Doc. No.

: UMD-HSE-H4WI-ML-G-0004
HSE RISK MANAGEMENT Revision : 2
PROCEDURE Date : 5 / 11 / 2019

Doc. No: UMD-HSE-H4WI-PR-G-0004

Document Title:
HSE RISK MANAGEMENT PROCEDURE

REPSOL OIL & GAS MALAYSIA LIMITED

PROVISION OF ENGINEERING, PROCUREMENT,

CONSTRUCTION AND INSTALLATION (EPCI) SERVICES
FOR NBO H4 WATER INJECTION PIPELINE PROJECT
CONTRACT NO:4600010175

2 5/11/19 Issued for Review NFA AF AY

ISSUE UMD RML

REV. DESCRIPTION PRE’D BY CHK’D BY
DATE APPR’D APPR’D

PROVISION OF ENGINEERING,
PROCUREMENT, CONSTRUCTION AND
INSTALLATION (EPCI) SERVICES FOR
NBO H4 WATER INJECTION PIPELINE
PROJECT

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RECORDS OF AMENDMENT

AFFECTED
REV. DATE DETAILS OF CHANGE
PAGE

2 5/11/2019 Issued for Review

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TABLE OF CONTENTS

1.0 INTRODUCTION…………………………………………………………………………. 5
2.0 PURPOSE …………………………………………………………………………………6
3.0 SCOPE …………………………………………………………………………………6
4.0 DEFINITION AND ABBREVIATIONS…………………………………………… …6
5.0 ROLES AND RESPONSIBILITY …………………………………………………………7
5.1 Project Manager………………………………………………………………………………7
5.2 HSE Manager…………………………………………………………………………………7
5.3 Construction Manager……………………………………………………………………….7
5.4 HSE Lead / Engineer ………………………………………………………………………..7
5.5 Work Leader ………………………………………………………………………………….8
5.6 Worker(s)……………………………………………………………………………………...9
6.0 PROCEDURE DETAILS………………………………………………………………… 10
6.1 Hazards Identification Process…………………………………………………………….10
6.2 Risk Assessment……………………………………………………………………………10
6.3 Managing Significant Risks………………………………………………………………..14
6.4 Monitoring HIRAC Action Plan…………………………………………………………….14
6.5 Reviewing HIRAC ………………………………………………………………………….15
6.6 Mechanism to Trigger New HIRAC……………………………………………………….15
6.7 Competency and Training………………………………………………………………….15
6.8 Implementation of HEMP…………………………………………………………………..15
6.9 HEMP Framework ………………………………………………………………………….16
6.10 The Steps In HEMP ………………………………………………………………………..17
6.11 Identification of Hazards, Threats and Top Events……………………………………...17
6.12 Assessment of Consequences and Risks………………………………………………..18
6.13 Control and Recovery Barriers…………………………………………………………….19
6.14 HEMP Deliverables………………………………………………………………………....20
6.15 Demonstration of ALARP…………………………………………………………………..21
6.16 Assurance and Review of HEMP………………………………………………………….22
6.17 Job Safety Analysis…………………………………………………………………………23
6.18 Communications of The Job Safety Instruction for The Job …………………………..25
7.0 APPENDICES………………………………………………………………………………26
7.1 Appendix 1: Hazard and Effect Template ……………………………………………27
7.2 Appendix 2: Critical Activity Cataloque Template …………………………………...28
7.3 Appendix 3: Remedial Action Plan Template ……………………………………………29

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1.0 INTRODUCTION

Repsol Malaysia Limited (RML) operates PM3-CAA block located between Malaysia and
Vietnam. There are two developments within PM3-CAA block, Northern and Southern Fields.
Each asset is operated through a dedicated FSO and a series of production platforms.

Figure 1.1: PM3 Commercial Arrangement Area (CAA) Overview

Northern Fields Complex is made up of the North-East Bunga Orkid (NBO) area. In 2014,
RML drilled development well (NBO-3) from BOC platform and discovered oil in H4 reservoir.
Well NBO-3 was later completed with well name BOC-19 and, together with the subsequent
well, BOC-22, these two wells are now producing (Oil) from the H4 reservoir. A further well
NBO-4 (including two side-tracks) was drilled to test the up-dip potential of the eastern most
section of the H4. The well encountered hydrocarbons in the H4ss10 and H4ss12 sand units.
Repsol Malaysia Limited has completed the evaluation of development design options for a
full H4 reservoir development during visualization & conceptualization phases. The selected
FEED design was based on drilling all 6 wells (2 oil producers and 4 water injectors) from
existing platform (BOC WHRP) with three (3) of the wells will be of extended reach design.
The decision to drill all wells from existing platform (full BOC concept) was driven largely by
the acceleration of first water injection / oil and the economic value the concept brings to the
overall development. H4 Field Development Plan (FDP) was approved in early August
signifying H4 project sanction. The project schedule indicates target date for First Water
Injection by July 2020 and First Oil by Nov 2020.

