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HSE Directive No.

35 Processing of undesired incidents and exemptions

Prepared by: Bjrn Ivar Amundsen Revision number: 2 Classification:

Verified by: Bjrn Ivar Amundsen Issue date: 2008-12-30


Public/unclassified BP internal

Approved by: Hugo Halvorsen Next review date: 2009-12-31


Confidential Secret

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Document control sheet


Document owner Review period Deviation management Revision history Bjrn Ivar Amundsen 1 Year Ref. HSE-directive No. 35

02

2009

01

2008

Rev.no

Issue date

HSE Directive No. 35 Processing of unwanted events and exemptions HSE Directive No. 35 Processing of unwanted events and exemptions Description

B.I.Amundsen

B.I.Amundsen

H.Halvorsen

B.I.Amundsen

B.I.Amundsen

H.Halvorsen

Prepared by

Verified by

Approved by

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Table of content
1 2 3 General..................................................................................................................................................4 Responsibility........................................................................................................................................5 Work Process........................................................................................................................................6 3.1 Alert and notification ....................................................................................................................8 3.2 Investegation..............................................................................................................................13 3.3 Registration: Normalization or applying for an exemption .........................................................16 3.4 Measure .....................................................................................................................................20 3.5 Learn ..........................................................................................................................................21 3.6 Reporting....................................................................................................................................21 3.7 Interface with contractors ..........................................................................................................22

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1
Purpose

General
The purpose of this directive is to ensure that unwanted events are identified, assessed, registered, investigated and analysed, and that measures and recommendations are registered and followed up in order to normalize the situation created by the unwanted event. The following are encompassed by this directive: Unwanted events (accidents and near misses) Non-conformances Exemptions The directive prevails for BPNs activities on the Norwegian Continental Shelf and onshore facilities where BPN is the responsible party under the Working Environment Act. Unwanted events related to work processes and products thereof having impact on health, safety, security and/or environment (HSE) shall be handled in accordance with requirements stipulated in this directive. During the realisation of a product within the companys key processes, Traction shall be the preferred tool used to process events having impact on the HSE-level. Contractors of contracted installations, who have a system that satisfies the requirements in this directive, may use their own system provided this has been clarified upon implementation. The Management Regulations Section 18 Collection, processing and use of data Section 19 Registration, examination and investigation of situations of hazard and accident Section 20 Handling of non-conformities Section 21 Follow-up Section 22 Improvement The Framework Regulations Section 5 Responsibility according to these regulations Section 6 Arrangements for employee contributions The Information Duty Regulations Section 11 Alert and notification to the supervisory authorities of situations of hazard and accident Section 12 Follow-up Section 13 Notification of an accident which has resulted in death or personal injury Section 14 Notification of possible work related disease Section 15 Reporting of work hours

Scope

References

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Definitions and abbreviations

The Working Environment Act The Pollution Act OSHA Regulations and standards 0.60.013 Supervisory Activities HSE Directive No. 37 HSSE&Q in Contracts BP OMS Practice for Reporting HSSE and Operational Incidents, January 2008 BPN, Retningslinjer for Traction, March 2008 (Norwegian version only)

ASR: BPN: CAM: Contract Account CLC: Comprehensive L DAFWC: Days Away Fro FAI: FAS: HSE Tag: Dedicated person following up a contractor an HSE: Health, Safety and External Environment. Also referred to as HSSE encom MOU: MTI: Medical Treat NPD: Norwegian Petroleum Directorate (i.e. resources and produ OIM: Offshore Installa OSHA: Occupational Safety and Health Administration is an office under the Am PDML: The steps Plan, Do, Measure and Learn in the quality cycle within BP fo PSA: Petroleum Safety Authority Norway (i.e PU: Performance Unit. BPN is referred to a PUL: Performance Unit Leader. Managing director of PULT: Performance Unit Leadership Team. The upper manage RWI: Restricted SOR: Serious Occu SPU: Strategic Performance Unit. The BPN is one PU within the N

Records

Responsibility
has the overall responsibility for ensuring that this directive is known and followed up by all personnel at the installation/operational site

Offshore installation manager/highest authority at the operational site HSE department

