Page 1 of 48

DOCUMENT NO.


BON-AME-3GN-G-00199-005







CONTRACT NO. :
L 00802
CONTRACT No:
P 0001



SNEPCO
BONGA FPSO TOPSIDES, COMMISSIONING
AND OPERATIONS HANDOVER



DOCUMENT TITLE :


HEALTH, SAFETY & ENVIRONMETAL PLAN



























A03 Revised NJ B Aug-01 RM Aug-01 DMH Aug-01
A02 Revised & Reissued BJ M Mar 01 NB Mar 01 DMH Mar 01
A01 Issue for Design NB Feb 00 BM Feb 00 DMH Feb 01
REV. ISSUE OR REVISION
DESCRIPTION
ORIG.
BY
DATE CHKD.
BY
DATE APPD.
AMEC
DATE APPD
Client
DATE


Page 2 of 48


REVISION CHANGE NOTICES

Rev. Location of Changes Brief Description of Change
Tender Version First Draft
A01 Throughout Updated with internal comment
A02 Throughout Re-worked to include SNEPCO &
BMT comments
A03 Throughout Yard HSE specific details deleted to
avoid duplication with local plans





Page 3 of 48

CONTENTS

AMEC HS&E VISION

INTRODUCTION

1 POLICY, STRATEGY AND GOALS

1.1 POLICY

1.2 STRATEGY

1.3 GOALS


2 PROCESSES AND PROCEDURES

2.1 Design Safety Processes

2.2 Construction/ Fabrication Processes & Procedures

2.3 Pre commissioning, Hook Up & Commissioning Processes & Procedures

2.4 Sub contractors Procedures


3 RESOURCES AND ORGANISATION

3.1 Project Management / HS&E Organisation

3.2 Communications and Interfaces

3.3 Training and Competency


4 IMPLEMENTATION, MONITORING AND REVIEW

4.1 Active Monitoring

4.2 Reactive Monitoring

4.3 Accidents/Incidents & Near Misses

4.4 Audit and Review

4.5 Site Safety Inspections

4.6 Management Review

4.7 Incentive Schemes



Page 4 of 48


5 DEMONSTRATE COMPLIANCE

5.1 Inspections

5.2 HS&E Audits


6 MANAGEMENT REVIEW

6.1 HS&E Actions


7 REFERENCES


8 DEFINITIONS




APPENDICES

1 Safety, Health and Environmental Policy

2 Review/Audit Program

3 Shell Shearwater Incentive Scheme

4 AMEC Policies in line with SNEPCO

5 Emergency Contact Details




Page 5 of 48





AMEC
HS&E VISION
FOR
BONGA


To be the safest and most environmentally responsible organisation in
the industry

through the achievement of:

Reduction in personal injuries


Minimising pollution to the environment


Continuous improvement in HS&E culture and behavioural
attitudes


Page 6 of 48

INTRODUCTION

Health, Safety and Environmental is an inherent aspect of our core business process and our day-
to-day activities. The AMEC health, safety and environmental management system is based on
the Health and Safety Executive publication Successful health and safety management HS(G)65,
which enables the development, implementation and monitoring of processes and procedures for
all our activities including engineering, design, construction and procurement, in line with
contractual requirements and AMEC/SNEPCO management systems. A key aim of the hazard
management process is to ensure that risks to personnel operating the Bonga FPSO are reduced
to levels that are as low as is reasonably practicable (ALARP) in the context of internationally
accepted standards.

This plan describes the management of HS&E within AMEC during the project. It illustrates the
AMEC commitment to the Health and Safety of all personnel involved in the design, engineering,
construction, commissioning and integration phases of the Bonga development.

All companies involved in the Bonga Development Project will interface their HSE responsibilities
through applicable bridging interface documents and procedures. This process will be recorded in
the SNEPCO Bonga HS&E Interfacing Document [Ref:1].

The chart below shows the HS&E Management System Interfacing Matrix:


AMEC
SNEPCO Bonga HS&E System Interfacing Matrix
Project Sub-Contractors / Vendors
SNEPCO Bonga
HS&E System
Interfacing Document
AMEC
HS&E
Management
System
Preliminary Objective to ensure:
Safe methods and systems of working and safe operations of
equipment at all worksites.
Arrangement in place to prevent injuries and eliminate
hazards, risk at the workplace & damage to equipment
Minimisation of environmental discharges, management of waste
Ensure smooth transition of the management of health, safety
and environmental concerns between all phases of the project.
Project Health, Safety &
Environmental Plans
Project HS&E Plans
Design / Procurement
Fabrication Topsides
Integration of Topsides /
Modules /Hull & Commissioning
Loadout / Transportation
Construction Activities
Offshore Nigeria
Post Start Up



AMEC acknowledges its responsibilities as a Contractor to comply with all relevant statutory
requirements pertaining to work completed by its employees and Sub-Contractors for all phases
of the project.



Throughout each phase of the Bonga development this HS&E Plan shall be considered as a
Live document and as such will be subject to continual review through each phase of the project.


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Any amendments to the plan will take into account any new HS&E initiatives and legislation that
may affect the work conducted on the project by AMEC or Sub-Contractor personnel. The plan is
organised in a hierarchical structure based on the policies, strategies and goals described in
section 1.0. The structure is headed by the policy and cascades down through the defined
management system strategy and goals and then into the more specific HS&E MS systems and
procedures.

The plan is designed to be flexible so that the HS&E requirements of the Bonga Project
Management and of sub-contractors can be interfaced successfully Fig 2. To this end the plan
together with the corporate AMEC HS&E Management System and the SNEPCO Bonga HS&E
Systems Interface Document [Ref: 1] shall be used as guidance for the development of specific
interface documentation covering the following phases of the project:

Design/Procurement
Fabrication Topsides
Integration of Topsides/Modules/Hull & Commissioning
Load-out/Transportation
Completion Activities Offshore (Nigeria)
Post Start Up

Others

Security Plan (Nigeria), [Ref: 6]
Community Affairs Plan (Nigeria)
Site Security (all locations)
IT Security


The Health, Safety and Environmental Plans shall be developed in line with the AMEC Safety
Management System Structure shown below.

AMEC
SAFETY MANAGEMENT SYSTEM STRUCTURE
Policy, Strategy and Goals
Processes and Procedures
Resources and Organisation
Implement, Monitor and Control
Demonstrate Compliance
Management Review
P
D
C
A Correct
Improve
Re-Define



Page 8 of 48


Fig: 2 Project Management & HS & E Document Interfaces


SNEPCO
Project
Management
SNEPCO
HSE Manual
SNHS-2000-0003
AMEC
Design &
Procurement
AMEC
Project
Management
AMEC
Corporate
HSE MS Policies
& Procedures
Bonga Project
HS&E Plan
BON AME-3GN-
G-00199-005
Heerema
HSE MS
PMP-H-01-001 &
PMP-77
Heerema
Hartlepool &
Zwijndrecht
Interface
Document
BON-AME-3GN-
G-00190-042
Amec
Construction
Wallsend
Wallsend
HSE Plan
AOS-PF-SM-001
& Procedures
Interface
Document
BON-AME-3GN-
G-00190-041
NETCO
Design
Nigeria
Construction
Site
NETCO
CASHES Policy
BON-AME-3AA-
X-09090-001
Interface
Document
BON-AME-3GN-
G-00190-043
Interface
Document
Hold
Nigeria
Contn HSE Plan
Hold
Offshore
HUC



Page 9 of 48


1.0 POLICY, STRATEGY AND GOALS

1.1 POLICY

AMEC Policy statements on Health and Safety and the Environment are the key polices
that shows the AMEC commitment to obtaining the highest practical achievable standards
of safety, occupational health and environmental protection, while conducting its business.
The corporate HS&E management system that clearly defines the activities and
responsibilities of all personnel support these management policies.

1.1.1 Health and Safety

AMEC will comply with all relevant applicable health and safety legislation. To this aim
AMEC has prepared Health and Safety Statements of Intent clearly stating the aims of the
company along with responsibilities of all employees.

A copy of the AMEC Health and Safety Policy Statement of Intent is attached within
Appendix 1.

1.1.2 Environment

A prime AMEC objective is to maintain a healthy and safe environment and to minimise
any impact on the environment. In order to achieve this, the AMEC environmental policy
and procedures ensure that we comply with current environmental standards.

Throughout the onshore pre-commissioning phase of the project, continuous monitoring
shall assess any environmental impact.