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The NBO H4 project covers the development section of the H4 reservoir. This “NBO-H4 Project
Development” consist of provision of two new oil producer wells and four water injection wells at
the BOC platform. The oil from the two new oil producer wells will be delivered to the existing
FWS oil manifold at BOC platform. The water source for water injection wells is will be supplied
from BOA platform. Injection water is delivered via bridge to BOD platform and then delivered via
a new subsea pipeline from BOD to BOC.
The project scope will include brownfield works at existing facilities on BOC and BOD to
accommodate new oil producer wells and water injection wells at BOC.

2.0 PURPOSE

2.1 This document provides a general overview of the HSE Risk Management and guidance
for its application, hence ensuring a consistent approach to risk management and
continuous risk reduction during execution of the NBOH4 Project.
2.2 HEMP is a structured methodology for the identification of HSE hazards and
assessment of the associated risks, and development of the control and recovery
measures to reduce HSE risks to as low as reasonably practicable (ALARP). HEMP
is central to the effective implementation of the HSE Management System.
2.3 The objectives of HSE Risk management are to ensure that:
2.3.1 The hazards and the associated risks inherent in the design, construction,
commissioning, operations and decommissioning are systematically identified and
assessed
2.3.2 Identification of safety & health hazards / risks at workplace
2.3.3 Assessment of the identified hazards / risks
2.3.4 Establishing and Implementation of the further risk controls

3.0 SCOPE

This procedure shall be applied and practice throughout the UMD work area.

4.0 DEFINITIONS & ABBREVIATIONS

ALARP - As Low As Reasonably Practicable

CAC - Critical Activity Catalogue
CHRA - Chemical Health Risk Assessment
CAPA - Corrective and Preventive Action
CLIENT - Repsol Oil & Gas Malaysia Limited
DOSH - Department of Occupational Safety & Health, Malaysia
FE - Field Engineer
HEMP - Hazards and Effect Management Process

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HER - Hazard and Effect Register

HSE - Health Safety and Environment
HRA - Health Risk Assessment
HOD - Head of Department
HIRARC - Hazard Identification Risk Assessment and Control
ISO - International Standards Organization
JSA - Job Safety Analysis
KPI - Key Performance Indicators
OCS - Offshore Construction Superintendent
PIC - Person in Charge
PMT - Project Management Team
PPE - Personal Protective Equipment
PTW - Permit To Work
RAP - Remedial Action Plan
RAM - Risk Assessment Matrix
SME - Subject Matter Expert
SOP - Standard Operating Procedure
UMD - UMD Energy Sdn Bhd
WI - Work Instruction
QA/QC - Quality Assurance & Quality Control
JOB - A job is defined as a number of steps or tasks performed in a
definite sequence to complete a work assignment
STEP - A segment of the job necessary to advance the work
ROUTINE / NORMAL - Work activity that takes on a regular frequency: The generic
WORK procedure to do the job was established and the employee is
always familiar with the job steps, its potential hazards and
necessary action to work safely. The operations are performed in
accordance to plan or within the operation conditions. Example
of routine work: Welding and Cutting plate inside workshop.
NON-ROUTINE / - Work activity that takes place infrequently and there was not
ABNORMAL WORK similar in job sequence or arrangement. No specific procedures
developed for it since the sequence or arrangement keeps
changing. As example, of non-routine work: Heavy lifting by using
two cranes (tandem lifting) will requires engineering calculation
on the eyepiece capacity and its position, and also the cranes
movement direction.

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5.0 ROLES AND RESPONSIBILITIES

5.1 Project Manager

The Project Manager is accountable for managing all HSE risks through the effective
implementation of this HSE Risk Management Procedure: -
5.1.1 Establish the detailed HEMP procedure for the project and carry out HEMP studies
prior to commencement of work.
5.1.2 Sign-off and approve the HEMP deliverables.
5.1.3 Appoint a HEMP custodian to facilitate the HEMP study and produce the report.
5.1.4 Establish the schedule for all HEMP studies and ensure compliance.
5.1.5 Identify suitable HEMP facilitators and ensure their competency HEMP facilitator.
5.2 HSE Manager
The HSE Manager is assuring and adopted for defining HSE Risk Management through: -
5.2.1 Implementing and administering this procedure.
5.2.2 Function as an adjudicator on any issues from the implementation of this
procedure.
5.2.3 Ensure the required HSE records are generated and available for review by
Management, Client and Authorities as appropriate.
5.2.4 Ensure the further control measures required to reduce the Significant Risks are
implemented, monitored and eventually closed by the affected HOD.

5.3 Construction Manager

The Construction Manager shall be responsible for: -
5.3.1 The overall responsibility for the implementation of this procedure and ensuring
that all entities at the jobsite actively participate.
5.3.2 Providing the personnel, facilities, and other resources necessary to implement
this procedure.
5.3.3 Ensuring the content of this Procedure is followed and implemented accordingly,
within their department and ensure all required Further Control Measures relevant
to their department are implemented and closed.
5.3.4 Ensuring the HIRAC requirements by the client on client site are complied.

5.4 HSE Lead / Engineer

5.4.1 Review, update and communicate the content of this procedure to HOD & relevant
staff.
5.4.2 Ensure PIC is trained on the preparation of HIRAC for each department.
5.4.3 Periodically audit the compliance and implementation of this procedure.
5.4.4 Highlight the result of the audit to the management team.
5.4.5 Ensure major issues that cannot be handle by the Engineers/Executives are
brought to the Management Team attention.

