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INTERNATIONAL DIPLOMA IN

OCCUPATIONAL HEALTH AND SAFETY

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UNIT D ASSIGNMENT
Table of Contents
1. Executive SUMMARY.....................................................................................................4
2. Introduction..................................................................................................................... 4
2.1 Aims and Objectives...............................................................................................4
2.2 Methodology........................................................................................................... 6
2.2.1 Research Methods..............................................................................................6
2.2.2 Critical Document Reviews.................................................................................6
2.2.3 Interviews............................................................................................................ 6
2.2.4 Questioning.........................................................................................................7
2.2.5 Referencing Style Employed...............................................................................7
2.3 Description of the Organisation...............................................................................7
2.3.1 The size of the organisation / workplace.............................................................7
2.3.2 The nature of the work undertaken.....................................................................7
2.3.3 A description of what processes are undertaken.................................................8
2.3.4 The employment profile.......................................................................................8
2.3.5 The work patterns and Production schedules employed.....................................9
2.3.6 department or site Chosen And its relationship to the work of the organisation. .9
2.3.7 Any special situations that are likely to have an impact on health and safety......9
2.4 Legal Environment................................................................................................10
2.4.1 Constitutional Structure of the UAE...................................................................10
2.4.2 Judicial System Adopted in the UAE.................................................................10
2.4.3 Types of Courts in the UAE...............................................................................11
2.4.4 Court of Cassation.............................................................................................11
2.4.5 Legislation Relating to Health, Safety and the Environment Federal (UAE). . .11
2.4.6 Legislation Relating to Health, Safety and the Environment Specific to the
Emirate of ABU DHABI..................................................................................................12
2.4.7 Codes of Practice Relating to Health, Safety and the Environment SPEcific to
the Emirate of ABU DHABI............................................................................................13
3. Review of the Health and Safety Management System.................................................14
3.1 Description............................................................................................................ 14
3.2 Gap Analysis.........................................................................................................14
4. Hazard Identification......................................................................................................16
4.1 Physical Hazards..................................................................................................17
4.2 Health and Welfare Hazards.................................................................................22
5. Risk Assessment........................................................................................................... 24
5.1 Background to risk assessment methodology.......................................................24

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5.2 Physical Hazards RISK ASSESSMENT................................................................27
5.3 Health and Welfare Hazards RISK ASSESSMENT...............................................30
6. Conclusions................................................................................................................... 32
7. Recommendations........................................................................................................ 33
8. Action Plan.................................................................................................................... 35
8.1 Management System............................................................................................35
8.2 Hazards and Risks................................................................................................38
9. References / Bibliography.............................................................................................41
10. Appendices............................................................................................................... 42

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1. EXECUTIVE SUMMARY
EMDAD LLCs OH&S management system was reviewed by carrying out a gap analysis
(attached to this document as Appendix A) and critical review of the integrated
Management system which has brought out points that will serve to improve the system
further to help conform with the requirements of OHSAS 18001:2007 standard and
applicable legal requirements in UAE.

Further a specific project, namely Oil Based Mud (OBM) cuttings treatment project was
selected to identify the hazards associated with the various activities and a risk assessment
was performed to identify areas of improvement which have been listed in section 7 and are
detailed as action plan in section 8 of this report. The action plan suggests recommendations
with responsibilities assigned along with the approximate associated costs to perform these
actions.

The few major points to be looked into as has been identified in the Risk assessment
(Section 5), Recommendations (Section 7) and Action Plan (Section 8) are listed here for
reference, for more details, specific sections may be referred to.
Hire the services of an independent third party to carryout monitoring of the OBM
cuttings to ascertain the presence or absence of radioactivity in the cuttings. Failing
this may lead to the exposure of employees to Normally Occurring Radioactive
Material (NORM) which may induce cancer over a period of time. The cost for
monitoring will be approximately AED 20,000.
Compliance to Abu Dhabi Company for onshore oil Operations(ADCO) medical
fitness assessment standards at present is not being complied to and this also
constitutes to a contractual breach. It is suggested that employees be sent for
medical examination as per requirement to comply with the contract and well being of
employees working in the Oilfield area. The approximate cost for carrying out medical
examination for 30 employees will be AED 24,000

Finally, it must be stressed here that the OH&S Management system has been well
implemented within EMDAD, barring few concerns mentioned above and in the
recommendation section of this report. Hence, it would be prudent to action the
recommendations to maintain a high level of legal & OH&S Compliance.

2. INTRODUCTION
2.1 AIMS AND OBJECTIVES
This report is being prepared for EMDAD LLC which operates in the Oil and Gas sector of
Abu Dhabi, United Arab Emirates and has various projects catering to the major clients in the

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region. The company is certified to ISO 9001:20081, ISO 14001:20042 & OHSAS
18001:20073 standards and maintains an integrated management system for Quality,
Environmental & Occupational Health & Safety management systems and is keen on
maintaining the highest standards of Occupational Health and Safety performance.

The basis of this report takes its origination from one of the company project, namely Oil
based mud treatment project by indirect thermal desorption. In order to maintain OH&S
standards the company complies with the requirements of UAE legislation on health &
Safety, namely the UAE Federal law 84 on Labour relations and the various ministerial
decisions complementing the Federal law 8. Apart from complying with the legal
requirements which are the minimum requirements to be complied to, the company also
subscribes to the other requirements such as client HSE requirements which are of a higher
standard. This gives the company a clear advantage and complying with the requirements of
the International OH&S standards like OHSAS 18001:2007 is manageable. The federal law
8 gives clear requirements under chapter 5 for the management of workers safety,
protection, health and social care and thus along with the OHSAS 18001:2007 standard
forms the basis of the structure of the OH&S management system of the company.

The aim of this report is to review the current state of Occupational Health and Safety
Management system implementation within the company and its various operations in
general and OBM Operations in particular as compared to the requirements of the
international standard OHSAS 18001:2007 and suggest to the management ways of
improving the system for better compliance to the requirements of the OHSAS 18001:2007
standard and applicable legal and other requirements.

This report is based on:


an extensive review of the applicable legal and other requirements

a review of the existing company OH&S procedures and

a series of interviews and discussions with individuals from various departments in


general and OBM project in particular

The objectives this report is;

a) To review the current status of the OH&S MS implementation by carrying out a gap
analysis.

b) Identify legal non - compliance and suggest ways for monitoring & compliance.

c) To identify areas which need attention by carrying out hazard identification and risk
assessment in order to provide the management with action areas for further
continual improvement of the OH&S management system.

1 ISO 9001:2008 Quality Management system requirements


2 ISO14001:2004 Environment Management systems general guidelines on principles, systems and supporting techniques
3 OHSAS 18001:2007 Occupational Health & Safety management systems - Requirement
4 UAE Federal law 8 of 1980 On regulation of labour relations

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2.2METHODOLOGY
The methodology adopted for completing this assignment was based on research on the
subject and document reviews. The following methods were deployed:

2.2.1 RESEARCH METHODS


The information for the research methodology comes not only from the field of OH&S
literature but also was based on reference to relevant legislation in UAE and Abu Dhabi,
code of practices, interviews and consultation with employees, actual on site measurements
using instruments where applicable and the internet for specific literature related to the
project. As the company is certified to the ISO 14001:2004 & OHSAS 18001:2007
standards, the OHSAS model on OH&S was used for the verification of implementation and
preparation of this report.

2.2.2 CRITICAL DOCUMENT REVIEWS


The following company documentation and other HSE related documentation pertaining to
the operations of the company were reviewed to ascertain the level of HSE MS
implementation based on the OHSAS 18001 model, the checklist used to ascertain this
implementation Gap analysis report is attached as Appendix A. The following were
reviewed;

a) Integrated Management System Manual (IMS)

b) HSE Policy statement

c) HSE procedures supporting the IMS

d) P&ID diagrams and operation flow chart

e) Review of previous HSE audits and HSE inspection reports

f) Review of applicable legal requirements

g) Review of applicable code of practices in the Emirate of Abu Dhabi

h) Review of HSE requirements of Clients, namely Abu Dhabi National Oil Company
(ADNOC) & ADCO

2.2.3 INTERVIEWS
Interviews were conducted with project employees in order to have better participation of
employees in the process of hazard identification, risk assessment and ascertaining the
controls5, this agreement of the controls would prove to be helpful in the implementation of
the same. Senior management personnel were also interviewed to gauge their commitment
to OH&S.

5 OHSAS 18001:2007, Occupational Health & Safety Management Systems-Requirements, Clause 4.4.3.2

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2.2.4QUESTIONING
The questioning techniques used in the process of collection of information required for the
preparation of this report included the following;

1) Contacting the project personnel (OBM) by developing an open conversation and


explaining the objective of the conversation

2) Where pertinent information was available from the employees more probing
techniques were used to elicit information

3) Employees who sought time for answering were contacted later for the information.