1.2 STRATEGY

The AMEC strategy, has been developed to achieve the highest possible health, safety
and environmental standards throughout each phase of the Bonga development is as
follows:

Project Management/Supervision will be assessed on a regular basis to ensure their
competence in HS&E Management. The HS&E Manager will conduct assessments
through the monitoring and review process.

This HS&E Plan will be fully disseminated to all personnel and implemented in its
entirety.

A message from the Project Manager to all new starters regarding the Projects HS&E
requirements and their responsibilities will form part of the induction process to
demonstrate his personal commitment and to request for the same commitment from
all Bonga Project employees.


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Responsibilities for HS&E will be clearly defined through to Area Engineers and
Supervision, they will be held accountable for all HS&E matters within their area of work
and authority. Project Sub-Contractors will also have to demonstrate HS&E
Management through their engineers and supervision.

The Company Disciplinary Procedure for breach of HS&E policies, procedures and
practices will be fully explained to all personnel and fairly administered by all levels of
Management and Supervision.

The Bonga Management Team ( BMT) will produce an annual Personal Safety
Contract. The HS&E Manager will audit the implementation of these Personal Safety
Contracts. All BMT Personnel Safety Contracts will be displayed.

All Project Personnel must acknowledge the HS&E Site Advisers position and authority
through actively supporting and acting upon their decisions.

AMEC/Sub-contractors/Supervision will be assessed on their performance and
approach to HS&E Management throughout the duration of the project. The Project
Manager, HSE Manager and site HSE Advisers will carry out this assessment. All
findings will be displayed on the project intranet site and notice boards.

All project management, including those of Sub-contractors must be seen to be visible
and play an active role in HS&E Management.

The HSE Manager will regularly brief the BMT on HS&E issues.

1.3 GOALS

Key health, safety and environmental goals have been set to give focus and direction to
our activities and improvement plans and the project performance standards.

The key goals are:

Minimise our impact on the environment.
Eliminate, reduce or control risks to levels that are demonstrably ALARP in the context
of an international project.
Fully comply with applicable standards and legislation.
Apply HS&E strategies that ensure compliance with SNEPCOs incident frequency
targets.

1.3.1 Project Health and Safety Performance Targets

AMEC endorse the SNEPCO visionary commitment to a zero target for health, safety and
environmental performance as identified within the SNEPCO Activity schedule.

The SNEPCO target that is in line with the overall target for Shell E&P worldwide are:

Year 2001 2002 2003

TROIF 5.0 5.0 5.0



Page 11 of 48

In addition, all violations to the following health targets shall be reported.

No violations of drug and alcohol policy
No cases of food poisoning.
No cases of exposure to asbestos without appropriate control procedures, precautions
and use of PPE.
No cases of smoking in non-designated areas.
No case of exposure to identified physical, chemical, biological, ergonomic and
psychological health hazards.
Reporting of non-accidental deaths, regardless of whether the likely cause was work
related or not.

AMEC shall report the Total Record-able Occupational Illness Frequency (TROIF) monthly
as:

TROIF = Total Reportable Occupational Illness x 1,000,000
Man-hours worked

Zero Fatalities and achievement of the following LTIF and TRCF rates:

Year 2001 2002 2003
LTIF 1.0 0.9 0.8
TRCF 2.6 2.3 2.0

1.3.2 Project Environmental Performance Targets

AMEC acknowledge SNEPCO environmental targets:

Zero controllable releases of hazardous substances i.e. if the release is controllable it
shall not happen
Zero uncontrollable releases of hazardous substances through adequate prevention,
control and emergency response arrangements
Minimise damage to plant, animal life and environment
Minimise negative long-term impact on the environment

All AMEC established Corporate Environmental Objectives should be targeted and
integrated with the Bonga project targets.




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1.3.3 Definitions

a) Total Reportable Occupational Illness (TROI)

An occupational illness is defined as a work related abnormal condition or disorder, other
than that resulting from a work injury caused by or mainly through exposure at work,
whether a case involves a work injury or occupational illness is determined by the nature
of the original event or exposure that caused the case not by the resulting condition. Work
injuries are caused by a single event in the working environment; cases resulting from
anything other than a single event are considered occupational illnesses are record-able.

b) Total Record-able Case incident shall be defined as:

Lost Time Incident (LTI)

The sum of fatalities and work related injuries that cause incapacity for more than three (3)
workdays beyond the day on which the incident occurred.

Incapacity Accidents

Work related injuries that cause incapacity for more then one (1) work day beyond the day
on which the incident occurred.

Medical Treatment Case (MTC)

A minor work related injury that requires hospital attendance/treatment and which result in
the injured person returning to work on the day of the accident or the first work day after
the day of the accident.

c) The Total Record-able Case Frequency Rate shall be calculated on the following
basis:

TRCF Rate = Incapacity Accidents + MTC x 1,000,000
Man-hours Worked
LTIF Rate = Lost Time Incidents >3days x 1,000,000
Man-hours worked

1.3.4 Project Objectives

Apply the AMEC experience in risk assessment and reliability engineering.
To produce a cost-effective design that minimises impact to the environment throughout
the project life cycle.
Promote Health, Safety & Environmental management as our prime company priority.
Consolidate and improve our health, safety & environmental performance.
Develop a culture of reporting without fear of blame.
Actively involve everyone in providing a safe and healthy environment.
Take ownership of our HS&E responsibilities.
Demonstrate to our customers the competence and commitment of our employees
To establish safe working practices that will meet, and better in some cases, the
acceptance criteria throughout the design, fabrication and installation.



Page 13 of 48

2 PROCESSES AND PROCEDURES

AMEC procedures for the Bonga Project define the management system for each phase
of the project.

AMEC procedures are managed and co-ordinated through the AMEC Quality Group. Full
details of these are given in the Project Quality Plan [Ref: 2].

2.1 Design Safety Processes

2.1.1 Organisation

The Bonga technical safety and environmental organisation for the detailed design phase
is set out below identifying personnel and contracted services. The engineers
responsible for studies will be drawn from the Principal and Senior engineering categories.


















Fire & Explosion ENVID Fire Protection
RAM EIA Fire & Gas
Evacuation, Escape ENV Awareness LSA
and Rescue Dispersion Analysis
Dropped Objects

Safety Studies Loss Prevention Environmental
HAZOP Chairman

Lead Safety Engineer
And
Environmental Engineer
HVAC



Page 14 of 48

AMEC will review the HAZID to identify all potential hazards to personnel and the
environment. Risks to personnel including the most exposed user group will be assessed
in accordance with the ALARP framework document [Ref:3].

2.1.2 Hazard Management Process

The Hazard Management Process is pivotal to an effective HS&E Management system.
AMEC will implement an extensive hazard identification process and consequence
evaluation in order to develop the appropriate control and mitigation features.

The management of hazards and risks process will include:

- Identification and assessment of hazards that are associated with significant risks to
Bonga
- Adopt an inherently safe approach by hazard elimination where feasible
- Classify risks when necessary
- Develop Control and Recovery measures to deliver an overall ALARP solution
- Apply best practice where appropriate
- Deliver robust solutions based on engineering judgment

The AMEC engineers awareness of hazards and aspects of operational risk ensures
that these effects are inherently minimized throughout the design and engineering
process.

AMEC will execute certain key hazard assessment activities under the appointment of
suitably qualified and competent subcontractors. The following activities shall be
performed on behalf of the project under a Bonga Subcontract:

HAZOP chairmanship
Availability and Reliability modeling

The activities of these Subcontractors shall be integrated into the project work.

Actions arising from the HAZID, HAZOP and ENVID and risk assessment process
will be recorded on the AMEC Safety and Environmental database for further
consideration and closeout.

2.1.3 Demonstration of ALARP

AMEC will contribute to the preparation of an HSE case (safety case) that demonstrates
that risks to personnel operating the FPSO are ALARP. This process is detailed in the
Guidelines for the Demonstration of ALARP [Ref: 3].
The demonstration of ALARP will include the following processes:

1. Identification of Hazards.
2. Assessment of Hazards.
3. Recommendations for measures to reduce risks.


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4. A Test of Significance will be carried out based on a comparison between the
specific risk and other risks identified by the HAZID
5. Implementation of measures if called for by Codes and Standards.
6. For measures not covered by existing Codes and Standards, a framework for risk
related support will be used to aid the decision making process.
7. Further consideration of measures using Good Practice/Engineering J udgment and
coarse quantification and cost benefit analysis if required.
8. Further consideration of the effect of Company Values (both SNEPCO and AMEC and
all other stakeholders) if required.
9. Further consideration of Societal Values if required.
10. Measurement of the process through performance standards.

2.1.4 Design Input

Contract Specifications shall be reviewed in accordance with the requirements of the
Quality Management System (QMS).

