Brunei LNG Sendirian Berhad. All rights reserved.
This document is classified as Restricted. Circulation is restricted to BLNG and its designated associates, contractors and consultants. Neither the whole nor any part of this document may be disclosed to any third party without the prior written consent of Brunei LNG Sendirian Berhad. BAM CODE AND NAME: HSE NON-COMPLIANCES & CONSEQUENCE PAGE 2 OF 8 BLNG.25.00 ENABLE THE BUSINESS – ENSURE HSSE MANAGEMENT PROCESS
Table of Contents 1.0 PURPOSE 3
2.0 SCOPE 3
3.0 RESPONSIBILITIES 3
4.0 PROCEDURE 4
5.0 RECORDS 7
6.0 REFERENCES 7
7.0 DEFINITIONS 7
8.0 CHANGE HISTORY 7
9.0 APPENDIX 8
Issue: 5 The controlled copy of this document is in electronic format in Brunei LNG web. Doc. No: The hardcopy is uncontrolled was printed on – 4 September 2014 9:18 AM HSEC-CP-219 BAM CODE AND NAME: HSE NON-COMPLIANCES & CONSEQUENCE PAGE 3 OF 8 BLNG.25.00 ENABLE THE BUSINESS – ENSURE HSSE MANAGEMENT PROCESS
1.0 PURPOSE The purpose of this procedure is to-
Strengten the HSE compliance culture particularly on 12 Life Saving Rules and Chronic Unease mindset among our staff and contractors. Provide guidance on how the investigation approach and timeline for 12 Life Saving Rules violations. Ensure that disciplinary actions related to non-compliance issues are dealth with in a consistent and similar manner throughout BLNG staff and among contractors working for BLNG.
2.0 SCOPE This section provides guidance of the application of Consequence Management on HSE non- compliances, 12 Life Saving Rules violation, deviation from technical standards and disregarding HSE interventions amongst BLNG staff and contractors working within BLNG assets/facilities.
3.0 RESPONSIBILITIES In line with BLNG’s Health, Safety and Environment Policy and Commitments, it is the individual staff responsibility and duty to adhere to ALL BLNG HSE policies. The BLNG HSE policies and standards include, but not limited to, Smoking Policy at Work Locations, Drugs Alcohol and Substance Abuse Policy, Use of Mandatory Personal, Protective Equipment (PPE), and PTW System Manual. Failure to comply constitutes a case of serious misconduct and will result in disciplinary action. Types of warning (e.g. verbal, written & dismissal) depend on the investigation findings. As per HRPPM Section 9.
Issue: 5 The controlled copy of this document is in electronic format in Brunei LNG web. Doc. No: The hardcopy is uncontrolled was printed on – 4 September 2014 9:18 AM HSEC-CP-219 BAM CODE AND NAME: HSE NON-COMPLIANCES & CONSEQUENCE PAGE 4 OF 8 BLNG.25.00 ENABLE THE BUSINESS – ENSURE HSSE MANAGEMENT PROCESS
Nos. Task Description Timeline R A C I
1 Appoint independent investigation Within Appoin Team’s team. the day HSQ ted Superv of the Team isors report 2 Conduct investigation to : Confirm that an LSR breach did/did not occur Establish evidence of prior LSR knowledge Within 3 Investig Dept DMD, Establish LSR enforcement by days ation HSQ Head, LM,LC Supervisor Team CO,CH Establish severity/risk rating Establish compliance history Establish clarity of applicable procedure 3 Finalize incident investigation report. Investig Dept Within 7 Incident ation HSQ Head, days Owner Team CO,CH 4 Determine consequence management Establish mitigating circumstances Within 14 CMP Dept Decide type of consequence days DMD Head, Panel CO,CH o Written Warning Letter o Dismissal 5 Implement consequence management Dept Within 21 CMP Head, • CMP to communicate DMD days Panel CO, CH 6 Update consequence management Once Dept Manag register and Dessiminate Lessons incident HSER HSQ Heads ers Learnt closed
4.0 PROCEDURE The key HSE expectations in BLNG are as follows:-
Set clear HSE expectations that HSE standards, technical standards, procedures & rules shall be complied with; A simple & consistent disciplinary framework to support these expectations Encouraging a proactive intervention culture and leaders must set the example
All staff and contractors working in BLNG must comply to the mandatory HSE documents such as:
BLNG HSE / SP Policy and Security Policy
HSSE Standards, Procedures (e.g. PTW) including Group HSSE Manuals & Mandatory Standards, Work Instructions, DEPs/Code of Practice, etc… Technical Standards e.g. Scaffolding Standards, Lifting and Hoisting Standards HSE Rules e.g. 12-Life Saving Rules
Issue: 5 The controlled copy of this document is in electronic format in Brunei LNG web. Doc. No: The hardcopy is uncontrolled was printed on – 4 September 2014 9:18 AM HSEC-CP-219 BAM CODE AND NAME: HSE NON-COMPLIANCES & CONSEQUENCE PAGE 5 OF 8 BLNG.25.00 ENABLE THE BUSINESS – ENSURE HSSE MANAGEMENT PROCESS
• All alleged Life Saving Rule violations shall be thoroughly investigated
Step 1 by an Independent Investigation Team within three (3) working days.