HSE function (safety officer/

is responsible for analysing accidents and incidents, reporting work hours to the PSA four times a year, preparing relevant HSE statistics, reports and analyses, including regular reports required by the BP Group and reporting HSE figures to the BP Group on a monthly and quarterly basis in line with the Group and SPU requirements. is responsible for taking part in investigations and providing the investigation leader/team with professional advice/assistance as required, quality assuring

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safety advisor)

Nurse

Safety delegate

FAS

CAM PULT

investigation reports initiated on the platform before sending them ashore and actively contributing to the identification and investigation of all losses, also in relation to the extended concept of loss. is responsible for filling in relevant personal injury forms in the event of personal injuries and illness. Informing the OIM and company management of all personal injuries, illnesses and epidemics. Sending relevant personal injury forms to the HSE department in the event of medevac or medrescue. Notifying FAS of the required assistance, and assist the alarm centre in filling out the necessary medevac / medrescue form. is entitled to participate in all investigations having to do with the health, safety and working environment of personnel. Commenting on investigations and proposed measures enclosed with the investigation report. is responsible for notifying the emergency response leader in accordance with the Onshore Emergency Response Plan. Filling in the medevac / medrescue form received from offshore in cooperation with the offshore nurse. is responsible to follow-up unwanted events originated by contractor having impact on the BPN HSE-level. is responsible for reviewing the HSE level via the Performance Management process and decide interventions where needed.

Work Process
Any unwanted event identified during the execution of a work process, and/or a nonconforming product thereto, shall be assessed with respect to its nature, consequence and potential. Based on same assessment, the unwanted event shall be processed accordingly. The application of the quality cycle for work processes in BPN upon the process related to unwanted events is visualized by the following flow chart. It is important to notice that the process have encompassed the four steps (Plan, Do, Measure and Learn) and by adhering to all these steps, the outcome will be an improved HSSE Level both in short terms and in the long term

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3.1
General

Alert and notification


Please consult appendix BPNs Matrix for Alert and Notification of unwanted events for details and guidance. The matrix is aligned with the Information Duty Regulations and Traction. An alert should be done without any undue delay after the initial assessment of the unwanted events potential is determined A notification shall be submitted no later than the first working day after the unwanted event occurred or was discovered. Unwanted events classified as a Defined Situation of Hazard (DSHA), shall be processed as stipulated in the Onshore Emergency Action Plan Unwanted events occurring as part of the petroleum activity shall as a general rule be alerted and notified to the Petroleum Safety Authority Norway (PSA) Unwanted events related to an unplanned production shut-down more than 24 hours, shall be alerted and notified to the Norwegian Petroleum Directorate (NPD) Unwanted events occurring onshore (e.g. fatalities, serious personal injuries and serious near-misses) shall be alerted and notified to the Local Labour Inspection Authority and Police The Information Duty Regulations (section 11 and 13) clearly defines what kind of unwanted events are subject to an alert and notification Any unwanted event subject to an alert or notification to the authorities is also subject to alert and notification within the company

Immediate actions pursuant an unwanted event

Unwanted event subject to an ALERT?

Immediate actions to secure the relevant area must be taken without undue delay Care must be taken to make sure that the required actions can be implemented without exposing personnel to unnecessary risk Once any injured personnel have been taken care of, the area must be secured/blocked off. Such blocking can only be removed after the area authority and investigation leader have given their approval If the incident is of such a character as to warrant a police investigation, the police will determine when to release the area. In order to start using areas/systems, the causes must have been established and necessary actions taken to make sure this is done in a completely safety manner. If systems, equipment or components involved in an accident or near miss have not been shut down as a result of the incident, it must be established immediately whether continued operation is justifiable in terms of (HSE). The following unwanted events which have led to or which, under insignificantly altered circumstances, might have led to: a. severe and acute injury b. acute life-threatening illness c. severe impairment or loss of safety functions or other barriers that endanger the integrity of the facility d. acute pollution

