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Health and Safety Management Plan BTC Project Final

BTC Pipeline Project

Execute Phase

Health and Safety Management Plan

Final April 2003


U01 Rev March 2003 Date Issued for use Reason for Issue Category Code Area Code Document Type Code System Number Life Cycle Code DOCUMENT NUMBER: AGT Project Core Team / IPMT Code Area Code Function Code Document Type Sequence Number Language Revision x 0000 Bethan Morgan Prepared by Alan Jones Checked by David Winter Project Approval

Category Code Description General (Common) Procedure Transitory

0000

HS

A01

Health and Safety Management Plan BTC Project Final


CONTENTS
INTRODUCTION...........................................................................................................................5 SCOPE..............................................................................................................................................5 STRUCTURE OF THE D OCUMENT ...........................................................................................................5 1 LEADERSHIP AND ACCOUNTABILITY.................................................................................8 1.1 1.2 1.3 2 INTRODUCTION ......................................................................................................................8 COMMUNICATIONS ..................................................................................................................9 ORGANISATION ......................................................................................................................9

RISK ASSESSMENT AND MANAGEMENT.......................................................................... 11 2.1 2.2 2.3 2.4 GENERAL............................................................................................................................ 11 H&S RISK MANAGEMENT OVERVIEW ....................................................................................... 11 H EALTH SAFETY DURING CONSTRUCTION................................................................................. 11 ENSURING HS SAFETY DURING O PERATION THROUGH THE DESIGN PROCESS ................................ 12

PEOPLE, TRAINING AND BEHAVIOURS ............................................................................ 13 3.1 3.2 3.3 3.4 GENERAL............................................................................................................................ 13 BEHAVIOURAL CHANGE ......................................................................................................... 13 H EALTH .............................................................................................................................. 14 DRUGS, ALCOHOL AND S MOKING ............................................................................................ 14

WORKING WITH CONTRACTORS AND OTHERS ............................................................... 15 4.1 4.2 GENERAL............................................................................................................................ 15 PERFORMANCE M EASUREMENT .............................................................................................. 15

FACILITIES DESIGN AND CONSTRUCTION ....................................................................... 16 5.1 5.2 GENERAL............................................................................................................................ 16 CONTRACTOR MANAGEMENT ................................................................................................. 16

OPERATIONS AND MAINTENANCE ................................................................................... 17 6.1 GENERAL............................................................................................................................ 17

MANAGEMENT OF CHANGE.............................................................................................. 18 7.1 GENERAL............................................................................................................................ 18

INFORMATION AND DOCUMENTATION............................................................................. 19 8.1 8.2 8.3 8.4 DOCUMENT CONTROL ........................................................................................................... 19 APPLICABLE R EGULATIONS , C ODES, STANDARDS ..................................................................... 19 INFORMATION S TORAGE AND R ETRIEVAL.................................................................................. 19 PROJECT MANUAL................................................................................................................ 19

9 10

CUSTOMERS AND PRODUCTS.......................................................................................... 20 COMMUNITY AND STAKEHOLDER AWARENESS ............................................................. 21 10.1 10.2 10.3 10.4 GENERAL............................................................................................................................ 21 INTERNAL COMMUNICATIONS .................................................................................................. 21 EXTERNAL COMMUNICATIONS ................................................................................................ 22 COMPLAINTS ....................................................................................................................... 23

11

CRISIS AND EMERGENCY MANAGEMENT ........................................................................ 24 11.1 11.2 EMERGENCY R ESPONSE PLANS ............................................................................................. 24 OIL S PILL R ESPONSE............................................................................................................ 24

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12 INCIDENTS ANALYSIS AND PREVENTION ........................................................................ 25 12.1 13 GENERAL............................................................................................................................ 25

ASSESSMENT, ASSURANCE AND IMPROVEMENT ........................................................... 26 13.1 13.2 13.3 13.4 GENERAL............................................................................................................................ 26 BTC ACTIVITIES AND SAFETY INPUTS ...................................................................................... 26 ASSURANCE OF CONTRACTORS .............................................................................................. 26 IMPROVEMENT ..................................................................................................................... 26