4) The Operations Manager, Site safety officer, Plant Supervisor, Plant Operator and
Deputy General Manager handling the project were also questioned to understand
the process and technical details on the project.

2.2.5 REFERENCING STYLE EMPLOYED


The referencing system that will be employed throughout this assignment presentation will
be based on the Harvard System.

2.3 DESCRIPTION OF THE ORGANISATION


2.3.1 THE SIZE OF THE ORGANISATION / WORKPLACE
EMDAD6 was founded in 1979 under the patronage of the Al Bawardi Enterprises Group
which has diversified business interests in the region. The company was formed to serve the
Oil & Gas sector which was at its infant stage with the vision of supporting the industry in
order to enable it to grow to greater strengths. From its humble beginnings in 1971 to date,
EMDAD has outperformed itself in terms of financial performance, value creation,
accomplishments and service provision. The company directly employs 100 employees on
various projects. For the purpose of this assignment the Oil Based Mud treatment project is
being referred to which employs 30 employees.

2.3.2THE NATURE OF THE WORK UNDERTAKEN


The Oil based mud treatment is the thermal desorption process which is state of the art
technology and its first large scale implementation in the Gulf is carried out by EMDAD LLC.
Oil-Based Mud (OBM a hazardous drilling waste) produced by other rigs operating in the
area is recycled and reused and at least 99.95% of oil from OBM cuttings is reclaimed as a
fuel. The final cuttings leaving the plant, with <0.05% hydrocarbons, are totally inert and
used for manufacturing compressed cement blocks. Recovered water, with less than 10 ppm

6 www.emdad.ae

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oil, is routed to develop green pastures and trees around the thermal treatment plant and
also in the rehydration of the treated OBM cuttings to prevent generation of dust.

Thermal technologies use high temperatures to reclaim or destroy hydrocarbon-


contaminated material. Thermal treatment is the most efficient treatment for destroying
organics, and it also reduces the volume and mobility of inorganic such as metals and salts 7.
Thermal treatment can be an interim process to reduce toxicity and volume and prepare a
waste stream for further treatment or disposal (e.g., landfill, land farming, land spreading), or
it can be a final treatment process resulting in inert solids, water and recovered base fluids.

The project treats the OBM cuttings supplied by various drilling rigs operating in the Emirate
of Abu Dhabi.

2.3.3A DESCRIPTION OF WHAT PROCESSES ARE UNDERTAKEN


As part of the processing of OBM cuttings, used OBM cuttings are brought in skips to the
plant for treatment and recovery of oil, mainly diesel. These skips are discharged into
cemented storage pits where they are mixed to homogeneous slurry, which is fed into the
feed hopper. A variable screw conveyor transfers the slurry into the drum (rotary dryer). This
drum is indirectly heated and is designed to withstand 2,400 degrees Fahrenheit. Due to the
indirect application of heat to the slurry, the liquid phase evaporates and the dried cuttings
are discharged from the dryer through and air lock and rehydrated with water in a dual
shafted pug mill mixer to minimize dust. The processed cuttings are then tested to ensure
compliance with environmental regulations.

The vaporised oil and water is passed through a cyclonic centrifugal separator to remove
dust particle and then condensed back into liquid phase by means of adiabatic quench
inside a condenser. The recovered liquid is passed through an oil/water/solids separation
system. The recovered oil is then pumped into a storage tank, where it can be used as a fuel
for the burners. Recovered water is used in the pug mill to rehydrate the cuttings. Any
vapours that do not condense are passed through an oxidiser system for complete
combustion.

2.3.4 THE EMPLOYMENT PROFILE


The project for its smooth operations on site (in Habshan approximately 170 kilometres from
Abu Dhabi) is manned by the following personnel and the support staffs are based in the
Head office in Abu Dhabi.

The personnel who have been assigned the on site responsibilities for the smooth operation
of the plant are:-

7 Bansal and Sugiarto(1999), Exploration and Production Operations - Waste Management A Comparative Overview

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Operations Manager, Site superintendent & lab in-charge, Plant Operators, Plant
technicians, Electricians, Mechanics, Equipment operators, skilled labourers, Site HSE
officer and camp administrator.

The above employees are supported by the HO personnel.

2.3.5 THE WORK PATTERNS AND PRODUCTION SCHEDULES


EMPLOYED
As the OBM treatment is a continuous process hence in order to operate the plant, the
employees work in shifts to cover the daily operations. The shift employees work in 8 hour
patterns starting at 06:00 hrs in the morning. The administrative staff work timings are from
08:00 hrs to 17:00 hrs with an hours lunch break. All employees get weekly off days and
those who perform duties on such days are paid overtime as per the requirements stipulated
in the Labour law 8 of 1980.

2.3.6 DEPARTMENT OR SITE CHOSEN AND ITS RELATIONSHIP TO


THE WORK OF THE ORGANISATION
The site/project chosen is the OBM project because of the hazardous nature of the rig waste
that is brought in for treatment and this is one of the largest projects undertaken by the
company in the field and is the only of its kind in the Gulf region.

The significance of this project is also because of the fact that diesel oil is extracted from the
rig waste (OBM cuttings) in significant quantities along with water which are reused as
burner fuel and rehydration of treated cuttings in the pug mill respectively, thus proving to be
an environmentally friendly process and satisfying the requirements of the companys
Integrated Management system manual requirements.

2.3.7 ANY SPECIAL SITUATIONS THAT ARE LIKELY TO HAVE AN


IMPACT ON HEALTH AND SAFETY
As the OBM cuttings come from different rigs operating in the area, know to contain high
H2S concentrations, hence there are chances of the release of H2S from these cuttings
when these are agitated during offloading into the pit, thus exposing the personnel working
in the offloading operations to H2S.

The discharge of the treated cuttings from the drum has a noticeable odour of the volatile
organic compounds which due to the prevailing winds is carried over the facility & beyond,
this has been reported by some employees to cause headaches.

As the operations are carried out in the oilfield area, there can be instances where in the
brought in material (OBM cuttings) may contain normally occurring radioactive material
(NORM).

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2.4 LEGAL ENVIRONMENT8
2.4.1CONSTITUTIONAL STRUCTURE OF THE UAE
The United Arab Emirates (UAE) was formed on 2nd December 1971 by the passing of the
Union Declaration by six states, namely, Abu Dhabi, Dubai, Sharjah, Ajman, Fujairah and
Umm Al Quwain. Ras Al Khaimah joined the Federation in 1972.

The UAE is governed in accordance with the Constitution as per the Constitutional
Amendment Law No 1 of 1996.

The UAE Constitution permits each Emirate to have its own legislative body and judicial
authority. Accordingly there are Federal Courts and Local Courts in the UAE.

All Emirates other than Dubai and Ras Al Khaimah have now brought their judicial systems
into the UAE Federal Judicial Authority, with Dubai and Ras Al Khaimah retaining their own
judicial systems which are not part of the UAE Federal Judicial Authority.

Federal and Local courts apply UAE Federal Laws which are enacted by the UAE Federal
Legislative Authority as well as laws and regulations enacted by the Rulers of the individual
Emirates.

Although the legal procedures and laws applicable to courts in the individual Emirates are all
fairly similar, there are differences, particularly where a special law has been enacted and
applied in a particular Emirate.

In the event of a conflict between the Federal and Local laws, the Federal Law will
supersede the Local law of the Emirate.

2.4.2 JUDICIAL SYSTEM ADOPTED IN THE UAE


The UAE is a civil law country and follows a civil law system; as such the primary source of
law is a statutory code.

The UAE legal system has been influenced to a large extent by the Egyptian legal system
which has its source in French and Roman law.

The law in the UAE has also naturally been influenced by Islamic law codified in the Sharia
and embodied in the UAE Civil and commercial law.

In matters of procedure, the UAE courts follow the Federal Law of Civil Procedure (No 11 of
1992) and Federal Law of Criminal Procedure (No 35 of 1992) in civil and criminal
proceedings respectively.

These laws set out in detail the law and procedures for conducting civil and criminal cases
before the UAE courts, whether local or Federal.

Judges in the UAE Federal and Local courts apply the provisions of the specific laws,
established usage, or customs as well as the Islamic Sharia.

8 Al Tamimi (2007) The Framework for Litigation in the United Arab Emirates. Al Tamimi, UAE, pp 2 - 10

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There is no system of case reporting in the UAE and as usual in a civil law system, a judge
is under no obligation to take previous decisions of the court into consideration in an action
before him. Such decisions are, however, persuasive and when repeated by the Supreme
Court established principles are laid down which serve as guidance rather than a precedent.