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This entails that the following specific unwanted events are subject to an alert: deaths severe personal injuries: head injuries involving concussion, loss of consciousness or other serious consequences, loss of consciousness as a result of working environment factors, skeletal injuries, with the exception of simple hairline fractures or fractures of fingers or toes, injuries to internal organs, whole or partial amputation of parts of the body, poisoning with danger of permanent health injury, such as H2S poisoning, burns, frost or corrosive injuries with full thickness skin injury (third degree) or partial thickness skin injury (second degree) to the face, hands, feet or abdomen, as well as all partial thickness skin injury that covers more than five per cent of the surface of the body, general cooling (hypothermia), permanent, or for a longer period of time, inability to work situations where there is danger that vessels and drifting objects may collide with facilities, blowouts from wells, explosions and fires, larger unintentional discharges of hydrocarbons and chemicals of significance to safety and working environment, unintentional discharges of significance to the exterior environment of petroleum, drilling fluid and chemicals, cf. recommended levels for alert of acute pollution, incidents in which the use of radioactive sources has got out of control situations where the emergency preparedness organisation on the installation has been activated, or preparations for evacuation have been implemented, situations where the safety delegate demands that dangerous work be stopped Unwanted event subject to a NOTIFICATION? Any unwanted event alerted to the authorities shall be confirmed with a notification. The notification shall be documented by using the form Confirmation of alert/report to Petroleum Safety Authority Norway about situation of hazard and accident. The form is available in the appendices section. In addition, for any unwanted events as mentioned on page Error! Bookmark not defined. (literas a to d inclusive), but of less severe or less acute character, a written notification shall be sent to the PSA on the first working day after the unwanted event occurred or was discovered. This entails that the following specific unwanted events are subject to a Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

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notification: situations where special hygienic or health preparedness measures have been implemented, such as in connection with illness caused by the water supply or food failure of normal, hygienic procedures that result in increased risk of illness less serious situations in connection with positioning, pipeline systems and load bearing structures violation of safety zones or special areas subject to restrictions, cf. Section 39 of the Framework Regulations on alert and notification in connection with penetration of safety zones situations that have led to loss of deck load, anchoring, mooring and towing equipment, and drilling and well equipment. The report should specify the exact position unintentional hydrocarbon and chemical discharges of lesser significance to safety and working environment unintentional discharges of lesser significance to the external environment of petroleum, drilling fluid and chemicals, cf. recommended levels for reporting such discharges situations where radioactive sources are stuck in the well situations where individual measurements show that employees have been subjected to a radioactive exposure (effective dose equivalent) of more than 20 mSv in the course of 12 months (cf. the Facilities Regulations section 25 and the Activities Regulations section 35) dropped objects potentially hitting personnel and having energy above 40J (Potential energy = mass x height x 9.81). Please consult information about Drops on the HSE intranet, for details. In addition, the following defined unwanted events are subject to additional specific requirements: OSHA: For reporting within the BP Group, the OSHA definition of occupational injuries and work-related illness is used (see OSHA 1904 for more information). The health department will provide details / clarifications. Personal injuries: All personal injuries, with the exception of first aid injuries, shall also be notified on the National Insurance Administration's form RTV 11.01 E and sent to Madla social security office. The notification shall be sent even if the appropriate authorities have been alerted of the injury. For BP employees, the HSE department shall send the notification, and for hired personnel their employer shall send the notification. The HSE department shall receive a copy of the notification submitted to the authorities by other employers performing work for BP. Possible work related illness: Any medical practitioner who through his/her work acquires the knowledge that an employee may suffer from a work-related disease, shall notify the Norwegian Petroleum Safety Authority in writing, cf. the Working Environment Act Section 22. Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