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ABBREVIATIONS AGI ALARP ASA BTC CDM COSHH DAFWC ERP ESIA GHSER HAZCON HAZID HGA HSE HS&ES-MS KPI MOC NOK OSHA PPE PTW QRA STOP TMP Above Ground Installation As Low As Reasonably Practicable Advanced Safety Audit Baku-Tbilisi-Ceyhan Construction, Design and Management (Regulations) Control Of Substances Hazardous to Health Days Away From Work Cases Emergency Response Plan Environmental and Social Impact Assessment Getting HSE Right Construction Hazard Identification Workshop Hazard Identification Workshop Host Government Agreement Health, Safety and Environment Health, Safety and Environmental, Social Management System Key Performance Indicator Management Of Change Next of Kin Occupational Safety and Health Administration Personal Protective Equipment Permit To Work Quantitative Risk Analysis Safety Training Observation Program Transport Management Plan

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Health and Safety Management Plan BTC Project Final


INTRODUCTION Scope The scope of this document describes the way in which the management of Health and Safety (HS) is implemented across the BTC Pipeline Projects activities. It is consistent with BPs Corporate HSE Management system, Getting HSE Right (GHSER). The requirements of this document will be implemented in the three host countries, Turkey, Azerbaijan and Georgia by their own local management systems and plans, suitably tailored to the local requirements. Structure of the Document This document is structured in terms of the 13 elements of GHSER, so that the means of implementation of the expectations of each element are described for clarity and consistency. It should be noted that Element 9 Customers and Products is excluded from consideration in this document because it is not yet relevant. The overall framework of the HS&ES Management System and Plan is shown in Figures 1 and 2.

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Figure 1 AGT HS and ES MANAGEMENT SYSTEM COMPONENTS


POLICY
LEVEL I: BP

AGT PROJECT MANAGEMENT SYSTEM FRAMEWORK

LEVEL II: PROJECT

LEVEL III: IN-COUNTRY

IN-COUNTRY MANAGEMENT SYSTEMS AND PLANS

TURKEY Botas/BTC Interface

LEVEL IV: CONTRACTOR

IN-COUNTRY CONTRACTORS OWN MANAGEMENT SYSTEMS PLANS PROCEDURES (APPROVED BY AGT)

SUB-CONTRACTORS OWN MANAGEMENT SYSTEMS PLANS PROCEDURES (APPROVED BY BOTAS)

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Figure 2 AGT HS and ES MANAGEMENT SYSTEM PROJECT DOCUMENTS


POLICY
LEVEL I: BP

AGT PROJECT MANAGEMENT SYSTEM FRAMEWORK

LEVEL II: PROJECT

Project wide GHSER Elements

H&S- specific Implementation Issues

E&S Implementation Issues (Structure that includes Contractor Control Plans, Commitment Registers etc.)

GHSER Based H&S Plan

AGT HS&ES PLAN- 2 Documents

E&S MS Framework Document

This document
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1 1.1 LEADERSHIP AND ACCOUNTABILITY Introduction

HS&ES leadership by demonstration and example is an essential requirement for improving safe behaviours. All management team personnel, from the most senior level, are expected to demonstrate positive HS&ES behaviour at all times. The management team will adopt a proactive leadership role in creating and managing the HS&ES Management System. Senior managers will be involved in proactive two-way communication on HS&ES matters, for example through:

Inclusion of HS&ES behaviours and proactive and reactive indicators in the leadership teams performance contracts, which will be subject to annual appraisal; Monthly Health & Safety Performance Meetings at the Project Core Management Team (CMT) level. Environment and Social issues will be reviewed on a similar basis; The Project Director has Quarterly Performance Review meetings in each Country with HS&ES issues on the agenda. Monthly in-country meetings will be held with the Contractors to ensure ongoing commitment to Project HS & ES Expectations; Actively complying with all local HS&ES policies and procedures e.g. use of PPE, safe driving etc.; and Incorporating HS&ES expectations into the business planning process.

