ZeTo Rules Violation Consequence Management

Guideline

GHSE/SP/PRO/2017/16
April 2017

Internal
© 2017 PETROLIAM NASIONAL BERHAD (PETRONAS)
All rights reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted in any form
or by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner.
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TABLE OF CONTENTS

1.0 INTRODUCTION ..................................................................................................... 4

1.1 Objective ..................................................................................................................... 4
1.2 Background ................................................................................................................. 4
1.3 Scope ........................................................................................................................... 4
1.4 Glossary of Terms ........................................................................................................ 4
1.5 Summary of Changes................................................................................................... 6
2.0 STAFF AND MANAGEMENT ACCOUNTABILITY ........................................................ 7
3.0 ZETO RULES ........................................................................................................... 8
3.1 Permit to Work ............................................................................................................ 8
3.2 Energy Isolation ........................................................................................................... 9
3.3 Bypassing of Safety Critical Equipment ..................................................................... 10
3.4 Confined Space.......................................................................................................... 11
3.5 Working at Height ..................................................................................................... 12
3.6 Chemical Handling..................................................................................................... 13
3.7 Excavation ................................................................................................................. 13
3.8 Lifting Operations ...................................................................................................... 14
3.9 Ignition Source Control ............................................................................................. 14
3.10 Driving ....................................................................................................................... 15
4.0 ZETO RULES VIOLATIONS CONSEQUENCE MANAGEMENT .................................... 16
4.1 ZeTo Rules Violation Consequence Management Process Flow for PETRONAS
staff/Contractor ........................................................................................................ 17
4.2 Reporting and Recording of ZeTo Rules Violations ................................................... 18
4.3 Verification of ZeTo Rules Violations ........................................................................ 18
4.4 Punishment on PETRONAS staff ................................................................................ 21
4.5 Punishment on Contractor staff ................................................................................ 21
4.6 Consequence on Contractor Company ..................................................................... 21
APPENDIX 1: SAMPLE OF ZETO RULE VIOLATION FORM.................................................. 23

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1.0 INTRODUCTION

1.1 OBJECTIVE
This guideline is developed to provide a systematic and structured process in managing
consequence to PETRONAS and Contractor staff who violates any of ZeTo Rules, either
resulting in incident or non-incident. The guideline also covers possible penalty to be meted
out to PETRONAS Staff, Contractor Staff and Contractor Company for confirmed ZeTo Rules
violation.

1.2 BACKGROUND

This standardised guideline is developed to be integrated with PETRONAS’ Disciplinary Action

Process & Procedure (DAPP). It is also developed to be in line and reinforces PETRONAS’ Code
of Conduct and Business Ethics (CoBE) and PETRONAS Cultural Beliefs.

1.3 SCOPE

This guideline shall be applicable to all PETRONAS staff and Contractor staff working for
PETRONAS Group of Companies.
This Guideline is applicable and enforceable for any ZeTo Rules violations, either resulting in
incident or non-incident; and whether the violation is done intentionally or unintentionally,
throughout PETRONAS global operations.

1.4 GLOSSARY OF TERMS

1.4.1 General Definition of Terms & Abbreviations

Specific Definition of Terms

Term Definition
Facility Head The most senior person on each site/facility, and is
accorded single point accountability by the
HCU/BU/OPU/JV/Project Head for all aspects of the
operation of the assets, over part or all of its
lifecycle in order to achieve the company objectives.
Fatality Death resulting from a recordable Injury or Illness
regardless of the time intervening between the
Injury/Illness and death.
Illness Any recordable abnormal condition or disorder,
other than an Injury, which is mainly caused by
exposure to environmental factors associated with
the employment. It includes acute and chronic
Illness or diseases which may be caused by
inhalation, absorption, ingestion or direct contact.
Whether a case involves a work-related Injury or an
Occupational Illness is determined by the nature of
the original event or exposure which caused the
case, not by the resulting condition of the affected
employee.