2.4.3 TYPES OF COURTS IN THE UAE


In general, in the UAE, both Federal and Local courts are divided into the Civil Courts, the
Criminal Courts and the Sharia Courts. The Civil Courts hear civil and commercial matters
including private suits and company and insurance matters.

The Sharia Courts are responsible for civil matters in the UAE for Muslims. Non-Muslims will
not appear before the Sharia Court in any matter.

The Sharia Courts hear mostly matters of family law relating to issues such as divorce,
inheritance and succession, alimony and custody of children.

Cases for non-Muslims will be decided in the Courts based on civil and commercial law in
general matters.

Criminal matters are almost always heard by the Criminal Courts after referral by the Police
to the Prosecutors office for investigation and prosecution. Some crimes such as assault
and adultery may be transferred to the Sharia Courts in some Emirates. However, even
where a case is transferred to the Sharia Court, the provisions of the UAE Federal Criminal
Code will be applied.

As far as procedure is concerned, the UAE Law of Criminal Procedure will always apply to a
case, whether it is heard by a Criminal Court or a Sharia Court.

2.4.4 COURT OF CASSATION


Federal judgements delivered by the Federal Courts in the UAE (Abu Dhabi, Sharjah,
Fujairah, Ajman, Umm Al Quwain) are subject to an appeal to the Abu Dhabi Supreme Court
of Cassation. Judgements delivered by the Dubai Court of Appeal are subject to an appeal to
the Dubai Court of Cassation. There is no Cassation Court in Ras Al Khaimah.

The UAE Federal Supreme Court of Cassation in Abu Dhabi is also the UAEs Constitutional
Court.

Appeals on facts are not referable to the Court of Cassation. Only appeals on a point of law
are allowed.

2.4.5 LEGISLATION RELATING TO HEALTH, SAFETY AND THE


ENVIRONMENT FEDERAL (UAE)
a) Federal Law No (1) 2002 - Regarding the regulation and control of the use of radiation
sources and protection against their hazards

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This law has provisions for the framework for the establishment of directorate for the control
of radiation sources, responsibilities of various ministries, roles and responsibilities of the
radiation protection committee, establishing of an emergency plan do deal with radiological
disasters, procedure for importing and use of radiological sources and penalties for not
complying with the regulation.

b) Federal Law no (8) of 1980 Regulating labour relations

The Federal Law no. 8 apart from addressing other labour related issues also addresses the
Occupational Health & Safety of the employees working for any employer under chapter 5
Safety & Protection of employees as well as their medical and social care, under clauses 91
to 101.

c) Federal Law no. 24 of 1999 Protection and the development of the environment

This federal law aims at the protection and conservation of the quality and natural balance of
the environment by control of all forms of pollution, developing the natural resources and
conservation of biological diversity in the region, protection of society, human health and the
health of other living creatures from activities and acts which are environmentally harmful or
impede authorised use of the environmental setting.

d) Ministerial Decision 32 of 1982 Determination of preventive methods and


arrangements to protect labourers from work hazards

This ministerial decision complements the federal law 8 in the way that it elaborates upon
the requirement of the law and gives specific direction to be adopted and complied to. This
document addresses the occupational health and safety requirements.

e) Ministerial Decision 37/2 of 1982 Standards of medical care which the employer shall
undertake to provide his labourers

This ministerial decision gives specific requirements in terms of medical care to be provided
to employees be it in establishing on site clinic for the medical care of employees in remote
areas, examination by qualified doctors, provision of first aid etc.

2.4.6 LEGISLATION RELATING TO HEALTH, SAFETY AND THE


ENVIRONMENT SPECIFIC TO THE EMIRATE OF ABU DHABI

1) Law no. 21 of 2005 Waste management in the emirate of Abu Dhabi

The local law describes the requirements for the management and disposal of waste in the
emirate of Abu Dhabi. This law clearly defines the responsibilities of the competent authority
of the state and that of the concerned parties to manage of waste generated through the
provision of efficient and integrated systems for storage, treatment and disposal of all types
of waste in order to achieve the requirements of the law.

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2.4.7 CODES OF PRACTICE RELATING TO HEALTH, SAFETY AND THE
ENVIRONMENT SPECIFIC TO THE EMIRATE OF ABU DHABI
1) Abu Dhabi Code of practice for construction projects Part one & two

This code of practice gives specific guidance to the construction contractors on the Health
and Safety issues related to the activities carried out with specific requirements to be
complied to.

2) Abu Dhabi National Oil Company (ADNOC) HSE Codes of practice

3) Abu Dhabi Company for onshore oil operations (ADCO) HSE Procedure manual

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3. REVIEW OF THE HEALTH AND SAFETY MANAGEMENT
SYSTEM
3.1 DESCRIPTION
The companys Health and Safety Management system is based on the OHSAS 18001:2007
standards model. This model was chosen for implementation because of the fact that the
OHSAS standard are intended to provide the organisation with the elements of an effective
OH&S management system which can be integrated with other management requirements
thus helping the organisation achieve the set HSE objectives and other economic objectives.

EMDAD LLC has integrated the three standards viz, ISO 9001:2008, ISO 14001:2004 &
OHSAS 18001:2007 standards to prepare the integrated management system, thus giving
an advantage of managing the common elements of these systems rather than applying
each of these in isolation. In order to improve the applicability the process approach has
been adopted for the various QHSE processes within the organisation and their interaction
with each other has been well established. These processes can be objectively audited to
establish conformance to the HSE Policy requirements, applicable legal and other
requirements, commitment to prevent injury and ill health and a commitment to continually
improve the OH&S management system.

EMDAD LLC is certified to all the above mentioned Quality, Environment & OH&S standards
and thus demonstrates its ability to develop and implement a HSE policy and Objectives
which take into account the legal and other requirements and information about the OH&S
risks in the various activities that the organisation performs. The commitment from the top
management drives the HSE policy and its implementation but the commitment of all team
members is vital to the success of the implementation of the OH&S standards, this is an
area which can be improved upon within the organisation as is shown by the gap analysis

3.2 GAP ANALYSIS


A gap analysis was carried out on the IMS system (Environmental & Occupational Health &
Safety). Although the company is certified to the three management standards but there are
areas which can be improved upon to have better compliance. Some areas of improvement
are highlighted here; the complete gap analysis is attached as appendix A.

1) Compliance to the requirements of article 12 of Ministerial decision 37/2 is not being


complied to by maintaining a register of occupational illnesses and injuries and
reporting of the same to the ministry as is prescribed in article 12.

2) Compliance to ADCOs medical fitness assessment standards is not complied with.

3) These objectives and targets are however not very effectively communicated to the
employees. The line managers must be entrusted with this job of ascertaining those
personnel working under him are aware of the OH&S objectives and targets that they have
been assigned to so that its implementation and achievement can be carried out.

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4) Some aspects, like generation of dust from the treated OBM cuttings need more detailed
attention as the same will become a nuisance during the summer months when the wind
velocities are considerably high and the dust will be airborne thus causing harm to the camp
residents.

5) OH&S hazards does not include hazards such as potential radiation harmful effects from
OBM cuttings, their assessment and control, exposure of workers to communicable diseases
when living in a camp environment, there is also very generic identification of hazards to
visitors visiting the workplace.

6) Approved job descriptions were not available for reference.

7) Effective communication system is implemented; this process can be further


enhanced by frequent Management HSE walkabouts to demonstrate management
commitment.

8) Incidents are investigated but trends are not established to have better understanding for
implementation of controls.
9) Participation of employees in the review of HSE policy and establishment of HSE
objectives to be promoted.

10) Emergency response plan is tested in most facilities but on some the frequency of
such tests to be increased, for example in Camp accommodation.

11) In the absence of the ISM coordinator this process is not being timely monitored and
as such the process of improvement to the IMS is delayed.

12) Near miss incident reporting is poor and has scope for improvement.

13) Audits to be carried out as process based to audit the process thoroughly the
eliminating any potential non conformities from the system.

14) Management reviews to take into account suggestions from client audit reports to
enhance the IMS.

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4. HAZARD IDENTIFICATION
Hazard identification is the process used to identify all the possible situations in the
workplace where people may be exposed to injury, illness or disease. This report shall
endeavour to identify hazards in the OBM plant and associated camp environment where the
employees live. The hazards have been categorised as;

4.1) Physical Hazards, and

4.2) Health & Welfare hazards

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4.1 PHYSICAL HAZARDS

Rating Impact Justification


Sno Hazard
Very Med Very
Low High
Low ium High

1 Physical

Noise Generated from the following Measurements taken


sources: On the employees working in the area - at 1 meters away from
Diesel driven electric generator. electricians/mechanic, plant technicians, the source showed
1a STP operator by inducing noise induced readings to be at or
Fan for the water cooling system. hearing loss over a period of time if controls above 87 dBA in some
STP circulation pumps located are not established. instances reaching 95
inside the room. dBA

Vibration of the grizzly the feed


area for OBM cuttings which is Employee is not
1b required to feed the material into Has low impact on the employee working always on the grizzly
the drum at the same time during the shift period.
separates any large chunks.