General Design Requirements

The designs shall be in compliance with relevant legislation.
The technical content of the design(s) shall be suitable for submission to the
Certification Authority
AMEC shall appoint a competent Classification Society.
The designs shall satisfy the SNEPCO environmental targets

2.1.5 Design Output

A formal process established in the Quality Management System (QMS) shall verify the
project design outputs.

2.1.6 Design Review

Peer group design review on all project scope of works shall be accomplished at specific
stages during the lifecycle of the Project by a number of methods including:

P & ID Reviews
HAZID/ENVID and HAZOP Reviews
Layout reviews
Hazardous Area Reviews

The reviews shall ensure that the design:

Complies with specific safety, environmental, availability, operability and maintainability
requirements and that operator health and welfare needs are addressed in the design
through either specification or ergonomic/human factors analysis.
Accounts for the major accident hazard consequences associated with un-ignited Gas
releases, Fires, Explosions, and Smoke dispersion.
Addresses Escape, Evacuation and Rescue control and recovery measures
Provides input into a Safety Case for Bonga
Demonstrates that the Bonga Topsides can be constructed, inspected, tested,
operated and maintained in accordance with accepted practices
Complies with weight and space requirements


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2.1.7 Design Certification

Design documents shall be subject to checks by independent competent persons in
accordance with relevant project procedures to ensure that:

a correct, clear and unambiguous interpretation of the Contract requirements,
the technical, format and presentation requirements,
they are adequately substantiated by calculation.

Design documentation shall also be subject to inter-discipline review, checked to ensure
that it incorporates applicable information and feedback from suppliers, sub-contractors,
the client and third parties such as regulatory bodies in accordance with the project
Quality Management System (QMS).

The output from computer calculations shall be verified as part of the audit process, spot
checks and verification of the computer program. Computer data shall be secured from
loss or damage by regular back up and protected from unauthorized access.

2.1.8 Design Validation

The Project shall utilize design validation to ensure that supplied product conforms to
agreed Contract requirements.

2.1.9 Design Change Control

Design change control procedures shall be in accordance with the requirements of the
AMEC Quality Management System (QMS).

2.1.10 Reliability, Maintainability and Operability

Reliability, maintainability and operability activities shall be performed using MAROS in
accordance with approved project procedures. In addition, formal assessments shall be
performed to demonstrate compliance with the specified reliability, maintainability and
operability targets.

2.2 Construction/Fabrication Processes & Procedures

At each construction site, site-specific safety processes and procedures will prevail. These
will adhere to project requirements/standards and will be subject to the review and audit
process.

2.2.1 Spill Response

Operatives will be made aware of the importance the Company attaches to minimising the
effect of its operations on the environment. Should spills of chemicals, hydrocarbons or
other potentially damaging materials occur or be observed by AMEC operatives or
contractors; the following actions must be taken.


Page 17 of 48

Attempt to contain spills to minimise potential pollution where practicable and without
endangering personnel.
Inform AMEC Bonga Project Management/Supervision/HS&E Management.
Where necessary, report the spill to the Emergency Services, local authorities,
Environmental Agency etc.

Once the incident is under control the Supervisor will complete an incident report, with the
assistance of the Bonga Project HS&E Adviser the report will be copied to the AMEC
Project HS&E Manager.

AMEC will ensure they fully comply with all relevant statutory and company requirements
relating to the environment. The Company also undertakes to comply with all legislation
regarding the disposal of waste materials.

2.2.2 Substances Hazardous to Health

Control of Substances Hazardous to Health (COSHH) Regulations 1999

All substances classified as hazardous to health that are transported, used or created
during work on the SNEPCO Bonga Project shall be controlled in such a way as to
minimise the risk to the health of employees, others and the environment in accordance
with COSHH or equivalent regulations.

COSHH related activities should be monitored to ensure all requirements of the
regulations are satisfied. AMEC will not accept any materials on site unless accompanied
with the supplier's/Manufacturers Material Safety Data Sheet (MSDS) documentation.

A register will be assembled incorporating all MSDS documents and this register shall be
readily accessible to all personnel required to transport, use or dispose of the hazardous
material.

The HS&E departments at each site shall hold all hazardous substance material safety
data sheets with a duplicate copy being held at the site Medical facility for use in an
emergency.

2.2.3 Ionising Radiation

Advice and information on radiography should be given as required under the Ionising
Radiation Regulations 1999 or equivalent.

Suitably qualified and competent personnel will carry out the work that for AMEC will be in
accordance with their Local Rules for Radiography. These will be subject to routine
HS&E audit and inspections.

In addition AMEC have also published and circulated contingency plans for dealing with
emergencies involving radioactive isotopes.

Notices will be displayed on project site notice boards and work areas giving details of
times and areas where radiography will be taking place.



Page 18 of 48

2.2.4 Noise/Nuisance

All UK sites shall comply with the Noise at Work Regulations 1989 and to limit potential
nuisance to neighbours as defined in the Environmental Protection Act 1990

Similar processes will be applied at other project site locations.

2.2.5 Permit To Work

Personnel involved in the administration and operation of permit to work systems will
receive training and information appropriate to their responsibilities and duties as set out in
the site applicable permit to work procedure.

Compliance with Permit to Work procedures will form part of the HS&E audit and
inspection programme.

2.2.6 Work Packs/J ob Safety Analysis/Risk Assessment

AMEC will ensure that J ob Safety Analysis/Risk Assessments will be carried out to identify
all the hazards and risks associated with work for the Bonga Project and that information is
communicated to the employees who are required to carry out the work.

2.2.7 Hygiene and Occupational Health

Each site location will be provided with First Aid and/or Medical facilities, or one that can
be accessed locally appropriate to the size of the operation, reflecting the risks and
promoting the general health and safety awareness of employees.

Where health hazards have been identified, appropriate information and training will be
given to the personnel involved in the specific or periodic medical will be confidentially
advised by a AMEC approved Doctor or Medical Advisor.

Information and Training

Where health hazards have been identified, appropriate information and training will be
given to the personnel involved in the specific work activity. Equipment, facilities and
information shall be provided as necessary so that work can be carried out safely and with
minimum risk to personnel.

First Aid

Each site shall have a suitable number of personnel trained in first aid.

Medical Evacuations

The decision to evacuate an injured person will rest with the qualified Medical Attendant.

Evacuation for medical reasons may be for one of the following.

Injury as a direct result of a accident

Ill Health or a recurrence of an illness not associated with an accident.

In all instances the Medical Attendant will advise the Bonga Site Project HS&E Adviser
and he, in turn, will advise Company Management, Bonga Project Manager and HSE
Manager.



Page 19 of 48

Welfare/Amenity Provision

Where appropriate, sufficient messing facilities will be provided to accommodate
personnel.

2.2.8 Emergency Response

All site locations will have an emergency response capability plan, which will be
maintained, exercised regularly and communicated to all personnel.

.
Emergency Exercises

Exercises and Drills will be held on a regular basis and will cover realistic emergency
scenarios, including all aspects of contingency planning and response procedures. Where
necessary external bodies will be advised in certain exercise functions. Key personnel will
be trained to a level of competence appropriate to their responsibility in an emergency
situation.

2.2.9 Safe Means of Access/Place of Work

All sites will ensure that a Safe Place of Work is provided where the facilities, work
methods and activities are managed and controlled to provide protection against injury or
ill health to personnel or damage to pant, equipment and the environment.

2.2.10 Fire Protection

Fire protection facilities will be provided at each site location as appropriate. In general
these will consist of a fire main, hydrants/hose-reels and extinguishers as necessary. All
office, welfare and storage areas have the appropriate certification where applicable. Fire
equipment will be inspected on a regular basis and maintained in good order.

Construction activities are catered for by the provision of sufficient numbers and types of
fire extinguishers at various locations throughout the working areas.


2.2.11 Waste Management

Waste management, including waste reduction, recycling and disposal is covered by
Waste Management procedures appropriate to each site location.


2.2.12. Electrical Safety

All portable electrical equipment and appliances shall be checked and certified as required
by the applicable Electricity at Work Regulations or equivalent




2.3 Pre/commissioning, Hook-Up Processes & Procedures

During the Pre/Commissioning phases of the project these activities will generally
conducted in accordance with AMEC written processes and procedures. Where possible
these same procedures will be carried over into the Offshore Hook-up phase so as to
retain continuity between on and offshore working. The SNEPCO offshore working
procedures will also be utilised where specific activities dictate their use.


Page 20 of 48


2.3.1 Training

Bonga specific HSE training needs are detailed in a separate document (Ref 7.)