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5.5 Work Leader

5.5.1 Establish and maintain HIRAC for their departmental routine and non-routine
activities.
5.5.2 Establish HIRAC for any new activities.
5.5.3 Review HIRAC when necessary particularly after an incident or when there are
changes in the process or activity.
5.5.4 At the planning stage of the proposed work and prior to the work taking place, bring
together all workers, who will be directly involved in the proposed work and carry
out the following: -
a) Using the JSA Form identify and record all work activities /steps associated
with the job.
b) Identify and record potential hazard for each activity.
c) Identify and record all controls required to eliminate/isolate/minimize the
hazard and identify responsible party.
d) Attach the completed JSA to the PTW.
e) Re-brief/communicate change of the approved JSA to workers prior to start
work.

5.6 Worker(s)
5.6.1 Is responsible to comply with the control measures stated in the HIRAC.
5.6.2 Shall report to work in a fit and proper condition to perform their job in a safe
and competent manner.
5.6.3 Shall observe and follow all established site HSE rules and regulations. They
shall adhere to all work directives and procedures for the tasks assigned
(whether provided orally or in writing).
5.6.4 Shall exercise the ‘STOP Work authority’ when they observe unsafe situation.
5.6.5 Shall always uses personal protective equipment (PPE) in good working
condition where it is required.
5.6.6 Shall encourages co-workers by words and example to use safe work practices
on the job.
5.6.7 Shall makes suggestions to supervisor, safety committee representative or
management about changes he believes will improve employee safety.
5.6.8 At the planning stage of the work “switch on” to the work environment,
participate and contribute in the development of JSA.

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6.0 PROCEDURE DETAILS

6.1 Hazard Identification Process

6.1.1 All activities including routine & non-routine, activities done by each department
have to be identified.
6.1.2 Each activity will then be transferred into the HIRAC Form for the hazard
identification and risk assessment processes.
6.1.3 For activities performed at Client site, the forms used for carrying out HIRAC will
have to be based on Client’s requirement.
6.1.4 In identifying the hazard for related activities, the list of common Hazards
identified (Hazard List) and list of consequences can be used as guidance.
6.1.5 To facilitate the process of identifying the hazard, each activity has to be broken
down into jobs steps.
6.1.6 Each job step will then be categorised either under direct or Indirect. Direct means
the personnel performing the activity is directly exposed to the hazard(s).
6.1.7 Once the hazard and consequences have been identified from each job step, the
existing controls, have to be determined.
6.1.8 The existing control measures have to be considered when carrying out the risk
assessment.

6.2 Risk Assessment

6.2.1 Risk should be determined using the following: -

RISK = LIKELIHOOD X SEVERITY

Where: -
a) Severity: the potential injury / loss exposures to people, equipment, material
and working environment.
b) Likelihood: What are the chances of the loss exposure to happen?
6.2.2 Once the hazards and consequences have been identified, the level or rates of risks
need to be classified. To determine the risk classification, below table should be
referred: -
a) Table A - Description /Explanation of Likelihood (with historical data)

Value & Ranking TABLE A - Description

Incident has happened more than 1 time each year for the past 5 years or incident
5 – Frequent has happened 10 times and above for the past 5 years
Incident has happened 1 time each year for the past 5 years or incident has happened
4 – Probable 5 to 9 times, for the past 5 years

3 – Occasional Incident happened 3 to 4 times for the past 5 years

2 – Remote Incident happened 1 to 2 times for the past 5 years

1 – Improbable Incident has never happened. Please refer to table B

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b) Table B: Description /Explanation of Likelihood (without historical data)

Existing Controls Frequency of Exposure & Value & Ranking Note

Bi-Monthly, More than
Daily to Monthly
Quarterly to Yearly Yearly
1. Activities not controlled, 1. Total breakdown –
and / or 5 4 3 no control measures,
2. No awareness and Frequent Probable Occasional no commitment, no
commitment awareness, no
(100% Chances of engineering control, no
Happening) administrative control,
no PPE, no
observation and follow
up
1. Minimum S&H 1. Severe breakdown –
awareness and/or 4 3 2 Minimum S&H
2. Only PPE provided and Probable Occasional Remote awareness e.g.:
inconsistently used and/or briefing, verbal advice,
3. No administrative and (75% Chances of no documents/ records
engineering control happening) 2. PPE provided but
inconsistently used;
3. No engineering and
administrative controls
1. In addition to PPE and 1. Potential breakdown
Administrative controls – Moderate S&H
such as regular 3 2 2 awareness
inspection/audit, SOP, Occasional Remote Remote 2. Administrative
instruction, relevant controls (i.e. Procedure
training, authorized or (50% Chances of / WI) are kept updated,
competent person, job happening) training is refreshed as
rotation are used, But needed, employees
[Link] is NOT are competent;
consistent 1. INCONSISTENT
and NO seriousness in
enforcement
1. In addition to PPE and 1. Compliance are
Administrative controls; 2 1 1 always maintained
2. Effective supervision, Remote Improbable Improbable 2. High S&H
and serious enforcement awareness;
is implemented (25% Chances of 3. Administrative
[Link] is ALWAYS happening) controls used;
Maintained 4. Effective
Supervision is carried
out
5. Serious enforcement
1. In addition to PPE & 1 1 1 1. Compliance are
Administrative Controls; Improbable Improbable Improbable always maintained.
2. Engineering measures 2. Engineering
e.g. automation, sensors, (0% Chances of measures are
interlocks, regularly happening) employed (e.g. robotic,
inspected and maintained automation, etc.)
3. Compliance is ALWAYS [Link] of
maintained Engineering Control
Measures are being
enforced and always
being complied;
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EXEMPTION:
1) In an instance, where it is not practical to implement Engineering Controls and the
Administrative Control is the highest possible Control Measures and the probability rating is
2, the Probability/Likelihood rating can be upgraded to 1.