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Term Definition
An Injury results from a single immediate event i.e.
event resulted from something that happened in an
instant. Cases resulting from anything other than a
single immediate event is considered Occupational
Illnesses i.e. resulted from prolonged or multiple
exposures to a hazardous substance or
environmental factor, it is an illness.
A single incident can give rise to several
occupational illnesses e.g. food poisoning, skin
rashes due to chemical exposure. An Injury case
can later become illness case if the acute effect has
later become chronic effect after certain duration.
This case will be considered as both injury and
illness case.
Injury Harm to a person resulting from contact between
the body of the person and an external agent or
from exposure to environmental factors. This
includes health outcome resulting from accident or
single instantaneous exposure example cut, sprain,
fracture, amputation, animal or snake bite, onetime
chemical exposure or poisoning
Table 1: Specific Definition of Terms

Specific Abbreviations

Abbreviation Description

AA Approving Authority

AAR Approving Authority Representative

AR Receiving Authority Representative

CoBE PETRONAS Code of Conduct and Business Ethics

CPE Contractor Performance Evaluation

CPRC Contractor Performance Review Committee

DAPP Disciplinary Actions Process & Procedures

EIC Electrical Isolation Certificate

HCU/BU/OPU/JV/Project Holding Company Unit, Business Unit, Operating

Unit, Joint Venture, Project

PA Punishing Authority

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Abbreviation Description

PIC Physical Isolation Certificate

RA Receiving Authority

SIPS Safety Interlock Protective System

UPS Uninterruptible Power Supply

VEC Vendor Evaluation Committee

Table 2: Specific Abbreviations

1.5 SUMMARY OF CHANGES

1.5.1 This revised Guideline supersedes ZeTo Rules Guideline Rev 1, July 2010.

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2.0 STAFF AND MANAGEMENT ACCOUNTABILITY

2.1.1 All PETRONAS staff and Contractor staff are accountable for full compliance with ZeTo Rules.
The Management of the respective HCU/BU/OPU/JV/Project shall ensure the effective
implementation of ZeTo Rules across its organisation.

Note: Effective implementation of ZeTo Rules means the rules are understood and abided by
all staff and contractors’ staff.

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3.0 ZETO RULES

3.1 PERMIT TO WORK

Rule 1 : Work with a valid work permit (PTW) required by the job

3.1.1 PTW is a written document authorizing persons to carry out the work concerned while
warning them of possible hazards and spelling out precautions needed for the job to be done
safely. A PTW is required for all construction, maintenance and non-routine hazardous
operations.

3.1.2 Permit is not valid when:

• the permit validity period has expired
• permit is not revalidated as per required frequency or interval
• the permit has been cancelled or suspended, or
• the permit has not been signed by Receiving Authority (RA) and Approving Authority
(AA).

3.1.3 Working outside PTW scope of work (e.g. activity, location, equipment) is also considered as
working without a valid PTW required by the job.

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3.2 ENERGY ISOLATION

Rule 2 : Verify energy isolation before starting work

3.2.1 Types of energy sources that needs to be isolated includes but are not limited to electrical,
mechanical, kinetic, potential, hydraulic, thermal, chemical, pneumatic and ionising radiation.

3.2.2 Upon isolation of an energy prior to do work on equipment, the equipment, e.g. valve, will be
locked, tagged and tested for zero energy.

3.2.3 Verification of energy isolation are done through the following:

• Site verification of isolation as per Physical Isolation Certificate (PIC), Electrical Isolation
Certificate (EIC) or Radiation Certificate prior to approval of PTW – applicable for
Approving Authority Representative (AAR) & Receiving Authority Representative (RAR),
and
• Verification of availability and validity of PIC & EIC prior to approval and/or extension of
PTW – applicable for AA.
For contactor staff (Work Leader), verification shall be done through by observing availability of
PIC/EIC/Radiation Certificate.

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3.3 BYPASSING OF SAFETY CRITICAL EQUIPMENT

Rule 3 : Obtain authorisation before overriding or disabling safety critical

equipment

3.3.1 Safety critical equipment is defined as any protective device (mechanical, pneumatic,
hydraulic, electrical, electronic), system or sub-system which provides the barrier to prevent
or limit the effect of a hazard with a major risk.

3.3.2 Examples include safety interlock protective system (SIPS), pressure/vacuum relieving
devices, detectors, alarms, emergency isolation valves, critical electrical equipment including
uninterruptible power supply (UPS), turbine over speed trips, fire protection equipment,
critical security devices and other safety and life-saving appliances.