Heat The heat in summer months


when temperatures reach 46oC in High ambient
the open where employees have to temperatures during
work. May cause heat related illness during the
1c the summer months
summer months to the exposed employees
Heat radiated from the drum with high humidity
affecting the employees working levels
nearby

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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High

Measurements
conducted by the
Environment Agency
Radiation Potential radiation Radiation induced cancer on the
Abu Dhabi showed
1d from the OBM cuttings delivered in employees handling the incoming and
activity & minute
skips from rigs treated OBM cuttings
traces of NORM.
Annual maximum
exposure is 50 Sv9

Compressed air points


in the plant are easily
Pressure Use of compressed air Might cause serious injury to the person
accessible,
1e to clean coveralls to get rid of the using the compressed air directed towards
communication of
dust his body
hazards is less than
adequate.

2 Chemical

Is handled on a daily
Handling sodium hypochlorite as
Can cause irritation to skin and is toxic by basis in quantities
2.1 disinfectant and bleaching agent in
all routes of entry to the STP Operator required to dose the
water treatment process
water being treated.

9 ADCO HSE Procedure manual, part 31

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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High

Some camp
Fumes (VOCs) generated during Depending on the wind direction can employees have made
2.2 the quenching process of the impact the camp residents by causing complaints of bad
treated OBM cuttings breathing difficulties odour coming from the
plant

3 Biological

The STP operator


Handling of waste in STP Diseases caused by infectious agents
3.1 monitors the plant on
Bacteria, Virus bacteria, virus
a continuous basis

All toilets in the camp


Housekeeping staff cleaning rooms Diseases caused by infectious agents
3.2 are cleaned on a daily
and toilets Bacteria, Virus bacteria, virus
basis

4 Mechanical

Overrun - Overhead crane


Crane not stopping at the end of the limits Crane is used at every
4.1 operations Absence of limit switch
thus might override the mechanical stopper. offloading operation.
on the crane

The wall is supported


The OBM pit wall in the verge of Spillage of oil Based cuttings and oil in the by pegs which is
4.2
collapse due to weld failure work area holding the same at
the moment

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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High

5 Fire & Explosion

Fire - Ingress of oxygen into the


Fire has been
OBM drum (indirect thermal heating Can cause fire at the seals, which needs to
5.1 reported in the past at
in the absence of oxygen is be extinguished quickly.
the seal.
required)

6 Ergonomic

Poor design of work stations in the


Musculoskeletal disorders to the Welder expressed
6.1 fabrication shop compelling the
welder/fabricator uneasiness in working
worker to adopt uneasy positions

Ergonomic survey was


Chairs with poor back rest
6.2 Back pain to the computer users carried out to address
adjustments in use
this anomaly

7 Electrical

All flammable
containers must be
Static Charges - The diesel storage
Can generate spark which might cause earthed and is
7.1 tanks are not earthed for dissipation
fire / explosion required by
of static charges
international
standards

Page 20 of 54
Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High

Electrician uses other


The electrical panels are not insulation methods
supported by a non conducting Might cause serious electrical shock to the (PPE) for protection,
7.2
floor/mat where the electrician electrician but provision of non
works conducting mats to be
made

8 Psychosocial

Some employees
Stress caused by the long work / Affects the employees psychologically and
8.1 have not seen their
leave schedules hence may become tensed and irritating.
newly born child

9 Transport

Movement of heavy equipment Movement of heavy


Shovel and excavator used in the Can hit and injure personnel, can cause equipment is required
9.1
work area to move untreated & asset damage, if unnoticed to keep the process
treated OBM cuttings going.

Incidents have been


reported when these
Reversing of skip trucks in the trucks have reversed
9.2 Can cause damage to asset.
offloading area and hit the offloading
bay limits and caused
slight damage.

Page 21 of 54
4.2HEALTH AND WELFARE HAZARDS

Rating Impact Justification


Sno Hazard
Very Med Very
Low High
Low ium High

1 Ventilation

Poor ventilation in the pug-mill area


Gives bad odour and irritate personnel
1.1 where the gases (VOC) from the Employee complaints
working in the area
chimney settle

In the lab when conducting sample


Only a common 6
tests on OBM samples the Gives bad odour and irritate personnel
1.2 exhaust fan provided
generated gases are not efficiently working in the area
in the lab
exhausted out of the room

No other arrangement
Poor ventilation Living rooms are Poor ventilation in the room affecting the for ventilation apart
1.3
provided with one window only employees from the air
conditioner.

2 Temperature

Temperatures in the
Low temperatures - During winters Employees have to sleep in the cabin in
2.1 winters go to as low
the nights are very cold very less temperatures and hence shiver
as 5oC

3 Living areas (accommodation)

Communicable disease - No
No isolation room/
isolation rooms in case of Spread of communicable disease amongst
3.1 availability of doctor in
communicable disease 4 the camp residents
the camp
employees share a room

Page 22 of 54
Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High

4 Sanitary Convenience

Is required as per the


Unavailability of toilets in the plant Employees have to walk 200 meters to go
4.1 labour law within 50
area. to toilet
meters of work

Dirty hands - Wash basins in the


4.2 labour area not provided with soap
and hand dryers

5 Facilities for rest & eat meals

Dust - Plant operator eat meals in Mess facility is


Food contaminated with dust although in
5.1 the plant presence of dust and available in less than
very small quantities
chemicals 200 meters

6 Drinking water

Pathogens Cleaning of water tank Six monthly cleaning


Contaminated water shall affect the camp
6.1 not carried out as per schedule, schedule, but not
residents
likelihood of breeding of bacteria followed

Page 23 of 54
5. RISK ASSESSMENT

5.1 BACKGROUND TO RISK ASSESSMENT METHODOLOGY


Risk assessments10 are very important as they form an integral part of a good occupational
health and safety management plan in addressing the hazards identified for the various
activities in the operations of the OBM plant. They help to:

1) Create awareness amongst employees of the hazards and risks,

2) Identifies who may be at risk (employees, cleaners, visitors, contractors, the public,
etc),

3) Determines if existing control measures are adequate or if more should be done to


eliminate or control the hazards,

4) Prevent injuries or illnesses, and

5) Prioritize hazards and control measures.

The aim of the risk assessment process is to remove a hazard or reduce the level of its risk
by adding precautions or control measures, as necessary thus creating a safer and healthier
workplace.

The hazard identification involved the following personnel and was selected based on their
experience in operating the plant;

Operations Manager, Plant Operator, Plant technicians, Site safety officer

The selected hazards were studied to determine its' level of risk. To research the hazard, the
following was looked at:

1) Product information (information of OBM cuttings),

2) Past experience of operations from previous contract (workers, etc),

3) Legislated requirements and/or applicable standards,

4) Industry codes of practice / best practices,

5) Health and safety material about the hazard

6) Information from received from governmental agencies (Environment agency Abu


Dhabi),

7) Results of testing and monitoring,

8) The expertise of an occupational health and safety professional,

9) Information about previous injuries, illnesses, "near misses", accident reports, etc.

10 http://www.ccohs.ca

Page 24 of 54
Ranking / prioritizing of hazards was done to help determine which hazard is the most
serious and thus which hazard to control first. Priority was established by taking into account
the employee exposure and the potential for accident, injury or illness.

Severity of harm
Likelihood of Harm
Slight Harm Moderate Harm Extreme Harm
Very unlikely Very Low risk Very low risk High risk

Unlikely Very low risk Medium risk Very high risk

Likely Low risk High risk Very high risk

Very Likely Low risk Very high risk Very high risk

Definitions for Likelihood of Harm

Very Likely - Typically experienced at least once every six months by an individual.

Likely - Typically experienced once every five years by an individual.

Unlikely - Typically experienced once during the working lifetime of an individual.

Very unlikely - Less than 1% chance of being experienced by an individual during their
working lifetime.

Definitions for Severity of Harm

Potential severity of harm - When establishing potential severity of harm, information about
the relevant work activity should be considered, together with:

a) Part of the body likely to be affected;


b) Nature of the harm, ranging from slight to extremely harmful:

1. Slightly harmful (e.g., superficial injuries; minor cuts and bruises; eye irritation from dust;
nuisance and irritation; ill-health leading to temporary discomfort)

2. harmful (e.g., lacerations; burns; concussion; serious sprains; minor fractures; deafness;
dermatitis; asthma; work-related upper limb disorders; ill-health)

3. extremely harmful (e.g., amputations; major fractures; poisonings; multiple injuries; fatal
injuries; occupational cancer; other severely life shortening diseases; acute fatal diseases)

Definition for Risk Level

Very low - These risks are considered acceptable. No further action is necessary other than
to ensure that the controls are maintained.