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Such notification shall be done using the Norwegian Petroleum Safety Authority and the Labour Inspection Authority's form 154b no later than one month after the disease was discovered. Employees who think they are suffering from a work-related disease shall notify the employer or his representative. If the employee agrees, the employer shall further notify the health personnel in his own enterprise. The health personnel shall make a professional assessment and, if applicable, notify the PSA. The health personnel shall always report any recurrence of the disease if the employee has been without any problems from the disease for a period of at least twelve months Helicopter accidents: In the event of helicopter accidents, the aviation enterprise shall notify the Civil Aviation Authority, the Aircraft Accident Investigation Board for Civil Aviation, and the police in accordance with BSL A 1-3. Communicable diseases: Alert and notification of all communicable diseases that are a hazard to public health, shall take place according to Section 2-3 of the Communicable Diseases Act, cf. Regulations 30 December 1994 No. 1224 relating to medical practitioners' and other health personnel's notification and alert of communicable diseases Sub-standard drinking water quality: According to the Regulations relating to water supply and drinking water, the owner (the operator) shall notify the Ministry of Health as the supervisory authority in the event of violations of the limit values for drinking water quality as stated in the appendix to the regulations. Reference is made to the explanation of limit values, etc. in the appendix to the Regulations relating to water supply and drinking water. Radiation sources: Incidents involving ionising radiation sources in connection with bore hole logging, use of industrial control sources and industrial radiography shall be reported directly to the Norwegian Radiation Protection Authority according to Section 11 in Regulations 21 November 2003 relating to radiation protection and use of radiation. For emergency preparedness related unwanted events (i.e. Defined Situations of Hazards), the sequence to adhere to is stipulated in the emergency plans. Please consult those for such unwanted events. For other unwanted events within the petroleum activity, the framework for alert is as follows: 1. The OIM informs Falken Alarmsentral (FAS) 2. FAS then make contact with the Emergency Duty Leader, who then contacts the HSE Duty 3. The HSE Duty shall quality control the initial information from the originating site and consult with the Emergency Leader on duty 4. The HSE Duty shall thereafter without any undue delay alert the person on duty at the Petroleum Safety Authority Norway (PSA) via PSAs switchboard +4751876050. 5. Normally, the person on duty at PSA will call back to the HSE Duty for details 6. The alert shall be confirmed with a notification. 7. Please consult the section How to NOTIFY? on page Error! Bookmark not defined. for the next steps. Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

How to ALERT?

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How to NOTIFY?

The framework for external notification is as follows: 8. The notification shall be documented by using the form Confirmation of alert/report to Petroleum Safety Authority Norway about situation of hazard and accident. The form is available on the HSE intranet. 9. Please be aware of the following check point when preparing the notification: a. Provide a brief, clear and concise description of what happened just prior to, under and after the unwanted event b. Describe the consequences and the potential of the unwanted event. Remember that the potential shall be evaluated based on what could have happened under slightly altered circumstances c. If the unwanted event encompass a personal injury, the employer shall be written on the notification form d. If the unwanted event is subject to an investigation, please detail so on the notification form e. Please make sure all fields on the notification form is filled in as appropriate f. The notification form, when finalised, shall be generated as a PDF-file 10. The PDF-file shall be sent to the following e-mail address only: varsling@ptil.no 11. If expedient, additional records (e.g. sketches / pictures) may be sent to the PSA via the Droppsone: http://www.ptil.no/Norsk/PtilDroppSone/Default.htm 12. The information compiled during steps 8-11 above shall be distributed internally. Please be aware of the distinction between what has been subject to an alert and what has been notified only.

Special provisions for BP NORGE alert and notification

The framework for internal notification is as follows: If the unwanted event has been subject to an alert; a. Create an e-mail where aforementioned records are attached and select the appropriate distribution list. (E.g. if the unwanted event occurred on the Tambar installation and it has been alerted to the PSA, the correct address is G SVG SOR Tambar) b. The heading shall have the syntax SOR + Asset Name + Keyword for the unwanted event c. If the attached records is in Norwegian, please provide a short summary in English in order to facilitate usefulness for recipients not fluent in Norwegian If the unwanted event has not been alerted, but is subject to notification only; Follow the aforementioned items g, h and i, but use the distribution list G SVG Melding instead. The HSE Duty shall make sure that FAS sends an SMS to the following positions

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with the Norway PU for any notification or confirmation of alert sent to the authorities; PUL, Business Managers, Fields Operations Manager, HSSE & Compliance Manager and the Coordinating Main Safety Delegate Special provisions for BP GROUP internal alert and notification Major Incidents shall be reported using the Major Incident Announcement Form as soon as possible and no later than 8 hours for severity levels A-D, E (Health and Safety) and 24 hours for all other than Health and Safety for severity level E pursuant to the Major Incident Distribution List. All fields in the form must be filled in. If the report is distributed via e-mail, the title must read Major Incident Announcement (MIA) to facilitate identification. MIA reports shall be presented to the legal department for assessment prior to being issued. In addition, serious major incidents are to be announced by PUL or his/her deputy personally contacting the Group Vice President with responsibility for the Norway PU. High Potential Incidents are to be reported using the High Potential Incident Distribution Form as soon as possible and no later than 24 hours pursuant to the High Potential Incident Distribution List. All fields in the form must be filled in. If the report is distributed via e-mail, the title must read High Potential Incident Announcement to facilitate identification. The reporting requirement also applies if the need to classify an incident as a high potential incident is not identified until after an investigation has been made. Local management to promptly advise BP Legal, if an incident occurs which is classified as Level A-E, or could lead to litigation or regulatory action.