3.3.3 Overriding or disabling safety critical equipment will result in interruption of its original intent
which may render plant, equipment or personnel unprotected while in normal, abnormal or
emergency situation.

To obtain authorisation, you need to get the Safety System Bypass/Override (SSBO) certificate
approved. This certificate needs to be endorsed and signed by the Receiving Authority (RA)
and Approving Authority (AA).

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3.4 CONFINED SPACE

Rule 4 : Obtain authorisation before entering a confined space

3.4.1 A confined space is an enclosed or partially enclosed space that is at atmospheric pressure
during occupancy and is not intended or designed for continuous occupancy, could have
restricted means for entry and exit and liable at any time to have any of the following
conditions:
• could have an atmosphere which contains potentially harmful levels of contaminants
• could have an oxygen deficiency or excess, or
• could cause engulfment.

3.4.2 For the purpose of this guideline, a person whose head or upper body is within a confined
space is considered to have entered the confined space.

3.4.3 For entry to confined space, the Confined Space Entry (CSE) PTW has to be approved upon
completion of the associated CSE Certificate and Checklist by relevant authorities.

3.4.4 The followings are considered working in confined space without authorisation:
• Entering confined space during a period where entering is not allowed even when the
permit is still valid, e.g. during lunch, work suspension due to emergency or whenever
the man hole is closed/barricaded
• Unauthorised entrant/person not listed as part of the work crew under CSE
PTW/Certificate, or
• Entering a confined space with an expired CSE PTW/Certificate.

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3.5 WORKING AT HEIGHT

Rule 5 : Protect yourself against a fall when working at height

3.5.1 A person is considered working at height when working in any place where he/she could fall
to a distance of 2 metres. The place may be above or below ground level.

3.5.2 For the purpose of this guideline, 'working’ exclude:

• ascending/descending a permanent or approved temporary platform
• walking through a permanent or approved temporary platform, and
• accessing a permanent or approved temporary platform for routine operational
activities, e.g. monitoring/inspection; except in situations where use of fall protection
equipment are mandatory as listed in 3.5.3.

3.5.3 Protection against fall shall be done by using full body harness tied-off to a fixed structure, an
anchor point or lifeline for the following activities:
i. Constructing or preparing (including inspection of newly constructed) temporary
platform, rope access facility, fall protection system e.g. safety net or other facilities.
ii. Working near the edge of a permanent or approved temporary platform where there is
a risk of fall due to:
o task requires body posture or condition to over-reach beyond the guardrail
o task requires the person to step off beyond the guardrail or
o in adverse weather, slippery or icy condition.

iii. Working at the edge of a location in the absence of a guardrail where there is a risk of
fall to a lower level e.g. near a trench, pond and pit.
iv. Working on a modified permanent or approved temporary platform where part of the
structure e.g. grating, floorboard, guardrail or toe-board, has been removed.
v. Working on a temporary platform during hazardous situations e.g. adverse weather,
slippery or icy condition.
vi. Working on top of the following structures, due to the risk of fall over/through:
o Roof or skylight and
o Road tanker.

vii. Using rope access system.

viii. Being onboard/inside a lifting or suspended access equipment or mobile equipment
designed for working at height e.g. gondola, boatswain chair, sky-lift, Mobile Elevated
Working Platform (MEWP), mobile scaffolds.

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3.6 CHEMICAL HANDLING

Rule 6 : Use the correct personal protective equipment (PPE) when handling
hazardous chemicals

3.6.1 Hazardous chemicals are chemicals with the properties of being explosive, oxidising,
extremely flammable, highly flammable, flammable, very toxic, toxic, harmful, corrosive,
irritant, carcinogenic, teratogenic and mutagenic. This includes hydrocarbons and catalysts.

3.6.2 Correct PPE shall be used when handling hazardous chemicals as follows:
• Receiving, storing, discharging, transporting and disposing chemicals
• Working on process equipment containing hazardous chemicals where the activity may
lead to exposure to the worker. Note: This excludes working on equipment which has
been confirmed free of the hazardous chemical.

3.6.3 The correct PPE to wear when handling hazardous chemicals are those which are specified in
the PTW for the job e.g. chemical apron, chemical respirator, chemical resistance glove, face
shield, etc. as per PTS 18.33.01 Chemical Management.

