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 TABLE OF CONTENTS

Section Table of Contain Page

0.0 Tutor Log.....04

1.0 Executive Summary....05
2.0 Introduction06
2.1 Aims an Objectives..06
2.2 Methodology.....06
2.3 Description of Organizations..07
2.4 Legal Environment...07
3.0 Review of Health and Safety Management System (H&S-MS) Description08
3.1 Descriptions ..08
3.2 Gap Analysis............09
4.0 Hazards Identification.10
4.1 Physical Hazards .......10
4.2 Health & Welfare Hazards .....13
4.3 High Priority Physical Hazards falling from height .14
4.4 High Priority Health Hazards -Sulfur Dioxide (SO2) exposure ...15
5.0 Risk assessment .....15
5.1 Methodology of Risk Assessment ....15
5.2 Risk Assessment for physical hazards falling from heights .16
5.2.1 Identify the hazards..16
5.2.2 Decide who might be harmed and how....16
5.2.3 Evaluate the risks and decide on precautions........16
5.2.4 Record findings and implement .19
5.2.5 Review risk assessment and update if necessary19
5.3 Risk Assessment for health hazards Exposure to SO2.....19
5.3.1 Finding out what the problems are(information gathering)....19
5.3.2 Evaluate the Health Risks ..20
5.3.3 Evaluation of Existing Controls.....20
5.3.4 Recording Risk Assessment findings and implementation..22
5.3.5 Proposed New Control measures.22
6.0 Conclusions..23
7.0 Recommendations ....24
8.0 Action Plan...26
8.0.1 Management System Gap Analysis & Gap Closure Action Plan...26
8.0.2 Cost and Benefit Physical Hazards Falling from Heights 27
8.0.3 Cost and Benefit Health Hazards Exposure to SO2 28
8.1 Hazards & Risk ....30
8.1.1 Physical Hazards Recommendation.....30
8.1.2 Health Hazards Recommendation......32
9 Reference / Bibliography ..33
10 Appendices 33

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1.0 Executive Summary
The report provides overview of current Tadmur Health and Safety management
arrangements with critical review of Health and Safety Management System (H&S-MS). This
will include an evaluation of risk assessment effectiveness respectively on one high priority
physical and health hazards. As improvement new control measures shall be introduced to
further reduce the risks. The recommendations for implementation of these new control
measures will be strengthened with evidence base justification, cost-benefit analysis with
specific action plan to improve company Health and safety performance.

Risk Assessment evaluated using recognized methodology involves physical hazards falling
from heights while working on ladders was rated High Risk. The risk rating reflected as
such due to significant height involves where the person working on ladder cannot maintain
three contact points and probability of falling is likely with fatal consequences. The risk
evaluation exercise successfully manages to further reduce the risk from high to low with
applications of new control measures by using new smart engineered designed platform
ladder. This ladder is designed with working platform, complete with hand rail & middle rails
which allow worker to work with both hands.

Similarly a health Risk Assessment evaluation found workers engaged in activity at AKG are
at high risk on exposure to hazardous Sulfur Dioxide Gas (SO2). This is due to inadequate
collective safety measures in place to provide early warning system to work group. They rely
on personal toxic clips, where plant fixed gas monitor is not strategically located near the
SO2 source or their workplace. New mitigation measures is to strategically place four unit of
Portable Multi-Gas detector which will give workers four minutes advance warning on SO2
hazards. Advance notice means more time to escape to safe area and less likely to be
exposed to such a hazardous gas.

It is estimated that the one-time cost (until project completions) of providing 2 units ladders
and 4 unit of portable gas monitor is eighteen thousand dollars.
Based on detail cost benefit calculations using recognized method, the investment on both
this item clearly indicate that company monetary saving is about one hundred eight thousand
dollars. This significant amount is saved when the probability of injury arising from fall from
height hazards and health exposure to SO2 was brought to low probability at the same time
drastically reduce the consequences throughout the project durations.