The following table outlines the key ways in which leadership and management commitments will be implemented throughout the project and, where relevant, the targets that apply. Category Means of Implementation Establish HS&ES Contract for all members of IPMT Management Leadership Commence each meeting with a Safety Moment Targets All All All 1 ASA each month 2 Cards each month Quarterly All

Participate in HS&ES Meetings (As often as possible; bias to attend) Conduct Advanced Safety Audits (ASA) One on one discussion on HS&ES

Management Visibility

Carry out Safety Observations Conduct formal HS&ES audit/ inspection of office or work site Project Management Representative is to take part /lead all investigations

Accident & High Potential Incident Investigations

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Category Personal Development Engage key contractors towards the zero accident culture Contractor Conduct project HS&ES workshops with groups of contractors Means of Implementation Attend management safety training Targets 5 days per year minimum Accident and Injury Free Programme Quarterly or as necessary Quarterly or as necessary

Assurance & Control

Review project HS&ES Performance at face to face meetings

1.2

Communications

Leadership will engage in two-way communication with employees, contractors and others through a variety of means, including: Regular safety and progress meetings which include both contractors and management; An open door policy for the discussion of HS&ES issues; and Provision of notice boards for HS&ES issues, which will present information on H&S performance and also lessons learned. Organisation

1.3

The following organisation chart shows the structure of the leadership team. The leadership team will ensure that appropriate resources are made available for the project in terms of competent individuals and HS&ES professionals to provide specific advice and expertise.

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Health and Safety Management Plan BTC Project Final Figure 1.1 IPMT Organisation Chart showing key H,S & ES individuals

David Winter Technical and H&S Compliance Manager

Phil Allison Project Director

Sheila Spence Environmental and Social Compliance Manager

Alan Jones H&S Manager

Ed Johnson Georgia Project Manager

Wayne Wheeler Azerbaijan Project Manager

Ed Truett Turkey Project Manager

Jaime Potes UK Project Manager (London)

Ed Walker H&S Manager M. Zaunbrecher Construction E & S Compliance Manager M. Aycrigg Cultural & Community Investment Manager

Ed Morgan H&S Manager Phil Middleton Env/Social Manager

Ingemar Bryngelsson HS&S Manager Martin Lednor LTO Manager

Frank Smith Safety Engineer Craig Warrender Environmental Engineer

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2 2.1 RISK ASSESSMENT AND MANAGEMENT General

Risk assessment and management is a key process for the management of HS&ES and is central to meeting expectations and the projects goals in these areas. The approach focuses on identifying, assessing and managing HS&ES related risks in project activities. The rest of this section concentrates on the management of HS risks. ES risks are addressed comprehensively in each countrys ESIA (see www.caspiandevelopmentandexport.com) and supporting documents. 2.2 H&S Risk Management Overview

The approach taken by the project is one of systematic identification of hazards, recording of hazards, performing of risk assessments, and devising risk controls to eliminate or reduce risk to a tolerable and as low as reasonably practicable level (ALARP). Risk identification has been a continuous process from the Define stage when a study was commissioned by the project to identify significant ways of improving the safety performance (during construction) . This study was based on extensive consultation with industry. The recommendations have been used, together with other advice from BP (e.g. the Golden Rules Of Safety) and industry sources on best practice, to develop comprehensive HS requirements. The project has implemented a number of risk assessment and risk management activities prior to the Execute phase. These have included: HAZIDs, HAZOPs, QRAs, Layout reviews, Design and engineering reviews, and Constructability reviews.