• Review investigation report and determine appropriate consequence
Step 2 management.
• Apply Consequence Management to the involved parties.
Step 3
• Close out Incident report and Disseminate Lessons Learnt.
Step 4
After receiving notification (via OMNISAFE and PAKAT reports) of the incident/ violations, incident owner shall carry out a preliminary investigation to first establish the exact circumstances that led up to the act or behaviour in question.
Once circumstances are established, HSQ shall appoint an independent investigation team to carry out detailed investigation. HSER Advisers are responsible in providing support and resources during the investigation and facilitation of RAM allocation. Within three (3) working days, the team shall :- Confirm that an LSR breach did/did not occur Establish evidence of prior LSR knowledge Establish LSR enforcement by Supervisor Establish severity/risk rating Establish compliance history Establish clarity of applicable procedure
Incident Owner shall prepare full investigation report using a standard Investigation Report presentation slides template, findings and recommendations with supporting evidences (e.g. PTW, Certificates, photos, etc..) within seven (7) days and presentation to Consequence Management Panel within fourteen (14) days after the incident occurred. This applies for potential severity finding is Medium /or High as per RAM assessment.
Peer to peer consultation will be applied for low severity findings.
Consequence Management Panel has full authority either to approve or reject the proposed recommendations.
The consequence management process shall be applied to any personnel (Staff/Contractor) if non compliance or deviations (including technical) are found i.e. LSR violations, deviations from HSSE policy, Standards, Procedures & Work Instructions and disregarding HSE intervention.
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The members of Consequence Management Panel and Technical Deviations Panel are as follows:
No CMP Member CMP Roles and Responsibilities
1 Thomas Jenke, DMD • Alternate Chair • Communicate Consequence
2 Hj. Yaakub Hj. Yusof, HSQ • Advise panel on outcome of investigation
• Organize CMP
3 Hjh. Zainab Omar, HC • Advise HR perspective for staff
4 Husini Bakar, LC • Advise Legal perspective
5 Functional Manager • As required
When the actual outcome of the investigation is High (red) in the RAM, LM or MD will be involved in the consequence management panel. HC advice must be obtained in all cases where disciplinary action is a potential outcome for own staff. 1. If the violator is aware of the rule or procedures through training experience or communication, and do not comply with the rules or procedures, the maximum appropriate disciplinary action will be applied. 2. If a supervisor (at all levels) fails to communicate the Rules, set the conditions for rules breaking or fail to follow through if one is broken, maximum appropriate disciplinary action will apply. 3. Invitation to the Panel maybe extended to the following (upon request): Incident owner any member of the investigation team Section / division / dept heads & functional managers if it relates to own staff. Contractor Managers or director if incident relates to the Contractors, Contract Holders & contractor supervisors where appropriate The involved person
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5.0 RECORDS Record Record Custodian Retention Period Record Location
N/A N/A N/A N/A
6.0 REFERENCES Human Resources Policy and Practice Manual (HRPPM) LSR Application of Consequence Management (HRPPM section 9)
7.0 DEFINITIONS
AIPS Asset Integrity Process Safety
CH Contract Holder
DEP Design Engineering Practice
HRPPM Human Resources Policy and Practice Manual
Intervention Become involved in a situation in order to improve or control. It could be
described as when a third party (subordinates, colleagues, manager, supervisors, other BLNG and Contractor Personnel) stop an employee or contractor from performing unsafe acts, or working under unsafe condition.
PTW Permit to Work
RAM Risk Assessment Matrix
TECHNICAL Examples: Scaffolding Standards, Lifting and Hoisting Standards, etc… STANDARDS
8.0 CHANGE HISTORY
Issue Revision Record Date 0 Draft for comments 17 June 2009
1 Issue for implementation 26 June 2009
2 12 LSR Consequence Management Update 30 September 2010
3 Reviewed to further improve Consequence Management 30 February 2011
processes and inclusion of Technical Deviation issues 4 Reviewed to further improve Consequence Management 30 August 2011 processes 5 Incident reporting and Timeline updated. CMP Panel revised. 10 September 2014
Issue: 5 The controlled copy of this document is in electronic format in Brunei LNG web. Doc. No: The hardcopy is uncontrolled was printed on – 4 September 2014 9:18 AM HSEC-CP-219 BAM CODE AND NAME: HSE NON-COMPLIANCES & CONSEQUENCE PAGE 8 OF 8 BLNG.25.00 ENABLE THE BUSINESS – ENSURE HSSE MANAGEMENT PROCESS
9.0 APPENDIX N/A
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