3.7 EXCAVATION

Rule 7 : Obtain authorisation before excavation or entering a trench

3.7.1 Excavation is work that involve removal, boring or penetration of soil, sand, clay, or the
breaking of concrete, asphalt, or rock to a depth of greater than 150 mm, by manual,
mechanical or other means.

3.7.2 A trench is a long narrow ditch embanked with its own soil formed during the excavation.

3.7.3 To obtain authorisation for excavation, you need to get a valid excavation certificate and PTW
approved specific for the job.

3.7.4 Authorisation is required for entering a specific part of a trench which has not been provided
with protection against soil collapse e.g. sloping, benching, shoring through the following:
• Approval from work supervisor.
• Separate PTW for specific work in the trench.

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3.8 LIFTING OPERATIONS

Rule 8 : Do not position yourself under a suspended load

3.8.1 A suspended load is any weight hung from a lifting equipment during lifting or temporary
suspension of the object for replacement/removal of the support.

3.8.2 The area is barricaded before lifting operation began to prevent people from working under
the suspended load.

3.8.3 A person is considered positioning himself under suspended load if he entered the barricaded
area or restricted area as shown by sign board or prohibited area as determined by work
supervisor.

3.8.4 Exception is given in a case where authorised personnel are required to be in the area such as
rigger and Signal Man.

3.9 IGNITION SOURCE CONTROL

Rule 9 : Do not smoke outside designated areas or bring potential ignition

sources into process areas without authorisation

3.9.1 This rule applies to area within process area i.e. areas where process facilities are located.

3.9.2 Smoking is not allowed in process area except at locations which have been approved for
smoking.

3.9.3 Ignition sources are equipment, tools or other items that could potentially introduce sparks,
flame, or electrostatic charge. Authorisation is required in the form of PTW OR written
approval to bring in these items into process area.

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3.10 DRIVING

Rule 10 : Do not use your mobile phone/walkie-talkie while driving, follow

the speed limit and use your seat belt

3.10.1 This rule applies for activities involving driving, using and operating company
owned/leased/hired vehicles, e.g. car, bus, van, road tanker, lorry, pick-up truck, forklift etc.
It is also applicable to those who are travelling on business using personal vehicle.

3.10.2 Driver is not allowed to use* mobile phone/walkie-talkie, although via hands free facilities,
while driving.

Note: * includes talking on mobile phone/walkie-talkie, texting and operating smart phone
applications.

3.10.3 Vehicle speed limit refers to:

• speed limit gazetted for the area or type of vehicle specified by highway, road transport
or other relevant government authorities, or
• speed limit specified by company while driving in company facility.

3.10.4 The use of seat belts is mandatory for all driver and passenger(s) for vehicles listed above.

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4.0 ZETO RULES VIOLATIONS CONSEQUENCE MANAGEMENT

ZeTo Rules violation can be identified via the following means/activities:

• Observed during an audit/inspection/operational activities, or
• Identified from a HSE incident investigation.

All ZeTo rules violations shall be subjected to the following processes:

i. Reporting and recording of ZeTo Rules violation in writing
ii. Verification of the ZeTo Rules Violation, and
iii. Application/invocation of ZeTo Rules Violation Consequence Management process to
involved and applicable parties (i.e. DAPP for PETRONAS staff and Group Procurement
Process & Procedure for contractor staff and contractor company).

HCU/BU/OPU/JV/Project shall ensure reporting of ZeTo Rules-related performance indicators

as specified in PTS 18.06.04 HSE Performance Monitoring and Reporting.

Detailed process for management of ZeTo Rules Violation by PETRONAS and contractor staff
is as per depicted below:

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4.1 ZETO RULES VIOLATION CONSEQUENCE MANAGEMENT PROCESS FLOW FOR PETRONAS STAFF/CONTRACTOR

Reporting & Recording

Verification Consequence Management
Incident Investigation
Observer Violator Verification Consequence Management
Team

Stop work/
Observe staff/ act and
Start contractor breach comply to
ZeTo Rule ZeTo Rule

No
Violation confirmed
Start Record & End
ZeTo?
Report and record
(in form e.g.
UAUC, email) and
submit for Yes
verification
Contractor
Group
Confirm
Identify ZeTo Staff / Procurement
nature of ZeTo DAPP End End
violation link with Contractor? Process &
violation Staff
incident Procedure
Phase

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4.2 REPORTING AND RECORDING OF ZETO RULES VIOLATIONS

4.2.1 The person who observes any ZeTo Rules violation shall intervene immediately by stopping
the act/activity. The matter shall then be highlighted to the Area Owner and the Facilities’
Head of HSE.

