TABLE OF CONTENT
The MCF supports the BOKOR Policy for HSE and provides the high-level framework
for the management of HSE. It covers 10 key elements of significant Health, Safety
and Environmental risks, including technical and operational integrity of facilities and
equipment. They are:
1. Capability
2. Health
3. Environment
4. Safety & Transportation
5. Process Safety & Asset Integrity
6. Management of Change
7. Safe Operations
8. CONTRACTOR HSE Management
9. Design, Engineering & Construction
10. Incident Management & Emergency Response
The PMT Project Director shall be accountable for the effective and consistent
implementation of MCF in BOKOR. PMT shall provide the necessary resources,
documented systems and processes in place to support this MCF.
Implementation targets shall be set for each of the elements. The PMT shall ensure
the necessary detailed action plans in order to comply with the deadlines of the MCF.
If theres a deviation from the requirements of the MCF, PMT shall get requires
approval from the respective relevant authority.
HSE philosophies:
The facilities shall be designed, operated and maintained to have the lowest
impact practicable on safety, occupational and public health, society and
the environment throughout its life cycle.
Zero Loss Time Incidents (LTI's) and no long term debilitating illnesses for either
PMT or CONTRACTOR personnel.
BOKOR PMT has established HSE KPI for the execution of this project as follows;
Target
No. KPI PROJECT X
Leading KPIs
1
Project Progress % Completion
2 HSE Plan Progress
% Completion
(monthly)
3 Management Walkabout
100%
(Plan vs. Actual) (monthly)
4
UAUC:Manhours (monthly) 1:250
6
ZeTo Rules Audit 1:5000
7
PTW Verification 1:5
8 Project Regulatory
100 %
Register
Commented [MRBO(1]: Number terlajak satu and
80 % (Based on
9 Touch The Heart Session tak allign
SPOT Scorecard)
Lagging KPIs
1 0
Fatality Accident Rate
2 Lost Time Injury
0
Frequency (LTIF)
3 0
Major Fire
4 Major Loss of Primary
0
Containment(LOPC)
PSM KPIs
Project PSM
1 3.0/4.0
Implementation Review
score
PHA and PSM
2 Implementation Review
100%
recommendations close-
out by PMT/Contractor
PSM Roadshow and PHA
3 80%
Tools Training
attendance by PMT
BOKOR PMT shall demonstrate our responsibility through daily commitment towards
HSE principles:
PROCEED only if you are TRAINED, PROTECTED, have a PLAN and are in the right
State of Mind; and
This section is covered in the next section 17, Compliance Related Matter. The national
laws that govern the project among others are:
Factory and Machinery Act [1967]
Environmental Quality Act [1974]
Atomic Energy Licensing Act [1984]
Petroleum (Safety Measure) Act [1984]
Occupational Safety and Health Act [1994]
Marine Accords (SOLAS, MARPOL, EEZ)
Below are some of regulatory requirement which are applicable to the project.
a) EIA requirement The project team has engaged DOE, Kuching and was
advised that no new EIA study need to be done for the project. The EIA approval will
ride onto the previously approved Bokor Phase 3 EOR development project. The
project team will however, need to develop and submit a revised Environment
Management Plan (EMP) Study report for DOE, Kuching approval prior to project
execution.
b) EMP - No new EIA Report submission is required but an update of the Bokor
Phase 3 EOR Environmental Management Plan (EMP) with Betty integration is required
as per Letter by DOE(Ref: AS (SWK) (B): 50/013/802. PMT will engage environmental
consultant to update the existing EMP to address environment and social related issues
and concerns of the project. PMT will ensure compliance with the Bokor EIA Approval
Condition, relevant Malaysian laws and regulations and PSCB Guidelines and policies
on the environment during design, construction, commissioning/start-up and
operation.
c) MDTCC Approval Project Team via PCSBs P&E HSE and MPA will apply for
approval from Ministry of Domestic Trade, Co-operatives and Consumerism (MDTCC)
prior any installation being done offshore (in EEZ). Preparation for this submission
should be done 6 months prior to the installation.
d) PTI & PTO requirement The project team will apply PTI/PTO to DOSH, for
any new hydrocarbon service pipelines. Project Team is required to apply for PTI 2
months prior to installation. Hydrotest for the new hydrocarbon pipeline must be
witnessed by officer from Department of Occupational Safety and Health Malaysia
(DOSH) with a minimum 2 weeks notification. For commissioning and start-up, PMT
shall apply for Permit To Operate (PTO) with a minimum of 2 months prior to the
planned date.
e) Crossing Agreement (if needed) - clearance for this shall be obtain from
relevant parties (e.g. Telekom Malaysia) with a minimum of 6 months prior to
execution.
f) FMA requirement for pressure vessel (above 1 atm bar) MPM requires
the project team to execute Offshore Self-Regulatory (OSR) and documents all the
design data and relevant drawings. Pressure vessel/unfired pressure vessel for
offshore installation has been waived for application of Perakuan Mesin Tekanan (PMT)
from DOSH. This is according to FMA (Exemption To PETROLIAM Nasional Berhad)
2013. Hence, with that exemption, PMT have to follow OSR-Management System, May
2013, Rev 3. The custodian is MPM.
Legal and other regulatory compliance requirements shall be identified and assessed
to determine those that are applicable in relation to Health, Safety, Environmental
impacts to BOKOR. PMT shall ensure that the CONTRACTOR maintains a HSE
Regulatory Compliance Register, relevant to the project scope of work, which is
monitored, reviewed and maintained on an annual basis, to ensure any legislative
change does not adversely affect the project. The Legal Register and compliance
register (BOKOR Regulatory Register) will be tracked and monitored monthly.