3.2
General

Investegation
The purpose of an investigation is to establish the immediate and root causes of an incident in order thereby to be able to propose efficient measures to prevent recurrence and furthermore contribute to the continuous improvement of BP's HSE performance. The method to be used is BP- Root Cause Incident Investigation with identification of the causes in line with the Comprehensive List of Causes (CLC). Reference is also made to Getting HSE Right - Key HSE Process 6, Incident Investigation Guidelines and HSE Toolbox, element 12. An investigation is mandatory for unwanted events representing actual or potential consequences A-D, E, F. In addition, an investigation is mandatory if specific unwanted events are recurring frequently. For remaining scenarios, investigations are optional. However, a stand alone Lessons Learnt (1pager) is mandatory to compile for recordable personal injuries in severity level G even though the unwanted event is not investigated.

Unwanted event subject to an INVESTIGATION?

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Severity Level

Terms of Reference approved by which client (minimum) Performance Unit Leader Field Operations Manager / Project Manager Offshore Installation Manager / Site Manager Offshore Installation Manager / Site Manager Offshore Installation Manager / Site Manager

Investigation lead by whom?

A-D E

Outside Norway PU Outside Norway PU

Norway PU. If DAFWC; Norway PUL to clarify within the PUL on-duty within the SPU Norway PU

Norway PU

Table 1 Severity vs. Level of investigation and Terms of Reference

Investigation process

1. The client for the investigation appoints and provides information to an investigation team, including relevant technical expertise, and an investigation leader with the necessary authority and independence from the operation concerned 2. The client issues terms of reference (TOR) 3. When an incident investigation team is established for an incident which is Level A-E or could lead to litigation or regulatory action, the team is to consult with BP Legal at the start of its investigation 4. The client specifies when the report, and any interim reports, must be finished 5. The investigation team leader makes sure the investigation is carried out according to the TOR, a report with conclusions and recommended actions written and a 1-page lessons learned report written in accordance with attached template 6. The client considers conclusions and proposed actions, and determines what do to with the proposals. The final report should contain the client's (management's) response to all actions proposed, with clear delegation of responsibilities for taking action. A decision must be made in each case as to whether the report shall undergo legal evaluation prior to distribution for final approval 7. The client approves the lessons learned report and makes sure it is distributed to relevant parties: 8. Mandatory: PU HSSE & Compliance Manager (he/she assess distribution within the SPU as deemed necessary) 9. Mandatory: If the investigated unwanted event involves a contractor, the lessons learnt report shall be distributed to the company in question. Normally, the CAM shall act as the focal point for distribution. 10. Optional: The client should assess if the lessons learnt should be distributed to relevant external parties (e.g. OLF network) 11. The investigation report with the lessons learned are published on the intranets HSE homepage The scope of the investigation shall be defined by an approved Terms of Reference encompassing the following subjects. The TOR should be tailored to the level of investigation required.: Short description of the unwanted event Investigation team members by name and roles in the team

Terms of Reference

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Due date for the final investigation report (and any interim reports, if applicable) Due date for the pursuant lessons learnt report, if applicable Language of the investigation report Distribution of the investigation report The scope for the investigation based on the following topics: the actual course of events and the consequences, other potential courses and consequences, existing non-conformities to requirements, approaches and procedures, human, technical and organisational causes of the situation of hazard and accident, as well as in which process and levels the causes may be found, which barriers have failed, the causes of barrier failure and, if applicable, which barriers should have been established, which barriers have functioned, i.e. which barriers have contributed to prevent a situation of hazard from developing into an accident, or which barriers have reduced the consequences of an accident, which actions should be taken in order to prevent similar situations of hazard and accident preparation of a lessons learnt report (always mandatory for recordable injuries). The lessons learnt report shall be in both Norwegian and English in order to facilitate maximum experience transfer Investigation team members and competencies For incidents involving occupational fatalities, the Group Fatal Accident investigation process will be activated Preferably, an investigation leader should be appointed who has a certain degree of independence in relation to the incident. The more serious the incident, the more important it is to ensure independence in the investigation. The investigation leader should be trained in investigation of accidents and near-misses The client will appoint an investigation team headed by an investigation leader. The size and composition of the investigation team will be determined based on the severity and nature of the incident. The investigation team should always include a safety delegate (VO) and a person trained in investigation No personnel who have been directly involved in the incident should participate in the investigation team For major incidents it should be assessed, unless PUL decides otherwise, whether it is required to appoint an investigation team with participants or leader from another business unit The report shall cover the TOR fully and be written on the template defined on the HSE section on the intranet. All investigation reports for potential A-D, E, F incidents should be written in English unless otherwise agreed.