2) Example: Job step is driving on the road; Hazard is road accident; Consequence is Fatality;
Current Control Measures are Trained, Licensed & Healthy Driver, regularly inspected and
maintained vehicle, Compliance to the road safety rules is always maintained; thus, the
highest probability rating is 2. However, in this instance, the application of Engineering Control
is not practical, therefore, the Probability rating can then be finalized to 1.

c) Table C: Description / Explanation of Severity

Business/ Property
Value Ranking Safety & Health Impact
Damage Impact

Fatality or Permanent Disablement or Irreversible/ Chronic

Property damage
5 Catastrophic Occupational illness (e.g. Very Toxic chemical, cancer, deaf,
above RM Above 50K
leukemia, slipped disc, blind etc.)

Lost time injury or illness (5 or more MC days) Property damage

between
4 Major Major illness (e.g. Toxic chemical, asthma, respiratory
problem, dermatitis, Gradual Hearing loss, back pain, watery RM 10001 to RM
eyes, etc.) 50K

Lost time injury or illness (1-4 MC days) Property damage

3 Significant between
Moderate illness (e.g. Corrosive chemical, skin redness,
inflammation, irritation, back discomfort, etc.) RM 5001 to RM 10K

Medical treatment injuries; or minor illness (e.g.: Harmful Property damage

2 Minor chemical, rashes, itchy, headache, flu, coughing, minor between
discomfort, etc.) RM 1001 to RM5K

Property damage RM
1 Slight First Aid Injuries or Negligible illness (Irritation chemical)
1K & below

Note: Worst case scenario has to be considered when assigning the Severity level

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d) Table D: Risk Assessment Matrix

Likelihood Improbable Remote Occasional Probable Frequent

Severity 1 2 3 4 5

Slight 1 2 3 4 5
1 (LOW) (LOW) (LOW) (LOW) (MEDIUM)

Minor 2 4 6 8 10
2 (LOW) (LOW) (MEDIUM) (MEDIUM) (HIGH)

Significant 3 6 9 12 15
3 (LOW) (MEDIUM) (MEDIUM) (HIGH) (HIGH)

8
Major 4 12 16 20
(MEDIUM)
4 (LOW) (HIGH) (HIGH) (VERY HIGH)

Catastrophic 5 10 15 20 25
5 (MEDIUM) (HIGH) (HIGH) (VERY HIGH) (VERY HIGH)

e) Table E: Risk Level

RISK VALUE RISK LEVEL

1-4 LOW

5-9 MEDIUM

10 - 19 HIGH

20 - 25 VERY HIGH

6.2.3 Tools for Risk Assessment - The HEMP tools to be applied should be selected by
trained staff on a case-by-case basis, and depending on the nature of the HSE
risk, the magnitude of the risks and costs involved to mitigate the risk.
6.2.4 The selection of the tools also depends on the phase of the project or operations,
the type of activities and purpose of the risk assessment study.
6.2.5 Control Measures - To determine the need for controls, below table should be
referred: -

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RISK LEVEL ACTION AND TIMESCALE

LOW No further action is required and no documentary records need to be kept. Risk is
1-4 too trivial and can be managed by routine practices

No additional control measures are required. Current control measures are

MEDIUM adequate. Monitoring (i.e. regular inspection, supervision and enforcement) is
5-9 required to ensure that the existing control measures are being maintained.
However, further controls may be imposed if found practicable and not costly

Senior Management attention needed. Efforts should be made to reduce the risk.
HIGH Risk reduction measures (CAPA) shall be implemented within a specified time
10 - 19 period through HIRAC Action Plan. Where risk involves work in progress, urgent
action should be taken

VERY HIGH Work should not start or continued and has to stop immediately until the risk has
been reduced, controlled or limited. CAPA have to be implemented immediately
20 - 25 through HIRAC Action Plan. Top management attention is needed.

6.3 Managing Significant Risks

6.3.1 Upon assessing the risks, control measures shall be developed while considering
the following: -
a) Prioritisation of hazards
b) Identification of affected groups
c) Employee participation
d) Legal requirements of control measures
e) Action plan
f) Follow up system
6.3.2 The control measures recommended shall be based on the hierarchy of control
(from most effective to least effective or ‘back up’ control measure) as follows: -
a) Eliminate
b) Substitute
c) Engineering Control
d) Administrative Control Less
e) Personal Protective Equipment (PPE) Effective

6.3.3 High and Very High Risks are categories as Significant Risks. Additional controls
shall be established to reduce the risks using the HIRAC Action Plan form.