PMT shall populate the Organization Chart with key personnel such as Company Site
Representative/Senior Resident Engineer, Resident Engineer and HSE Officers to
undertake the contract administration and provide HSE leadership to the Contractor
project team.
The roles and responsibility of each personnel at all level shall be identified and
communicated. PMT shall provide the necessary resources, documented systems and
processes in place to support the execution of HSE strategy
13.6. HSE Plan
Contractors HSE Plan will be reviewed and approved by PMT after taking comments
from HSE team . Upon approval, Contractor shall cascade the HSE Plan to all sub-
contractors hired by the Contractor. A copy of the approved HSE plan will be forwarded
to HSE PD&T for performance monitoring.
In order to achieve project HSE objectives stated at the HSE Plan the following actions
shall be taken:
Ensure that Contractors comply with all aspects of the design and are in
compliance with the project specifications and drawings and relevant
industrial standards.
Ensure that Contractors fully comply with all the HSE procedures (PTW, JHA
etc.) and safety work practices as stipulated in the existing contract
documents such as HSE Policies, ZeTo rules, HSE MCF and HSEMS, Manual
etc.
Ensure that the requirements outlined inside the approved Contractors' HSE
Plan are implemented such as HSE briefing to workers prior to mobilization,
HSE meetings, HSE trainings, HSE inspections & audits, wearing of Personal
Protective Equipment (PPE), availability of work procedures prior to
commencement of work etc.
Ensure that Contractor has well established Emergency Response Plans. The
ERP shall be bridged when there is concurrent activities/involve multiple
parties i.e. Operations and/ or Drilling.
Ensure that Contractor has adequate medical facilities and medical
evacuation (MEDEVAC) procedures in place.
SK-Oil Asset shall lead the Pre-Activity Safety Review (PASR) with the
involvement of offshore Operations, P&E HSE , and PMT prior to the
introduction of hydrocarbon into the system.
SKO Operation Readiness, Strategy and Assurance (ORSA) shall lead the
Pre-Activity Safety Review (PASR) with the involvement of offshore
Operations, P&E HSE , and PMT prior to the introduction of hydrocarbon into
the system.
Undertake PPMS stage gate reviews e.g. Project Integrated Reviews (PIR),
Project Risk Assessment and Pre-start-up Audit by independent parties from
P&E Line Departments.
PMT site representatives will supervise daily activities to ensure that the
work is performed in a safe and efficient manner and is in accordance with
the specifications and job scope requirements.
Establish a site specific Emergency Response Plan (ERP) prior to mobilization
and covering all activities as specified in the Work Breakdown Structure. This
ERP shall bridge all parties having concurrent activities at site e.g.
Operations, Drilling, Pipe laying.
CONTRACTOR is accountable and responsible for all HSE activities throughout the
duration of the project and shall manage in accordance with their HSE Management
System to be in line with COMPANY HSE Management System (HSEMS).
It is the aspiration and commitment by the PMT that the BOKOR Project will be
completed with the high standard of the HSE practice with no Lost Time Injury
(LTI) case or any Fire/Explosion incident and non-compliance to the environmental
requirements.
8) Audit HSE management conduct HSE site audit, pre-load out inspection
and pre-start up audit
1) Develop and implement HSE plan HSE plan to spell out how does contractor
apply HSE management system to manage the project activities and HSE
hazard including HSE scorecard, HSE competence assurance, incident reporting
and investigation
4) Random drug and alcohol check conduct random drug and alcohol check for
site personnel
13.11.Environment Plan
The environment management shall cover the monitoring and measurement of at least
the following key criteria in meeting PCSB targets, regulatory requirements, permits,
licenses and other requirement in order to conform to operational target. These are:
Emission to air
Effluent discharge to sea
Scheduled waste
TENORM waste
Fuel consumption
The project will develop a revised Environment Management Plan (EMP) as part of EIA
approval condition, to be submitted to DOE, Kuching, Sarawak for approval.
Below are the summary of the responsibilities of the contractor in managing the waste
but not limited to:
b) Pay due regard to the environment by acting to protect air, water, animal and plant
life from adverse effects of project activities, and to minimise any adverse effects
which may arise from such operations in accordance with the legal requirements
and PETRONAS Carigalis environmental policies.
c) Develop site Environment Management Plan (EMP) by incorporating Environmental
Impact Assessment (EIA) Approval Condition from relevant authority, other
applicable environmental requirements, and PETRONAS Carigali requirements. The
Plan shall address among others, waste management procedure relevant
approval/written permission by DOE (e.g. installation of fuel burning equipment,
waste water treatment system, etc.), implementation of recommended mitigation
measures as per approved EIA and EMP, environmental audit programme and, etc.
The plan shall be available before the commencement of any physical activity at
site and shall be regularly updated as conditions change. Project EMP shall also
be adhered to.
The HSE Audits will be developed and scheduled to comply with PETRONAS HSE
Management System. They shall be undertaken to monitor, analyze and record project
compliance with the PETRONAS HSE Management System and PTS. The audit results,
along with nominated correction actions will be forwarded to the CONTRACTOR Project
Manager. Recommended actions from each audit shall be tracked by the Project
Manager.
PMT and CONTRACTOR will develop Tier 1 Audit checklist based on the PETRONAS
GHSED (eg. ZeTo Rules compliance inspection checklist) requirements and program to
comply with BOKOR HSEMS and PTS prior to implementation.
Internal and external audits which may be undertaken during the project will be
documented within the Project HSE Audit Schedule. The HSE management strategy
identified for each project CONTRACTOR will determine the requirements for a formal
audit of their operations and HSE management system.
GPD will carry out a HSE Tier 2 assurance once per year and all the findings will be
reported to the PMT for actions and closeout.