4.2.2 The observer shall then report and record details of the violation in writing, either via ZeTo
Violation Form or by other means of communication within 24 hours.

Note: Sample of Violation Form is as per Appendix 1. HCU/BU/OPU/JV/Project shall make the
Violation Form available to all PETRONAS staff and Contractors within the facility.

4.3 VERIFICATION OF ZETO RULES VIOLATIONS

4.3.1 In verifying the violation, HCU/BU/OPU/JV/Project shall establish the following:

i. Confirm the act/activity as described in the Violation Form relates to violation of a ZeTo
Rule. General guide on common ZeTo rule violation acts are as per Section 3.
Note: In the event where is not clear whether the violation constitutes a ZeTo Rule
Violation, HCU/BU/OPU/JV/Project shall consult Operational Safety’s OPU/Business
Technical Authority.
Should there be further dispute, HCU/BU/OPU/JV/Project shall consult Operational
Safety’s Group Technical Authority for final classification.
ii. Determine Category of ZeTo Rule Violation as guided by 4.3.4 – 4.3.9 below.
iii. Ascertain gap(s) in Training & Procedures to address element of
gaps/omissions/effectiveness of HCU/BU/OPU/JV/Project’s Management System.
Note: HCU/BU/OPU/JV/Project shall correct these specific gaps.
iv. Deliberate and decide on the next course of action, which may include DAPP.

4.3.2 Verification of ZeTo Rule violation observed during inspection and audits shall be done within
48 hours following reporting of ZeTo Rule violation.

Note: HRM representative shall be involved in the verification process if the violation involves
PETRONAS staff.

4.3.3 Verification of ZeTo Rule violation identified from a HSE incident investigation shall be done
by the Incident Investigation team.

Note: HRM representative shall be invited to participate in the incident investigation once it
has been established that violation by a PETRONAS staff has led to said incident.

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4.3.4 ZeTo Rule Violations have been categorised based on its potential consequence ranging from
1 to 3, as per PETRONAS’ historical data.
Category 1 Category 2 Category 3
• Injury/Illness not leading • Single Fatality or • Multiple Fatalities
to disability or fatality • Permanent Disability
Table 3: ZeTo Violation Consequence Categories

4.3.5 The Violation Categories for each specific ZeTo Rule are as per tabulated below:
Violation
ZeTo Rule Description
Category
Rule #1 Work without a valid work permit (PTW) required by the job 3
Rule #2 Not verifying energy isolation before starting work 2 / 3*
Not obtaining authorization before overriding or disabling
Rule #3 3
safety critical equipment
Not obtaining authorization before entering a confined
Rule #4 2
space
Rule #5 Not protecting yourself against a fall when working at height 2
Not using the correct personal protection equipment (PPE)
Rule #6 1 / 2**
when handling hazardous chemicals
Not obtaining authorization before excavation or entering a
Rule #7 2
trench
Rule #8 Positioning yourself under a suspended load 1
Rule #9 Smoking in process area 3
Bringing potential ignition sources into process areas
2
without authorization
Rule #10 Using mobile phone/walkie-talkie while driving 2
Not following the speed limit 2
Not using seat belt 2
Table 4: Zeto Violation Consequence Categories per respective ZeTo Rule

Note:
i. The respective ZeTo Rule Violation Category shall be subjected to review from time to
time, as deemed appropriate by the Management.
ii. Rule #2: Category 3* is for cases involving absence of positive energy isolation,
exposing personnel to hazardous substances.
iii. Rule #6: Category 2** is for not using the correct Respiratory Protective Equipment
(RPE) when handling hazardous chemicals with risk of acute effect.