The project also commissioned an aviation risk assessment of charter aircraft and helicopter companies available to operate in-country. 2.3 Health Safety during Construction

The contractor(s) is required to continue the development of the above studies to ensure that risks are assessed and reduced to ALARP prior to operational acceptance. These are among

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a very comprehensive group of requirements in the area of H&S described in the Invitation to Tender Document. See also Element 4. The contractor is also required to organise and facilitate a Construction Hazard Identification Workshop (HAZCON) to brainstorm, identify, discuss and agree with the project the appropriate management controls for hazards arising during the execution of the work activities during this phase. A joint risk assessment between project personnel and the contractor will then be conducted and actions resolved prior to beginning work or mobilisation to site, underlining the need to determine levels of risk for all activities to impose appropriate management controls, in particular the need for an effective Permit to Work system. The contractor is required to develop risk assessments and method statements to manage all identified risks and hazards after break down of the work scope. The contract documents give a minimum but non-exhaustive list of these areas. 2.4 Ensuring HS Safety during Operation through the design process

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3 A RISK BASED APPROAC H HAS BEEN FULLY INTEGRATED INTO THE DESIGN. A SAFETY CASE HAS BEEN DEVELOPED WHICH SUMMARISES ALL THE RELEVANT PROJECT INFORMATION AND SAFETY STUDIES TO THE END OF THE DEFINE STAGE, AND DEMONSTRATES THAT THE DESIGN IS ALARP. A SEPARATE SAFETY CASE WILL BE PRODUCED FOR OPERATIONS, ENSURING THAT ALL ASSUMPTIONS REGARDING THE WAY THAT THE PIPELINES ARE TO BE OPERATED WILL BE EXPLICITLY IDENTIFIED SO THAT APPROPRIAT E PROCEDURES CAN BE DEVELOPED, AND THE IMPACT OF ANY CHANGE CA N BE READILY ASSESSED. PEOPLE, TRAINING AN D BEHAVIOURS General

3.1

The behaviour of people at all levels of the project is critical to its success and to the achievement of the HS&ES goals. It is therefore essential that all personnel are carefully selected and trained, and that their skills and competencies are regularly assessed. It is also essential that good HS&ES performance is encouraged and rewarded, in part through the KPIs that have been developed for the project. Line management will be responsible for providing the appropriate training and procedures necessary to ensure safe work. All personnel employed on the BTC Pipeline Project will be responsible for the safety of their work and the safety of others who may be affected by it. 3.2 Behavioural Change

There is a project commitment to achieving a substantial improvement in safety performance over current industry practice for the construction activity. HS&ES programmes and training have been implemented that engage managers, supervisors and personnel in behavioural change and improved safety performance such as: STOP (Safety Training Observation Program), with STOP cards submitted regularly ASA (Advanced Safety Auditing) to identify, recognise and eliminate unsafe acts and conditions

Project Management have engaged contractors senior management and HS&ES Professionals in workshops to communicate the projects expectations. Personnel going to site will be required to carry a Safety Passport (with photograph), detailing the training that that employee has received. Training records will be documented in the passports and kept in the permanent training files.

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3.3 Health

The Azerbaijan Business Unit Health department supports the project on all health issues incountry. There are Doctors in the in-country offices and a health/medical services risk assessment has been carried out for each country. This risk assessment has been provided to contractors to assist them in determining their own level of medical support requirements, which they then provide themselves. The contract HS&ES requirements also specify minimum camp welfare standards for contractors personnel. Each Office Manager will ensure that workstation health risks and ergonomics are assessed. 3.4 Drugs, Alcohol and Smoking

It is the projects policy to maintain a work environment free from the influence of alcohol and other drug abuse. Accordingly, the project prohibits the consumption, use or influence of alcohol and/or illicit drugs during working hours. This includes to/from and during work or when conducting business on the projects behalf. Additionally, there are specific restrictions with respect to smoking. There is a programme for drug and alcohol abuse prevention and random testing that is consistent with the scope and objectives of the BP Drug and Alcohol Abuse Policy. There is a program for medical review and maintenance of records for drug and alcohol testing programs and other mandated compliance programs.

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4 4.1 WORKING WITH CONTRAC TORS AND OTHERS General

The importance of successfully working with contractors to achieve a step-change in safety was identified in the Define stage. This led to: The development of comprehensive contractual requirements as part of the tendering process ; Pre-qualification of contractors with HS&ES issues contributing significantly to the scoring of bids; Requiring contractors to have certain HS&ES items as lump sum amounts and separate budget items in the lump sum amounts, for which payment would be against delivering promised programmes and performance.

