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HSE NON-COMPLIANCES & CONSEQUENCE

MANAGEMENT PROCESS

Control Procedure

 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

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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.

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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

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• 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.

Issue: 5 The controlled copy of this document is in electronic format in Brunei LNG web. Doc. No:
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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

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 7 OF 8
BLNG.25.00 ENABLE THE
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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
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9.0 APPENDIX
N/A

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