4.3.6 ZeTo Rule Violation observed during inspection and audits shall be categorised based on its
potential consequence i.e. as per Table 4.

4.3.7 For violation that has led to an incident, the actual Violation Consequence Category shall be
based on actual impact on People, Asset, Environment and Reputation, as per Incident Rating
in PTS 18.06.01 Incident Notification, Investigation and Reporting:
• Category 1: Rating 3 and below.
• Category 2: Rating 4.
• Category 3: Rating 5.

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4.3.8 For the purpose of consequence management, the incident shall be classified according to the
‘higher Category’ between the actual and the potential consequence Category. See
illustrations below:
Illustration 1: A HSE incident took place whereby there was an injury resulting from violation
of ZeTo Rule 4 i.e. Not obtaining authorization before entering a confined space.

• Potential Consequence for ZeTo Rule 4 = Category 2 (from Table 4).

• Actual Consequence = Category 1 (injury; from Table 3).
• Actual Classification = Category 2.

Illustration 2: A HSE incident took place whereby there were multiple fatality resulting from
violation of ZeTo Rule 4 i.e. Not obtaining authorization before entering a confined space.

• Potential Consequence for ZeTo Rule 4 = Category 2 (from Table 4).

• Actual Consequence = Category 3 (multiple fatality; from Table 3).
• Actual Classification = Category 3.

4.3.9 For Multiple ZeTo Rules violations conducted by one staff and observed in one event, use the
more severe violation as principal.

4.3.10 All document including evidences, supporting documents and other related media being
considered during verification shall be recorded and retained for a period of 12 years.

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4.4 PUNISHMENT ON PETRONAS STAFF

4.4.1 Below is the guide of possible punishment for PETRONAS staff following DAPP:

Possible Punishment

ANY or a COMBINATION
of the following Disciplinary Punishments

1. Warning;
2. Suspension without pay for 1 week;
3. Suspension without pay for 2 weeks;
4. No increment for 1 year;
5. No performance bonus for 1 year;
6. Dismissal.
Table 5: Guide of possible punishment for PETRONAS staff

4.4.2 Repetition of ZeTo Rules violation may lead to dismissal.

4.4.3 If during verification and/or incident investigation, there’s element of coercion, inducement
or encouragement from any person, the said person shall receive more severe penalty than
the violator.

4.5 PUNISHMENT ON CONTRACTOR STAFF

4.5.1 Listed below are the punishments for Contractor staff following confirmation of ZeTo Rules
violation verification:
a. 1st offence: Ban from entering Company facility for 1 month following confirmation of
offense.
b. 2nd offence: Ban from entering Company facility indefinitely.

4.6 CONSEQUENCE ON CONTRACTOR COMPANY

4.6.1 Consequence on Contractor Company following confirmed verification of ZeTo Rules violation
conducted by Contractor staff would be at operational and/or PETRONAS level.

4.6.2 At Operational level, consequence will be as follows:

• Issue warning letter to affected Contractor’s Company
• Record non-compliance in PETRONAS’ Supplier Relationship Management (SRM) system
• Payment deduction on the lost work day (if applicable), and/or
• Cost of legal, fines, claims and damages incurred as a result of or arising from ZeTo Rules
Violation (if applicable).

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4.6.3 At PETRONAS level, the consequence will be for ZeTo Rules violation linked to a major HSE
incident. The Contractor Company shall automatically be rated “D” in the Contractor
Performance Evaluation (CPE) to ensure their performance deliberated at Vendor Evaluation
Committee (VEC) and Contractor Performance Review Committee (CPRC).

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APPENDIX 1: SAMPLE OF ZETO RULE VIOLATION FORM

ZeTo Violation Acknowledgement Form

Date
Time
Location of violation
ZeTo Rule No

Observation

The Observed PETRONAS/Contractor Staff Details (to be filled by the Staff)

Name
Staff No
Position
Dept/Company

Signature & Date Signature: Date:

ACKNOWLEDGEMENT

Observer Witness Verifier

Name: Name: Name:
Staff No: Staff No: Staff No:
Position: Position: Position:
Dept/Company: Dept/Company: Dept/Company:

Signature & Date: Signature & Date: Signature & Date:

Note:
1) The completed form is to be submitted to <please specify> within 24 hours of violation.

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