4.2

Performance Measurement

Contractors must develop KPIs against which they will be audited and there is a documented approach to performance measurement.

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5 5.1 FACILITIES DESIGN AN D CONSTRUCTION General

The project has and continues to undertake the activities necessary to meet the expectations for this element. For example: Baseline technical, environmental and health data have been collected and formed the basis of the ESIAs; Facilities have been designed using technology that balances HS&ES risks and financial benefits; Design, procurement and construction standards have been formally approved by the designated technical / engineering authority; Formal design review, verification and validation studies have been carried out based on risk assessment; Operational, maintenance and HS&ES expertise have been integrated early in the project / design stage. Experience from previous projects and current operations have been applied; and Risks have been assessed using appropriate risk assessment tools during the preceding project phases and will continue to be assessed (see Section 2). Risks will be mitigated and managed accordingly.

5.2 Contractor Management

Contractor documentation will be reviewed and approved by appropriate project personnel.

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6 6.1 OPERATIONS AND MAINTENANCE General

The key activities relating to this element for this stage are related to ensuring: Integrity assurance of as-built facilities with design intent; Readiness for handover to operations including pre-start up reviews and documentation, and acceptance by Operations; Commissioning procedures oversight; and Lessons learned handover, e.g., due to local geographical or other risks encountered during construction.

HS&ES impacts associated with waste, emissions, noise, biodiversity and energy use during construction are addressed in contractual requirements documentation and in the ESIAs. Decommissioning, remediation and restoration plans will also be developed prior to handover to operations. Simultaneous construction and operation, e.g., adjacent pipelines will be addressed in the field by the contractors Permit to Work systems. Simultaneous construction and operation at Ceyhan Terminal and Jetty will be addressed initially through risk assessment, with activity matrices being used to identify prohibited concurrent activities, and where additional control procedures may be necessary. This will then provide input to the PTW procedures.

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7 7.1 MANAGEMENT OF CHANGE General

A suite of documented procedures address Management of Change across the project.

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8 8.1 INFORMATION AND DOCUMENTATION Document Control A system is in place to securely manage drawings, design data and other documentation, including definition of responsibilities for maintaining this information.

The information requirements for operations have been identified and described. A project wide action tracking system has been set up. A system has been set up for tracking all the different sections of pipe to ensure that they are deployed as intended in the field. 8.2 Applicable Regulations, Codes, Standards

Applicable regulations, permits, codes, standards and practices have been identified and have been included in the contractual documents and HGAs. 8.3 Information Storage and Retrieval

All general project information is retained by DCC. Confidential medical records will be kept by the HR department for London based staff and by the relevant in-country teams for personnel working in-country. 8.4 Project Manual

A manual of essential project-wide information, plans and procedures has been compiled and is structured by GHSER element.

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9 CUSTOMERS AND PRODUCTS

Not relevant at this stage.

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10 COMMUNITY AND STAKEHOLDER AWARENESS 10.1 General The BTC Project has and as a whole has and will continue to expend significant effort on developing open communication with communities, regulators and other project stakeholders. The project will communicate openly to its customers, employees, neighbours, public interest groups and contractors regarding significant HS&ES aspects of the project. The method for communicating H&S aspects both internally and externally is discussed in the following subsections. 10.2 Internal Communications By effective internal communication of the relevant HS&ES aspects, project employees will be made aware of the Projects HS&ES requirements, expectations and performance. 10.2.1 Responsibilities 10.2.1.1 Project Manager The Project Director has the ultimate responsibility as to what information will be shared with Project employees and representatives. 10.2.1.2 HS&ES Managers The HS & Technical Compliance Manager, the ES Manager and the HS Manager have the responsibility to ensure that the personnel, resources and procedures exist that provide for the widest dissemination of HS&ES information. 10.2.1.3 Project Management and Supervisors Project In-Country Managers will be responsible for ensuring that those personnel under their supervision or responsibility are aware of and understand the applicable HS&ES project requirements, goals, and objectives. 10.2.1.4 Project Employees Project employees will be responsible for the information provided to them by their direct line management. When there is uncertainty as to what the requirements, goals and/or objectives are, the employee will be responsible for initiating the clarification process (i.e., ask the question).