Investigation report

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Investigation reports shall be sent to public authorities on request only. This, however, does not apply to investigations of acute pollution in which case the investigation results will be sent to the Norwegian Pollution Control Authority unsolicited. Any action in the investigation report shall be registered into Traction, and the final investigation report shall be attached same

3.3
General

Registration: Normalization or applying for an exemption


Processing an unwanted event may have the following two outcomes: Situation fully normalised or improved: The root causes for the unwanted event are used to identify actions needed to close the gap between the normal situation and the identified situation. Need for an exemption: The root causes for the unwanted event are identified, but it is not possible or feasible to fully normalise the situation. The first is the preferred outcome. The latter outcome is described fully on page Error! Bookmark not defined.. This section covers registration and follow-up of actions and recommendations pursuant to: 1. 2. 3. 4. Extrinsic audits towards the Norway PU (e.g. audits by the authorities, certification body, etc) External audits conducted by Norway PU Internal audits conducted by Norway PU Unwanted events and any investigation report hereto

As a general rule all unwanted events shall be registered in Traction, except stated other wise within the BP Framework. For IM-related unwanted events, the relevant Technical Authority / SPA Engineering Authority shall be consulted as deemed necessary in order to assure that expedient corrective actions are defined. In the process of normalisation of an IM-related unwanted event, a start-up review shall be conducted in order to quality control that necessary actions have been processed as planned and that the Plant is ready for safe start-up. The causes leading to the unwanted event shall be used to define detailed corrective actions in order to normalise the situation. When allocating actions and deadlines, the responsible personnel must be made aware of and accept the responsibility for this In case of additional actions, these must be communicated to those responsible for taking the action concerned Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

Registration requirements

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In case of organisational changes, change processes shall include a review of changes in responsibilities for outstanding actions as a result of the change process. Traction shall be updated in case of changes, and the new responsible persons be made aware of and accept the changes Any changes of actions or deadlines must be agreed with the person responsible for following-up the unwanted event Documentation supporting the process pr. unwanted event shall be attached and be easily available in Traction Reference is made to the Traction guideline for further details All leaders are to ensure that actions taken within their areas of responsibility are followed up by the deadlines Employees shall be entitled to participate in the following up of actions in accordance with the Framework Regulations. All departments are to keep an overview of and make sure the status with regard to outstanding actions is updated monthly If an action results in a modification proposal (Approval for Alteration) or a work order, a clear reference to the Traction ID shall be given on the AFA/work order No action can be closed unless a clear and concrete description has been made of the actions taken In case of comments on and changes of actions in Traction, the initials and date shall be entered in the comments field to facilitate tracking A due date shall not be amended more than once, and the person responsible for follow-up of the unwanted event must be consulted prior to amending the due date If an unwanted event can not be normalized within stipulated requirements, it will be subject to an application for exemption. The purpose of this section is to ensure that the process of applying for exemptions from directives and regulations is safe and includes the following: an assessment of possible risks to which personnel, the external environment and the company will be exposed if current statutory requirements or company's requirements are not adhered to. implementing compensating actions in order to prevent personnel, the external environment or the company from exposure to an increased risk of injury or damage in case of exemptions information to relevant personnel of exemptions submission of applications for exemption to the appropriate authorities proper documentation of the treatment of exemptions In cases where it has been deemed necessary or appropriate in advance to be in a non-conforming situation: from applicable requirements in the regulations that lead to a lower HSE level than specified in the regulations from company requirements in HSE directives, procedures and standards Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