2.4 Subcontractors Compliance

Where appropriate project sub-contractors will comply with the AMEC standard rules for
contractor management of HS&E. Proposed sub-contractors will be required to
demonstrate their competency and will be fully integrated into the project and subject to an
integrated HSE/Q audit during the HSE Plan compliance audit programme.


3 RESOURCES AND ORGANISATION

The foundations of health, safety and environmental control rely heavily on human factors
for their success. It is therefore necessary that systems, which operate to manage the
human element in the company, have HS&E considerations built into them. The following
five Human Resource elements are addressed by the Bonga management system:

1 Recruitment of competent personnel
2 Training of personnel
3 Medical fitness
4 Assessment of attitudes to Health, Safety & Environmental matters
5 Disciplinary measures associated with infringement of HS&E standards.

3.1 Project Management/HS&E Organisation

The BMT are directly responsible for the implementation of the HS&E Plan, its policies,
procedures and safety objectives.

The overall organisation for the Project shall be as per the organisation charts included
within the Project Execution Plan [Ref: 4].

AMEC Bonga Project Manager. Is responsible for endorsing the HS&E policies, by
making available sufficient resources to enable the Project to meet its safety objectives
and ensuring that all project staff are conversant with the requirements of the this Plan and
are aware of their individual HS&E responsibilities.

Project HS&E Manager. Is responsible for the implementation of the HS&E Plan and for
ensuring by review and audit, that all Project and Legislative requirements are complied
with and any actions resulting from audits are followed through and implemented. The
HS&E Manager is also accountable for ensuring the Plan is followed and that the
responsibilities and accountabilities specified therein are adhered to.

Construction & Integration Manager and Site Construction Manager. Are responsible
in assisting the Project and HS&E Managers in promoting HS&E in their sphere of
influence in providing a safe working environment for all personnel in the Bonga Project.
They are also required to assist in the implementation of the Bonga Project HS&E Plan
and in achieving its objectives.



Page 21 of 48

HS&E Design team. Are required to achieve an integrated safe and environmentally
sound design where risks are as low as reasonably practicable and for maintaining HS&E
practices as an integral part of project philosophy. The HS&E design team shall contribute
to the Bonga Safety Case.

Site HS&E Advisers. Are required to assist the HS&E Manager, Site Construction
Manager and Supervision in meeting the project HS&E objectives and implementation of
the project performance standards. They are also responsible for ensuring that all project
personnel are conversant with their obligations relating to HS&E in accordance with this
Plan and the requirements of the company and relevant legislation. The site HSE/Q
advisers shall prepare the site HSE/Q plans for implementation during the work phase

Environmental Specialist. Is required to provide a point of contact for environmental
matters and advise the Project and HS&E Manager on environmental management
implementation. He is also responsible for ensuring Company operations are in
compliance with AMEC, SNEPCO and statutory requirements.

Safety Representatives. AMEC actively encourages and supports safety
representatives and recognises the valuable contribution they can make as a direct link
between the workforce and management in HS&E matters. Safety representatives are
required to participate in site safety inspections and accident investigation teams as
required. They shall also be consulted on health and safety issues, such as the selection
of personal protective equipment and proposed changes to equipment or systems of
work.

Project Team. All members of the Project team will be responsible for the participation in
and the implementation of the Project HS&E philosophy. Ensuring that corporate and
project safety objectives are met and to report all accidents, incidents and unsafe acts or
conditions.

All Employees. Have a responsibility for HS&E matters while working on the Bonga
Project. AMEC requirements are clearly set out within the policy statements in the HS&E
Management System. Each employee has a duty to co-operate in ensuring that they
maintain a safe system and a safe place of work at all times.

3.2 Communications and Interfaces

Personnel are actively encouraged to be directly involved in the ongoing development and
maintenance of the management system. This involvement and participation is sustained
by line management commitment, effective communication and the co-operation of the
workforce. Formal arrangements in terms of meetings, forums and a communication
network have been developed in which personnel will participate in and contribute to as
much as possible.

3.2.1 Project HS&E Meetings

Project site HS&E tours will be held on a monthly basis and will include a review of the
project weekly reports, any previous minutes and the action points arising. The location for
this meeting shall be on a rotational basis with each yard acting as host.

In addition to the HSE manager the attendees will include but not necessarily be limited
to:-

Site Construction Manager
Site Construction HS&E Adviser
Environmental Adviser
Area Engineers


Page 22 of 48

Supervision
Workforce
Staff
Safety Representatives
Sub-contractors Site Management
Operations Department
Integration/Commissioning Representative
SNEPCO Site Representatives

3.2.2 Project HS&E Forums

Project HS&E Forums will be held at quarterly intervals where safety representatives are
invited together with Bonga Project Management, Supervision, and Directors, workforce
and SNEPCO personnel.

3.2.3 Toolbox Talks

Toolbox Talks/Safety Briefings are designed to allow two-way communications, and to
ensure that the work team fully understand the work to be undertaken, the hazards
involved, the procedures to be followed and the precautions to be taken.

3.2.4 Safety Meetings

Safety meetings are conducted within a structured framework, with line management
planning and co-ordinating the meeting, and encouraging group members participation,
in accordance with project procedures contained within the Quality Manual.

3.2.5 General Promotions

Safety Programmes in conjunction with various forums, meetings and communication
structures help provide the knowledge and awareness, which promote a strong HS&E
culture. To this end AMEC will promote the use of incentive schemes, periodicals,
posters bulletins, mail-shots and promotions as a constant reminder of the commitment
to HS&E issues.

3.3 Training & Competency


A training matrix shall be developed for all levels of employee to ensure that the minimum
levels of HS&E training is identified and personnel are trained and competent to do their
job.

3.3.1 Inductions

The project will ensure that all personnel (including staff, manual workforce, Sub-
contractors, vendors and pre-commissioning personnel) involved in any activities at a
Bonga office or site location attend a project induction prior to commencement of any
work.

A message from the Project Manager to all new starters regarding the Projects HS&E
requirements and their responsibilities will form part of the induction process to
demonstrate his personal commitment and to request for the same commitment from all
Bonga Project employees.

The HS&E Advisers shall conduct the inductions at each specific yard location. The
induction course may be tailored to suit the current status of the project. In general the
course will include but may not be limited to the following headings shown below:


Page 23 of 48


Welcome and Introduction
Corporate Information
Working at the location (office or fabrication site)
Security and Awareness
Policy, Law and Information
Manual Handling
Safety in Practice
Safety in an Emergency
Personal Protective Equipment
Injuries and Emergencies
Safety Systems
Environmental Care Systems Implementation

3.3.3 J ob Safety Analysis/Risk Assessment Training

The project will ensure that where applicable, personnel assigned to the project will
receive training in Risk Assessment/J ob Safety Analysis.

The training will provide the basic knowledge of hazard identification and the steps the
Bonga Project Management will take for risk reduction.

3.3.4 Competency

A developed and implemented procedure that ensures all personnel are suitably
qualified in terms of education, training and experience shall be applied on Bonga.

Office based staff shall be subject to annual appraisals in order that:

Performance is assessed against annual personal objectives.
New objectives are defined and agreed for the forthcoming year.
Any additional training requirements are identified.
Personnel can discuss their job expectations.

The competence and abilities of subcontractors employees is assessed as part of the
process of subcontractor evaluation.


4. IMPLEMENTATION, MONITORING AND REVIEW

The Plan-Do-Check-Act cycle is an integral mechanism in the implementation of
management system control. This forms the first level of continuous performance
improvement to our operating processes and is directly influenced by the personnel who
operate the process.

The effectiveness of the HS&E controls within the management system is evaluated by
the use of:

Active monitoring which measures compliance with standards and achievement of
objectives.
Reactive monitoring reports.


Page 24 of 48

Continuous improvement.
Preparation and implementation of performance standards

Measures used for both active and reactive monitoring are supported by formal
procedures that ensure that suitable corrective and as necessary preventative actions are
identified.

4.1 Active Monitoring

All site supervisors shall derive their own standards for active monitoring.

4.2 Reactive Monitoring

Reactive monitoring includes recognition, consideration and reporting of:

Injuries and case of ill health.
Other loss events e.g. property damage, fire.
Incidents including near misses with the potential to cause injury, ill health, damage,
loss or harm to the environment.
Hazards.
Weakness or omissions in the company arrangements.
Complaints

Formal procedures exist to ensure the systematic recording of accidents, incidents,
defects and hazards so that causes and potential loses may be analysed, corrective
actions identified and implemented. Investigation to determine underlying causes may also
highlight negative aspects of the operation of the Management System, however, these
are viewed as "earning opportunities" allowing improvements to be made and the direction
or resources and attention towards safety and environmental priorities thus strengthening
the Management System.