6.4 Monitoring HIRAC Action Plan

6.4.1 Status of additional controls implementation shall be monitored and reviewed in
the HSE Committee meeting to ensure completion.
6.4.2 When establishing Objectives, the Significant Risk shall be considered.

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6.4.3 To ensure additional controls effectiveness, a minimum period of 6 months is

required to evaluate the implementation. Once evaluated and additional controls
found effective, the Risk Rating should be reviewed, in this case, to lower levels.
6.4.4 Effectiveness of additional controls will be monitored through Inspections, Audits,
Observations, KPI’s and Employee Feedback.

6.5 Reviewing HIRAC

6.5.1 HIRAC process and documents shall be reviewed at least once a year or at
predetermined period by the PIC in charge of the activities to evaluate the
effectiveness of control measures established in reducing or minimising the risks.
6.5.2 HIRAC shall also need to be reviewed on the following reasons: -
a) Need to determine whether existing risk control is effective and adequate
b) Introduction of new hazard
c) Introduction of new corrective and preventive actions resulted from accident
investigation and emergency situation
d) Changes in legislation pertaining to HIRAC
e) Changes to processes.

6.6 Mechanism To Trigger New HIRAC

6.6.1 The staff that have to perform the new activity or the PIC who is supervising a
Contractor’s work activity shall prepare new HIRAC if there isn’t any existing
HIRAC.
6.6.2 The PIC in charge of the activity shall prepare HIRAC for that particular job if it is
not listed in HIRAC Register. If the activity is already listed in the HIRAC Register,
but need revision, the PIC shall carry out the revision. The completed HIRAC is
then passed to the HSE Lead / Engineer for checking, and then pass to relevant
HOD or Department Manager for approval.
6.6.3 The copy of the approved HIRAC will be attached to the Permit To Work by the
person that carry out the job and the original copy will be kept by the HSE Lead /
Engineer for record keeping.
6.6.4 Any new major equipment or facility such as Hoist, Compressor, Generator,
Machines, pumps, etc to be installed shall also be analysed to identify whether
there is already an existing HIRAC done on that particular equipment or facility’s
operation. The PIC who is coordinating or supervising the installation work shall
perform this analysis.

6.7 Competence and Training

6.7.1 All personnel involve in the establishment of project HEMP (HER, CAC and RAP)
must attend HEMP awareness training and relevant workshop.

6.8 Implementation of HEMP

6.8.1 The HEMP shall be implemented throughout the project life cycle, with due
emphasis on relevant risk areas as shown in Table below.

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Phase HEMP Area of Focus

 Conceptual Design  Identification of HSE hazards and sustainability issues

 Engineering  Identification and implementation of control and recovery
measures for elimination and/or reduction of HSE and social
 Construction
impacts e.g. application of inherently safer design in
 Commissioning engineering, technology selection, facility siting,
administration and arrangement of people etc.
 Start-up

6.8.2 HEMP studies should be undertaken and implemented in a timely manner so that
the results can be proactively incorporated without incurring rework and related
costs. They should be documented such that the key information and decisions
made are transparent and traceable for future reference.
6.8.3 All recommended actions arising from HEMP studies shall be recorded and
tracked to closure.
6.8.4 Any decision to override recommended actions arising from HEMP shall be
assessed and undergo the approval process to ensure that all risks are adequately
mitigated.

6.8.5 HEMP studies should be performed by staff who: -

a) Have the experience and knowledge of the facility and operation under study
b) Are from the correct mix of discipline (e.g. maintenance, operations, design,
seismic, drilling, health, safety, environment etc.)
6.8.6 The facilitator should be trained and experienced in the HEMP methodologies and
tools being applied.

6.9 HEMP Frameworks

6.9.1 HEMP is an umbrella concept of hazard review tools and techniques, as
depicted in Figure below.

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6.10 The Steps In HEMP

6.10.1 HEMP is a structured and systematic analysis methodology involving the

identification, assessment and control of hazards and the recovery from effects
caused by a release of the hazards. The four components, namely Identify,
Assess, Control and Recover, are essential for proper hazard management. HEMP
Process flow is shown below;

Steps Tool/Technique Project

Deliverables
Identify 1) Identification of ▪ Used Hazards Checklist ISO 17776
hazards, threats and provided by the guideline to assess
top events. the applicable hazards for projects
2) Identification of
consequences. ▪ Used input from SME’s within Line
Department to develop project
Assess 3) Assessment of the specific HER (as per sample in
impact. APPENDIX II of the guideline).
▪ Based on PEAR NOTE: Organize group discussion
▪ Worst case or workshop for HER development
scenario. activities.
4) Determine Risk
Rating ▪ Identified applicable standards, Project
procedures and best practices. Manager sign-
5) Identification of Captured them in HER. off and
Control and approve each
Recovery Barriers ▪ Ensure control/ recovery barriers deliverable
6) Demonstration of identified in should be effective,
ALARP independent and auditable. HER
▪ Comply with NOTE: The control and recovery
tolerability barriers will not decrease the
criterion risk rating, because it is
▪ Application of historical.
codes and
standards ▪ Developed Bowties Analysis for all
▪ Monitor and identified Major Accident Hazards
record all (MAH)
options
considered ▪ Identified critical activities and
positions to keep control and
recovery barriers in
place.
Control 7) Establishment of ▪ Developed project specific CAC for
& integrity of control & the above-mentioned Bowtie, based CAC
Recovery recovery barriers on the input given in the review
▪ Critical sessions.
activities.
▪ Critical ▪ RAP will be determined by any gaps
positions. RAP
identified during the HER and CAC
▪ Performance development.
Standards
8) Development of
RAP