Follow-up and closing of actions

Exemptions: General

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the application for exemption shall be prepared, processed and approved as described below. The process shall ensure that compensating measures are implemented without the HSE level being impaired. If lengthy exemptions from requirements are required, or if the application for exemption is repeated, the person approving the application must implement preventive actions to prevent potential recurrence. Exemptions: Process The following is the framework for processing an application for an exemption: 1. The application for an exemption, including the rationale and compensating measures are registered in Traction If the application encompasses HSE, a statement from the safety delegate organisation shall be compiled and attached in Traction The relevant Technical Authority shall be informed about the application and be consulted The Technical Authority shall assess the application and pertinent records and clearly state if the application is endorsed or not and inform the originator The originator of the application shall then contact the approver / owner of the subject requirement the application for exemption is based on Based on the aforementioned records, the approver / owner of the requirement shall unambiguously approve or reject the application and inform the originator about the decision taken. The OIM has the authority to approve / reject an application for an exemption towards local Norway PU requirements only. a. If the application for an exemption is based on a statutory requirement, the relevant authority body will have the role as the owner of the requirement and be the correct party in step 6 above. b. The Authority Contact within the Norway PU shall be the focal point for administering the flow of information between the Norway PU and the subject authority All other involved parties in the aforementioned steps shall be informed by the originator about the final decision

2.

3. 4.

5.

6.

7.

All actions stipulated in the application for an exemption are followed up the same manner as for all other unwanted events in Traction.

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

HSE Directive No. 35 Processing of unwanted events and exemptions [Subtitle/Chapter title] Authority: [Title] Issue date: 2008-12-30

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Exemptions: Registration

Applications for exemption shall be registered in Tra@ction as a deviation. The following information needs to be registered: Specification of the act, regulations, HSE directive, procedure or standard from which exemption is sought A description of the non-conformance and its duration An account of special conditions that render the exemption necessary or reasonable An account of the non-conformance's individual and aggregate risk, both for one's own and other petroleum activities A description of any measures which are to compensate for the nonconformance, either completely or partly A statement from the safety delegate service if relevant In the event of non-conformance with statutory requirements: An account of how the application for exemption has been handled in the company Processing an unwanted event may have the following two outcomes: Situation fully normalised or improved: The root causes for the unwanted event are used to identify actions needed to close the gap between the normal situation and the identified situation. Need for an exemption: The root causes for the unwanted event are identified, but it is not possible or feasible to fully normalise the situation. The first is the preferred outcome. The latter outcome is described fully on page Error! Bookmark not defined.. This section covers registration and follow-up of actions and recommendations pursuant to: 1. 2. 3. 4. Extrinsic audits towards the Norway PU (e.g. audits by the authorities, certification body, etc) External audits conducted by Norway PU Internal audits conducted by Norway PU Unwanted events and any investigation report hereto

General

As a general rule all unwanted events shall be registered in Traction, except stated other wise within the BP Framework. For IM-related unwanted events, the relevant Technical Authority / SPA Engineering Authority shall be consulted as deemed necessary in order to assure that expedient corrective actions are defined. In the process of normalisation of an IM-related unwanted event, a start-up review shall be conducted in order to quality control that necessary actions have been processed as planned and that the Plant is ready for safe start-up.

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

HSE Directive No. 35 Processing of unwanted events and exemptions [Subtitle/Chapter title] Authority: [Title] Issue date: 2008-12-30

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3.4
General

Measure
Measure is vital part of the process in order to quality control that actions originated after an unwanted event has had the desired and planned effect. Measure in this context means that: Actions are performed as defined and completed within due dates The effect of the unwanted event to the specific work process is normalised The likelihood of the same unwanted event occurring again is minimised or neutralised In a broader context, measure also encompasses monitoring and benchmarking of the HSE level such as: Within the PU and Assets Within the SPU and/or the segment and group Towards other operators on the Norwegian Continental Shelf via OLF Within the Norway PU the Performance Management process facilitates measure. In practical terms, the following are defined arenas where measure of HSE-data are measured frequently and in depth: Weekly HSE and Operations meeting at the management level Monthly Performance Reviews at the management level within the PU and within the SPU Within the contractor management framework, contractor generated HSE data is reviewed regularly via planned Quarterly Performance Review meetings for Tier 1 contractors and at regular intervals for Tier 2 and Tier 3 contracts. Key contractors have a dedicated Norway PU Contract Accountable Manager (CAM) and a HSE Tag, which is obligated to conduct subject review meetings and have a Performance Contract in place. The Performance Contract shall contain HSE-related KPIs.

