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PETRONAS TECHNICAL STANDARDS

HEALTH, SAFETY AND ENVIRONMENT MANAGEMENT


SYSTEM (HSE MS)

PTS 18.00.01
March 2019

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Health, Safety And Environment Management System March 2019
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FOREWORD

PETRONAS Technical Standards (PTS) has been developed based on the accumulated knowledge,
experience and best practices of the PETRONAS group supplementing National and International
standards where appropriate. The key objective of PTS is to ensure standard technical practice across
the PETRONAS group.

Compliance to PTS is compulsory for PETRONAS-operated facilities and Joint Ventures (JVs) where
PETRONAS has more than fifty percent (50%) shareholding and/or operational control, and includes all
phases of work activities.

Contractors/manufacturers/suppliers who use PTS are solely responsible in ensuring the quality of work,
goods and services meet the required design and engineering standards. In the case where specific
requirements are not covered in the PTS, it is the responsibility of the
contractors/manufacturers/suppliers to propose other proven or internationally established standards
or practices of the same level of quality and integrity as reflected in the PTS.

In issuing and making the PTS available, PETRONAS is not making any warranty on the accuracy or
completeness of the information contained in PTS. The contractors/manufacturers/suppliers shall
ensure accuracy and completeness of the PTS used for the intended design and engineering requirement
and shall inform the Owner for any conflicting requirement with other international codes and technical
standards before start of any work.

PETRONAS is the sole copyright holder of PTS. No part of this document may be reproduced, stored in
a retrieval system or transmitted in any form or by any means (electronic, mechanical, recording or
otherwise) or be disclosed by users to any company or person whomsoever, without the prior written
consent of PETRONAS.

The PTS shall be used exclusively for the authorised purpose. The users shall arrange for PTS to be kept
in safe custody and shall ensure its secrecy is maintained and provide satisfactory information to
PETRONAS that this requirement is met.

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© 2019 PETROLIAM NASIONAL BERHAD (PETRONAS)
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner. PETRONAS Technical Standards are Company’s internal standards and meant for authorised users only.
PTS 18.00.01
Health, Safety And Environment Management System March 2019
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ANNOUNCEMENT

As part of the recent transformation exercise, the PTS numbering system has been revised to 6-digit
numbers and drawings, forms and requisition to 7-digit numbers. All newly revised PTS will adopt this
new numbering system, and where required make reference to other PTS in its revised numbering to
ensure consistency. Users are requested to refer to PTS 00.01.01 (PTS Index) for mapping between old
and revised PTS numbers for clarity. For further inquiries, contact PTS administrator at
ptshelpdesk@petronas.com.my.

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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner. PETRONAS Technical Standards are Company’s internal standards and meant for authorised users only.
PTS 18.00.01
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Table of Contents
PART I INTRODUCTION ......................................................................................................6
1.1 SCOPE .................................................................................................................................. 6
1.2 GLOSSARY OF TERMS .......................................................................................................... 6
1.3 SUMMARY OF CHANGES ................................................................................................... 16

PART II PETRONAS HSE MANAGEMENT SYSTEM ............................................................ 17


1.1 HSE MANDATORY CONTROL FRAMEWORK (HSE MCF) .................................................... 18

PART III HSE MS ELEMENTS ............................................................................................ 20

1. LEADERSHIP AND COMMITMENT ................................................................................ 20


1.1 VISIBLE HSE LEADERSHIP................................................................................................... 20
1.2 PROACTIVE IN MANAGING HSE RISK ................................................................................ 20
1.3 ACCOUNTABILITY & INFORMED INVOLVEMENT .............................................................. 21
1.4 DRIVE HSE CULTURE ......................................................................................................... 21

2. POLICY AND STRATEGIC OBJECTIVES............................................................................ 23


2.1 CONTENT........................................................................................................................... 23
2.2 DISSEMINATION ................................................................................................................ 24
2.3 STRATEGIC HSE OBJECTIVES ............................................................................................. 24
2.4 HSE PLAN........................................................................................................................... 24
2.5 HSE PROGRAMmES AND ACTIVITIES ................................................................................ 25

3. ORGANISATION, RESPONSIBILITIES, RESOURCES, STANDARDS AND DOCUMENTS ........ 26


3.1 ROLES AND RESPONSIBILITIES (ORGANISATION STRUCTURE AND RESPONSIBILITIES).... 26
3.2 HSE ADVISORS/MANAGEMENT REPRESENTATIVE (MR) .................................................. 27
3.3 RESOURCES ....................................................................................................................... 27
3.4 COMPETENCE.................................................................................................................... 28
3.5 CONTRACTOR HSE MANAGEMENT ................................................................................... 28
3.6 COMMUNICATION ............................................................................................................ 29
3.7 LEGAL AND OTHER GOVERNING BODIES’ REQUIREMENTS .............................................. 31
3.8 DOCUMENTATION AND CONTROL ................................................................................... 31

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4. HAZARDS AND EFFECTS MANAGEMENT PROCESS ........................................................ 33


4.1 IDENTIFICATION OF HAZARDS AND EFFECTS .................................................................... 33
4.2 ASSESSMENT ..................................................................................................................... 34
4.3 CONTROL MEASURES ........................................................................................................ 34
4.4 RECOVERY MEASURES ...................................................................................................... 35
4.5 STATUTORY HSE RISK ASSESSMENT REQUIREMENT ........................................................ 35

5. PLANNING AND PROCEDURES ..................................................................................... 37


5.1 ASSET INTEGRITY & RELIABILITY ....................................................................................... 37
5.2 PROCEDURES AND WORK INSTRUCTIONS ........................................................................ 38
5.3 MANAGEMENT OF CHANGE ............................................................................................. 39
5.4 EMERGENCY PREPAREDNESS AND RESPONSE/CRISIS MANAGEMENT REQUIREMENTS . 39

6. IMPLEMENTATION AND MONITORING ........................................................................ 41


6.1 PERFORMANCE MONITORING .......................................................................................... 41
6.2 RECORDS ........................................................................................................................... 42
6.3 NON-COMPLIANCE, CORRECTIVE AND PREVENTIVE ACTION........................................... 43
6.4 INCIDENT REPORTING AND FOLLOW UP .......................................................................... 43

7. ASSURANCE ................................................................................................................ 45
7.1 ASSURANCE PLAN ............................................................................................................. 45
7.2 ASSESSOR COMPETENCY .................................................................................................. 46
7.3 CONTRACTOR ASSURANCES ............................................................................................. 46

8. MANAGEMENT REVIEW .............................................................................................. 47


8.1 MANAGEMENT REVIEW.................................................................................................... 47

APPENDIX 1: PETRONAS HSE POLICY STATEMENT ............................................................... 49

APPENDIX 2: CORRESPONDENCE BETWEEN THE SUB-ELEMENTS OF PETRONAS HSE MS WITH


ISO 14001:2015 AND ISO 45001:2018 ................................................................................. 50

APPENDIX 3: CORRESPONDENCE BETWEEN THE SUB-ELEMENTS OF PETRONAS HSE MS, US


OSHA PSM REGULATIONS AND CCPS RISK BASED PROCESS SAFETY ................................. 55

APPENDIX 4: EXAMPLES OF COMPLIANCE EVIDENCE FOR RELEVANT SUB-ELEMENTS ........... 60

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PTS 18.00.01
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PART I INTRODUCTION

The objectives of this document are to provide:


i. A comprehensive and standardised guidance on all aspects of an HSE Management
System in PETRONAS.
ii. A common framework towards working together with contractors and suppliers in
contract environment.

1.1 SCOPE

This document describes the requirements that shall be used by PETRONAS Group of
Companies, which comprise of holdings company, business/operating units, project
organisations including joint-venture companies where PETRONAS has operational control, to
establish, implement and maintain a HSE Management System (HSE MS).

The above entities are hereinafter referred to as “Organisation”.

1.2 GLOSSARY OF TERMS

1.1.1 General Definition of Terms & Abbreviations.

Refer to PTS Requirements, General Definition of Terms, Abbreviations & Reading Guide PTS
00.01.03 for General Definition of Terms & Abbreviations.

1.1.2 Specific Definition of Terms

No Term Definition
An accident is an incident which has resulted in
actual injury or illness and/or damage/loss to
1. Accident
assets, the environment, reputation, or third
parties.
The ultimate responsibility for an area of
authority defined by the individual’s Job
Description, and will include authority
delegated to a subordinate albeit temporary or
2. Accountability permanent. He/She is answerable for specified
health, safety and environmental
responsibilities particularly connected with
tasks, objectives and targets within their area of
authority. Accountability cannot be delegated.
Work to be carried out as part of a process
3. Activity characterised by a set of specific inputs and
tasks that produce a set of outputs to meet
customer requirements.
Level of risk, objectively assessed, at which the
As Low As Reasonably Practicable time, effort, difficulty and cost of further
4.
(ALARP) reduction measures becomes unreasonably
disproportionate to the additional risk
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Health, Safety And Environment Management System March 2019
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No Term Definition
reduction obtained from the incremental
efforts.

The process of analysing and evaluating hazards.


5. Assessment (or Evaluation) It involves both causal and consequence
analysis and requires determination of
likelihood and risk.
A discrete element of a Business that has a
6. Asset monetary value. Assets include physical plant
and equipment e.g. a refinery, chemical plant,
production platform, retail network, project.
Is the documented assurance that the
equipment and structures remain reliable for
continued service thereby preventing the
release of contents to the environment and/or
7. Asset Integrity is guaranteed to function correctly on demand
either in an emergency or otherwise.
Commonly referred to as the “Mechanical
Integrity” element in the Process Safety
Management requirements.
A systematic, independent evaluation to
determine whether or not the health, safety and
environment management system and its
8. Assurance operation comply with planned arrangements,
and whether or not the system is implemented
effectively, and is suitable to fulfill the
Organisation’s health, safety and environmental
policy and objectives.
Definition of Biodiversity:
The sum of all life on Earth. Biodiversity includes
the diversity of all life forms and the
components of that diversity (plants, animals
and genes) as well as the interactions between
Biodiversity and Ecosystem them (IFC, 2011).
9.
Services (BES)
Definition of Ecosystem Services:
The essential services that support human
needs such as food, water, shelter, clothing,
medicines and fuel (IFC, 2012).

BESRA aims at minimizing threats and


maximizing opportunities to enhance and
conserve biodiversity. It was developed using
Biodiversity and Ecosystem international best practices – International
10.
Services Risk Assessment (BESRA) Finance Corporate (IFC), International Union for
Conservation of Nature (IUCN), International
Petroleum Industry Environmental
Conservation Association (IPIECA), PETRONAS
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No Term Definition
HSE Risk Management. It identifies the risk and
gaps in current operations for continuous
improvements and improving BES data for
PETRONAS operations group-wide

11. CIMAH Report A written report, prepared by a Competent


Person, as required by CIMAH Regulations 1996.
The ability to undertake responsibilities and
perform activities to the relevant standard, as
necessary to ensure process safety and prevent
12. Competence major accidents. Competence is a combination
of knowledge, skills and experience to
undertake work activities in accordance to
agreed standards, rules and procedures.
A pre-established plan to mitigate an unusual
13. Contingency Plan situation which has the potential for harm, which
incorporates the best use of local as well as
remote facilities and resources.
Year-on-year enhancement of overall health,
14. Continual Improvement safety and environmental performance, not
necessarily in all areas of activity, resulting from
continuous efforts to improve.
A formal business agreement detailing the terms
15. Contract and conditions for the supply of products or the
provision of services.
Person (including department or section) within
16. Contract Holder the Organisation who has the budget,
responsibility and management authority to
execute the contract.
A firm which has entered into a legal contract to
supply services or material to the Organisation.
Any reference to Contractors shall, unless
17. Contractor otherwise stated, be taken to include
Consultants, Agents, and other Third Parties who
has entered into similar legal contract for the
supply of services or material to the Organisation.
The consequence of an event attributed to any
18. Effect HSE hazards, normally expressed in terms of
consequences to people, environment, asset
and reputation.
A person who is directly employed by PETRONAS,
19. Employee this includes executives, non-executives,
secondees, secretaries and individuals on direct
hire.