Low - No additional controls are required unless they can be implemented at very low cost
(in terms of time, money, and effort). Actions to further reduce these risks are assigned low
priority. Arrangements should be made to ensure that the controls are maintained.

Page 25 of 54
Medium - Consideration should be as to whether the risks can be lowered, where
applicable, to a tolerable level and preferably to an acceptable level, but the costs of
additional risk reduction measures should be taken into account. The risk reduction
measures should be implemented within a defined time period.

Arrangements should be made to ensure that controls are maintained, particularly if the risk
levels area associated with harmful consequences.

High - Substantial efforts should be made to reduce the risk. Risk reduction measures
should be implemented urgently within a defined time period and it might be necessary to
consider suspending or restricting the activity, or to apply interim risk control measures, until
this has been completed. Considerable resources might have to be allocated to additional
control measures. Arrangements should be made to ensure that controls are maintained,
particularly if the risk levels are associated with extremely harmful consequences and very
harmful consequences.

Very high - These risks are unacceptable. Substantial improvements in risk control
measures are necessary so that the risk is reduced to a tolerable or acceptable level. The
work activity should be halted until risk controls are implemented that reduces the risk so
that it is no longer very high. If it is not possible to reduce the risk, the work should remain
prohibited.

Table for hazard priority setting


Very likely Likely - Unlikely - Very unlikely -
- could could could could happen
happen at happen happen but but probably
any time sometime very rarely never will
Kill or cause
permanent 1 1 2 3
disability or ill
health
Long term
illness or 1 2 3 4
serious injury
Medical
attention and 2 3 4 5
several days
off work
First aid 3 4 5 6
needed
Note: - 1 = extremely important to do something as soon as possible, 6 = hazard may not
need immediate attention.

Page 26 of 54
5.2PHYSICAL HAZARDS RISK ASSESSMENT
The physical hazard selected for further risk assessment is 1d - Radiation from the OBM cuttings delivered in skips from rigs because the
risk posed by the same is high and may effect several employees in the long term and may lead to cancer.

Operations Manager, Site HSE Officer, Plant Operator, HSE Date of risk
Team members 16th July 2009
Manager assessment
What further
What are the Who might be What is already Risk Completio
action is Action by Whom? Action by When?
Hazards? harmed and how? been done? rating n date
necessary?
The hazards of the The employees Initial EMDAD to obtain PRO11 & Contracts
OBM cuttings are handling the skips measurements environment licence Manager to discuss
potential presence during the have been taken to operate as waste the same with Dy. By end of the year
High
of NORM offloading process, with the assistance service provider. GM and ADCO and 2009.
(Normally the excavator of Environmental ADCO to assist in apply for the
occurring operator who agency, Abu Dhabi this process. licence.
radioactive mixes the slurry, and have shown Obtain the Procurement By the end of High
material) the grizzly operator radioactivity. necessary Manager with the October 2009.
who monitors the equipment to assistance of HSE
feed into the drum, measure radiation, manager who shall
the pug-mill surface pollution give the
operator who and radioactive specifications of
monitors the detection the instrument

Page 27 of 54
Operations Manager, Site HSE Officer, Plant Operator, HSE Date of risk
Team members 16th July 2009
Manager assessment
What further
What are the Who might be What is already Risk Completio
action is Action by Whom? Action by When?
Hazards? harmed and how? been done? rating n date
necessary?
Hire the services of
an approved
external agency to
constitute an Dy.GM to contact
independent study approved supplier
By the end of
to identify the of such services High
October 2009
presence of NORM with the help of
contamination of HSE Manager.
the material
handled and store
by EMDAD
treated material, Train an appointed
HSE Manager to By the end of
the shovel operator person as radiation High
arrange the training September 2009
who transfers the protection officer
material to storage HSE Manager to
area, camp Procedure to be write the procedure
residents. These established for with the help of
employees might identifying, Operations By October 2009
High
be at risk of handling, treating Manager. end
contracting cancer and disposal of General Manager
by the exposure in NORM Waste to approve the
the long term. procedure.

11 Public relations officer (PRO)

Page 28 of 54
Operations Manager, Site HSE Officer, Plant Operator, HSE Date of risk
Team members 16th July 2009
Manager assessment
What further
What are the Who might be What is already Risk Completio
action is Action by Whom? Action by When?
Hazards? harmed and how? been done? rating n date
necessary?
The employees
handling the skips
during the
offloading process, Conduct awareness
the excavator sessions for HSE Manager &
operator who employees to make Site HSE Officer to By the end of
High
mixes the slurry, them aware of the conduct awareness September 2009
the grizzly operator hazards and its sessions
Employees who monitors the Initial consequences
unaware of this feed into the drum, measurements
hazard and are the pug-mill have been taken
required to handle operator who with the assistance
the skips which monitors the of Environmental
bring in this treated material, agency, Abu Dhabi
material on a daily the shovel operator and have shown Procurement of Procurement
basis who transfers the radioactivity. radiation Manager with the
material to storage badges/dosimeters assistance of HSE
area, camp By the end of
for exposed manager who shall High
residents. These October 2009.
employees to give the
employees might monitor the specifications of
be at risk of exposure the instrument
contracting cancer
by the exposure in
the long term.
The treated OBM Construct semi
cuttings are stored closed storage
in the open and as area taking into
this dries up it All employees in Water sprinkling consideration the
Operations By the end of year
spreads to the work area and arrangements are wind direction to Medium
Manager 2009
adjacent areas as camp residents made preserve the
dust in the summer resulting waste
months when the until proper
winds are gusty. disposal.

Page 29 of 54
Page 30 of 54
5.3HEALTH AND WELFARE HAZARDS RISK ASSESSMENT

The health and welfare hazard selected for further risk assessment is 1.1 Poor ventilation in pug-mill area where the gases form the chimney
settle.
Operations Manager, Site HSE Officer, Plant Operator, HSE Date of risk
Team members 16th July 2009
Manager assessment
What further
What are the Who might be What is already Risk Completio
action is Action by Whom? Action by When?
Hazards? harmed and how? been done? rating n date
necessary?
VOC from the The pug mill The mixture that is The height of the
chimney in the pug operator and other fed into the drum is chimney to be Operations
mill area (poor when the analysed in the lab increased so that manager to give By end of Dec
High
ventilation) wind/breeze carries and now this gas is proposals and 2009
to distances. The appropriate dispersed over a design for the same
smell of the gas quantities / density large area.
causes irritation in of the mixture Stack emission
people and some along with the analysis to be
complain of polymer is fed into reinstated and an
Operations
headache the drum. external party to be
Manager to invite
called in to perform By end of Sept
quotations for High
Stack emission the same. 2009
carrying out stack
analysis was Depending on the
emission analysis.
carried out in 2007. results further
action to be
Respiratory established.
protective The respirators HSE Manager with By end of October Medium
equipment issued provided is to be the help of site 2009
to personnel analysed for safety officer to
working in the plant suitability and if conduct a study on
need be shall be the respirators
replaced.

Page 31 of 54
Operations Manager, Site HSE Officer, Plant Operator, HSE Date of risk
Team members 16th July 2009
Manager assessment
What further
What are the Who might be What is already Risk Completio
action is Action by Whom? Action by When?
Hazards? harmed and how? been done? rating n date
necessary?
Operational
procedures to be
amended to include Operations
the Manager in By end of year
Medium
recommendation of conjunction with 2009
the stack analysis HSE Manager
report and
respirator study.

Page 32 of 54
6. CONCLUSIONS

Although EMDAD LLC is performing well in terms of OH&S management of its facilities and
processes, but as mentioned in the gap analysis in section 3.2 of this report there are
specific areas which can be improved based on the recommendations given in section 7.

The hazards identified and risk assessment carried out was specific to the OBM treatment
plant and hence would benefit the employees working if the recommendations are
implemented.

As the aim of this report was to review the Occupational Health & Safety Management
system implementation within the company and OBM operations in particular, it is clearly
evident from section 3, 4 and 5 of this report that areas of improvement do exist which must
be worked upon in order to establish compliance.

Page 33 of 54
After critical review of the current OH&S Management system, legal and other requirements
and other pertinent documentation, areas have been identified where improvements can be
effected. The recommendations for the assessed risks and gap analysis is given in section 7
for which management is to assure resources shall be available so that the responsible
persons can action the recommendations for the benefit of the employees and to a greater
extent help the company comply to the legal requirements.

7. RECOMMENDATIONS

The following are the recommendations based on the research, review of the IMS, gap
analysis, hazard identification and risk assessment carried out. These recommendations will
help the company to comply with the legal and other requirements and enhance the
implementation of the occupational health and safety management system.

The recommendations are further tabulated in section as action plan in section 8 and are
categorised as Management system improvements and Hazard and risks improvement.