Table-1: HEMP Process Flow

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6.11 Identification of Hazards, Threats and Top Events

6.11.1 This step is required to ensure that hazards, threats and top events are
systematically identified. All hazards associated with the following should be
considered and documented in a consolidated hazard register: -
a) Major accidents
b) Chemicals
c) Workplace-related
d) Environment
e) Health
f) Psycho/Social aspects
g) Off-site impact
h) Security

6.11.2 All hazards and threats associated with each top event shall be identified.

6.12 Assessment of Consequences and Risks

6.12.1 For each hazard release scenario or top event, it is necessary to determine the
potential harm or consequences to people, environment, asset and reputation (P,
E, A, R).
6.12.2 The risk is assessed and prioritized according to their potential impact and the
probability of the hazard being released.
6.12.3 Where a hazard may result in different top events, separate assessments for each
top event shall be made.
6.12.4 The assessment of risk ratings should be in accordance with the HSE RAM as
shown above.

6.12.5 The assessment is for the worst-case scenario assuming all barriers have failed
and there is no mitigation.
6.12.6 The Likelihood of the Top Event is based on historical data and does not apply
probability.
6.12.7 When assessing Likelihood, incidents from the location, the Company and from
industry shall be used.
6.12.8 Based on the identified hazards, the risks and the controls should be evaluated by
applying either qualitative or quantitative HEMP study with reference to relevant:
a) National and International regulatory requirements
b) Recognized codes and standards
c) Industry best practices

6.12.9 The assessments should include the potential for human error and measures must
be established to reduce the likelihood and consequence of any human error.

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6.13 Control and Recovery Barriers

6.13.1 Control and recovery barriers should be identified for Major Risks, by applying
Bowtie or other equivalent tools.
6.13.2 Major Risk is defined as a risk that has the potential to result in a Major Accident
with severe or catastrophic consequences to people, assets, the environment
and/or Company reputation i.e.: -
a) Red - VERY HIGH (E3, E4, E5, D4, D5, C5);
b) Orange - HIGH (E2, D3, C4, B5); and
c) Yellow – MEDIUM (E1, D2, C3, B4, A5) in the HSE Risk Matrix.

6.13.3 In order for a barrier to be considered valid, it should be effective, independent and
auditable.
6.13.4 The barrier is effective if it is able to prevent the consequence from occurring when
it functions according to design.
6.13.5 It must include a sensor, logic and actuator. It must also be independent of the
initiating event i.e. the threat, as well as the components of any other barrier
already validated for the same condition.
6.13.6 Barriers are not independent from one another if there is a common failure mode.
6.13.7 The barrier is auditable if there are records to verify that it can operate correctly on
demand e.g. testing records.
6.13.8 In determining the appropriate barriers, the principles of ALARP shall be applied.
6.13.9 The identification of control and recovery measures should ensure the
effectiveness and feasibility of the proposed controls, and be based on the
Hierarchy of Controls, namely: -
a) Elimination
b) Minimization
c) Substitution
d) Isolation
e) Engineering Control
f) Administrative Controls
g) Procedural Control
h) PPE

6.13.10 Control barriers are required to prevent the threat or combination of threats from
causing the release of the hazard.
6.13.11 The barriers may be physical e.g. safety critical element (SCE), or nonphysical
e.g. competent personnel, systems, activities, procedures.
6.13.12 Recovery barriers are installed or established to minimize the consequences or
impact to people, environment, asset and reputation, where they reduce the
possibility of a catastrophe that could have occurred in the absence of the
recovery measures in place.
6.13.13 The recovery measures should include active, passive and operational response
arrangements that consist of detection, abatement and recovery management
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e.g. gas detection, deluge system, passive fire protection, and emergency
response plans (ERP).
6.13.14 For workplace HSE hazards a combination of organizational and procedural
controls should be applied e.g. competence assurance, procedures, JSA and safe
systems of work control.
6.13.15 Toolbox meetings can be used to communicate the control and recovery
measures adopted.
6.13.16 The performance standards shall be established for all existing control and
recovery measures.
6.13.17 The integrity of the control and recovery barriers shall be monitored and validated
according to the performance standards.
6.13.18 Emergency response plans shall have established and tested using information
available from the relevant HEMP studies.
6.13.19 Escalation factors may cause the control or recovery barriers to be ineffective e.g.
bypassing of the safeguarding systems, adjustment of trip settings, abnormal
operating conditions, weather conditions on sensitivity of gas detectors, etc.
6.13.20 Controls should therefore be established to ensure that the effectiveness of
control and recovery barriers is not compromised by the escalation factors.
6.13.21 For all risks other than Major Risks shall identify the appropriate control and
recovery barriers to ensure that these risks are also managed to ALARP.