Overview of Tadmur H&S-MS satisfactorily demonstrates that they have established policies
and processes, to safely manage the work. Nevertheless there area of improvement or gap
identified during the HSE-MS review process. Issues are insignificant in nature however
need to be attended by providing adequate resources, coaching and mentoring. Concern
including lack of updating legal register, Incident investigations root causes not giving
significant to system factor (organization failures) and Lagging in emergency response plan
implementations.

Exposing personal at high risk is a non-conformance to safety standard set by company,

client as well Qatar legal requirement on related laws, Timely approval by management on
item involving additional cost shall allow all action items implemented without further delay.
All administrative actions item has been progressively implemented. The fundamental
questions need to be asked is not how much it cost but how bit many life it can safe.

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2.0 Introduction
2.1 Aims an Objectives
The aim of assignment is to carry out the detail review of health and safety performance of a
workplace selected and produces a justified action plan to improve safety performance. This
including review of Tadmur health and safety management system as an organization and
indicate using risk assessment, the priorities for organization in future. The assignments will
priorities the identified hazards and carry out a risk assessment on one physical and one
health hazards. This shall include an evaluation of the effectiveness of organization in
controlling the risk from hazards identified and proposed to further control the hazards and
reduce the risks as low as reasonably practical.

Specific action plans proposed with clear accountability measurable, realistic, timely &
effectively implemented. This action plan if successful implementations can be measured for
effectiveness using existing company key performance indicators (KPIs).

Obtain management approval by providing required resources to implement the proposed

new action items. This shall be significant undertaking by the organization to improve
workplace health & safety. At the same time provide data on relevancy of costs involve to its
benefits, nevertheless made them aware of the implications if the action plan not
implemented. Report is structured in a way so that the Management is clear and realizes
that there is important outcome identified both on health and safety issues related to
workplace that must be urgently addressed by company.

2.2 Methodology
As part of my assignment I shall review and conduct gap analysis on Tadmur H&S-MS. The
Gap analysis shall recognized process e to determine where shortfalls occurring in Tadmur
H&E-MS. Use the gap analysis to figure out what is needed to get what currently exists to
the point where it becomes what the company desires (what is needed to get from point A to
point B).

Method of collecting information, data and feedback for assignment will be by participating in
Safety walkthrough, inspection, hazards hunting, list all work activities and look at each step,
look at the ways different tasks could interact and create hazard. Also look at past near
misses incident, accidents, injuries and look at any hazards, safety information and
instructions from manufacturers or suppliers instructions. Most importantly I will talk to
people who have the knowledge on the similar job & finally with direct interaction with
workers involved in the tasks. I obtained additional information by referring to OSHA, HSE
UK and other relevant publications or website.

The process will involve various methods including but not limited to comparisons against
recognized Health & Safety model such HSG65 to determine the continuing suitability,
adequacy and its effectiveness so that we can propose to improve and update an existing
one if required.

Meanwhile the Risk assessments shall be completed using recognized risk assessment tool
combined with research, field observation, local legal applications and information gathering
using various methods. I shall measure the adequacy of existing control measure & residual

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risk, study the consequence & probability of the hazards and identify new control measures.
This will eventually reduce the risks further as low as reasonably practicable (ALARP) and
ensure fully comply with Qatari applicable legal requirements & best practices in the
industry.

2.3 Description of Organizations

Practical workplace assignment focused on one specific project, constructed by a
company called Tadmur ROOTS Energy & Engineering Services W.L.L (Tadmur). The
workplace location is at Ras Laffan Industrial City in Qatar. This project was awarded to
Tadmur by one of world largest single LNG Producer RasGas Company Limited on January
2012. The project is plant labeling project which currently ongoing at our client RasGas sales
gas processing unit called AKG. This is standalone complete processing plant.

