3.2.7 Asset Integrity Assurance for Production Facilities;

7.3.3.2.8 Internal Environmental Management System Audit; and

7.3.3.2.9 Project Integrated Review (e.g. Conceptual Design, Detail Design, Fabrication, Installation, etc).

7.3.3.3 The primary standards for technical HSSE assurance shall be SEAH HSSE Management System and the
associated procedures and guidelines as well as those applicable International and/or Industry
Standards adopted for use by SEAH.

7.3.3.4 Technical HSSE Assurance team shall comprise, as a minimum, the following:

7.3.3.4.1 Assurance Team Leader shall be a Technical Manager; and

7.3.3.4.2 The Assurance Team members shall be Subject Matter Experts from relevant technical disciplines.

7.3.3.5 The implementation of recommendations arising from technical HSSE assurances shall be monitored
by SEAH Management HSSE Committee, as well as the respective location HSSE Committee until
completion.

7.3.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) SEAH HSSE Assurance Plan;

(2) Technical HSSE Assurance reports; and

(3) Records associated with technical HSSE assurance, e.g. status of implementation of HSSE assurance
recommendations, evidence of close out, minutes of meeting, etc.

7.4 EXTERNAL HSSE ASSURANCE

7.4.1 Purpose

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This Sub-Element defines SEAH requirement in respect of external HSSE assurance by external bodies,
including for the purpose of certification.

External HSSE assurance includes those assurances carried out by external bodies; for example, ISO
certification, OHSAS certification, insurance audit, audit carried out as part of HSSE award and recognition
programmes, etc.

7.4.2 Scope

The requirements defined in this Sub-Element shall apply throughout SEAH operations, including
Contractors engaged in work for the Company.

7.4.3 Expectations

7.3.4.1 Each location may choose to undergo an international and/or industry certification programmes as part
of HSSE management. The frequency of this external HSSE assurance would be based on the
requirement of the respective international and/or industry certification bodies.

7.3.4.2 The implementation of recommendations arising from external HSSE assurances shall be monitored by
SEAH Management HSSE Committee, as well as the respective location’s HSSE Committee until
completion.

7.4.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) External HSSE assurance reports; and

(2) Records associated with external HSSE assurance, e.g. status of implementation of HSSE assurance
recommendations, evidence of close out, minutes of meeting, etc.

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HSSE MANAGEMENT SYSTEM

ELEMENT 8: MANAGEMENT REVIEW

8.1 MANAGEMENT REVIEW

8.1.1 Purpose

This Sub-Element defines SEAH requirement for the review of the HSSE Management System, in order to:

(1) Assess the adequacy of the HSSE Management System, including benchmarking to industry best
practices;

(2) Review the effectiveness of implementation of SEAH HSSE Management System;

(3) Review the adequacy of the associated HSSE policy, organisation, arrangements, procedures and
guidelines; and

(4) Identify gaps and weaknesses such that appropriate intervention plan can be taken, with a view to
ensuring the achievement and sustenance of continual improvement to SEAH HSSE performance.

8.1.2 Scope

The Management Review shall cover wholly or any parts of SEAH HSSE Management System, as well as
the associated procedural arrangements integral to the HSSE Management System.

8.1.3 Expectations

8.1.3.1 SEAH Management Review

8.1.3.2.1 The SEAH Management Review shall be carried out at least once in year, by SEAH Management HSSE
Committee.

8.1.3.2.2 The review should include, but not limited to, the followings:

Assessment of the overall effectiveness of implementation of the HSSE Management System within SEAH;

Review the adequacy of the HSSE Management System, benchmarking to SEAH Technical Standards,
International Standards and industry standards/best practices; and

Generally, addresses the HSSE policy, organisation and arrangements necessary to achieve continuous
improvement of SEAH HSSE Performance.

8.1.3.2 Location Management Review

8.1.3.2.1 The location Management Review shall be carried out, at least once in six months, by the respective
location HSSE Committee.

8.1.3.2.2 The review should include, but not limited to, the followings:

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8.1.3.2.2.1 Assessment of the overall effectiveness of implementation of HSSE Management System within the
location and

8.1.3.2.2.2 Identify gaps, as required, and develop intervention plans to ensure full compliance to HSSE
Management System.

8.1.3.2.3 Findings and recommendations from the location Management Review should be presented to SEAH
Management HSSE Committee.

8.1.4 Verifications

Compliance to the above expectations may be demonstrated by the following documentations:

(1) Minutes of meeting of HSSE Committees; and

(2) HSSE Management System Implementation Plan.