It is suggested that these recommendations are reviewed after six months and gaps closed.

Following is the list of recommendations:

1) Policy was communicated to all employees and interested parties, this process can
be further improved by conducting road shows to elucidate the contents of the
statement to the employees in the presence of Senior Management personnel.

2) Objectives and targets are not very effectively communicated to the employees. The
line managers must be entrusted with this job of ascertaining those personnel
working under him are aware of the OH&S objectives and targets that they have
been assigned to so that its implementation and achievement can be carried out.

3) Compliance to the requirements of article 12 of Ministerial decision 37/2 is not being


complied with. This shall be done by maintaining a register of occupational illnesses
and injuries and reporting of the same to the ministry as is prescribed in article 12 of
the ministerial decision.

4) Compliance to ADCOs medical fitness assessment standards is not complied with.

5) Some hazards, like generation of dust from the treated OBM cuttings need more
detailed attention as the same has become a nuisance during the summer months
when the wind velocities are considerably high and the dust is airborne thus causing
harm to the camp residents. This storage space/area shall be enclosed by walls and
water spraying to be carried out at frequent intervals to keep the dust settled.

6) Hazards such as potential radiation harmful effects from OBM cuttings, their
assessment and control, exposure of workers to communicable diseases when living
in a camp environment shall be assessed further and studies conducted to establish
monitoring methods and controls.

7) Legal register to me made available in a central location.

Page 34 of 54
8) Quarterly monitoring of the implementation of HSE objectives is to be applied
company wide operations covered under the Integrated Management System.

9) Job descriptions shall be available with the employees so that responsibilities are
clearly defined and known to them.

10) Effective communication system is implemented; this process can be further


enhanced by frequent Management HSE walkabouts to demonstrate management
commitment.

11) Hazard identification process is not complete in all aspects as this has not covered
some likely hazards associated with the projects.

12) Participation of employees in the review of HSE policy and establishment of HSE
objectives to be promoted.

13) There are some lapses noted with respect to legal compliance which must be
rectified for instance the periodic medical examination of employees, periodic
monitoring of ambient air quality as listed in the contract documents is not being met.
This shall be carried out for compliance.

14) Emergency response plan is tested in most facilities but on some the frequency of
such tests to be increased, for example in Camp accommodation.

15) Due to the absence of the ISM coordinator this process is not being timely monitored
and as such the process of improvement to the IMS is delayed.

16) Near miss incident reporting is poor and has scope for improvement. HSE incentive
process must be maintained to motivate the employees to perform well in their
respective activities and report all near miss incidents

17) It is suggested that such audits to be carried out as process based to audit the
process thoroughly the eliminating any potential non conformities from the system.

Page 35 of 54
8. ACTION PLAN
8.1 MANAGEMENT SYSTEM

Priorit TIME SUCCESS REVIEW BY


RECOMMENDATIONS ACTION(S) RESPONSIBILITY COST
y SCALE CRITERIA DATE

Compliance to ADCOs medical


fitness assessment standards to be
Compliance to ADCOs Medical
complied with as this is a
medical fitness By end of 1st Operations AED examination
1 contractual requirement as well, Annually
assessment standards Qtr 2010 manager 24,000 reports of
employees to be sent for medical
to be complied to employees
examination as per the
requirements.
Periodic monitoring of
ambient air quality as
listed in the contract Carryout stack emission analysis Third Party
documents is not By end of Operations AED
2 by third party to monitor air quality stack emission Every six months
being met. This shall Dec 2009 Manager 10000
in the work area. analysis report
be carried out for
compliance.
Compliance to the requirements of
article 12 of Ministerial decision
37/2 is not being complied with.
This shall be done by maintaining Operations
Legal compliance to be a register of occupational illnesses By end of Injury and
3 Manager & Site - Quarterly
ensured and injuries and reporting of the year 2009 illness register
HSE Officer
same to the ministry as is
prescribed in article 12 of the
ministerial decision.

Page 36 of 54
Priorit TIME SUCCESS REVIEW BY
RECOMMENDATIONS ACTION(S) RESPONSIBILITY COST
y SCALE CRITERIA DATE
The line managers must be
entrusted with this job of
OH&S Objectives & ascertaining those personnel Minutes of
working under him are aware of At monthly
targets to be meetings, Annual IMS
4 the OH&S objectives and targets project Line Manager(s) -
communicated to Interview of audits
that they have been assigned to meetings
employees employees
so that its implementation and
achievement can be carried out.
Communication of HSE Conduct road shows to elucidate Attendance
the contents of the statement to HSE
Policy statement to Once Every AED records, Annual IMS
5 the employees in the presence of Manager/GM/DG
employees and Six months 5000 Quarterly HSE audits
Senior Management personnel. M
interested parties reports
Effective
communication system
HSE
can be further
enhanced by frequent Inspection
Carryout monthly walk about in the Minimum
Management HSE GM, DGM, HSE reports, Annual IMS
6 work place and discuss with once every -
walkabouts to Manager improved audits
employees their HSE concerns quarter
demonstrate management
management visibility on site
commitment.
Emergency response
plan is tested in most
facilities but on some Conduct quarterly emergency drills Emergency
Minimum
the frequency of such in the accommodation camps to AED drill report of
7 once every Site HSE Officer Every Quarter
tests to be increased, make employees aware of the 2000 the drill
Quarter
for example in Camp procedure for evacuation. conducted
accommodation.

Page 37 of 54
Priorit TIME SUCCESS REVIEW BY
RECOMMENDATIONS ACTION(S) RESPONSIBILITY COST
y SCALE CRITERIA DATE
Near miss incident
reporting is poor and
has scope for
improvement. HSE Conduct presentations on the HSE
incentive process must Increased Review of
incentive scheme and how it
be maintained to By end of AED reporting of incidents
8 operates so that employees HSE Manager
motivate the Oct 2009 2000 Near miss reported on
understand it better and report near
employees to perform incidents quarterly basis
miss incidents
well in their respective
activities and report all
near miss incidents

Page 38 of 54
8.2 HAZARDS AND RISKS

Priorit SUCCESS REVIEW BY


RECOMMENDATIONS ACTION(S) TIME SCALE RESPONSIBILITY COST
y CRITERIA DATE

Potential radiation from


the OBM cuttings
delivered in skips from
rigs induced cancer on
the employees Hire the services of an independent Report from the
handling the incoming third party to carryout monitoring of the independent
By end of Dy GM & Operations AED By end of Nov
1 and treated OBM obm cuttings to ascertain the presence party carrying
October 2009 Manager 20000 2009.
cuttings. Carryout an or absence of radioactivity in the out the
independent analysis / cuttings. monitoring
monitoring of the OBM
cuttings to ascertain
the presence of
radiation in the cuttings

In order to disperse the


Operations manager
pug mill gases (VOC) Increase the height of the chimney from Installation of a
for increase height
the height of the its present 3 meters height to 9 meters longer chimney.
By end of 1st of the stack, Site AED
2 chimney to be and carryout an ambient air monitoring Results of the End of April 2010
Qrt 2010 HSE officer to 20000
increased so that this to ascertain the levels of the gases in ambient air
monitor ambient air
gas is dispersed over a the work area. monitoring.
quality
large area.

Page 39 of 54
Priorit SUCCESS REVIEW BY
RECOMMENDATIONS ACTION(S) TIME SCALE RESPONSIBILITY COST
y CRITERIA DATE
Some hazards, like generation of
dust from the treated OBM cuttings
need more detailed attention as the Activity wise
same has become a nuisance review of hazard
during the summer months when identification.
the wind velocities are considerably HSE Manager,
Hazard identification to be
high and the dust is airborne thus By end of Nov Operations AED Installation of End of 1st Quarter
3 reviewed to include other
causing harm to the camp 2009 Manager, Site HSE 10000 system for 2010
pertinent hazards
residents. This storage space/area Officer spraying of
shall be enclosed by walls and water over OBM
water spraying to be carried out at cuttings
frequent intervals to keep the dust
settled.
Handling of waste in
STP & housekeeping
staff can cause
AED 800
diseases caused by Carryout medical assessment/ Medical
Every six per
4 Bacteria, Virus. Such examination of employees handling Operations Manager examination Annual IMS audits
months employe
employees shall be waste in STP. report
e
monitored for their
health at six monthly
intervals

The OBM pit wall in the


verge of collapse due
Construction of
to weld failure. A Construct a reinforced concrete pit
By end of AED concrete pit to Monthly HSE
5 reinforced concrete shall be erected to contain all the Operations Manager
year 2009 30000 contain all the Inspections
bund shall be erected OBM cuttings
OBM cuttings
to contain all the OBM
cuttings