4.3 Accidents/Incidents & Near Misses

4.3.1 Accident/Incident Prevention

To prevent injury and damage it is necessary to recognise potential hazards and take
action to control or eliminate them. This involves systems of control, which will include safe
methods of work, adequate supervision, planned maintenance, machinery guarding,
personal protection and personnel HS&E awareness.

4.3.2 Accident/Incident Reporting & Investigation


The Bonga project shall adopt an accident and incident reporting and investigation for
system for all sites. Each site may opt to employ its own system however the project
system shall always apply. Refer SAD-92-005.

4.4 Audit and Review

The BONGA project shall develop a program of audits and reviews throughout the
lifecycle of the project [Ref: 5]. These shall include design and engineering activities.
The HUC Team shall implement a system of audit, to include both internal and external
audits of Sub-contractor (if deemed necessary).



Page 25 of 48

The audits will address those areas identified as critical within the work processes,
systems and operating procedures. They will be planned and programmed to reflect the
contract Key milestones/activities, Performance Measurements and Deliverables.

4.5 Site Safety Inspections

Site safety Inspections shall be carried out on a weekly basis (as a minimum).

4.6 Management Review

The HSE Management system shall be reviewed periodically to ensure that the system
reflects the objectives of the project the review shall consider the following:

Contract Strategy and Goals
Processes and Procedures
Resources and Organisation
Implementation, Monitoring and Control measures
Compliance

The above subjects shall be reviewed with regards to the effectiveness of control and
achievement of specific milestones against annual strategic targets.

4.7 Incentive Schemes

AMEC utilises various incentive scheme methods to promote safety and environmental
improvements. Bonga shall establish its own scheme and arrangements covering all site
and locations.

4.8 Performance Standards

A 10 element series of performance standards developed by AMEC shall be
implemented on the Bonga project.


Page 26 of 48

5 DEMONSTRATE COMPLIANCE


5.1 Inspections

Supervisors are responsible for carrying out daily inspections of the workplace where
Bonga fabrication activities are being undertaken.

These inspections will relate to the general tidiness and condition of the area, to ensure
that safe working practices are being maintained.

The Project HS&E Adviser will also carry out daily HS&E inspections to monitor
compliance with this Bonga Project Health, Safety & Environmental Plan, Company
Policies, legislation and good HS&E practises.

Weekly Safety Inspections

Site Management shall conduct weekly HS&E tours.

The inspection team shall be led by the Site Construction Manager and shall include
representation from the following:

Area Engineers
Area Supervision
HS&E Advisers/Manager
Environmental Adviser
Workforce Representative
Safety Representative
Sub-contractors
AMEC Services Limited
Integration/Commissioning Representative
SNEPCO.

An inspection report will be produced and forwarded to the applicable personnel
department for action.

Copies of the inspection report will be submitted to the inspection team and persons who
have been given a corrective action.

HSE site construction meetings

The BMT Construction and Integration manager and HSE manager shall convene a
monthly site construction HSE meeting involving other members of the BMT and all project
site location HSE representatives

Monthly BMT site safety tours

Each month the BMT shall perform a scored HSE tour of the construction sites and
offices.
5.2 HS&E Audits & Reviews



Page 27 of 48

HS&E audits and reviews will be conducted to an agreed audit schedule by a combined
audit team to evaluate compliance with the HS&E Management System and Bonga
Project Health, Safety & Environmental Plan.
The audit schedule will be combined where practicable with the Project QA audit and
review programme as shown on the Integrated QA/HSE Audit & Review Schedule [Ref: 5].
The overall HS&E audit programme will be agreed with AMEC Project Management and
SNEPCO Bonga teams.

The aim is to perform the audits as the relevant activities are being carried out in order to
maximise the benefit of the audit and have the opportunity to implement corrective actions
when the function is being carried out.









































6 MANAGEMENT REVIEW


Page 28 of 48


6.1 HS&E Actions

HS&E actions, identified and recorded as a result of Accident/Incident Report, HS&E
Management System/Project HS&E Plan Audit or a HS&E inspections will be constantly
monitored to ensure they are completed.

A realistic target date will be set to complete actions and the person nominated to
complete the action will report back to the Project HS&E Adviser. A copy of the report will
be maintained in the Central Health, Safety & Environmental Department.

AMEC, through continuous analysis of site inspections, audits and accident/incident
reports will identify trends for which corrective action can be established and implemented
in order to prevent future accidents/incidents.

The AMEC reporting procedure will provide the basis for monitoring HS&E performance
and the assessment of improvement measures. Every effort will be made to encourage
the reporting of near miss incidents and property damage as a significant contributing
factor to a pro-active HS&E program.

Apart from the review and action raising processes by the site management teams the
overall BMT will actively monitor HS&E performance.

7.0 REFERENCES

1. SNEPCO Bonga Interface Document Hold

2. Project Quality Plan BON-AME-003-G-0001

3. Guidelines for the Demonstration of ALARP BON-AME-3GN-X-00190-001

4. Project Execution Plan BON-AME-3GN-G-00199-001

5. Integrated QA/HSE Audit Schedule BON-AME-399-Q-PRC002

6. Security Plan (NIGERIA) BON-AME-3GN-G-00199-006

7. Bonga HSE Training Plan BON-AME-XXX-X-XXXXX-XXX



Page 29 of 48


8.0 DEFINITIONS

ALARP As Low As Reasonably Practicable

TROIF Total Record-able Occupational Illness Frequency

TROI Total Record-able Occupational Illness

LTI Lost Time Incident

MTC Medical treatment Case

HAZOP Hazard Operability Study

HAZID Hazard Identification Study

ENVID Environmental Identification Study

OIM Operations Installation Manager

HUC Hook-up &Commissioning

LSA Life Saving Appliances

JMS J ob-card Management System

QRA Quantitative Risk Assessment

CFD Computer Fluid Dynamics

QMS Quality Management System

MAROS Maintainability, Availability, Reliability, Operability Simulations

MSDS Manufacturers Safety Data Sheet

PTW Permit to Work

PPE Personal Protective Equipment


APPENDICES

1. AMEC Policies in line with SNEPCO


Page 30 of 48


APPENDIX 1

AMEC POLICIES IN LINE WITH SNEPCO







Page 31 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

SNEPCO HSE STATEMENT

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
Give the highest priority to the Health &
Safety of Employees, Contractors and
Member of the Public.




Ref. APEL Health & Safety Policy
attached to HSE Questionnaire.
Continually assess Environment Impact and
reduce it to a level as low as practicable.



Ref. APEL Environmental Policy.
Integrate Risk Management in the business
plan.



Ref. APEL HS&E Policies
HSE Management System
Have Staff and Contractors maintain an
open dialogue with Stakeholders.



Dialogue is maintained but not in
policies.
Work in partnership with Communities on
Community Development projects.



Actioned but not explicit in policies.
Participate openly in regulatory
development.



Actioned but not explicit in policies.
Make Supervisors responsible for
compliance with relevant HSE standards.



Ref. HS&E Policies attached to HSE
Questionnaire.
Have employees and Contractors
competently trained to perform their job in
line with this policy.



Ref. APEL HS&E Policies attached to
HSE Questionnaire
HSE Management System
Ensure that progress toward the
implementation of this policy is measured
against plans.



Ref. APEL HS&E Policies.
Implementation is assessed on a regular
basis through inspections and audit.





Page 32 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES
HEALTH, SAFETY & ENVIRONMENT COMMITMENT

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
Pursue the goal of no harm to people.

Ref. HS&E Policy
APEL HS&E Objectives 1999
Protect the environment.

Ref. HS&E Policy
APEL HS&E Objectives 1999
Use materials and energy efficiently to
provide products and services.



Ref. Environmental Policy
APEL Environmental Objectives 1999
Develop energy resources, products and
services consistent with HSE aims.




Consult with our stakeholders and publicly
report on performance.



APEL do consult with stakeholders.
Currently we do not report outside the
AMEC Group.
Play a leading role in promoting best practice
in the industry frontiers.



Through the Offshore Contractor
Association
Step Change in Safety
Manage Health, Safety and Environment
matters as any other critical business activity.


Ref. HS&E Policies.
Promote a culture in which all SNEPCO
employees, contractors and partners share
this commitment.



AMEC Promote the AMEC HS&E
culture with clients, subcontractors and
Partners. APEL openly and fully
support the Shell HSE Commitment
through the course of the project.