Performance Management

Trend analysis

Data registered into Traction shall be processed at regular intervals in order to extract trends in the data set and act as input to the Performance Management process within the PU. The reports shall be compiled with sufficient details in order to monitor and control technical, operational and organisational aspects for the unwanted events registered into Traction. The reports shall be made available throughout the organisation as deemed necessary. The HSE Department is responsible for this delivery. Based on the outcome of the Performance Management process, specific intervention plans may be prepared and entered into force to support the KPIs set in the annual plans (e.g. HSE Plans and the Norway PU Performance Contracts)

Intervention plans

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

HSE Directive No. 35 Processing of unwanted events and exemptions [Subtitle/Chapter title] Authority: [Title] Issue date: 2008-12-30

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3.5
General

Learn
Learn is the final stage of the quality cycle and as such a key stage to acheive to continuous improvements. In order to improve the HSSE level within the PU, unwanted events originated either within the Norway PU, or outside, shall form the basis for learning. Upon preparation of the annual HSE plan for the PU, the following sources of information shall as a minimum be consulted in order to adopt learnings and make sure the plan is made contemporary (in an unranked order): Traction records Offshore team leaders Safety delegate system Unions BP Group and SPU prioritisations Prioritisation set by the authorities Annual Contractor HSE Day

HSE Plan

Unwanted events originated outside the Norway PU

Based on the outcome of the Performance Management process, specific intervention plans may be prepared and entered into force to support the KPIs set in the annual plans (e.g. HSE Plans and the Norway PU Performance Contracts). At regular intervals lessons learnt reports are received from the SPU. The unwanted events described therein shall be reviewed by applicability for the assets within the Norway PU. All lessons learnt received through the SPU lesson learnt process are registered and followed-up within Traction.

3.6

Reporting
The number of work hours shall be reported on the form stipulated by the PSA and be submitted at latest 14 days after the end of each quarter. The report is compiled by the HSE department. As part of the RNNS project, certain defined situations of hazard and accident are to be reported twice a year to the PSA. KPIs regarding noise and chemicals are reported to PSA once a year. The details for reporting are determined by the PSA. The reply to the PSA is administered by the HSE department. For hydrocarbon leaks exceeding 0.1 kg per second, detailed data must be collected and recorded on the Additional report of hydrocarbon leaks (appendix) and in the HCLIP database. The data must also be sent to the PSA

Reporting work hours

Risk level on the Norwegian continental shelf (RNNS) Discharge and leaks

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.

HSE Directive No. 35 Processing of unwanted events and exemptions [Subtitle/Chapter title] Authority: [Title] Issue date: 2008-12-30

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3.7
General

Interface with contractors


Follow-up of unwanted events related to the realisation of a product by use of a contractor is to be handled in the performance management process in force for the subject contract. A dedicated project execution plan is to be prepared by the contractor as part of the tender process. Even though caution shall be displayed in intervening into the contractors procedures for unwanted events (e.g. Mobile Offshore Units holding an Acknowledgement of Compliance), BPN must ascertain that principles stipulated in this directive are adhered to by the contractor. The Contract Accountable Manager (CAM) is responsible for ensuring that the procured service covered by the contract includes the principles stipulated in this directive. Often, a bridging document is put in place. If the unwanted events is part of the petroleum activity (e.g. within the 500 meter safety zone), the unwanted event relevant to the realisation of the product shall be registered in Traction.

Provisions for mobile offshore units (MOUs) Provisions for vessels Provisions for helicopter service Provisions for land based services

Reference is made to the prevailing bridging document in force for the MOU.

The CAM will receive unwanted events originated on the vessels from the contractor and decide follow-up as deemed necessary together with the HSE Tag. The CAM will receive Air safety Reports (ASR) from the contractor and decide follow-up as deemed necessary together with the HSE Tag. The ASRs are subject for review at Performance Review meetings. The CAM will receive unwanted events originated from the land based site (e.g. base services) from the contractor and decide follow-up as deemed necessary together with the HSE Tag.

Attention: Paper copies of governing documents are uncontrolled. This copy is valid at time of printing only. The controlled document is available at the Governing Documents Triangle at BP Norway Intranet.