Page 40 of 54
Priorit SUCCESS REVIEW BY
RECOMMENDATIONS ACTION(S) TIME SCALE RESPONSIBILITY COST
y CRITERIA DATE

Static Charges - The


diesel storage tanks
are not earthed for
Monthly HSE
dissipation of static
Inspections,
charges, such tanks Provision of adequate earthing
By end of 1st AED Provision of Periodic testing by
6 shall be provided with arrangement to be made for the diesel Operations Manager
Qrt 2010 12000 earth connection electrician for
earth connections to tanks
checking
dissipate the static
continuity.
charges produced
during filling / pumping
operations

Use of compressed air


All employees to be briefed on the Attendance
to clean coveralls to
hazards of compressed air and suitable record, pressure
get rid of the dust to be By end of HSE Inspection
7 sign to be posted. Further such Operations Manager AED 500 reducing device
stopped as this might October 2009 Nov 2009
connection shall be fitted with pressure fitting, safety
cause serious harm to
reducing devices. signs posted
the employee

Page 41 of 54
9. REFERENCES / BIBLIOGRAPHY

1) UAE Federal Government (2002), Law 1 of 2002 regarding the regulation and control of the
use of radiation sources and protection against their hazards, UAE federal Government, UAE,

2) UAE Federal Government (1980), Law 8 of 1980 - On regulation of labour relations, UAE
Federal Government, UAE

3) UAE Federal Government (1999), Law no. 24 of 1999 Protection and the development of
the environment, UAE Federal Government, UAE

4) UAE Federal Government (1982), Ministerial Decision 32 of 1982 Determination of


preventive methods and arrangements to protect labourers from work hazards, UAE Federal
Government, UAE

5) UAE Federal Government (1982), Ministerial Decision 37/2 of 1982 Standards of medical
care which the employer shall undertake to provide his labourers, UAE Federal Government,
UAE

6) Abu Dhabi Municipality (2007), Abu Dhabi Code of practice for construction projects Part
one & two, Abu Dhabi Municipality, Abu Dhabi

7) Abu Dhabi National Oil Company (Various), HSE Codes of practice, ADNOC, Abu Dhabi

8) Abu Dhabi Company for onshore oil operations (Various), HSE Procedures manual, ADCO,
Abu Dhabi

9) BSI (2007), OHSAS 18001:2007 Occupational Health & Safety Management Systems
Requirements, BSI, UK

10) International Organisation for Standardization (2004), ISO 14001:2004 - Environment


Management systems general guidelines on principles, systems and supporting technique,
ISO, Geneva

11) EMDAD LLC (2008), HSE Policy Statement, Rev 4,EMDAD LLC, Abu Dhabi

12) Al Tamimi (2007), The Framework for Litigation in the United Arab Emirates, Al Tamimi, UAE

13) ADCO Medical fitness assessment standard Reference - L-HS-GM-07-065

14) Bansal and Sugiarto(1999), Exploration and Production Operations - Waste Management A
Comparative Overview,

15) Environment Agency Abu Dhabi (2007), letter EPD/07/L/1121 dated 26th Dec
2007,Environment Agency Abu Dhabi, Abu Dhabi

16) ADCO (2007),Contract document contract no. 6500.01, the provision of treatment of oil
based mud cuttings & sludge services by indirect thermal desorption, ADCO, Abu Dhabi

17) http://www.ilo.org/safework_bookshelf/english?d&nd=170000102&nh=0

18) http://www.ccohs.ca

19) http://www.epa.gov/waste/hazard/testmethods/index.htm

20) http://www.emdad.ae

Page 42 of 54
10. APPENDICES

APPENDIX - A

10.1 INTEGRATED MANAGEMENT SYSTEM GAP ANALYSIS REPORT.


The gap analysis was carried out on the integrated management system applied by EMDAD
LLC on the various activities being carried out by the organisation. For the purpose of this
report only the Environmental & Occupational Health & Safety aspects were considered for
the analysis although the company is certified to all the three management systems, i.e
quality, Environment and Occupational Health and safety.

Gap Analysis Report


FOR

EMDAD LLC
ABU DHABI

Prepared By

HSE Manager
PO Box 4118, Abu Dhabi
Reference Standards - ISO 14001:2004 OHSAS 18001:2007
Company Contact(s) - General Manager

Page 43 of 54
INTRODUCTION

Purpose
The gap analysis was necessary to be carried out as this is the critical review of the
established Environment and Occupational Health and Safety Management Systems
implemented in the company. This review of the Integrated Management System
provides the opportunity to identify the gaps between the existing Integrated
Management system which EMDAD LLC has and ISO14001:2004 and OHSAS
18001:2007 standards requirements.

ISO 14001:2004 & OHSAS 18001:2007 Requirements

HSE POLICY
Clause 4.2 HSE policy

Description

1. HSE policy should be appropriate to the nature, scale, environmental


impacts and OH&S risks of its activities, products and services.

2. HSE policy should include commitment to continual improvement, prevention


of pollution and prevention of injury or ill health.

3. Should include commitment to comply with applicable legal requirements and


other requirements to which the organization subscribes which relate to its
environmental aspects and OH&S hazards.

4. HSE policy should provide frame work for setting and reviewing
environmental and OH&S objectives and targets.

5. Communicated to all persons working for or on behalf of the organization and


aware of their individual OH&S obligation.

6. HSE policy should be available to the interested parties and the public

7. Reviewed for continual improvement.

Observations
There is a HSE policy statement found matching to the requirements of ISO
14001:2004 and OHSAS 18001:2007 standards.
The HSE Policy statement includes commitment to prevent injury or ill health.

Policy clearly demonstrates commitment to comply with applicable health and


safety, legal and other applicable requirements, however it was noticed that

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the compliance to the requirements of article 12 of Ministerial decision 37/2 is
not being complied to by maintaining a register of occupational illnesses and
injuries and reporting of the same to the ministry as is prescribed in article 12.

Further the compliance to ADCOs medical fitness assessment standards 12 is


not complied with.
The policy has frame work for setting objectives and targets for OH&S
management system, these objectives and targets are set for various
projects of EMDAD LLC. These objectives and targets are however not very
effectively communicated to the employees. The line managers must be
entrusted with this job of ascertaining those personnel working under him are
aware of the OH&S objectives and targets that they have been assigned to
so that its implementation and achievement can be carried out.
Policy was communicated to all employees and interested parties, this
process can be further improved by conducting road shows to elucidate the
contents of the statement to the employees in the presence of Senior
Management personnel.
HSE policy is available to the interested parties and public on demand and is
also publically available on the company internet (www.emdad.ae) in three
different languages, namely English, Arabic and Hindi for the benefit of those
who understand these languages
The policy is reviewed for continual improvement; the last review was carried
out in December 2008 when the same was revised (revision no. 4) to include
the arrangements to comply to the requirements of the ISO 14001:2004 and
OHSAS 18001:2007 standards.

PLANNING

ISO 14001:2004Clause 4.3.1 Environmental aspects

Description

1. Identify the environmental aspects of its activities, products and services

2. Determine those aspects that have or can have significant impact(s) on the
environment.

Observations

12 ADCO Medical fitness assessment standard L-HS-GM-07-065

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Environmental aspects were identified for COMPANY activities, products and
services. However some aspects, like generation of dust from the treated
OBM cuttings need more detailed attention as the same will become a
nuisance during the summer months when the wind velocities are
considerably high and the dust will be airborne thus causing harm to the
camp residents.
Environmental aspects identified has been categorised into significant
aspects and an environmental programme is established to control these
aspects. Inclusion of the aspects affecting camp residents to be considered
and taken into account when establishing control programmes.

OHSAS 18001:2007 clause 4.3.1 hazard identification, risk assessment and


determining controls

Description

1. Identify the OH&S hazards of its activities including contractors and visitors
and assessing their risk.

2. Identify the appropriate application of controls for its risks.

Observations
OH&S hazards have been identified for COMPANY for its various activities.
This hazard identification however does not include hazards such as potential
radiation harmful effects from OBM cuttings, their assessment and control,
exposure of workers to communicable diseases when living in a camp
environment, there is also very generic identification of hazards to visitors
visiting the workplace,
Appropriate controls have been identified for the hazards identified but do not
fully address the risks present in the facilities and on the project.

Clause 4.3.2 legal and other requirements

Description

1. Organization shall identify and have access to the applicable legal and other
requirements to which the organization subscribes related to its
environmental aspects and OH&S hazards.

2. Determine how these requirements apply to its environmental aspects.

3. The organization shall communicate relevant information on legal and other


requirements to persons working under the control of the organization and

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other relevant parities.