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No Term Definition
The surroundings and conditions in which an
20. Environment organisation operates or which it may affect,
including Biodiversity and Ecosystem Services
(BES) therein.
A study to identify, predict, evaluate and
communicate information about the impacts of
Environmental Impact Assessment a proposed project on the environment including
21.
(EIA) the surrounding community, and to detail out
the mitigating measures prior to project
approval and implementation.
An operational unit consisting of buildings,
containers, or equipment e.g. complex or cluster of
off-shore platforms serviced from the same hub,
22. Facility
gas processing plant, refinery, distribution
terminals, pipelines, depots, warehouses,
workshops, laboratories.

23. Grievance Mechanism A mechanism to manage actual or perceived


impacts cause directly or indirectly by PETRONAS.
The potential to cause harm, including ill health
24. Hazard and injury, damage to property, products or the
environment; production losses or increased
liabilities.
A structured methodology for the identification
of HSE hazards and assessment of the
Hazards and Effects Management associated risks, and development of the
25.
Process (HEMP) control and recovery measures to reduce HSE
risks to as low as reasonably practicable
(ALARP).
The identification of health hazards in the work
place and subsequent evaluation of risk to
26. Health Risk Assessment health, taking account of existing control
measures. Where appropriate, the need for
further measure to control exposure is
identified.
HSE encompass ensuring the Organisation’s
activities, products and services are in
accordance with all legal requirements and
industry best practices to safeguard the health,
safety and wellbeing of our employees,
Health, Safety & Environment
27. contractors, communities and the local
(HSE)
environment.
HSE is taken to include health, safety and
environment, as well as toxicology, product
stewardship, social performance and natural
resources management.

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Health, Safety And Environment Management System March 2019
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No Term Definition
A person(s) with the role to provide specialist
HSE Advisor/ Management HSE advice on HSE matters, in enabling the
28. effective implementation of arrangements
Representative (MR)
specified in the HSE MS, including benchmarking
to international and industry standards.
A demonstration of how the Organisation’s
HSE objectives are being met in a methodical
and accessible reference document. A
29. HSE Case completed HSE Case will provide a reference
document to all information relevant to the
safety and health of the operations personnel,
environment and resources on an installation.
HSE critical activities are activities or measures
that have been identified in the Hazard and
Effects Management Process (HEMP) as vital to
ensure:

30. HSE Critical Activities i. Integrity of an asset and the associated


control and recovery barriers i.e. the safety
critical elements (SCEs).
ii. The effectiveness of operational controls in
order to prevent incidents and/or mitigate
adverse HSE effects.
A systematic review to verify conformance with
the HSE Management System and its associated
arrangements. It shall employ a well-defined
31. HSE MS Assurance
review procedure to ensure consistency and
allow the assessors to reach a defensible
conclusion.
A description of the means of achieving the HSE
objectives. In the case of a project or contract,
the HSE Plan specifies the activities and
32. HSE Plan deliverables with associated resource
commitments to be conducted at different
stages in order to meet the project or contract
HSE objectives.
The Organisation’s policy statement on Health,
Safety, and Environment. It is a public statement
33. HSE Policy of the intentions and principles of actions of the
Organisation regarding health, safety and
environmental effects, giving rise to its strategic
and detailed objectives.
PETRONAS HSE Policy Statement, PETRONAS
34. HSE Standards HSE Standards, strategic objectives, procedures,
and guidelines that make up the total PETRONAS
HSE Management System.

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No Term Definition
Basic standards of treatment to which all people
35. Human Rights are entitled, regardless of nationality, gender,
race, economic status or religion.
Human Rights Due Diligence Procedure to assess and manage human rights
36.
(HRDD) risks.
An event or chain of events which has caused or
could have caused injury, illness and/or damage
37. Incident (loss) to assets, the environment, reputation, or
third parties. An incident involves the release or
near release of a hazard.
Physical harm or damage to a person resulting
38. Injury from traumatic contact between the body of
the person and an outside agency, or from
exposure to environmental factors.
A short document which sets out an employee’s
authority and responsibilities in the job, who he
39. Job Description reports to, and who reports to him; what his
duties are and the qualifications necessary to
perform those duties.
Understanding of the task, job or work through a
40. Knowledge learning experience or study of the “process”
and related subject matter.
An occurrence including, in particular, a major
emission, fire or explosion resulting from
uncontrolled development in the course of an
industry activity, which leads to serious danger
41. Major Accident to persons, whether immediate or delayed or
inside or outside, and installation, or the
environment, and involving one or more
hazardous substances. (Occupational Safety
and Health [Control of Industrial Major
Accident Hazards] Regulations, 1996).
Set of interrelated or interacting elements of an
42. Management System (MS) organisation to establish policies and objectives
and processes to achieve those objectives.
Defines the limit of safe operation permitted
for a particular asset if control and/or
Manual of Permitted Operations mitigation measures are reduced and/or
43.
(MOPO) removed with the objective of maintaining a
tolerable level of risk. Considers combinations of
hazards and hazardous events.

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No Term Definition
The operation, tests, inspections, and
maintenance to assure that SCEs has been
44. Mechanical Integrity designed, constructed, installed, operated and
maintained in a way which minimizes the risk of
releasing highly hazardous chemicals and
energy.

45. Mitigation Measures taken to reduce the consequences of


a potential hazardous event.
Performance criteria describe the measurable
standards set by the Organisation’s
46. Performance Criteria management to which an activity or system
element is to perform. (Some organisations
may refer to performance criteria as goals or
targets.)

47. Performance Indicator Performance Indicators, against which the


targets can be set to measure performance.
To determine what is practicable in the
circumstances, all relevant matters are taken
into account, including:
i. the severity of the hazard or risk in question;
ii. the state of knowledge about the hazard or
48. Practicable risk and any way of removing or mitigating
the hazard or risk;
iii. the availability and suitability of ways to
remove or mitigate the hazard or risk; and
iv. the cost of removing or mitigating the hazard
or risk.

49. Prevention Eliminating a threat, escalation factor or a hazard.

A procedure is a document that:


i. provides series of steps to be carried out in a
50. Procedure logical order for a defined operation or in a
given situation.
ii. describes how an activity is to be performed
and by whom.
Quantitative evaluation of the risk imposed by a
Quantitative Risk Assessment system design, whether those risks are from
51. human, hardware or software failures, or
(QRA)
environmental events, or from combinations of
such failures/events.
All technical, operational and organisational
52. Recovery Measures measures that limit the chain of consequences
arising from the first hazardous event (or 'top
event'). These can:

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No Term Definition
i. reduce the likelihood that the first hazardous
event or 'top event' will develop into further
consequences and
ii. provide lifesaving capabilities should the 'top
event' develop further.

53. Resources The necessary personnel, time, equipment and


infrastructure to carry out a specified task.
Obligated to undertake, or alternatively
54. Responsibility delegate to authorised and competent persons,
specified duties and tasks connected with their
job and position.
A careful consideration by competent people of
the hazards associated with a task. The potential
effect of each hazard, how severe it might be
and the likelihood of it occurring should be
55. Risk Assessment considered to determine the effort required to
make the work site as safe as reasonably
practicable. The whole process of risk analysis
and the evaluation of the results of the risk
analysis against technological and/or economic,
social and political criteria.
The structured hazard analysis methodology
involving hazard Identification, Assessment,
Control and Recovery and comparison with
56. Risk Management Process
screening and performance criteria. To
manage a hazard completely requires that all
four steps must be in place and recorded.
The matrix portraying risk as the product of
probability and consequence, used as the
basis for qualitative risk determination.
Considerations for the assessment of
57. Risk Matrix probability are shown in the horizontal axis.
Considerations are included: impact on people,
assets, environment and reputation. Plotting
the intersection of the two considerations on
the matrix provides an estimate of the risk.
Managing impacts arising from areas of our
58. Social Performance business while contributing to the society in a
responsible manner.

59. Social Risk Assessment (SRA) A procedure to identify and manage social risk
and develop social baseline.
A prescribed set of rules, conditions or
requirements Standard is an all-inclusive term
60. Standards denoting specifications, recommended
practices, procedures, guidelines philosophies,
and handbooks.

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No Term Definition
The broad goals, arising from the HSE policy,
that an organisation sets itself to achieve, and
which should be quantified wherever
practicable. In PETRONAS terminology this
61. Strategic Objectives means objectives. Goals that the
organisation wishes to achieve over the long-
term provides a basis for judging progress and
achievements. Strategies provide the
framework for plans to achieve the
objectives used as a screen for possible plans.
The measurable standards set by PETRONAS
management committee to which an activity
62. Targets or system element is to perform. Essentially,
these are the agreed plans and measurements
used to assess the Organisation’s performance
against the strategic objectives.

63. Top Management People or group of people who direct and


control an organisation at the highest level.
Table 1: Specific Definition of Terms

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1.1.3 Specific Abbreviations

No Abbreviation Description
1. BU Business Unit

2. CHRA Chemical Health Risk Assessment

3. CIMAH Control of Industrial Major Accident Hazards

4. CPO Capital Project Owner


Department of Occupational Safety and
5. DOSH
Health (Malaysia)
6. EAI Environmental Aspects and Impact

7. EIA Environmental Impact Assessment

8. HAZID Hazard Identification

9. HAZOP Hazard and Operability Study

10. HCU PETRONAS Holding Company Units

11. HSE Health, Safety, and Environment


Health, Safety, and Environmental
12. HSE MS
Management System
International Organization for
Standardization, based in Geneva,
13. ISO Switzerland. Produces certification
standards series such as ISO 9000, ISO
14000, etc.
International Ship and Port Facility Security
14. ISPS
(ISPS) Code
15. JV PETRONAS Joint Venture Companies

16. OPU PETRONAS Operating Units

17. PASR Pre-Activity Safety Review

18. PHA Process Hazard Analysis

19. QRA Quantitative Risk Assessment


Table 2: Specific Abbreviations

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1.3 SUMMARY OF CHANGES


This PTS 18.00.01 (March 2019) replaces the previous PTS 18.00.01 (March 2014).

No Changes Description
1. Figure 1: Relationship between PDCA + PETRONAS
HSE MS
1 New
2. Appendix 4: Examples of Compliance Evidence for
Relevant Sub-elements

1. PART I Introduction
i. 1.1 Scope
ii. 1.2.2 Specific of Terms (Updated)
2. PART III
i. 1. Leadership and Commitment (1.1-1.4)
ii. 2. Policy and Strategic Objectives (2.1,2.3)
iii. 3. Organisation Responsibilities, Resources,
Standards and Documents
(3.0,3.2,3.5,3.7,3.8)
2 Amendments
iv. 4. Hazards and Effects Management Process
(4.0,4.1)
v. 5. Planning and Procedures (5.1,5.2,5.4)
vi. 6.Implementation and Monitoring
(6.1,6.2,6.3,6.4)
vii. 7. Assurance (7.1)
viii. 8. Management Review (8.1)
3. Updated Appendix 2 (mapping with latest ISO)

Table 3: Summary of Changes

Internal
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PART II PETRONAS HSE MANAGEMENT SYSTEM

A management system describes the way an organisation is managed with respect to its stated
objectives. It does this by concentrating on critical activities, ensuring that they are properly
controlled and those measurements are made and reported so as to enable monitoring of
overall performance and identification of areas for improvement. Management systems provide
continuity, consistent and structured approach in identifying improvement opportunities, and
can be used to demonstrate that controls supported by procedures and documentation are in
place. The introduction of such systems is required in some areas by legislators. In PETRONAS,
the changing face of the business, including the increasing use of contractors for non-core
business activities requires more, rather than less, formalisation of the business processes.