6.14 HEMP Deliverables

6.14.1 The main deliverables from any HEMP include: -

a) Hazard and Effects Register (HER)
b) Critical Activities Catalogue (CAC)
c) Remedial Action Plan (RAP)

6.14.2 These deliverables shall be developed for all projects and facilities.
6.14.3 The Project Manager shall sign-off and approve each of these deliverables as they
are completed, before the next step of the HEMP can proceed.
6.14.4 The HER is a comprehensive register of all identified (H, S and E) hazards,
locations, threats, top events, consequences and risk rating. A template for HER
can be found in Attachment 1.
6.14.5 The CAC is a comprehensive catalogue of the following, which are required to
maintain the integrity of the control and recovery barriers.
6.14.6 The control and recovery barriers, which may be in the form of hardware or
procedures. The hardware barriers are also known as the Safety Critical Elements
(SCE).
6.14.7 HSE Critical Activities, which are the activities, including tasks, that ensure the
barriers function properly to prevent the top event and consequences.
6.14.8 HSE critical positions, which are the positions responsible to carry out technical
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assessment in maintaining the integrity of the barriers.

6.14.9 Performance standards, which are qualitative as well as quantitative criteria that
the barriers are expected to perform at: -
a) Inputs, which are related references for the above e.g. maintenance
procedures, equipment specification, schedules, manuals, etc.
b) Outputs, which are records of the critical activities above e.g. inspection
records, equipment testing records, QA/QC records, etc.
6.14.10 The RAP captures any gaps identified during the HER and CAC development and
the ALARP assessment.
6.14.11 The RAP shall be incorporated into the annual HSE plan.
6.14.12 The progress of the RAP implementation should be tracked in a formal database
and followed through till all action items are implemented.
6.14.13 The HER and CAC shall be updated accordingly as the remedial actions are
completed. Attachment 3 provides a template of RAP.
6.14.14 The completed HER and CAC should be used as references to provide input for
risk assessment, training and work planning.
6.14.15 All these deliverables shall be updated whenever changes are made, e.g. plant
modification, changes in the operation, audit findings, incident investigations etc.

6.15 Demonstration of ALARP

6.15.1 UMD are responsible to demonstrate that all risks are tolerable and have been
reduced to ALARP. The decision flow to demonstrate ALARP is shown in Figure
below: -

6.15.2 The level of detail in the ALARP assessment shall commensurate with the actual
and perceived risk. The exercise shall apply the following principles: -
a) HSE risk tolerability criteria has been defined and shall not be exceeded
b) Critical controls are identified, in place and maintained e.g. Bowtie diagram,
CAC
c) Compliance to statutory requirements
d) For common or generic hazards in the same circumstances, tolerability and
ALARP may be demonstrated by reference to solutions incorporated in codes,
standards and legal requirements.
e) A record shall be established for all options considered. The record shall

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include the description of the options and their rationale.

6.15.3 The HSE risk tolerability should be in line with the Local Regulatory Acceptance
Criteria for Voluntary and Involuntary Risks, or more stringent criteria as may be
decided by Management. If specific acceptance criteria are not set by the Local
Authority, then acceptance criteria according to industrial best practice can be
adopted.
6.15.4 ALARP is achieved when the risk is reduced to a level at which the cost and effort
of further risk reduction are grossly disproportionate to the achieved reduction of
risk. This is illustrated in Figure below.

6.16 Assurance and Review of HEMP

6.16.1 The assurance on the integrity of the control and recovery barriers shall be
established through regular review and inspection depending on: -
a) Criticality
b) Magnitude of the risk
c) Performance of the control barriers

6.16.2 HEMP studies shall be reviewed and updated when there are changes to the
project operation, audit findings, incident investigations, post-mortem of
emergency response, etc. or at least once every five years. The changes resulting
from this review shall be managed accordingly.

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6.17 Job Safety Analysis (JSA)

6.17.1 JSA is an accident prevention technique which seeks to: -
a) Identify the Hazards associated with each activity of a job.
b) Develop control measures which will eliminate or guard against injury, illness,
property damage or environmental incidents.
c) JSA is conducted for non-routine, high risk operations or when there are
changes in existing work procedures.

6.17.2 Developing JSA

a) Work Activity/Step

• Break down the work into critical steps describing what is to be done and
in what sequence. This is to be done using the JSA Form.
• Break the job into successive steps or tasks.
• The job should be broken down into steps or tasks following the natural
sequence of events.
• On average, there will be approximately fifteen (15) job steps. The job
under study should be sub-divided if there are more than twenty (20) steps.
• A bigger slice of the jobs should be analyses if there are less than ten (10)
steps.
• Critically assess each steps of the job to determine the hazards.
• Each step should be assessed for accident potential. It is not necessary at
this stage to think about safety precautions but only to identify the hazards
relating to the job steps.
• Particular attention should be given to those steps where a person could
be struck by objects, exposed to gas, dust, heat or radiation, get caught in
or between anything and be subjected to strain / or over-exertion.

b) Potential Hazards

• To be effective, hazard identification should involve all workers in the

process of identifying, defining and assessing the hazard since they are
exposed to the environment they are working.
• The person involved in leading the Hazard Identification shall have a level
of technical competency relevant to the job to be analyzed.
• The composition of the team depends on the individual task being
analyzed.
• A front-line Supervisor for each skill shall be represented. For simpler
tasks, a small team led by the Work Leader of the activity may be sufficient.
• Tasks of greater complexity shall involve HSE Personnel, Operations and
an Engineering Superintendent(s).
• The team must identify and list all hazards associated with the work to be
carried out, together with those hazards present in the workplace that pose
a threat to the worker, the asset or the environment.
• Break down every hazard in every step of the work.