HEALTH, SAFETY AND ENVIRONMENT POLICY
YES NO N/A COMMENTS
Has a systematic approach to Health, Safety
and Environmental management designed to
ensure compliance with the relevant National
laws and Shall Group standards and to
achieve continuous performance
improvement.



Ref. HS&E Policies and
HS&E Management System.
Sets targets for improvement and monitors,
appraises and reports HSE performance.



Ref. HS&E Policies and
APEL HS&E Objectives.
Requires contractors to manage Health,
Safety and the Environment in line with this
policy.



AMEC require all subcontractors to
comply with its HS&E policies and its
standard rule for subcontractors.
Requires partners not under its operational
control to apply this policy and uses its
influence to promote it in its other ventures.


When AMEC work on joint ventures
and on alliancing projects we would
always seek to influence and promote
the improvement in HS&E
performance. This has been successfully
done on the Shell Shearwater project.


Page 33 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

COMMUNITY DEVELOPMENT POLICY

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
Establish a community development
programme which applies world standards of
practice to serve its communities.



AMEC understand the need for smooth
harmonious relationships with the
various host communities during the
various stages of the Bonga project. It is
the intention of AMEC to adapt and
implement policies to ensure that
AMEC is valued as a business partner
and neighbour of choice to our host
communities and other stakeholders in
the projects in which we participate.
Work in partnership with host communities
and where appropriate with government,
donors, non-governmental organisations,
community-based groups and other
stakeholders.



AMEC intend to deal with the
communities as partners in our
relationships with them, and will treat
their internal matters with due
sensitivity. AMEC will, within the limits
of available resources assist in
community development.
Encourage the full participation of host
communities in project planning,
implementation and monitoring.



AMEC will seek to ensure that
recruitment and sub-contract awards
will take due cognisance of the need to
adequately embrace the core catchment
areas where its operations are based or
carried out. By adhering to the
principles / policies included above we
aim achieve the desired harmonious
relationships without sacrificing
standards or quality required for the
safe, efficient and effective
implementation of the project.
Maintain communication with all social
segments of host communities in order to
address their needs.



AMEC will promote and sustain trust
and favourable reputation with the host
communities, the media and other
stakeholders, through constant
communication, education and support
of suitable activities.
Focus community development assistance on
activities having high impact and broad
benefits for the host population.



We will base the extent of assistance to
communities on need, proximity to
AMECs operations and communities
contribution to harmonious co-
existence
Pay special attention to the most
economically disadvantaged social groups.


AMEC will within its limits of available
resources help in this area.



Page 34 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

COMMUNITY RELATIONS POLICY

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
Establish and maintain close relationships
with all segments of the local population to
better understand their concerns, needs and
aspirations.



AMEC will co-ordinate all external
relations efforts through a highly
competent External Affairs unit and a
committed management. We will strive
for mutual understanding, using
efficient, but transparent and ethical
processes.
Continuously assess and abate the social and
economic impact of all business activities and
take needed preventive or mitigating
measures.



AMEC will continuously assess/review
that social/economic impact of its
business activities and take preventative
or mitigated measures as required.
Respond to formal community requests in an
appropriate and timely manner.



AMEC are committed to maintaining
open communications internally and
externally to guard against
misconceptions, while ensuring
confidentiality of project proprietary
information.
Bring relevant issues affecting host
communities to the attention of appropriate
authorities and other bodies that can be of
assistance.



AMEC will assist within its limits to
bring issues affecting host communities
to the attention of appropriate
authorities/bodies that can be of
assistance.
Manage the settlement of compensation for
land acquired for company operations and for
damages in a demonstrably fair, accountable
and transparent manner and in accordance
with statutory provisions and approved
procedures.



If there was any requirement AMEC
would comply with its legal obligation,
but would discuss the matter fully with
SNEPCO.



Page 35 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

SECURITY POLICY

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
If sufficient physical threats exist against our
people and property we would expect the
forces of law and order of the State to give us
appropriate protection. The right to use force
rests with the state. In pursuance of the
mission and objectives of the security
management system, line management will
draw on the services of SNEPCOs security
department and, through the latter, the
support of the SPDC Supernumerary Policy
Unit, the Nigerian Police Force and other
Nigerian Security Organisations as required,
subject to (ii) and (iii) below.



AMEC will develop a security plan to
ensure a secure environment and
physical security of Personnel, work-
sites, equipment and material of AMEC,
Clients and Sub-contractors. AMEC
agree with SNEPCO Policy. Discussion
on the matter would be essential.
SNEPCO will not operate in an environment
where the continuous deployment of military
or para-military forces is required to comply
with the above policy, except where
deployment is at the instance of Government
for protection of key national facilities.



AMEC agree with SNEPCO Policy.
Where the lives of personnel are at risk,
SNEPCO recognises that the deployment of
military or para-military forces by the
government, in support of the police and civil
authorities, may be necessary for as long as is
required to restore law and order, if
protection cannot be achieved by other
means.



AMEC agree with SNEPCO Policy.
Discussion on the matter would be
essential.
This policy will be pursued in compliance
with SNEPCOs Guidelines on Use of External
Security agents, insofar as SNEPCO is able to
exercise control.



AMEC agree with SNEPCO Policy.
Discussion on the matter would be
essential.



Page 36 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

HSE MANAGEMENT POLICY


HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
Set targets for improvement and monitor,
appraise and report performance against
those targets.



AMEC have an HS&E Leadership Team
consisting of Director/Senior Managers
and HSE Professional who monitor and
review HS&E Performance and
compliance to objectives set.
Leadership and Board Report also
document performance.
Make an assessment of the major hazards and
effects to the environment and to the health
and safety of people on all activities,
materials, products and services to ensure
that risks are tolerable and as low as
practicable.



AMEC will assess all aspects of health,
safety and environmental hazards and
effects to ensure the health and safety of
people and the environment.
Implement and maintain an HSE
Management System, develop and maintain
HSE Cases for HSE critical activities and
assets that demonstrate HSE risk
management application and improvement
measures.



AMEC review and maintain its HS&E
Management System regularly. HS&E
cases are prepared when the project
demands.
Conduct Environmental Impact Assessments
for all key activities and include the relevant
recommendations in project execution plan
for implementation.



AMEC conduct environment impact
assessments for all projects where it is
required.
Comply with relevant legislation, identify
areas of non-compliance and remedy as
necessary.



Ref. HS&E Policy. AMEC also maintain
a register of HS&E legislation and
assess to identify areas of non-
compliance.
Investigate and report all HSE incidents and
near misses.



All accidents/incidents and near misses
reported. The level of investigation is
determined by actual or potential loss
or harm.
Provide the resources necessary to manage
HSE risks.



Full resource are provided within
AMEC to manage HS&E risk.



Page 37 of 48

HSE MANAGEMENT POLICY

YES NO N/A COMMENTS
Develop and maintain an HSE awareness and
competence programmes for employees and
contractors. Develop an awareness
programme for third parties that may be
impacted by her activities.



Ref. HS&E Policies and its HS&E
Management System addresses
competency of its employees. A training
matrix has been produced and where
necessary a project HS&E programme
of training for AMEC personnel and
third parties.
Have an audit programme in place to review
and verify effectiveness of the management
system.



Ref. HS&E Policies, HS&E Management
System document and project HS&E
Plans identify audit review will take
place.
Externally verify the SNEPCO HSE
Management System to Group &
international standards.


N/A
AMECs HS&E Strategy document
commits to external scrutiny of
companies HS&E Management System,
e.g. ISO 18001 assessment.
Require partners, contractors, and suppliers
to align with this policy.


N/A
AMEC will always seek to influence and
improve the HS&E performance of all
we work with.




Page 38 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

EMERGENCY RESPONSE POLICY

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
That response to any emergency will be
directed towards:
- Saving life
- Caring for the injured
- Protecting the environment
- Limiting damage to assets



AMEC do not have a written policy for
Emergency Response. However specific
arrangements are set out in:
Company Standard Health, Safety
& Environmental Procedure;
AMEC-SP-GSP-010, International
Emergency Response, which
addresses emergencies occurring
overseas. This requires that all
overseas locations implement an
emergency response procedures
that addresses local arrangements
Local procedures at each UK
location addressing the
arrangements for local
emergencies.
Close liaison shall be maintained with
appropriate government and industry
organisations and with host communities
during emergencies.



Addressed in company and local
emergency response procedures
Regular exercises shall be carried out to
confirm effectiveness of response and
identified improvements made promptly.