The benefits and stability afforded by management systems are self-evident, particularly in
helping to identify gaps in the existing management structure. However, for management
systems to be successful, it is essential to avoid rigidity, bureaucracy, over-complexity, and the
suppression of innovative thinking.

The focus must be maintained on the critical issues. Most management systems are founded on
the concept of 'plan,' 'do,' 'check,' and 'act/feedback' (PDCA).

Figure 1 shows how the framework introduced in this management system incorporate the
PDCA concept as aligned to ‘International Organization for Standardization (ISO)’, which can help
new and existing users understand interrelations between PDCA and PETRONAS HSE MS.

NOTE: The numbers given in brackets refer to the element/sub-elements of this HSE MS

Figure 1: Relationship between PDCA + PETRONAS HSE MS


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PETRONAS HSE Management System was established within the context of the PDCA continual
improvement loop. It comprises of 8 main elements covering:
i. Leadership and Commitment
ii. Policy and Strategic Objectives
iii. Organisation, Responsibilities, Resources, Standards and Documents
iv. Hazard and Effect Management Process (HEMP)
v. Planning & Procedures
vi. Implementation & Monitoring
vii. Assurance and
viii. Management Review

1.1 HSE MANDATORY CONTROL FRAMEWORK (HSE MCF)


The HSE Mandatory Control Framework (MCF) contains the mandatory requirements to be
implemented in PETRONAS group-wide.

The MCF supports the PETRONAS HSE Policy Statement and provides clear and prescriptive
requirements related to management of the 10 focus areas of significant HSE risks, including
technical and operational integrity of facilities and equipment. They are:
i. Capability
ii. Health
iii. Environment
iv. Safety & Transportation
v. Process Safety & Asset Integrity
vi. Management of Change
vii. Safe Operations
viii. Contractor HSE Management
ix. Design & Engineering
x. Incident Management & Emergency Response

The implementation of the 10 focus areas is managed through the elements of PETRONAS HSE
management system, as depicted in Figure 2.
i. Leadership and Commitment
ii. Policy and Strategic Objectives
iii. Organisation, Responsibilities, Resources, Standards and Documentation
iv. Hazards and Effects Management Process (HEMP)

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v. Planning and Procedures


vi. Implementation Monitoring and Reporting
vii. Assurance
viii. Management Review

Effective implementation and sustenance of this Management System will ensure compliance
to the requirements of the MCF and, consequently the delivery of improved and sustainable HSE
performance and culture.

Figure 2: MCF Compliance through Effective HSE Management System

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PART III HSE MS ELEMENTS

1. LEADERSHIP AND COMMITMENT

This element sets the expectations on leadership and commitment to strengthen and sustain a
HSE culture that drives sustainable HSE performance.

1.1 VISIBLE HSE LEADERSHIP

1.1.1 Top Management and Leaders at all levels of the Organisation shall demonstrate, visible HSE
leadership in leading and driving a culture in which all employees share a unified commitment
to HSE.

1.1.2 Top management shall as minimum:

i. Set a personal example in day to day work by:

a) Prioritising HSE matters high on the agenda of meetings, from BOARD and downwards.

b) Embedding HSE considerations in decisions and communicating the same expectation


to all employees and stakeholders.

c) Leading or participating in site visits to engage with employees and contractors.

d) Leading or actively participating in HSE meetings (not limited to Management Review,


assurances, incident investigations, HSE Committee, HSE campaigns, etc.)

ii. Ensure the effectiveness and continual improvement of HSE Management System through
a formal review process.

1.1.3 Leaders at all levels shall continuously communicate with employees and contractors with clear
HSE messages through daily job briefings, toolbox meetings and other meetings.

1.2 PROACTIVE IN MANAGING HSE RISK

1.2.1 Top Management shall demonstrate understanding of HSE risks associated with specific
business activities and how they are managed by:

i. Knowing major HSE hazards and risks to the business

ii. Being proactive in target setting by integrating PETRONAS HSE targets and risk mitigation
into business activities including leading (proactive) and lagging (reactive) KPIs and cascade
to all employees & contractors.

iii. Prioritising and providing sufficient resources to manage the risks to ALARP

iv. Taking corrective actions if the existing controls are ineffective


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v. Implementing learnings from Lesson Learnt.

vi. Considering risk throughout asset lifecycle

1.3 ACCOUNTABILITY & INFORMED INVOLVEMENT

1.3.1 Top Management shall as minimum:

i. Embed HSE values in business strategies and plan

ii. Include HSE KPIs into personal scorecard

iii. Jointly develop and discuss HSE plans and targets and indicators with their managers,
employees and contractors for continual improvement

iv. Align KPIs and targets and ensure that performance is evaluated against leading (proactive)
and lagging (reactive) indicators at appropriate levels. Employees shall have HSE targets and
indicators in their performance appraisals

v. Provide direction and expectation to contractors/stakeholders

vi. Attend HSE-related competency trainings

vii. Being personally involved in programme/initiatives that improve HSE

viii. Attend and Chair meetings as required by HSE MS

ix. Take actions against concerns and grievances raised by employees/contractor arising from
incidents, audits, visits, etc.

x. Take overall responsibility and accountability in safeguarding the health, safety and
wellbeing of employees, contractors, as well as effectiveness of the HSE MS.

1.3.2 Leaders at all level shall ensure compliance with applicable laws, regulations and PETRONAS HSE
requirements.

1.4 DRIVE HSE CULTURE

1.4.1 Top Management act as role model by:

i. Assigning responsibility and accountability to manage HSE risks and hold individuals
accountable for their HSE behaviours and performance.

ii. Recognising positive behaviour and take actions against at risk and non-compliance
behaviour.

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iii. Providing and receiving feedback on HSE behaviours and performance, and celebrate
success.

iv. Including HSE behaviours and performance in decisions for performance rewards,
employees’ development and employees’ promotions.

v. Enforcing consequence management on HSE Violations based on appropriate HSE


indicators, as per PETRONAS’ policies and guidelines.

vi. Developing own competence and that of the team.

vii. Protecting employees from reprisals when reporting grievances, incidents, hazards and
risks.

viii. Ensuring compliance with PETRONAS HSE requirements by reporting HSE incidents, near
misses and issues.

1.4.2 Top Management shall further drive HSE culture by:

i. Making deliberate effort and driving programmes to nurture and elevate the maturity of
HSE culture towards generative.

ii. Monitoring and tracking of progress of these programmes

iii. Driving and sustaining HSE conversation at Leadership Team level.

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2. POLICY AND STRATEGIC OBJECTIVES

The Organisation shall have a written HSE Policy in line with the PETRONAS HSE Policy Statement
as a minimum. In setting strategic objectives and developing HSE Plan, the Organisation
management shall consider the overall risk levels of its business activities taking into
consideration the legal requirements, technological change, emerging issues and key
stakeholders expectations.

2.1 CONTENT

2.1.1 The Organisation (with management and operational control) HSE Policy and associated policies
shall be available to relevant parties and shall:

i. Be consistent with the PETRONAS HSE Policy Statement and include commitment to take
reasonable and practicable steps to prevent and eliminate the risk of injuries, occupational
illnesses and damage to properties as well as conservation of the environment.

ii. Be relevant and take into consideration the current and future nature and scale of the
activities, products and services of the Organisation.

iii. Include a commitment to fulfil legal requirements and other requirements.

iv. Include commitment to consultation to and participation of employees and relevant


stakeholders.

v. Be approved and signed by the Top Management of the respective Organisation and be kept
current.

2.1.2 The Top Management of the Organisation shall be the custodian of the HSE Policy and be
responsible for its review. At least once a year the HSE Policy shall be reviewed taking into
account the continued relevance of its intent, scope and adequacy as part of the formal HSE
Management System Review.

2.1.3 Contractor HSE policies shall be consistent with the Organisation policies.

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2.2 DISSEMINATION

2.2.1 The HSE Policy shall be communicated to all employees and key stakeholders e.g. contractors,
visitors, suppliers etc.

2.2.2 The HSE Policy shall be readily available to the public in a language and format that is easily
understood.

2.2.3 All employees and contractors shall be informed of the HSE Policies and their personal role in
meeting the requirements of the policies.

2.2.4 Records shall be maintained to demonstrate that employees and contractors have received this
information.

2.2.5 Any changes in HSE Policy shall be communicated to all employees and contractors.

2.3 STRATEGIC HSE OBJECTIVES

2.3.1 Each Organisation shall establish and maintain documented HSE objectives, at each relevant
function and level within the Organisation.

2.3.2 Strategic objectives shall be in line with the PETRONAS HSE Policy Statement, Corporate
Commitments (e.g. PETRONAS Carbon Commitments and Human Rights), the Organisation’s HSE
Policies, risk profile and business activities taking into consideration the legal requirements,
technological change, emerging issues and result of consultation with employees for the
purpose of:

i. Providing assurance that the HSE MS is established and effectively implemented at site.

ii. Preventing, or reducing identified risks of undesired effects.

iii. Achieving continual improvement.

2.3.3 The strategic objectives shall provide a framework for setting and reviewing HSE Plan and targets
to ensure continual improvement.

2.3.4 The strategic objectives shall be communicated, monitored and updated, as appropriate.

2.4 HSE PLAN

2.4.1 Within its Business Planning Cycle, the Organisation shall prepare HSE targets and plans annually
in line with the Organisation’s HSE Policy and strategic objectives. The targets and plans shall
clearly identify accountable parties and milestones and shall be linked to the Business Plan.

2.4.2 HSE Plans shall cover activities such as exploration, new developments, existing operations,
modifications, acquisitions, abandonment programmes, research and development, product
development, etc.
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2.4.3 HSE Plans shall take into account present and anticipated future legislative and regulatory
requirements, intolerable risks, technological options, financial, operational and business
requirements and expectations of stakeholders.

2.4.4 The Organisation HSE targets and plans shall be communicated to employees.

2.5 HSE PROGRAMMES AND ACTIVITIES

2.5.1 Detailed HSE Programmes and Activities shall be developed to support the annual HSE Plan. The
programmes shall establish clear milestone and schedule with respective accountable parties
assigned. HSE Programmes shall be developed to support the mitigation measures arising from
the risk assessment.

2.5.2 Key Performance Indicators (KPI) shall be established for all HSE programmes.

2.5.3 KPI shall be monitored, tracked, analysed and reported to ensure effective and timely
implementation of the programmes.

2.5.4 All HSE programmes and activities shall be cascaded to relevant departments, communicated
and promoted through various platforms to engage all employees and contractors in enhancing
HSE culture.

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3. ORGANISATION, RESPONSIBILITIES, RESOURCES, STANDARDS AND DOCUMENTS

This element addresses the organisation of people, resources and documentation for sound and
sustainable HSE performance. The Organisation and resources shall be adequate for its purpose.
Responsibilities at all levels shall be clearly described, communicated, understood and
demonstrated. Employees including contractors at each level of the organization shall assume
responsibility for those aspects of the HSE MS over which they have control. Employees
development shall follow a structured competency assessment and training systems.

