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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.
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.
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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:
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;
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.
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.
The project treats the OBM cuttings supplied by various drilling rigs operating in the Emirate
of Abu Dhabi.
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.
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 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.
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.
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.
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.
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.
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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.
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.
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.
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.
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) 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.
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;
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4.1 PHYSICAL HAZARDS
1 Physical
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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
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.
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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
4 Mechanical
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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High
6 Ergonomic
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
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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High
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
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4.2HEALTH AND WELFARE HAZARDS
1 Ventilation
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
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
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Rating Impact Justification
Sno Hazard
Very Med Very
Low High
Low ium High
4 Sanitary Convenience
6 Drinking water
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5. RISK ASSESSMENT
2) Identifies who may be at risk (employees, cleaners, visitors, contractors, the public,
etc),
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;
The selected hazards were studied to determine its' level of risk. To research the hazard, the
following was looked at:
9) Information about previous injuries, illnesses, "near misses", accident reports, etc.
10 http://www.ccohs.ca
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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
Very Likely Low risk Very high risk Very high risk
Very Likely - Typically experienced at least once every six months by an individual.
Very unlikely - Less than 1% chance of being experienced by an individual during their
working lifetime.
Potential severity of harm - When establishing potential severity of harm, information about
the relevant work activity should be considered, together with:
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)
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.
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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.
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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.
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
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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.
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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.
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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.
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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.
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.
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.
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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.
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.
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8. ACTION PLAN
8.1 MANAGEMENT SYSTEM
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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.
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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
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8.2 HAZARDS AND RISKS
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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
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Priorit SUCCESS REVIEW BY
RECOMMENDATIONS ACTION(S) TIME SCALE RESPONSIBILITY COST
y CRITERIA DATE
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
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
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
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
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10. APPENDICES
APPENDIX - A
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
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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.
HSE POLICY
Clause 4.2 HSE policy
Description
4. HSE policy should provide frame work for setting and reviewing
environmental and OH&S objectives and targets.
6. HSE policy should be available to the interested parties and the public
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.
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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.
PLANNING
Description
2. Determine those aspects that have or can have significant impact(s) on the
environment.
Observations
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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.
Description
1. Identify the OH&S hazards of its activities including contractors and visitors
and assessing their risk.
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.
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.
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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.
Description
1. Measurable and quantifiable HSE objectives for all the relevant functions
in the organization shall be defined.
3. Shall take into account the significant environmental aspect and legal and
other requirements when establishing the HSE objectives
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.
Description
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.
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.
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Description
3. the organization should establish and implement procedure for workers and
contractors involvement in:
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.
Description
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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.
Description
Observation
Emergency situations have been identified for the various locations.
CHECKING
Description
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.
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.
Description
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.
Description
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.
Description
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..
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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