Observations
EMDAD LLC has identified the applicable legal and other requirements
related to its environmental aspects and OH&S hazards on the various
projects and facilities.
A detailed review has been carried out to identify the activities to which these
legal and other requirements are applicable.
The organization has communicated such information to the employees and
interested party via emails. It is recommended that this to be presented to all
employees using various presentation methods so as to communicate such
requirements to all concerned. Such legislation shall also be made available
in a central location and controlled by an appointed person so that the same
is available to employees who require access to such legislation and other
requirements to which the company has subscribed to.

Clause 4.3.3 Objectives, targets and Programmes

Description

1. Measurable and quantifiable HSE objectives for all the relevant functions
in the organization shall be defined.

2. Resources required to achieve HSE objective are identified and planned.

3. Shall take into account the significant environmental aspect and legal and
other requirements when establishing the HSE objectives

4. The organization shall establish programmes for achieving the HSE


objectives which shows:

a. the designations of responsibilities for achieving these objectives


and targets at relevant functions and levels

b. The means and time frame by which they are to be achieved

Observation
HSE objectives and targets established for the relevant functions and levels
in COMPANY have been established. These objectives and targets are
however not very effectively communicated to the employees. The line
managers must be entrusted with this job of ascertaining those personnel
working under him are aware of the OH&S objectives and targets that they
have been assigned to so that its implementation and achievement can be
carried out.

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Resources required to achieve HSE objectives have been identified and a
detailed Environmental & OH&S management plan established. Resources
and responsibilities for communication of such objectives and targets to the
employees need to be established.
Quarterly monitoring of the implementation of HSE objectives is carried out
and any objective that is not met is carried forward to the next quarter for
implementation. This process is to be applied company wide operations
covered under the Integrated Management System.

IMPLEMENTATION AND OPERATION

1.4.1 Resources, roles, responsibility, accountability and authority

Description

1. Provision of workspace, associated facilities, equipment, hardware,


software, supporting services (transport, communication etc).

2. Functions within the organization shall be identified and interactions with


other functions shall be defined.

3. Assignment of resources based in order to maintain and implement HSE


and continually improve its effectiveness.

4. Assignment of resources to ensure prevention of pollution and eliminate/


minimize where possible OH&S hazards by having proactive approach
rather than reactive approach.

5. Assignment of personnel based on the competencies.

6. management shall appoint a specific management representative(s) who,


irrespective of other responsibilities shall have defined roles,
responsibilities and authority for:

a. Ensuring the Management system is established, implemented


and maintained in accordance with the standards requirements.

b. Reporting to the top management on the performance of the HSE


system

Observations
COMPANY is committed to provide quality work environment, risk free
and environmental friendly to its employees and the environment. All
necessary facilities required to perform to the best standards are
available for the employees.

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Transportation facilities are available to the employees to fulfil their duties
outside the COMPANY premises.
Assignment of resources in the organization is based upon the
competency level in order to improve overall of the HSE management
system.
Competent team members have been hired to provide quality services to
the valued customers, with maximum safety that could be affecting any
interested party while maintaining the environment in efficient way.
There is appointed management representative in the organization to
control the QHSE Management System in accordance with the various
standards requirements.

Clause 4.4.2 competence training and awareness


Description

1. Human resources should be competent, educated, trained, skilled and


experienced.

2. Assignment of personnel based on the competencies.

3. Personnel must be aware of the relevance and importance of their


contribution in the HSE objectives.

4. Records of training must be maintained.

5. Awareness among the employees upon importance of their activities and


contribution to the achievement of the HSE objectives.

Observation
COMPANY team members are competent and educated in their
respective fields. Training is one of the important elements in EMDAD
corporate culture. Company believes in continuous enhancement of team
members skill in order to produce quality results.
Trainings records are being maintained by the HR department. Team
members also keep the records with themselves as well.
Employees in the organization are aware of their responsibilities; however
approved job descriptions were not available for reference.
Awareness among employees upon the importance of their activities to
the achievement of the HSE objectives is as desired but there is scope for
further improvement.

Clause 4.4.3 Communication, participation and consultation

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Description

1. Effective communication system with regard to the organizations OH&S


hazards, Environmental impacts and HSE management System should be
established for:

a. Communicating internally among various functions and levels.

b. Communicating externally with contractors and other visitors to the


work place.

c. Receiving documenting and responding to relevant communications


from external interested parities.

2. The organization shall decide whether to communicate externally about its


significant environmental aspects. If the decision is to communicate, the
organization should implement method(s) for this external communication.

3. the organization should establish and implement procedure for workers and
contractors involvement in:

a. Hazard identification, risk assessment and determining controls.

b. Incident investigations development.

c. Review of the HSE policy and HSE objectives by workers.

Observation
Effective communication system is implemented; this process can be
further enhanced by frequent Management HSE walkabouts to
demonstrate management commitment.
The organization has taken the decision to communicate its significant
aspects to the interested parties and has done so with its clients and sub
contractors.
Procedures have been established for hazard identification, incident
investigation; however the hazard identification process is not complete in
all aspects as this has not covered some likely hazards associated with
the projects. Incidents are investigated but trends are not established to
have better understanding for implementation of controls.
Participation of employees in the review of HSE policy and establishment
of HSE objectives to be promoted.

Clause 4.4.6 Operational control

Description

The organization should decide which operational control / actions to be taken


and plan them effectively to meet the HSE objectives including objectives related

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to significant environmental aspects, OH&S hazards and legal and other
requirements, where in their absence could lead to deviation from the HSE policy
and HSE objectives.

Observation
Operational controls to meet the HSE objectives and to comply with the legal
requirements exist. There are some lapses noted which must be rectified for
instance the periodic medical examination of employees, periodic monitoring
of ambient air quality as listed in the contract documents is not being met.

Clause 4.4.7 Emergency preparedness and response

Description

1. Organization should identify the potential for emergency situations.

2. Plan to response to such emergency situations


3. these plans shall be tested periodically where practicable involving relevant
interested parities

4. these plan should be reviewed periodically

Observation
Emergency situations have been identified for the various locations.

Emergency response plan is established and employees trained for the


same.
Emergency response plan is tested in most facilities but on some the
frequency of such tests to be increased, for example in Camp
accommodation.

CHECKING

Clause 4.5.1 performance monitoring and measurement

Description

Organization shall establish procedure to measure the following:

1. Performance of applicable operational control applied for the HSE system

2. Conformity with the organizations HSE objectives, target and programme

3. Corrective and preventive action analysis

4. Performance in meeting the applicable legal and other requirements.

Observation

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Performance monitoring on the projects is carried out on a quarterly basis,
this good practice is to be extended to the other facilities as well.
Corrective and preventive action analysis was evidenced and this is carried
out by the name of ISM (Innovation, Strategy, and Management) process.
However due to the absence of the ISM coordinator this process is not being
timely monitored and as such the process of improvement to the IMS is
delayed.

Clause 4.5.2 evaluation of compliance

Description

The organization shall evaluate its compliance with the applicable legal and other
requirements periodically, and the organization shall keep record of this periodically
evaluation
Observation

Various applicable legal and other requirements to which the organisation subscribes
are reviewed at scheduled intervals. The updated document is available to all
employees on the company intranet.

Clause 4.5.3 Incident investigation, non conformity, corrective action and


preventive action

Description

1. The organization should have a procedure for investigating and analysing


incident.

2. Organization shall plan and manage processes for the continuous


improvement of the HSE management system.

3. A procedure for implementing corrective and preventive action must be


available.

4. organization shall identify and correct nonconformities to mitigate their


environmental impact and investigate the non conformity to avoid its
reoccurrence

5. Review the effectiveness of the corrective and preventive actions shall be


taken.

Observation
Incident investigation and reporting procedure exists and is implemented,
however near miss incident reporting is poor and has scope for improvement.
The HSE incentive process must be maintained to motivate the employees to

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perform well in their respective activities.

Clause 4.4.5 Internal audit

Description

1. HSE audit plan, programme and procedure must be established.

2. There must be adequately trained, independent auditors.

3. Results of audits must be recorded and brought to the attention of the


personnel responsible for the area and to the management.

Observation
HSE audit plan is available and is adhered to. Such audits are being carried
out as full system audit at specified intervals. It is suggested that such audits
to be carried out as process based to audit the process thoroughly the
eliminating any potential non conformities from the system.
There are trained independent auditors.

Clause 4.6 Management review

Description

1. Management Reviews to be carried out.

2. Review inputs include: audit results, evaluation of compliance with legal and
other requirements, communication from external interested parities, result of
participation and consultation, the HSE performance of the organization,
objectives and target achievement, Status of incident investigation corrective
and preventive actions, follow-up from previews Management review,
changes to the Management system, recommendation for improvement..

3. Review output includes: decisions and actions related to possible changes to


the HSE performance, HSE policy, objectives, targets and other elements of
the HSE system, resources for continual improvement.

Observation
Management reviews are carried out at specified intervals.
It is suggested that such reviews to take into account suggestions from client audit
reports

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