3.1 ROLES AND RESPONSIBILITIES (ORGANISATION STRUCTURE AND RESPONSIBILITIES)

3.1.1 The organisational structure, roles, responsibilities, authorities, accountabilities and


interrelations (e.g. partners, contractors, regulators) necessary to implement the HSE MS shall
be defined, documented, communicated and reviewed at regular intervals.

3.1.2 The application of the HSE MS to a local operation or plant shall be the responsibility of the local
line management, in accordance with the asset management hierarchy.

3.1.3 All HSE Critical Activities shall be identified and recorded in the HSE MS (See 3.8 Documentation
and Control) and HSE Case(s) (See 4.5 Statutory HSE Risk Assessment Requirement).
Responsibilities shall be assigned for every HSE critical activity and inputs and outputs necessary
for its control recorded. Performance standards and mechanisms for verification shall also be in
place.

3.1.4 Employee’s (the organisation and contractors) competencies for HSE critical activities shall be
defined and responsibilities and requirements associated with the control of the activities
understood by the employee.

3.1.5 The Top Management is accountable to establish a governance structure, which shall show who
is responsible for:

i. Implementation of HSE governance.

ii. Monitoring of HSE performance.

iii. Leading HSE continuous improvement plans.

iv. Managing employees’ HSE capability.

3.1.6 The Organisation’s Top Management is accountable to establish and maintain a governance for
the effective implementation of the HSE MCF as part of the business management system. This
includes defining roles, responsibilities and authorities to implement and comply with the HSE
MCF and the relevant regulations and laws.

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3.2 HSE ADVISORS/MANAGEMENT REPRESENTATIVE (MR)

3.2.1 HSE Advisors/MR shall be HSE competent persons:

i. who meet the relevant regulatory and professional requirements to provide professional
HSE advice

ii. who have sufficient knowledge of the organisation and its activities, and of HSE issues.

3.2.2 HSE Advisors/MR is a role and may be performed by any appointed personnel within the
Organisation irrespective of their designation.

3.2.3 HSE Advisors/MR shall have sufficient authority to ensure HSE MS requirements are established,
implemented and maintained in all locations and spheres of operation within the organisation.

3.2.4 HSE Advisors/MR shall monitor and communicate information on HSE issues and best practice
from internal and external sources.

3.2.5 HSE Advisors/MR shall collate HSE performance reports and maintain HSE performance data for
internal use & external reporting to local authorities.

3.2.6 HSE Advisors/MR shall also regularly report on the performance of the HSE MS to Top
Management for review, as a basis for improvement.

3.2.7 HSE Advisors/MR shall provide input to Top Management for the review and co-ordinate the
preparation and verification of the annual HSE Report, wherever applicable.

3.2.8 HSE Advisors/MR shall maintain a schedule of HSE assurance/inspections and participate in the
review of findings from all assurance/inspections/incident investigations.

3.2.9 The Organisation shall appoint HSE Advisors/MR in its management team for the purpose of
influencing policies, strategies and operations of the Organisation. HSE Advisor/MR shall have
direct access to Top Management of the Organisation.

3.3 RESOURCES

3.3.1 Top Management shall provide sufficient resources to ensure the effective operation of the HSE
MS and effective management of risks. This shall include provision of resources for:

i. prompt rectification of HSE–related deficiencies identified by the organisation or regulators.

ii. on-going verification that HSE Critical Systems function in accordance with the design intent
and objectives.

iii. on-going training to maintain and enhance competencies.

3.3.2 Establish recruitment, selection and placement processes to ensure that personnel are qualified,
competent, and physically and mentally fit for their assigned tasks.

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3.3.3 Ensure current resource levels are sufficient to meet the requirements for staffing all HSE critical
roles and shall be regularly reviewed. Procedures shall ensure that any changes in resource level
do not increase HSE risk e.g. leave rotations shall ensure resource does not drop to a level that
will compromise HSE Critical Activities and shall comply with the requirement in 5.3
Management of Change.

3.4 COMPETENCE

3.4.1 All HSE critical activities shall have defined competency levels recorded in the hazard
register/safety/CIMAH report.

3.4.2 All personnel who perform HSE critical activities require appropriate experience, qualifications
and training to ensure they are competent to undertake these important risk control measures.

3.4.3 An HSE competency assurance process shall be in place for all HSE critical employees (the
organisation and contractors). This process shall be documented and the record of
competencies to be maintained.

3.4.4 The competency requirements of all HSE critical activities shall be periodically reviewed and
improved. The competence of employees shall be reassessed and shortfalls addressed.

3.5 CONTRACTOR HSE MANAGEMENT

3.5.1 Contractor HSE Management shall be based on the principle of only contractors’ employees who
are competent and equipment which meets the Organisation specification, are allowed at the
Organisation’s operations. Incompetent personnel and sub-standard equipment are considered
hazards and thus are not acceptable.

3.5.2 HSE risks shall be formally assessed for every contract prior to the invitation to tender. This shall
include, but not limited to the following:

i. The contract’s activities and operations that impact the organisation

ii. The organisation’s activities and operations that impact the contractors’ employees and

iii. The contractors’ activities and operations that impact other interested parties in the
workplace.

3.5.3 A person, with relevant competency and experience, within the Organisation shall be identified
for every contract as being responsible for all activities in the contracting process and the
execution of the contract.

3.5.4 Contractor HSE competence shall be assessed against the HSE risks in every contract prior to
contract award.

3.5.5 Contractor mobilisation shall be conditional upon receipt of an acceptable HSE Plan based on
the level of HSE risks and suitable interface arrangements to ensure compliance with the
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Organisation’s HSE MS. All high-risk contracts shall have a documented demonstration as to how
the risks from hazards and effects are reduced to ALARP. This can be in the form of a HSE Case
for major contracts or a HSE Plan.

3.5.6 Contracts shall specify an assurance schedule, action to be taken in case of non-compliance with
standards, terms and conditions defining merits and demerits for HSE performance and the
requirement for at least an annual formal review of HSE MS for contracts running for long
periods.

3.5.7 The Organisation shall demonstrate that the HSE MS of contractors are subject to continuous
improvement in the course of execution phase.

3.5.8 Evaluation of Contractor HSE performance shall be conducted as per contract requirement.

3.5.9 The Organisation shall ensure clear deliverables and performance standards are agreed to, and
system are put in place to assure HSE and technical compliance for the purpose of monitoring
of contractor performance throughout the contract period.

3.5.10 The Organisation shall ensure that outsourced functions and processes are controlled. The
Organisation shall ensure that its outsourcing arrangements are consistent with legal
requirements and other requirements and with achieving the intended outcomes of the HSE MS.
The type and degree of control to be applied to these functions and processes shall be defined
within the HSE MS

3.6 COMMUNICATION

3.6.1 The Organisation shall:

i. Establish a formal platform and mechanism for internal and external HSE communication
that encourages two-way communication, consultation and participation on HSE issues for
continual improvement. In establishing the platform and mechanism, the Organisation shall
consider the following:

a) The Organisations’ legal requirement and other requirements

b) Consistency of information communicated with information generated within its HSE


MS.

ii. Provide timely access to clear, understandable and relevant information about its HSE MS.

iii. Determine and remove obstacles or barriers to participation and minimise those that cannot
be removed.

iv. Emphasise the consultation of non-managerial employees on the following:

a) Determining the needs and expectations of interested parties

b) Establishing the HSE Policy Statement


Internal
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c) Assigning organisational roles, responsibilities and authorities, as applicable

d) Determining how to fulfil legal requirements and other requirements

e) Establishing HSE objectives and planning to achieve them

f) Determining applicable controls for outsourcing, procurement and contractors

g) Determining what needs to be monitored, measured and evaluated

h) Planning, establishing, implementing and maintaining an audit programme

i) Ensuring continual improvement

v. Emphasise the participation of non-managerial level employees in the following:

a) Determining the mechanisms for their consultation and participation

b) Identifying hazards and assessing risks and opportunities

c) Determining actions to eliminate hazards and reduce HSE risks

d) Determining competence requirements, training needs and evaluating training

e) Determining what needs to be communicated and how will this be done

f) Determining control measures and their effective implementation and use

g) Investigating incidents and nonconformities and determining corrective actions.

3.6.2 Internal communication platforms shall comprise, as a minimum, an HSE Committee to


deliberate decision making and information from various source of platform. The hierarchy of
HSE meetings and information flows within the organisation shall be described and documented.

3.6.3 Composition and arrangements of HSE committee shall comply with the regulatory or
Organisation’s requirements, whichever more stringent.

3.6.4 Procedures shall also be in place for the management of external communications. At minimum
the procedure shall include identification of the relevant stakeholder, effectiveness of
engagement conducted and proactive mitigation to address potential risk.

3.6.5 Stakeholder feedback shall be established through the Contractor’s and the Organisation’s
Grievance Mechanism.

3.6.6 All employees and contractors shall be aware of key HSE information, expectations and process
for raising concerns through the Contractor’s and the Organisation’s Grievance Mechanism.

3.6.7 All employees and contractors shall be made aware of the relevant workplace hazards and risks,
their HSE responsibilities and their rights in relations to Stop Work Authority, among others,
during their induction. Records of the HSE induction process shall be maintained.
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3.6.8 All employees shall also be made aware of their contribution to the effectiveness of the HSE MS,
including the benefits of improved HSE performance. Employees shall also be informed of the
implications and potential consequences of not conforming to HSE requirements.

3.6.9 Methods shall be in place to motivate employees to be more aware of HSE controls and to
elevate the maturity of HSE Culture. This can include:

i. direct and personal interest shown by a supervisor in his subordinate’s work through
recognition or feedback.

ii. HSE performance boards sited in prominent locations e.g. notice board, website within
intranet with regular update that provides focus to the HSE effort.

iii. establish and enforce consequence management based on appropriate HSE indicators.

3.7 LEGAL AND OTHER GOVERNING BODIES’ REQUIREMENTS

3.7.1 The Organisation shall develop procedures to identify the relevant legal, standards and other
requirement applicable to their operations in a HSE Legal Register. This includes tracking of new
requirements, changes and deviation, and Evaluation of Compliance.

3.7.2 The Organisation shall:

i. conduct evaluation of compliance on annual basis;

ii. take action if needed and

iii. retain documented information as evidence of the compliance evaluation result(s).

3.7.3 All action plans identified to meet new, changes and deviation to the legal, standards and other
requirements shall be endorsed by the Top Management.

3.7.4 The HSE Legal Register shall be kept and maintained to demonstrate compliance.

3.7.5 Communication process shall be established to disseminate the information and changes to the
employees, contractors and relevant third parties.

3.8 DOCUMENTATION AND CONTROL

3.8.1 A system shall be in place for the management and control of documents in paper and/or
electronic format. This shall include formal administration, custodianship and review frequency
requirement for technical correctness and communication of correct use. The appropriate
approving authorities for review and approval shall be established.

3.8.2 The Organisation shall establish, maintain and continually improve an HSE MS manual in
accordance with the requirement of this document. The manual’s scope shall include the

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner. PETRONAS Technical Standards are Company’s internal standards and meant for authorised users only.
PTS 18.00.01
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activities, products and services within the Organisation’s control that can impact the HSE
performance.

3.8.3 The function of the manual is to describe or reference the processes, documents and standards
used to manage HSE and assist employees and contractors in understanding how the
Organisation will meet the objectives of the HSE Policy.