Addressed in company and local
emergency response procedures



Page 39 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

HEALTH POLICIES

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
DRUG AND ALCOHOL POLICY
STATEMENT

The abuse of drugs and alcohol can be
injurious to people and impair performance at
work. SNEPCO shall ensure that all
employees recognise this fact and aim to
minimise associated risks.

AMEC Group AMEC Approach and
Procedures relating to Substance Abuse
Policies GSD/DRUG/REV 0-2/99,
(sect. 3.0 Framework Substance Abuse
Policy).
Copy of AMEC Approach Procedure
attached.
SNEPCO recognises alcohol or drug
dependence as a treatable condition.

GSD/DRUG/REV 0-2/99, (sect. 3.7
Advice and Assistance).
Employees who have an alcohol or drug
dependence are encouraged to seek medical
advice, and to follow treatment.

GSD/DRUG/REV 0-2/99, (sect. 3.7
Advice and Assistance).
SNEPCO will assist any employee to obtain
treatment.

GSD/DRUG/REV 0-2/99, (sect. 3.7
Advice and Assistance).
Any employee who seeks such help will not
jeopardise his employment, however,
alternative work may be considered.

GSD/DRUG/REV 0-2/99, (sect. 2.2,
3.7).
For any employee to be at work whilst
impaired by drugs or alcohol.

GSD/DRUG/REV 0-2/99, (sect 3.6
appropriate to testing, sect. 3.7
appropriate to personnel requesting
help.
For any employee to possess, uses, distribute
or sell alcohol or illegal drugs on company
business or work locations.

GSD/DRUG/REV 0-2/99, (sect. 3.4,
3.5).

Take disciplinary action against any employee
who, due to illegal drug or alcohol use is
unable to work, except where such employee
is undergoing medical help.

GSD/DRUG/REV 0-2/99, (sect. 3.4,
3.6, 3.7).



Page 40 of 48

HEALTH POLICIES

YES NO N/A COMMENTS
Test for abuse of drug and alcohol
prior to accepting individuals for
employment and at any other such
time that there is reasonable cause for
suspicion with the employees
consent.

GSD/DRUG/REV 0-2/99, (sect. 3.6
pre-employment screening,
unannounced and testing on suspicion.
Conduct impromptu searches for drugs and
alcohol at work locations.

GSD/DRUG/REV 0-2/99, (sect 3.4,
pre-mobilisation search).
Conduct impromptu and periodic or random
testing on employees.

GSD/DRUG/REV 0-2/99, (sect 3.6,
unannounced and random testing).
If, on a first time basis, a test result is positive
the employee will be allowed to continued in
employment, provided there is compliance
with the appropriate rehabilitation
procedures. If thereafter a test result is
positive, disciplinary action will be at
SNEPCO discretion.

GSD/DRUG/REV 0-2/99, (sect.3.6,
3.7)
All SNEPCO contractors and subcontractors
are required to comply with this policy.

All AMEC locations have a substance
abuse policy.
In pursuing this policy, the company will
continue to respect the rights of individuals,
and will minimise intrusion into the private
lives of its employees.

AMEC agree.
In the case of any illness, normal company
benefits will be available.
GSD/DRUG/REV 0-2/99, (sect. 3.7)
SMOKING POLICY
Smoking, being recognised as injurious to
health, is actively discouraged.

AMEC have a Company Policy on
smoking in the workplace.
The smoking of cigarettes, cigars or pipes is
prohibited in all SNEPCO hydrocarbon-
processing facilities, and other designated
non-smoking areas, which includes offices
and shared areas.

AMEC will comply fully with SNEPCO
Smoking Policy.
CATERING HEALTH
POLICY

All catering premises and activities over
which SNEPCO has prevailing influence,
should present no risk of illness to people.

AMEC agree with SNEPCO Policy.


Page 41 of 48

HEALTH POLICIES

YES NO N/A COMMENTS
All food be protected from the risk of
contamination of any kind.

AMEC agree with SNEPCO Policy.
All catering staff be certified medically fit
before employment, and periodically
thereafter, and obtain a certificate of health
and fitness.

AMEC will comply fully with SNEPCO
Policy.
OCCUPATIONAL
HEALT
H
POLICY

To identify and make inventory of potential,
physical, chemical, biological, ergonomic and
psychological health hazards that may be
associated with work and the effects of the
working environment on employees.

AMEC Health and Safety Policy
General Statement of Intent, Jan 16,
1998, endorsed by Roddy Grant,
Managing Director.
Evaluate the risk to health associated with
exposures to these hazards and take action to
remove or adequately reduce them.

Health and Safety Policy, (above).
AMEC Group AMEC Approach and
Procedures relating to Management of
Health and Safety at Work Regs. 1992
GSD/MHS/REV 1-12/97, (sect. 3.0,
Risk Assessment).
ASBESTOS POLICY
It is SNEPCO policy not to use asbestos. Use
of Asbestos cement products is acceptable
provided precautions are taken to eliminate
any exposure of people to asbestos dust
generated during a dust producing operation.
Asbestos waste is extremely hazardous to
health and shall be disposed in strict
accordance with SNEPCO asbestos disposal
procedures.

AMEC will comply fully with SNECCO
procedural requirements with regard to
asbestos.
AMEC also prohibit the procurement of
asbestos products. Where asbestos is
encountered in existing facilities AMEC
have procedures for dealing with this.
MEDICAL EMERGENCY
POLICY

Maintain Medical Emergency Response Plans
with the objective of minimising the
consequences of acute illness or injury
occurring at the work place.

AMEC have an International
Emergency Response procedure which
deals with acute situations and illness.
Local UK arrangements are also in
place.
Maintain readiness to rapidly respond at all
times.

As above.
Carry out regular exercises to confirm and
assure effectiveness and identify
improvement.

Yearly exercises are carried out to
ensure effectiveness and identify
improvements.



Page 42 of 48

SHELL NIGERIA EXPLORATION AND PRODUCTION COMPANY
LIMITED (SNEPCO) HSE POLICIES

ENVIRONMENTAL POLICIES

HSE Policy and Objectives

In this Section the Tenderer is required to include its policies on Health, Safety and
Environmental Preservation. In addition, the Tenderer shall document where its Company
Policies are in line and where they deviate from SNEPCO policies included in Part 4 Proposed
Contract, Section VIII Drawings and Documents. Special, attention is brought to SNEPCOs
Third Tier (Worksite level) HSE Policies.

YES NO N/A COMMENTS
ENVIRONMENTAL ASSESSMENT
POLICY

Identify any such interface between activities
and environment for the complete lifecycle of
facilities and operations.



Each phase of activity shall undergo an
assessment to determine all the
environmental impacts associated with
it. A significance evaluation is then
carried out to determine those with the
highest impact. Refer to APEL-EMP-01.

Enhance positive effects and prevent
intolerable impacts from occurring.



Significant impacts are included within
a Management Programme, ensuring
that targets are set for continuous
improvement.

Limit the nature and extent of any residual
negative impacts, however caused, such that
they are as low as practicable.




Impacts of medium and low
significance are monitored as part of a
programme to ensure that their impact
does not increase.
Consult relevant stakeholders.

All relevant stakeholders are consulted.

Leave the environment at the end of the
useful life of any operation in a condition
suitable for future use.



The operational controls in place as part
of APELs Environmental Management
System ensure that environmental
impact is minimised.

Routinely monitor the environmental status
of each operation and take corrective action
as necessary.


Monitoring of each operation is carried
out on a routine basis, with corrective
action being taken where necessary.

MATERIALS & ENERGY
POLICY

Use for its field location roads, facilities,
borrow pits, etc the minimum surface area of
land necessary for efficiency and safety.



Refer to APEL Environmental Policy.



Page 43 of 48

ENVIRONMENTAL POLICIES

YES NO N/A COMMENTS
Use the minimum of material and resources
such as sand, laterite, fresh water and timber
in order to achieve its business objectives.



Refer to APEL Environmental Policy -
waste minimisation and efficient
resource use are key to AMEC
continuous improvement.
Avoid competition that may arise with other
users of natural resources.



Refer to APEL Environmental Policy
Include fuel and energy efficiency as
specifications and considerations in the
procurement and operation of equipment.



Energy efficiency is a consideration in
procurement decisions. Site based
equipment is subject to a Planned
Preventive Maintenance Schedule to
ensure efficient working. Employees are
encouraged to operate equipment
efficiently through awareness
programmes.

Be committed to development and application
of renewables for its own energy
consumption.







Return any used assets to its original owners
in a condition that is as near as reasonably
possible to its original condition.



All assets shall be treated with respect
and care and will not be maliciously
damaged.