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10.2.2 HS & ES MS Availability The HS&ES key documents will be referenced within the Project Management Manual and will be available for review by all project employees. A copy of the manual will be available in project offices and electronically in Infoworks. 10.2.3 Monthly Reporting At a minimum, monthly H&S reporting will include the number of (unless otherwise specified) occurrences during the reporting period. Health: Safety: fatalities; road accidents; total kilometres driven; recordable injuries; days away from work due to injuries; and hours worked. recordable illnesses; and days away from work due to illnesses.

10.2.3.1 Emergencies Emergency communications are addressed in the Projects Emergency Preparedness and Response Plans see Section 11. 10.3 External Communications External communications regarding significant Project HS&ES aspects must receive prior approval from the Project Director. There are circumstances where HS&ES aspects will be considered strictly confidential, until the circumstances are completely known and/or otherwise notified by the Project Manager. These include (but are not limited to) any event that: involves one or more fatalities; may receive national or international recognition; is a consequence of a major failure to the pipeline or its facilities; has implications to the Project Partners or Companys reputation;

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Information regarding the items listed above may be communicated externally, but not until they have been fully investigated, appropriate persons notified, and the full details of the events known. 10.4 Complaints As a result of project activities, complaints may be received either internally or externally that have HS&ES aspects. Complaints will typically be managed on a case-by-case basis. All complaints shall be included in the HS&ES monthly reports.

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11 CRISIS AND EMERGENCY MANAGEMENT 11.1 Emergency Response Plans An overall Emergency Response Plan is in place for the BTC Project, which provides an overall framework for emergency response.

In-country plans address eventualities at the work site including, for example, fire, explosion, collapse of structures, serious injuries, medivac, spillage of chemicals and exposure to toxic substances. The plans also address response to natural occurrences such as lightning, storms and floods and other important security issues such as civil unrest or terrorist activity. The plans dovetail into the Azerbaijan Business Unit Incident Management System. The plans detail emergency organisation, resources and equipment, identification and testing of equipment and facilities, the responsibilities of key personnel, communications to be made, from where assistance should be sought, site evacuation, and rescue of persons.

The plans include a medical emergency plan for dealing with injuries. Where appropriate, the in-country plans have been developed in consultation and co-operation with the local authorities and emergency services. Contractors own plans will be integrated with the in-country plans and include Emergency Response Plan (ERP) Bridging Documents. 11.2 Oil Spill Response Specific oil spill response plans will be in place for operations.

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12 INCIDENTS ANALYSIS A PREVENTION ND 12.1 General Injuries, illnesses, accidents, near misses and hazards will be reported, investigated and documented according to the BTC procedures . Contractors will have their own equivalent procedures.

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13 ASSESSMENT, ASSURANCE AND IMPROVEMENT 13.1 General HS&ES assessment and assurance through audits and inspections will carried out in accordance with control and assurance procedures: In addition each country has developed its own audit activity schedules. 13.2 BTC Activities and Safety Inputs There are monthly targets for the numbers of ASAs, STOPs and H&S training hours and these will be recorded and reported. This information will be collected and analysed by the relevant H&S Manager at each level. Contractors will be expected to deliver similar inputs. 13.3 Assurance of Contractors Contractors must develop KPIs against which their H&S performance will be measured (see Section 4). Contractors will also develop an incentive scheme for its staff and subcontractors, which involves an assessment of the effectiveness of HS&ES procedures and how well they are implemented. Monitoring the activities of the Contractor, collaborating and assisting where required, and providing feedback on performance, are key activities to be undertaken. 13.4 Improvement Findings from learning processes (e.g., audits, incident investigations, near misses, HAZOPS, etc.) will be prioritised and tracked using the Project wide Action Tracking system (ATS) and used to systematically improve the H&S processes.

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