3.8.4 Manual shall be accessible to employees and contractors in the most effective format.

3.8.5 All the documents required for the maintenance of HSE MS shall be identified and controlled to
ensure relevancy. This shall include the HSE Legal Register, Hazard Register, procedures/working
instructions/documents referred in the HSE Manual.

3.8.6 The Management of Change (MOC) process shall be applied for document and data changes, as
well as communication of the changes. Obsolete documentation shall be identified and removed
from circulation.

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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4. HAZARDS AND EFFECTS MANAGEMENT PROCESS

Hazards & Effects Management Process describes the identification of HSE hazards and
evaluation of HSE risks, for all activities, products and services, and development of control and
recovery measures to reduce HSE risks to as low as reasonably practicable (ALARP).

There are four steps in the HEMP process namely: ‘identify’, ‘assess’, ‘control’ and ‘recover’.

An HSE risk assessment shall be conducted for all activities within the control and influence of
the Organisation which include:

i. acquisition, divestment, abandonment or merger of business entities.

ii. design and development, commissioning, operation and decommissioning of facilities and
services.

iii. manufacturing, storage, transport, use and disposal of new and existing product.

The Organisation shall also determine and assess the other risks and opportunities related to
the establishment, implementation, operation and maintenance of its HSE MS, which include:

i. opportunities to adapt work, work organization and work environment to employees

ii. opportunities to eliminate hazards and reduce HSE risks and

iii. other opportunities for improving the HSE MS

The Organisation shall maintain documented information on:

i. The HSE risk and opportunities.

ii. The processes and actions needed to identify, assess, and implement the controls for the
HSE risks, as per plan.

4.1 IDENTIFICATION OF HAZARDS AND EFFECTS

4.1.1 The HSE MS shall include procedures for the systematic identification of the HSE hazards, effects
and aspects’ that may either affect, or arise from, the activities and services of the Organisation.
These shall cover routine, non-routine, start-up, shutdown and emergency operating conditions
and activities, social factors, leadership and the culture involving all personnel inclusive of
contractors working at the Organisation facilities.

4.1.2 Procedures for HEMP shall be based on established PTS and shall include a process for updating
the hazard, effects and aspect/impact inventories/registers as a result of plant facility changes,
process and technology changes or findings from e.g. job hazard analyses, inspections,
assurances or incident analyses and completion of corrective action undertaken to address the
risks. This procedure shall be linked to the Management of Change procedure.
Internal
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4.1.3 The scope of the identification step shall include those activities that the Organisation can have
control of and over which it can be expected to have an influence. It shall cover the whole
lifecycle of an activity.

4.1.4 Identification of HSE hazards shall take into account the hazards identified through assessments
such as, but not limited to CHRA, QRA, CIMAH, Safety Report, Fire Risk Assessment, HAZOP,
HAZID, EAI, EIA, PHA, Social Risk Assessment (SRA), Social Impact Assessment (SIA), Human
Rights Due Diligence (HRDD), Biodiversity and Ecosystem Services Risk Assessment (BESRA),
Product Risk Assessment and PASR. The identification of hazards shall include potential human
failures on situation influencing human performance.

4.1.5 A comprehensive inventory or register of HSE hazards shall be maintained in the Organisation.

4.2 ASSESSMENT

4.2.1 The Organisation shall develop and maintain procedures to assess the HSE risks and significance
of the identified ‘hazard, effects and aspects’ for all operations and assets, compliant with
PETRONAS Technical Standards.

4.2.2 All hazards, effects and aspects/impacts identified in the HEMP process shall be ranked based
on the risk matrix.

4.2.3 A qualitative assessment of risk is adequate for most situations but when the risk level is
intolerable a quantitative risk assessment (QRA) may be required.

4.2.4 In all cases identified risk reduction measures shall be undertaken to bring the risk to a level
deemed 'as low as reasonably practicable' (ALARP).

4.2.5 Risk assessment and significance evaluation methodology taking into account the severity of the
consequence, frequency of the activities and probability of the incident occurrence as per
respective risk assessment matrix.

4.2.6 A complete review of the assessments (hazard register and aspect tables/registers) shall be
conducted at minimum once in every five (5) years. The Organisation shall acknowledge that
risk is dynamic and shall be monitored continuously with proactive actions taken when risk level
has changed. This is to prevent escalation of risk to cause incidents.

4.2.7 Assessments shall be conducted by a team comprising competent personnel and the personnel
directly involved with the risk.

4.3 CONTROL MEASURES

4.3.1 HEMP procedure shall describe the process of establishing control measures based on the risk
assessment. Hierarchy of controls (elimination, substitution, isolation, engineering,
administrative & Personal Protective Equipment) shall be applied to reduce the risk.

Internal
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4.3.2 Control measures identified through risk assessment shall be implemented to bring the risk level
to ALARP. This shall be maintained to ensure its integrity and continual improvement to further
lower the risk.

4.3.3 The control measures established shall be commensurate with the risks where the
responsibilities and accountabilities for their implementation are clearly defined.

4.3.4 Performance against each controls indicator shall be monitored and measured routinely. The
results shall be trended and reviewed.

4.3.5 Control measures shall be reviewed and updated and included in HSE Plans whenever there are
changes in the situation, in light of incidents and/or based on industry best practice.

4.4 RECOVERY MEASURES

4.4.1 HEMP procedure shall describe the process of establishing recovery measures based on the risk
assessment. Recovery measures such as early warning system, medical response, emergency
response, oil spill response, fire-fighting equipment shall be evaluated and applied to minimise
the consequence of the event.

4.4.2 In the operations phase established recovery measures must be maintained to ensure its
integrity and continual improvement to further lower the risk.

4.4.3 The recovery measures established shall be commensurate with the risks where the
responsibilities and accountabilities for their implementation are clearly defined.

4.4.4 Performance against each recovery measures indicator shall be monitored and measured
routinely. The results shall be trended and reviewed.

4.4.5 Recovery measures shall be reviewed and updated whenever there are changes or in light of
incidents, post mortem of drills/exercises and industry best practice and included in HSE Plans.

4.5 STATUTORY HSE RISK ASSESSMENT REQUIREMENT

4.5.1 The Organisation shall identify Statutory Risk Assessment Document and document those critical
operations and installations, which require a fully documented demonstration that risks have
been reduced to a level as low as reasonably practicable (ALARP) to comply with relevant
regulatory requirements e.g. HSE Case, CIMAH, CHRA & EIA.

4.5.2 The Statutory Risk Assessment Document should also accurately reflect current practice at the
location or site and be reviewed as per regulatory requirements.

4.5.3 The Statutory Risk Assessment Document should demonstrate that controls are in place reduce
risks to ALARP.

4.5.4 The Statutory Risk Assessment Document shall detail activities that must be discontinued or
restricted in given circumstances. These circumstances might be when HSE critical equipment is
Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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not available, during adverse weather or when particular non-routine hazardous activities are
being carried out. The Statutory Risk Assessment Document shall be endorsed by the Asset or
Process Owner and by those managing the asset or operation.

4.5.5 Retention period of documents shall be defined according to requirement stated specifically by
the relevant authority.

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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5. PLANNING AND PROCEDURES

This element addresses the planning of work activities, including the risk reduction measures
(selected through the evaluation and risk management process). This includes planning for
existing operations, managing changes and developing emergency response measures.

Adequate standards and procedures shall be in place and understood at the appropriate
organisational levels. Preparation, review and distribution of all key reference documentation
shall be adequately controlled.

Emergency response procedures (including medical, operational and environmental


emergencies) shall be regularly tested.

5.1 ASSET INTEGRITY & RELIABILITY

5.1.1 The Organisation shall establish and maintain procedures which ensure:

i. There is a clearly defined responsibility for asset ownership.

ii. That there is a signed statement of fitness to demonstrate that existing operating facilities,
new facilities and modifications to existing facilities are designed constructed and
commissioned in accordance with PETRONAS’ and external standards, codes and
regulations; wherever applicable as required under local regulatory or PETRONAS
requirement.

iii. Maintenance and safekeeping of written approvals, written notification and


acknowledgements, certificate of fitness and other licenses/documents, as issued by
authority. In Malaysia, example of such documents are as follow, but not limited to:

a) Certificate of fitness for DOSH registered machineries, equipment and pressure vessels.

b) Written notifications and acknowledgements from DOE.

c) Fire Certificate for Building from Fire Department

d) Certificate of Fitness for Occupancy from Local Council

e) International Ship and Port Facility Security (ISPS) for offshore facilities

5.1.2 Authority for approval of deviations from the design intent and/or the existing standards and
codes shall be defined in the Organisation’s Management of Change procedure (See 5.3
Management of Change).

5.1.3 Validation process or original design and subsequent changes shall be defined in the
Organisation’s Management of Change procedure.

5.1.4 The documentation necessary (including the HSE Case/CIMAH) to support operation,
maintenance and inspection is complete prior to facilities start-up.

Internal
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5.1.5 Those activities and equipment critical in the safeguarding of asset integrity shall be identified
and documented in the HSE MS (typically in the HSE Case/CIMAH, Operating Manual and
Maintenance Plan).

5.1.6 The technical and operational integrity of asset (facilities and equipment critical in the
safeguarding of asset integrity during the life cycle) shall be maintained, performance tested,
and inspected.

5.1.7 A clear maintenance and inspection philosophy and strategy shall be established in order to
develop a comprehensive plan covering both reactive and preventive maintenance.

5.1.8 That the design of new facilities shall be in line with the Hazard and Effects Management Process.
(See 4.0 Hazards & Effects Management Process)

5.1.9 Human factors consideration shall be taken into account during the design, construction,
operations, maintenance and decommissioning of any facilities and plants including
modification works.

5.1.10 Human factors implementation at different sites shall be driven by the needs of each site and
shall be tailored made for each site.

5.1.11 Human factor performance data shall be analysed to identify the human factors issues with
appropriate intervention plans developed, covering the use of different human factors tools
described in the related human factors PTS.

5.2 PROCEDURES AND WORK INSTRUCTIONS

5.2.1 All HSE Critical Activities arising from risk assessment and the supporting tasks (arising from
HEMP 4.0) shall have written procedures or work instructions where the absence of such written
procedures could result in infringement of the HSE Policy, or breaches of legal, regulatory,
and/or other requirements, or performance criteria.

5.2.2 The appropriate standards and procedures shall be readily accessible to employees, suppliers
and contractors and be written in a way that users will understand. Asset/Area Owner shall
ensure that relevant HSE procedures and requirements or their assets/area are communicated
to suppliers and contractors.

5.2.3 PTS or equivalent the Organisation’s standards shall be consistently applied and any deviation
shall be assessed, reviewed and approved by the Organisation’s management according to
Management of Change procedure.

5.2.4 The HSE MS shall include documented and maintained procedures to monitor the
implementation of the HSE MS which include, but not limited to:

i. progress on close out of audit action items

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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ii. HSE performance including lagging (reactive) KPIs e.g. incidents, deviations, breaches of
standards and leading (proactive) KPIs e.g. assurances, management HSE visits, Unsafe Act
Unsafe Condition (UAUC), etc.

iii. periodic evaluation of compliance with relevant HSE legislation and regulations including
product regulations shall be maintained.

iv. data handling and interpretation including the calibration of critical HSE monitoring
equipment.

5.3 MANAGEMENT OF CHANGE

5.3.1 The Organisation shall maintain written procedures for planning and implementing all changes
(i.e. not only equipment changes but also organisational, people and procedures), both
permanent and temporary, to assess HSE impact and avoid adverse HSE consequences.