Ensure that disposed items shall wherever
technically feasible and economically viable;
be maintained in a condition such that they
can be re-used by other interested parties.




Whenever practicable, equipment is
retained and refurbished for further
use, for example computer equipment.
PRODUCED WATER
POLICY

Dispose of produced water in an
environmentally acceptable manner.



All emissions to water are with the prior
knowledge and consent of the
Environment Agency.

Prevent the disposal of produced water into
inshore waters.



Adequate control measures are
implemented to prevent this
occurrence.

Reduce level of oil in water to the prevailing
regulatory requirement as a minimum
standard.



In accordance with the APEL
Environmental policy, oil levels are
reduced to a practicable
minimum and are in full compliance
with legislative requirements.

WASTE MANAGEMENT
POLICY

Take all practical and reasonable measures to
minimise the generation of solid and liquid
waste, as well as emissions to air from flares
or otherwise.




AMEC strives to reduce emissions and
wastes wherever possible, All aspects of
waste minimisation are included within
our objectives and targets in order to
achieve continuous improvement. Refer
to APEL-EMP-04.




Page 44 of 48

ENVIRONMENTAL POLICIES

YES NO N/A COMMENTS
Not dispose to sea Oil-based Mud during
drilling, but will return such wastes to shore
for proper recycling or disposal.







Manage and dispose all wastes in line with
relevant regulatory requirements and
environmentally responsible manner.



All AMEC produced waste is handled,
segregated and stored in an appropriate
manner. The waste is disposed of in
accordance with our Duty of Care, using
licensed waste management companies
and disposal sites.

Track and maintain records of the full life
cycle of waste streams and provide an
auditable trail as to its management and
disposal.



A clear auditable trail can be shown
from Duty of Care licenses through to
waste transfer and consignment notes.
Audits are also carried out upon the
Waste Disposal Companies.

POLICY ON THE USE OF CHEMICALS
Use chemicals only where operationally
necessary.

Refer to APEL Environmental Policy.
Consider HSE aspects of all chemicals
together with their commercial and process
performance attributes and consideration of
safer alternatives, before selecting and
deploying them for use.




Chemicals are only used where
necessary and where practicable,
alternatives with less environmental
impact are used.
Store, transport, and dispose of all chemicals
in accordance with statutory requirements.



All chemicals are stored, transported
and disposed of in accordance with
statutory requirements. Refer to APEL-
SP-016.

Eliminate Halons and CFCs from operations
and prevent losses from existing stocks.



Halons and CFCs shall, where used, be
phased out in accordance with the
regulations governing substances that
deplete the ozone layer.

Not accept any new chemicals from a supplier
without the appropriate Material HSE Data
Sheet (MDS).



MSDS are required for all chemicals in
use. The MSDS are retained and
updated when necessary. Refer to
APEL-SP-016.

Provide Safe Handling of Chemicals (SHOC)
cards for all chemicals used in the company.





Details of any chemicals used would be
included within the job risk assessment,
and would highlight any precautionary
measures.




Page 45 of 48

ENVIRONMENTAL POLICIES

YES NO N/A COMMENTS
Specifically train all chemical handlers and
emergency response staff in the safe handling
of chemicals.



All necessary training is provided to
ensure the safe and correct handling of
chemicals.

GAS FLARING POLICY
Ensure that all projects and activities avoid
routine flaring as a means to dispose
associated gas and similarly, require
operators to do the same in other acreage
with SNEPCO interest.




Routine flaring of associated gas is
avoided. For example, the Shearwater
Environmental Discharge Objective for
flaring is to restrict flare gas emissions
to 0.3% boe.

Keep flaring to a minimum during production
tests, commissioning, start-ups and
operational upsets.



Flaring in these situations is minimised,
as on the Shearwater project where
onshore commissioning was maximised
using LNG as the fuel gas, the use of
Bacton pipeline gas and recycle mode
for offshore start-up, and the control of
WOBBE onshore by nitrogen injection,
allowing off spec gas to be potentially
exported and the WOBBE to be
corrected onshore rather than having to
by flare it offshore.

POLICY ON USE OF HALON FIRE
EXTINGUISHING SYSTEMS

SNEPCO is aware of potential impact of its
activities on the environment and the people
living in its area of operations.



AMEC are also aware of potential
impact of its activities on the
environment and people. APELs HS&E
Policies, HS&E Management System
and procedures are in place to protect
both the environment and people.
The use of portable and fixed Halon fire
extinguishers systems remain prohibited in
SNEPCO operations as a result of its ozone
depletion potential.



AMEC do not use halon fire
extinguisher systems due to their
damaging effect on the ozone layer.
This policy shall be applicable to all SNEPCO
locations and our contractors shall comply
with it. It is the responsibility of every
contract supervisor therefore, to ensure that
no Contractor deploys any Halon based fire
extinguishing or suppressing medium.






Refer to comment above.
POLICY ON SPILLS
Clean up all hydrocarbon and chemical spills
emanating from the Companys operations in
a timely and efficient manner.



Any spillage that may occur is
responded to rapidly to ensure minimal
environmental impact. The response is
effective due to defined procedure and
adequate training. Refer to APEL-EMP-
06 for typical example.




Page 46 of 48

ENVIRONMENTAL POLICIES

YES NO N/A COMMENTS
Draw up contingency plans and provide
resources for prevention and timely response
to spills.



Spill response kits are made available
throughout each area of operation as
appropriate, in order to bring about a
timely response. However, the
occurrence of spills is minimised by
control measures and procedural
control.

Effect clean up where the cause of the spill or
the party responsible is unknown and in
situations where SNEPCO is not liable, but
public opinion may tarnish the companys
image.




Wherever possible, AMEC shall always
assist in situations where there is
potential for environmental harm, and
when necessary, would liase with the
appropriate organisations to effect a
clean up response.






Page 47 of 48







APPENDIX 5

EMERGENCY CONTACT DETAILS





Company Telephone Fax Mobile Email
Robbie Blight AMEC 00 234 053 253085 00 234 053 253085 rblight@skannet.com Warri
Tunde Ogunbiyi DEXTRON 00 234 1 615254 00 234 1 610299 002341 4708654 Lagos
Denis Railton SPIE 00 234 1(2)616798 00 234 1 261 6618 Lagos
Philip Thomas British Embassy 00 234 1 262 5930
to 37
00 234 1 262 5940 Philip.Thomas@abujx.
mail.fco.gov.uk
or
consular@lagos.mail.fco.go
v.uk

Dr Alibe NETCO 00 234 1 (2) 611 232 00 234 1 (2) 611 230 alibe@netco.com.ng Lagos











Page 48 of 48






2001 Schedule


2002 Schedule
BMT
Representative
W/c 15
th

September
W/c 15
th

October
W/c 15
th

November
W/c 15
th

December
W/c15
th

J anuary
W/c15th
February
W/c 15
th

March
W/c 15
th

April
W/c 15
th
May

Brian Dixon


(Hartlepool)

Zwijndrecht


(Zwijndrecht)


(Wallsend
211,Old St.)


Colin Schofield


(Zwijndrecht
211,Old St.)

(Hartlepool)
(Wallsend) 5.

Hartlepool
5



Zwijndrecht

Bob Austin




(Hartlepool
211,Old St.)

(Wallsend)


(Zwijndrecht)

Wallsend


Derek Harwood


Wallsend
6.




Zwijndrecht 5.
211,Old St.)

(Hartlepool)


Hartlepool


Stephen Hope


(Hartlepool 5.
211,Old St.)

(Wallsend)

(Zwijndrecht)

Hartlepool


Bob Hamilton


(Hartlepool)

(Zwijndrecht)



Wallsend
(Wallsend
211,Old St.)


Eric Abbott

(Zwijndrecht
211,Old St.)

(Wallsend)

(Hartlepool)

Zwijndrecht


1. Fabrication starts in Hartlepool 4.9.01
2. Fabrication starts in Wallsend & Zwijndrecht on the 1.10.01
3. Sites in BOLD type are the monthly HSE construction site meetings attended by the nominated BMT representative and Ron Malone/Nick Beesley for all meetings. Refer to
the HSE plan S5.1 Demonstrating Compliance. This will also incorporate a BMT site safety tour and scoring audit.
4. The locations in (brackets) reflect the allocated BMTsite and office inspection rota.
5. Please note the changes and switch in site allocated.
6. The first meeting at Wallsend is targeted to be a best practises workshop and will also incorporate a BMT site safety tour and scoring audit.
7. Nigerian Fabrication to be added when available.
8. NETCO office inspections to be undertaken as visited by BMT.