HEALTH SAFETY ENVIRONMENT


Hazardous material Fire &Explosion Airborne Emissions
 Sulphuric Acid  Flammability  Vents (CO2, CH4)
 Caustic Soda  Expansion  Flares
 TENORM (Technologically  BLEVE (Boiling Liquid Expanding  Fugitives
Enhanced Naturally Vapour Explosion)  General Exhaust
Occurring Radioactive  VCE (Vapour Cloud Explosion)
Material)
Underground Equipment Failure
 Hydrogen Sulphide Flammable Properties  Corrosion soil
 Chlorine
 Crude Oil  Erosion contamination
 Nitrogen
 Hydrogen Gas
 Solvent Fumes
 Hydrogen Sulphide
 Mercury
 Hydrogen Jetty/Ship Operations
 Condensate
 Hoses/Boom
Asphyxiation  SBMs (Single Buoy
 Nitrogen Ignition Sources Mooring)
 Oxygen deficiency  Ballast Disposal
 Electrical
 Stray currents  Spillages
Radiological  Static
 Instrumentation  Lightning Surface Water Run-Offs
 Inspection  Pyrophorics  Contamination
 TENORM  Smoking Waterways
 Welding
 Grinding/cutting
Lighting Process Effluents
 Lightning strikes  Recovered Oils/Ballast
Fire types
 Produced Water –
 Jet, Pool and Flash Fires barium, zinc, trace of
Burns  Lagging Fires radioactive materials
 Hot & Cold Material  Smoke  Condensate Water from
Slug Catchers
 Surge Vessel Liquids

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HEALTH SAFETY ENVIRONMENT


Water from Drain
 Low points  Triethylene Glycol
 Draining  Biocide (glutaraldehyde)
 Hydrates  Magnesium Hydroxide
 Emulsions/Tank Layering
 Dead Legs

Air
 Start-Up/Shut Down
 Flare Systems

Noise Flare Systems Separators


 Compressors  Puking  Emulsions
 Vents  Deposits/Blockage  Detergents
 Pump  Pyrophorics  Ballast Disposal
 Power Generators  Chemicals
Process Hazards
Vibration  Water Hammer Waste Generation/ Disposal
 Power Tools  Large Inventories  Garbage
 HP/LP Let Downs  Metallic Waste
Dust  Hot Pumps (product above auto-  Unused Chemicals/Oils
ignition)  Used Batteries
Asbestos  High Pressure Systems  Engine Oil
 Lagging  Rotating Equipment
Gaskets  Thermal Relief
Sludges
 Vents
 Separators
 Drains
 Tanks
Carcinogens  Sample Points
 Pigging
 Benzene  Clearing Blockages
 PCA/Bs  Under lagging Corrosion
Visual Impact
e.g. Transformer Oils  Instrument Tapping’s
 Damage toUnderground Piping Sewage
 Erosion
 Corrosion Refrigerants
Ergonomics
 Defects
 Manual Handling  CFCs, HCFSs
 Fatigue
 Workstation/VDUs

Opening Equipmentfor Maintenance Drilling


Microbiological
 Inerting  Mud - Lignite
 Cooling Water Systems  Escape of Flammables - Barium
 Pressure - Chemicals
Hygiene/Cleanliness
 Dining room Entry into Confined Spaces Noise
 Washrooms  Oxygen Deficient  Compressors
 Kitchen  Fires  Vents
 Ice-cream Maker  Explosions

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HEALTH SAFETY ENVIRONMENT


 Freezer  Pumps
 Food Preparation  Power Generators

Ill Health
 Illness
 Heat Stress
 Transmitter Diseases

Hot Work
 Cutting/Grinding
 Welding
 Hot Tapping
 Oxygen Enrichment

Tank Farm Hazards


 Floating Roofs (sinking drainage)
 Boil-Overs
 Internal Explosions

Lifting
 Cranes
 Heavy Lifts
 Chains
 Ropes
 Slings

Machinery
 Guards
 Protection

Security
Electricity
 Scaffolding
 Ladders
 Fragile Roofs

Flare Systems
 Cutting/Grinding
 Welding
 Hot Tapping
 Oxygen Enrichment

Excavations
 Buried Facilities
 Collapses

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HEALTH SAFETY ENVIRONMENT


 Gas Accumulations

Working At Height
 Scaffolding
 Ladders
 Fragile Roofs

Floating Drill Vessels


 Capsize (stability)
 Fire/Explosion
 Collision
 Drowning
 FPSV

Utility Vessels
 Supply Boats
 Personnel Transfer
 Handling Containers
 Boat Capsize
 Diving Vessels
 Seismic Survey Vessels
 Accommodation Vessels
- Fires
- Capsize
- Collision

Flare Systems
 Fishing
 Submarine

Excavations
 Buried Facilities
 Collapses
 Gas Accumulations

Working At Height
 Scaffolding
 Ladders
 Fragile Roofs

Floating Drill Vessels


 Capsize (stability)
 Fire/Explosion
 Collision
 Drowning
 FPSV

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HEALTH SAFETY ENVIRONMENT

Structures
 Structural Failures
 Platform Collapse
 Environmental Loadings
 Scour/Subsidence
 Overloading

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