5.3.2 The Organisation’s Management of Change procedures shall document the assessment, review
and approval processes, and define the responsibilities and competencies of those involved.

5.3.3 Assessment and documentation of the HSE impact for implementing the change shall be defined
in the Management of Change procedure.

5.4 EMERGENCY PREPAREDNESS AND RESPONSE/CRISIS MANAGEMENT REQUIREMENTS

5.4.1 The Organisation shall develop and maintain emergency plans conforming to regulatory
requirements to manage the response operation and associated external issues.

5.4.2 A process shall be in place to identify and document credible emergency scenarios including
medical (e.g. mass casualty, haze, pandemics (including Avian Flu, SARS, etc.) operational (e.g.
toxic release, LOPC, fire), environmental emergencies (e.g. oil spill), and natural disaster (e.g.
flood, landslide, tsunami, hurricane, haze, drought) that can have impact on People,
Environment, Asset and Reputation (PEAR). The identification of credible scenarios may be
based on a risk management process. Emergency/crisis plans shall be developed and maintained
to ensure effective responses to emergency/crisis situations and to prevent escalation.

5.4.3 There shall be a comprehensive tiered Emergency Response Plans, Oil Spill Response Plans,
Business Unit Crisis Management Plans, Country Contingency Plans and integration with
external agencies as appropriate. This shall be compliant with local legislation and PTS
requirement. The plan shall include (but not limited to):

i. Emergency/crisis organisation structures and its roles and responsibilities of key personnel,
e.g. Duty Manager, Emergency Response Team (ERT), Oil Spill Response Team (OSRT),
Emergency Management Team (EMT), Country Contingency Team (CCT), Business Crisis
Management Team (BCMT).

ii. Internal and external notification, communication and activation procedures.

Internal
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iii. List of resources and personnel including SMEs.

iv. Post emergency procedures.

v. Training, drill and exercise matrix.

5.4.4 All emergency/crisis plans shall be periodically reviewed at least once in 3 years or as and when
necessary and tested as per PETRONAS requirements.

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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6. IMPLEMENTATION AND MONITORING

This element addresses how activities are to be performed and monitored, and how corrective
action is to be taken when necessary. In principle:

i. HSE performance objectives & targets shall be set to ensure progression towards the long-
term goals of no harm to people, asset, reputation and no damage to the environment.

ii. Performance indicators shall be established, monitored and results reported in a way that
can be verified.

iii. All HSE incidents and near misses with significant actual or potential consequences shall be
thoroughly investigated and reported.

6.1 PERFORMANCE MONITORING

6.1.1 Activities and tasks shall be conducted according to the procedures and work instructions of the
Organisation (See 5.2 Procedures and Work Instructions). The management of the Organisation
shall ensure that there are systems in place to verify that the tasks and activities are carried out
in accordance with these procedures and work instructions.

6.1.2 HSE critical activities with their performance indicators shall be specified, documented and
aligned to PETRONAS’ monitoring and performance standards.

6.1.3 Each critical activity shall be assigned to an accountable party who shall monitor and regularly
report the performance of their activity(s) using the indicators. Performance monitoring of the
critical activities shall cover different levels of accountable parties.

6.1.4 Performance monitoring shall cover both leading (proactive) and lagging (reactive)
measurements.

6.1.5 Proactive measures of performance shall be put in place to measure the implementation of the
HSE MS and the evaluation of stakeholder concerns. Proactive measures such as ‘unsafe act
auditing', 'site inspections', and ‘self-assessments' shall be used to monitor performance and
identify shortcomings.

6.1.6 The Organisation shall regularly measure, record, track and report HSE performance against
objectives & targets set in the HSE Plan (See 2.4 HSE Plan) and in maintaining control (See 4.3
Control Measures & 4.4 Recovery Measure).

6.1.7 The Organisation shall ensure HSE performance data are transparent within the Organisation.

6.1.8 Where monitoring equipment is required for performance measurement and monitoring, the
Organisation shall establish and maintain procedures and retain records for the calibration and
maintenance of such equipment; this also includes monitoring done by third party.

6.1.9 Management shall ensure that HSE performance of individual Employee at all levels are
measured against HSE Objectives and targets, and reviewed periodically.
Internal
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6.2 RECORDS

6.2.1 The Organisation shall establish and maintain procedures for the identification, maintenance
and disposition of HSE records. These shall include, but not limited to:

i. Reports of audits and reviews.

ii. Audit tracking data.

iii. Register of or a means of identifying and accessing legislation applicable to the


Organisation’s activities.

iv. Legally required documents.

v. Situations of non-compliance with HSE Policy Statement, and of improvement actions.

vi. Any incidents and follow-up actions.

vii. Any grievances and follow-up actions.

viii. HSE Communication record

ix. Appropriate supplier and contractor information.

x. Inspection and maintenance reports of HSE critical equipment i.e. equipment providing a
control and recovery function.

xi. Product identification and composition data.

xii. Data obtained from monitoring as input to performance records.

xiii. Results of emergency drills and exercises.

xiv. Training records which include HSE competency requirements.

xv. Management of Change record.

xvi. Related Asset Integrity Record.

xvii. Operations logs

xviii. Occupational Health and Medical Record required by authorities and Organisation.

6.2.2 HSE records shall be legible, identifiable; traceable to the activities involved with retention times
defined. They shall be stored and maintained to prevent loss and unintended use. Where there
are contractual, legislative and regulatory requirements for record keeping, such requirements,
including those relating to duration for the records to be retained, shall be complied with.

6.2.3 Records supporting the performance data provided to the PETRONAS Group on an annual basis
shall be kept in an auditable form.
Internal
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6.2.4 Records shall be maintained, as appropriate to the system and to the organisation, to
demonstrate conformance to the HSE Management System, Group requirements and
international standards and are used in HSE improvement planning.

6.3 NON-COMPLIANCE, CORRECTIVE AND PREVENTIVE ACTION

6.3.1 The Organisation shall maintain procedures for defining responsibility and authority for:

i. the handling and investigating of non-conformances against legislation, regulations,


HSE MS policies, procedures, standards and action items arising from HSE Assurances and
Incident Investigation.

ii. identify root causes and taking action to mitigate any consequences arising from such non-
conformances.

iii. the initiation and completion of corrective and preventive actions.

iv. confirmation of the effectiveness of corrective and preventive action taken.

6.3.2 Any corrective or preventive action taken to eliminate the causes of actual and potential non-
conformances shall be appropriate to the magnitude of problems and commensurate with the
HSE risks encountered.

6.3.3 The Organisation shall implement and record any changes in the documented procedures
resulting from corrective and preventive action.

6.4 INCIDENT REPORTING AND FOLLOW UP

6.4.1 The Organisation shall maintain procedures for the reporting and investigation of hazardous
situations and incidents, which are compliant with the regulatory, Organisation and Group
policies and procedures and applicable international standards.

6.4.2 The Organisation shall foster a culture of openness in reporting all incidents.

6.4.3 Employees shall be aware of the incident reporting procedures and participate in incident
investigations.

6.4.4 Training shall be provided in incident investigation to appropriate employees throughout the
Organisation.

6.4.5 Incidents shall be investigated and analysed in a timely manner, with accountabilities assigned,
and progress on recommended actions monitored until close out.

6.4.6 Any corrective or preventive action taken to eliminate the causes of potential incidents shall be
appropriate to the magnitude of problems and commensurate with the HSE risks encountered,
in accordance to hierarchy of controls and the Management of Change.

Internal
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6.4.7 The Organisation shall implement and record any changes in the documented procedures
pertaining to corrective and preventive action arising from incident.

6.4.8 HSE Hazard and Effect Register shall be reviewed following the incident findings and
recommendations.

6.4.9 Lessons learnt from accidents and incidents shall be disseminated to employees. The
Organisation shall implement learnings from lessons learnt wherever appropriate.

Internal
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7. ASSURANCE

An assurance programme shall be in place to review and verify effectiveness of the management
system. It shall include audits by assessors independent of the process or facility audited.

The Organisation shall retain documented information as evidence of the implementation of the
assurance programme and the assurance results.

7.1 ASSURANCE PLAN

7.1.1 The Organisation shall establish and maintain an assurance programme and procedure for HSE
assurances to be carried out in accordance with PETRONAS Assurance Standard, international
standards and regulatory requirements.

7.1.2 A rolling (e.g. five year) assurance plan shall be established including HSE audits of all facilities
and operations on a fixed time scale appropriate to the facility and the risks associated with the
activity or the operation.

7.1.3 Assurance programmes shall include:

i. First Line HSE Assurance (self-assurance programme undertaken by the Organisation i.e.
Functional Assessment and Management System assessment).

ii. Second Line HSE Assurance (assurance programme undertaken at the Organisation by
PETORNAS Corporate Assurance Providers under Integrated Assurance Unit).

iii. Third Line HSE Assurance (Internal Audit programme undertaken at the respective
Organisation by Internal Audit function which reports to Board Audit Committee).

iv. External audits (audit conducted on the Organisation by external parties, e.g. Insurer,
certification bodies, shareholders.

v. Regulators (Audit/verification/validation/witness by regulators or appointed bodies).

7.1.4 A detailed annual assurance plan shall be in place and cover all business activities including
operations and projects that have been contracted out.

7.1.5 Only competent and appointed personnel shall be part of the assurance team. (See 7.2 Assessor
Competency).

7.1.6 The Organisation shall develop and maintain a system to ensure that audit findings are recorded,
prioritised, corrective actions identified, action parties are assigned and targeted completion
dates are identified, findings tracked to final close-out and communicated to relevant employees
and other interested parties.

7.1.7 Best practices and key lessons learnt shall be captured and shared across the Organisation as
appropriate.

Internal
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7.1.8 A periodic management review shall be conducted covering audit findings/trends and tracking
of action plans. (See 8.0 Management Review).

7.2 ASSESSOR COMPETENCY

7.2.1 HSE Assurance procedures shall specify the requirements of audit teams in terms of competency
and experience in subject or area of the audit.

7.2.2 An Organisation audit focal point or department responsible for the HSE MS assurance process
shall co-ordinate the appointment of competent HSE assessors.

7.2.3 A competency assurance system shall be in place to include the specific requirement on assessor
competency and relevant HSE assessor training and development.

7.2.4 Employees from different functions and departments of the Organisation shall form part of the
HSE Assurance team.

7.3 CONTRACTOR ASSURANCES

7.3.1 The Organisation shall ensure that contractors participate in the Organisation-led joint HSE MS
assurances of the jobs contracted to them.

7.3.2 The Organisation shall ensure that contractors establish an HSE Assurance process and schedule,
which includes external audits carried out by external auditors. Records of audits/assurances
findings and corrective actions shall be retained as per sub-element 6.2 Records.

7.3.3 An HSE inspection/audit programme for all contracts shall be in place monitoring the effective
implementation of the HSE MS and interfaces between the contractor and Organisation.

Internal
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8. MANAGEMENT REVIEW

Management shall regularly review the suitability, adequacy and effectiveness of the system.

The Organisation shall retain documented information as evidence of the results of


Management Review.

8.1 MANAGEMENT REVIEW

8.1.1 A formal process shall be in place for Top/Senior Management to review the suitability,
adequacy and effectiveness of the MS in managing HSE risks and ensuring continuous
improvement in HSE performance.