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• Do not list major Hazards such as “uncontrolled release of Ammonia or

VCM under pressure” or minor domestic Hazards such as “stairways,
housekeeping” etc. Remember the definition of Hazard – keep focused.
• The potential threats and escalation factors arising from the hazard will also
be determined. If the acceptable criteria are not met, recommendations on
control shall be made for improvement.

c) Control and Recovery Measures

• The defined hazards will be evaluated to establish the controls and

recovery measures for each hazard and by risk analysis to determine they
are adequate and meet the acceptable criteria.
• Together with the Supervisor list the existing controls that are in place to
effectively manage the Hazard(s).
• List the control and recovery measures i.e. fire/ gas detection, fire and
safety equipment, emergency/ crisis procedures, pre-plans and
contingency plans.
• The following is a list of fundamental controls required but not limited to: -

➢ Isolation
➢ Procedures (operational, maintenance or HSE procedures, regulations,
legislation etc.)
➢ Standard operating conditions.
➢ Competence
➢ Safeguarding systems
➢ Machinery and equipment guards
➢ Signage
➢ Physical barriers
➢ Routine periodical testing
➢ PPE and safety equipment
➢ SDS sheets
➢ Design
➢ Monitoring employees
➢ Substitution

6.17.3 Approval
a) The Work Leader shall then complete the “Prepared By” section of the JSA
and forward to the Immediate Supervisor in-charge who shall review and
complete the “Reviewed By” section of the JSA.
b) Having carried out the above the team can analyses the job by agreeing and
implementing: -
• Sequential steps critical to the job
• Identifying pre-cautions
• Alternative way of doing the job
• PPE requirements
• Developing procedures
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• List recommendations for improvements

6.17.4 The completed JSA(s) shall be attached to the PTW when applying to do the
work.
6.17.5 The PTW Approving Authority (OCS / SFE) shall review the JSA and if satisfied
shall complete the “Approved By” section in the JSA form.

6.17.6 Review and update JSA

a) JSA shall be reviewed if it fails to identify all significant hazards, the way in
which the task is done may differ from that identified in the original JSA.
b) To ensure that the experience and information gained by doing the job remains
available to others who may be required to perform the same or similar jobs,
the JSA team should, at the completion of each job, review and update the
original JSA.
c) When reviewing the JSA on completion of the job, the following should be
considered: -
• Changes to job circumstances
• Changes in the environment, specifications, or tools and equipment used
can cause job steps to be added, deleted or changed. Changes in job steps
can introduce new Hazards requiring new solutions.
• Unforeseen Hazards.
• Once a job has commenced additional unforeseen ‘Hazards may present
themselves so that solutions have to be developing on the job. These jobs
developed solutions need to be included on the revised JSA.
• External influences and interfaces.
• When doing a JSA it is often difficult to identify all of the possible external
factors that impact on the job and the interface with other jobs and people
in the immediate vicinity. Feedback of this type can be invaluable to people
planning similar jobs in the future.

6.17.7 On completion of the work file the JSA for future reference for similar work.

6.18 Communications of The Job Safety Instruction for The Job

6.18.1 Written procedures and systems must be communicated to the people performing
the tasks. The JSA will provide the necessary material for Hazard Communications
to work force at the toolbox talks on JSA briefing.
6.18.2 The Work Leader and/or Person In-Charge of the job shall carry out JSA briefing
to all workers involved on site prior to the commencement of the work activity.
6.18.3 HSE Lead / Engineer and Supervisor shall be present during the briefing and also
ensure that all requirements are understood.
6.18.4 All Personnel involved in the JSA briefing is required to record and sign their
attendance on the attendance form.
6.18.5 Field Engineer and Supervisor in-charge of the activity is required to supervise the
work until completion.

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6.18.6 HSE Lead / Engineer and Supervisor is required to be present and ensure
adherence to all safety requirements.

7.0 APPENDICES

7.1 Appendix 1 Hazard and Effects Register (HER) Template

7.2 Appendix 2 Critical Activity Catalogue (CAC) Template

7.3 Appendix 3 Remedial Action Plan (RAP) Template

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Appendix 1 Hazard and Effects Register (HER) Template

Risk Rating Critical Activity

Remedial Action
Ref. No Hazard Activity Threats Top Event Consequences RR Control & Doc Catalogue (CAC)
Plan (RAP) Ref. No.
Ref. No.

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Appendix 2 Critical Activity Catalogue (CAC) Template

CRITICAL ACTIVITY CATALOGUE (CAC)

Control & Recovery Barriers Critical Position
Ref. No Input Output

Barriers Critical Activities Performance Standard Position Competence

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Appendix 3 Remedial Action Plan (RAP) Template

REMEDIAL ACTION PLAN (RAP)

Priority
Reference Required Action Responsible Party Target Completion Date
H/M/L

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