8.1.2 The Review shall address but not be limited to:

i. the findings of previous reviews.

ii. HSE Performance.

iii. the need to change HSE policies and strategic objectives.

iv. the impact of significant organisational, location or activity changes.

v. the HSE concerns of employees, contractors and external stakeholders.

vi. the provision of adequate resources and competent personnel to achieve HSE targets
objectives and strategies.

vii. audit findings.

viii. HSE MS Self-Assessment.

ix. verification of closure of corrective actions resulting from HSE reviews, assurance/audits,
self-assessments, inspections and incident investigations.

x. review of legal compliance.

xi. relevant communication(s) from external parties including grievances.

xii. significant social impacts including human rights issues on operations.

8.1.3 HSE performance shall be trended and analysed to facilitate decision making.

Internal
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Health, Safety And Environment Management System March 2019
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8.1.4 The outcome from management reviews shall be consistent with the Organisation’s
commitment to continual improvement and shall include any decisions and actions related to
possible changes affecting:

i. HSE performance

ii. HSE Policy Statement and objectives

iii. Resources

iv. Other elements of the HSE management

v. The strategic direction of the organisation.

8.1.5 Management Reviews of the MS shall take place annually at minimum, preferably within the
Business Plan cycle.

8.1.6 The Management Review shall be the basis for setting proactive HSE Objectives, Plan,
Programmes and Targets.

8.1.7 Results of Management Reviews and identified remedial actions shall be documented,
communicated to employees and other interested parties and monitored until conclusion.

Internal
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by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
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APPENDIX 1: PETRONAS HSE POLICY STATEMENT

Internal
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APPENDIX 2: CORRESPONDENCE BETWEEN THE SUB-ELEMENTS OF PETRONAS HSE MS WITH ISO 14001:2015 AND ISO 45001:2018

ISO 14001:2015/ISO 45001:2018 Elements HSE MS Element/Sub-Element


4 Context of the organization
4.1 Understanding the organization and its context 1.2 Proactive in Managing HSE Risks
2 Policy and Strategic Objectives
4.2 Understanding the needs and expectations of workers and other 3.1 Roles & Responsibilities (Organisation Structure and
interested parties Responsibilities)
2 Policy and Strategic Objectives
4.3 Determining the scope of the OH&S management system 3.8 Documentation and Control
4.4 OH&S management system 3.8 Documentation and Control
5 Leadership and worker participation
5.1 Leadership and commitment 1.1 Visible HSE Leadership
1.2 Proactive in Managing HSE Risks
1.3 Accountability & Informed Involvement
1.4 Drive HSE Culture
2 Policy and Strategic Objectives
2.1 Content
2.4 HSE Plan
3.6 Communication
5.2 OH&S policy 2 Policy and Strategic Objectives
2.1 Content
2.2 Dissemination
2.3 Strategic HSE Objectives
5.3 Organizational roles, responsibilities and authorities 3 Organisation, Responsibilities, Resources, Standards and
Documents
3.1 Roles & Responsibilities (Organisation Structure and
Responsibilities)

Internal
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ISO 14001:2015/ISO 45001:2018 Elements HSE MS Element/Sub-Element


5.4 Consultation and participation of workers 1.3 Accountability & Informed Involvement
2.0 Policy and Strategic Objectives
3.6 Communication

6 Planning
6.1 Actions to address risks and opportunities
6.1.1 General 2.3 Strategic HSE Objectives
2.4 HSE Plan
4.0 Hazards and Effects Management Process
4.1 Identification of Hazards and Effects

6.1.2 Hazard identification and assessment of risks and opportunities 4.0 Hazards and Effects Management Process
4.1 Identification of Hazards and Effects
4.2 Assessment
6.1.3 Determination of legal requirements and other requirements 2.3 Strategic HSE Objectives
3.7 Legal and Other Governing Bodies’ Requirements

6.1.4 Planning action 2.4 HSE Plan


4.3 Control Measures
5 Planning & Procedures
6.1 Performance Monitoring

6.2 OH&S objectives and planning to achieve them


6.2.1 OH&S objectives 2.3 Strategic HSE Objectives

6.2.2 Planning to achieve OH&S objectives 2.3 Strategic HSE Objectives


2.4 HSE Plan
2.5 HSE Programs and Activities
7 Support

Internal
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ISO 14001:2015/ISO 45001:2018 Elements HSE MS Element/Sub-Element


7.1 Resources 3.1 Roles and Responsibilities (Organisation Structure and
Responsibilities)
3.3 Resources
7.2 Competence 3.4 Competence
6.2 Records
7.3 Awareness 1.4 Drive HSE Culture
2.2 Dissemination
2.3 Strategic HSE Objectives
3.6 Communication
6.4 Incident Reporting and Follow Up
7.4 Communication
7.4.1 General
3.6 Communication
6.2 Records
7.4.2 Internal communication
3.6 Communication

7.4.3 External communication 3.6 Communication

7.5 Documented information


7.5.1 General 3.8 Documentation & Control - HSE MS
7.5.2 Creating and updating 3.8 Documentation & Control - HSE MS
6.2 Records
7.5.3 Control of documented information 3.8 Documentation & Control - HSE MS
6.2 Records
8 Operation
8.1 Operational planning and control
Internal
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ISO 14001:2015/ISO 45001:2018 Elements HSE MS Element/Sub-Element


8.1.1 General 2.1 Content
3.5 Contractor HSE Management
5 Planning and Procedures
5.1 Asset Integrity and Reliability
6 Implementation and Monitoring
6.1 Performance Monitoring

8.1.2 Eliminating hazards and reducing OH&S risks 4.0 Hazards and Effect Management Process
4.3 Control Measures
5.3 Management of Change
8.1.3 Management of change 1.2 Proactive in Managing HSE Risk
3.7 Legal & Other Governing Bodies’ Requirements
5.3 Management of Change
6.3 Non-compliance, Corrective and Preventive Action
6.4 Incident Reporting and Follow Up
8.1.4 Procurement 3.5 Contractor HSE Management
7.3 Contractor Assurances
8.2 Emergency preparedness and response 4.4 Recovery Measures
5.0 Planning and Procedure
5.4 Emergency Preparedness and Response/Crisis Management
Requirements
9 Performance evaluation
9.1 Monitoring, measurement, analysis and performance evaluation
9.1.1 General 6 Implementation and Monitoring
6.1 Performance Monitoring
8.1 Management Review
9.1.2 Evaluation of compliance 3.7 Legal and Other Governing Bodies’ Requirements

9.2 Internal audit

Internal
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ISO 14001:2015/ISO 45001:2018 Elements HSE MS Element/Sub-Element


9.2.1 General 7.0 Assurance
7.1 Assurance Plan

9.2.2 Internal audit programme 7.1 Assurance Plan

9.3 Management review 8 Management Review


8.1 Management Review
10 Improvement
10.1 General 4 Hazards and Effects Management Process
10.2 Incident, nonconformity and corrective action 6.3 Non Compliance, and Corrective and Preventive Actions
6.4 Incident Reporting and Follow Up
10.3 Continual improvement 1.3 Accountability and Informed Involvement
1.4 Drive HSE Culture
2.1 Content
8.1 Management Review

Internal
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APPENDIX 3: CORRESPONDENCE BETWEEN THE SUB-ELEMENTS OF PETRONAS HSE MS, US OSHA PSM REGULATIONS AND CCPS RISK BASED PROCESS
SAFETY
PETRONAS HSE MS (MCF) US OSHA PSM Regulations CCPS Risk Based Process Safety
Elements Description Sub- Description Element Description Description
element
1 Leadership and 1.1 Visible HSE Leadership Process safety culture
Commitment 1.2 Proactive in Managing HSE Risk Stakeholder outreach
1.3 Accountability & Informed
Involvement
1.4 InvolvementInvolvement
Drive HSE Culture
2 Policy and Strategic 2.1 Content Stakeholder outreach
Objectives 2.2 Dissemination Workforce Involvement
2.3 Strategic HSE Objectives Measurement and Metrics
2.4 HSE Plan
2.5 HSE Program and Activities
3 Organisation, 3.1 Roles and Responsibilities Workforce Involvement
Responsibilities, (Organisational structure and
Resources, Standards responsibilities)
and Documents 3.2 HSE Advisors/ Management
3.3 Representative(s)
Resources
3.4 Competence 2 Training Process Safety Competency
• MCF 1.1 Competence Ensuring competency of personnel through Training and Performance
Assurance training requirement, plans and Assurance
implementation – training on hazards, safe
work practices and emergency operations
3.5 Contractors 3 Contractors Management Contractors management
• MCF 8.1 Contractor HSE Management of contractor through proper
Management selection, effective hazards communication,

Internal
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Page 56 of 64

PETRONAS HSE MS (MCF) US OSHA PSM Regulations CCPS Risk Based Process Safety
safe work practices and performance
monitoring and evaluation
3.6 Communications 1 Employee Participations Workforce Involvement
Participation and involvement of employees
in development and implementation of
safety programs, including communicating
and sharing of PSM information
3.7 Legal and other Standards, Codes, Regulations and
requirements Laws
• MCF 9.0 Design, Engineering
and Construction
• MCF 9.1 Technical Standards
• MCF 9.2 Process Safety
Requisites (PSR)
3.8 Documentation and Control Process Knowledge
• MCF 5.1 Process Safety Management
Information (PSI)
4 Hazards and Effects 4.1 Identification of Hazards and 6 Process Hazard Analysis Hazard Identification and Risk
Management Process Effects Identification, assessment and mitigation Analysis
• MCF 5.4 Process Hazard of process hazards Operational Readiness
Analysis (PHA)
• MCF 5.5 Pre-Activity Safety 8 Pre-Startup Safety Review
Review (PASR) Readiness review to ensure all
• MCF 5.8 Proprietary and outstanding actions are closed-out and
Licensed Technology hazards are addressed and mitigated
Assessment (PLTA) before commencement of activities
4.2 Assessment 11 Trade Secret
4.3 Control Measure Assessment of inherent risks from
4.4 Recovery Measures technologies which have limited

Internal
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4.5 Statutory HSE Risk information due to intellectual property (IP)


Assessment Requirement rights or licensing issues
• MCF 3.3 Environmental
Impact Assessment (EIA)

PETRONAS HSE MS (MCF) US OSHA PSM Regulations CCPS Risk Based Process Safety
5 Planning and 5.1 Asset Integrity and reliability 9 Mechanical Integrity Asset Integrity and reliability
Procedures • MCF 5.6 Mechanical Integrity Prevention of equipment/system failure
(MI)
through reliability and integrity
• MCF 5.7 Design Integrity (DI)
• MCF 9.2 Process Safety management programs
Requisites (PSR) 13 Emergency Response & Preparedness
Establishment and implementation of
emergency action plans to respond and
mitigate process safety events

5.2 Procedure and Work 4 Hot Work Permit Operating Procedures Safe
Instructions Achieving high level of human reliability Work Practices Conduct of
• MCF 4.0 Safety and through PTW system and procedures for Operations
Transportation
• MCF 5.2 Operating
prevention of fire incident in operation
Procedures and maintenance
• MCF 9.1 Technical Standards 7 Operating Procedure
• MCF 7.0 Safe operations Documentation of work methods or tasks
• MCF 2.1 Fitness to work
to ensure the facilities are operated safely
• MCF 2.6 Management of
fatigue and within safety limits
5.3 Management of Change 5 Process Safety Information Management of Change
• MCF 6.1 Management of Management of information relating to
Change
the plant/facility and technology related
to the process
10 Management of Change
Evaluation of hazards arising from changes
to the plant/facility, organization and
procedure
Internal
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PETRONAS HSE MS (MCF) US OSHA PSM Regulations CCPS Risk Based Process Safety
5.4 Contingency and Emergency 13 Emergency Response & Preparedness Emergency Management
Planning Expectations Establishment and implementation of
• MCF 10.3 Emergency emergency action plans to respond and
Preparedness and Response
mitigate process safety events
6 Implementation and 6.1 Performance Monitoring Measurement and Metrics
Monitoring
6.2 Records Process Knowledge
• MCF 7.5 Operations Logs Management
6.3 Non Compliance and
Corrective and Preventive
Actions
6.4 Incident Reporting and 12 Incident Investigation Incident investigation
Follow Up Identification of basic and root causes of
• MCF 10.1 Incident process safety incidents and the
Investigation and Reporting
corrective and preventive actions to
prevent recurrence
7 Assurance 7.1 Assurance Plan 14 Compliance Audit Auditing
Assessment of compliance level to process
safety standards and requirements
through audits
7.2 Assessor Competency 14 Compliance Audit
Assessment of compliance level to process
safety standards and requirements
through audits
7.3 Contractor Assurances 14 Compliance Audit
Assessment of compliance level to process
safety standards and requirements
through audits

Internal
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PETRONAS HSE MS (MCF) US OSHA PSM Regulations CCPS Risk Based Process Safety
8 Management Review 8.1 Management Review Management review and
continuous improvement

Internal
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APPENDIX 4: EXAMPLES OF COMPLIANCE EVIDENCE FOR RELEVANT SUB-ELEMENTS

ELEMENT PROCEDURES, DOCUMENTS & RECORDS (non-exhaustive)


1.0 Leadership and Commitment
1.1 Visible HSE Leadership i. The Organisation’s management-level meeting agenda(s)
ii. Site visit records (Management HSE Visit, Contractor HSE
Engagement sessions, etc.)
iii. HSE Meetings Minutes
iv. HSE Management System Review session conducted on the
Organisation Minutes
1.2 Proactive in Managing HSE Risk i. The Organisation’s HSE Risk Profile
ii. HSE Lesson Learnt
1.3 Accountability & Informed i. Business strategies and plans
Involvement ii. Employee appraisal system
iii. Records of HSE-related trainings attended by Top
Management
iv. Minutes of relevant HSE MS meetings
v. Evidence of follow up on Grievance raised by
employee/contractor
vi. Drive HSE Culture
1.4 Drive HSE Culture i. Result of the Organisation’s HSE Culture
ii. Evidence of involvement in HSE Culture improvement
programmes/initiatives
iii. Stop work authority records
iv. Relevant HR records
2.0 Policy and Strategic Objectives
2.1 Content i. PETRONAS HSE Policy Statement
ii. PETRONAS Policy on Substance Misuse
iii. PETRONAS Human Rights Commitment
iv. PETRONAS Carbon Commitment
v. The Organisation’s HSE Policy Statement and all associated
policies
2.2 Dissemination i. Attendance records of employees (the Organisation’s and
contractors’) attending HSE induction/briefing covering HSE
Policy Statement
ii. The Organisation’s communication procedure
2.3 Strategic HSE Objectives i. Business Plan
ii. HSE Legal Register
iii. The Organisation’s Business Plan communications and
monitoring record
2.4 HSE Plan i. Business Plan
ii. HSE Plan
iv. HSE Objectives and Targets
v. The Organisation’s HSE Objectives and Targets
communication record
2.5 HSE Programmes & Activities i. The Organisation’s HSE Legal Register
ii. Departmental HSE programmes and activities
iii. Record of communication to relevant departments
Internal
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ELEMENT PROCEDURES, DOCUMENTS & RECORDS (non-exhaustive)


iv. Risk assessment report e.g. aspect/impact assessment,
HRA, JSA, Social Risk Assessment, Human Rights Due
Diligence, product risk assessments and all accompanying
documentation such as measurements, lab reports,
references documents etc.
3.0 Organisation, Responsibilities, Resources, Standards and Documents
3.1 Roles and Responsibilities i. Organisation Chart
(Organisation Structure and ii. Job Description including HSE responsibilities
Responsibilities) iii. Catalogue and specification of HSE Critical Activities
iv. HSE tasks and targets in employees’ appraisals
v. HSE performance criteria in “scorecards”
vi. HSE Competence Assurance Procedure
3.2 HSE Advisors/Management i. Specification of HSE Critical Activities for which MR is
Representative(s) (MR) responsible for.
ii. Appointment Letter and Job Description of MR.
iii. HSE Inspection/Audit/Review Programme.
iv. Minutes of HSE MS Review meetings.
v. HSE MS Manual and change register.
vi. Audit/Review and the respective follow-up reports.
vii. Annual HSE reports.
3.3 Resources i. Approved Organisation Chart
ii. Minimum acceptable resource levels for HSE critical
activities (manning philosophy)
iii. Leave schedules/rotas
iv. Recruitment, selection and placement/organisation change
procedure
3.4 Competence i. Competence Assurance System Procedures and Records.
ii. Training Matrix.
iii. Training Programmes.
iv. Competence Standards.
v. Individual Appraisal.
3.5 Contractor Management i. Contractor HSE pre-qualification procedures.
ii. Assessment of Contract HSE Plans.
iii. Register of contractors, pre-qualified to carry out
Organisation’s work.
iv. Records/database of contractor performance on existing
and previous Organisation’s contracts.
v. HSE Cases and HSE Plans.
vi. Contractor HSE MS and plans (including bridging
documentation).
vii. Database or list of contracts and contract holders.
viii. HAZOP, QRA, project risk assessment etc.
ix. Monitoring reports on HSE requirements as per contracts.
x. Adherence to PETRONAS Contractors Code of Conduct on
Human Rights.
xi. Contract close-out report.
Internal
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ELEMENT PROCEDURES, DOCUMENTS & RECORDS (non-exhaustive)


3.6 Communication i. Procedure for internal communication and reporting
ii. Procedure for managing external communications
iii. HSE Meeting Minutes
iv. Incentive and suggestion schemes
v. Register of complaints grievances from employees (via
specific HR channels), customers, service providers (e.g.
logistics providers), regulators and public community
vi. Register of suggestions for improvement
vii. Overview of meeting types, frequency, participants,
objectives etc.
viii. Employee HSE MS training record
ix. Company communication evidence
x. Evaluation of compliance record
xi. Outsourcing procurement and contractor management
procedure
xii. Record of HSE Committee (e.g. appointment letter &
minutes)
xiii. Organisation’s Management Review record

3.7 Legal and Other Requirements i. HSE Legal Register


ii. Host Country Legislative Requirements Register
iii. Applicable standards and other requirements (e.g. Paris
Agreement and member nations Nationally Determined
Contribution (NDC), Basel Convention, Montreal Protocol,
United Nations Guiding Principles on Business and Human
Rights (UNGP), host country National Action Plans on
Business and Human Rights etc.)
v. Evaluation of Compliance record
vi. The Organisation’s Legal and other Requirements
Communication record.
3.8 Documentation and Control i. The Organisation’s HSE Management System Manual
ii. Documentation Management and Control Procedure
iii. Procedure to manage key work processes
4.0 Hazards and Effects Management Process
4.1 Identification of Hazards and i. Hazard register
Effects ii. Environmental Aspect Impact Register
iii. Environmental Impact Assessment Report
iv. Chemical Health Risk Assessment Report
v. Quantitative Risk Assessment
vi. Control of Industrial Major Hazard
vii. Safety report
viii. Fire Risk Assessment
ix. Hazard Operability Study
x. Manual of Permitted Operations (MOPO) [Applicable to
E&P]
xi. The Organisation’s HEMP Procedure
Internal
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ELEMENT PROCEDURES, DOCUMENTS & RECORDS (non-exhaustive)


xii. The Organisation’s Standard Operating procedures and
work instructions
xiii. PTS 18.04.02 Hazards and Effects Management Process
xiv. Occupational Health Record
xv. HSE Critical Activity Catalogue
xvi. Ergonomics assessment
4.2 Assessment Refer to 4.1 Identification of Hazards and Effects
4.3 Control Measures Refer to 4.1 Identification of Hazards and Effects
4.4 Recovery Measures i. Emergency Response Call Out and Duty Roster (internal)
ii. Contact numbers for external agencies
iii. Emergency Response Procedures
iv. Oil Spill Clean-up Procedures
v. Medical Emergency Procedures
vi. Post mortem report of emergency exercise/drill
vii. Emergency exercise/drill/training plan
viii. Hazard and Effect Register
4.5 Statutory HSE Risk Assessment Refer to 4.1 Identification of Hazards and Effects
Requirement
5.0 Planning and Procedures
5.1 Asset Integrity and Reliability i. Change Control Register (deviation from original or existing
designs).
ii. Variance Control Register (deviation from codes and
standards).
iii. HSE Cases/CIMAH.
iv. Operating Manual.
v. Maintenance and Inspection Strategy, plan & records.
vi. Organisation’s design and engineering practices.
vii. Management of Change Procedure (e.g. design,
construction, operation, inspection).
5.2 Procedures and Work i. Procedures and Work Instructions.
Instructions ii. List of operation and maintenance procedures and
instructions.
iii. List of HSE procedures.
iv. Document control procedures.
5.3 Management of Change i. MOC Register and records.
ii. Management of Change Procedure.
5.4 Emergency Preparedness and i. Records of emergency training, drills and exercises
Response/ Crisis Management ii. List of credible scenarios and Incident Action Plans
Requirements iii. Drills and exercise post mortem report
iv. Emergency/crisis plans and mutual aid plan (where
applicable)
v. Relevant PETRONAS Technical Standards
6.0 Implementation And Monitoring
6.1 Performance Monitoring i. HSE Plan & Targets.
ii. Organisation/Departmental/Asset HSE Performance
measurements/indicators.
Internal
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Health, Safety And Environment Management System March 2019
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ELEMENT PROCEDURES, DOCUMENTS & RECORDS (non-exhaustive)


iii. Register of public complaints community and contractor
grievances.
iv. Register of HSE Performance Indicators.
v. Register of HSE Critical Activities.
vi. Calibration logs.
vii. Compliance Monitoring Procedure & Programme.
viii. Procedure for HSE Reporting and HSE data collection (incl.
accidents and near miss).
ix. Employee appraisal system.
6.2 Records i. Document Management Code of Practice.
ii. Web Management Code of Practice.
iii. Procedure for HSE Data Reporting and Record Keeping.
6.3 Non-Compliance, Corrective i. Register of legislative non-compliance and status.
And Preventive Action ii. Register of non-conformance, corrective action and status.
6.4 Incident Reporting and Follow i. Incident Reporting and Investigation Procedures
Up ii. Incident Investigation reports and analysis
iii. Register of follow up on actions arising from incident
investigations
iv. Medium for lateral dissemination of lessons learned
7.0 Assurance
7.1 Assurance Plan i. Assurance plan or programme.
ii. Assurance procedure.
iii. Audit tracking procedure/system.
iv. Audit/Assurance findings and action status reports.
v. Internal/External Audit reports.
vi. List of approved Lead Assessors and Assessors.
7.2 Assessor Competency i. Assurance Procedure.
ii. Training records.
7.3 Contractors Assurances i. Contractor HSE Assurance Procedure.
ii. As for 7.1 Assurance Plan but for contractors and held by
contractors.
iii. Contractor audit programmes and reports.
iv. PETRONAS Contractors Code of Conduct on Human Rights.
8.0 Management Review
8.1 Management Review i. Report on annual HSE MS Review

Internal
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