The number of workforce engaged in particular project is 292 persons including

administration and management staffs. The organization leads by a Project Manager with
two Construction Managers, four Site Engineers, and 10 Discipline Supervisor. Dedicated
safety section oversees this project lead by Safety Manager with six Safety Officers and one
Safety Administrator. Contractor work force include Skilled/ unskilled, different age group
that range from 19 to 58 years, different ethnical backgrounds and nationalities such as
Indian, Philippines, Pakistan, Qatari, Malaysian and British. Indian nationality made up 60 %
of the total man power in the project, Filipino nationality 25% and the other 15% are equal
representation of Qatari, Malaysian & British mainly on Senior Management levels. No
female, young person or staff with disability engaged either from contractor or clients in the
field.

The project work equipments including various types of work at height equipments,
machinery such as folk-lift, Man-lifts. Mobile crane, pick-up trucks, 3 ton cargo trucks,
passenger bus and some specialized equipment used on ad-hoc on rental basis. Most, if not
all of this machinery & equipment used at sites are relatively new approximately below five
years.

Currently work progresses on day shift, daily work start at 0700 hours and shift end at 1700,
a total of 09 hours. This nine hours shift consists of eight hours of normal working hours and
an hour for lunch break. The work currently 85% completed, well ahead of scheduled 80%
versus actual as of July 2013. The project expected to be completed on December 2013,
twenty four months from the day actual physical work started on January 2012.
The physical work nature is to place color coded self-sticking adhesive label either with
signage such as arrow or wording indicating the product & flow directions on each and every
pipe line, valve and selected equipments covering the AKG plant area. The purpose of
placing the stickers is for operator to easily identify the process flow direction. This project
when completed is expected to improve process safety in particular related incident involving
human error opening wrong valve or operating wrong equipments.

2.4 Legal Environment

HSE Framework issued by Directorate on 5 May 2011 is the main piece of legislation on for
oil & gas industry in Qatar. However HSE Framework is not an independent piece of
legislation, but rather takes the relevant HSE provisions of the various Qatari laws and
regulations and assembles them into a single document. Although the HSE Framework does

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not replace the provisions of existing legislation, it cross-refers specific articles to their
original legislative source, thereby providing valuable assistance and guidance in respect of
complying with the various H&S requirements e.g. Qatar Construction Specifications 2010
(CDS), Qatar Labor Law 14 (2004), Qatar Environmental Law 30 (2002), Civil Defense, Fire
Safety Standards Handbook, Qatars Penal Code, Consumer Protection Law.

A code of practice is admissible in court proceedings as evidence when managing a hazard,

risk or control at workplace of whether or not a duty of care has been complied with.
Approved code of practice applies to anyone who has a duty of care in the circumstances
described in the code e.g. QCS Specifies Legal Duties to duty holders & empowers Qatar
Authorities to prosecute for non-compliance.

Current law mainly Prescriptive Legislation where the law state clearly what must be done or
not done in particular situations. The government is moving towards Goal Setting type law,
which is more relevant in this modern era when things keep changing in fast phase with
benefit of promotion of self-regulation legislation e.g. CDS.

Overall Qatar H&S legislation is influencing company to pursue high standard on H&S by
exceeding the minimum standard set by legal requirement. A major incident at workplace
will result in significant fines, jail term, attract unwanted publicity by media and these can
tarnish company reputations hence is bad for business. Employers are more vigilant and
committed in developing and enforcing H&S programs which can bring about improvements
in safety management and more effective means of preventing harms and preparing for
emergencies.

3.0 Review of Health and Safety Management System (H&S-MS)

3.1 Descriptions
Tadmur is adopting OHSAS 1800, an internationally recognized accredited standard for
occupational health and safety management. It provides detailed requirements for
compliance with the legal requirements. It was awarded to organizations following a
successful audit by an awarding body. Tadmur Management is aware that effective health
and safety system will typically create safer and healthier workplaces, meet customer
expectations better than an organization that does not have an effective H&S-MS comply
with regulations e.g. (Section 11 - Health & Safety: Part 2 SAMAS 2.1 Safety, Health &
Environmental Management System.

Similar to HSG 65, it principles still revolve on plan, do, check, and act. HSG 65 Health and
Safety Management System (H&S-MS) is well known for systematic POPMAR policy,
organization, planning and implementing, measuring, auditing and all elements are cross
referencing with reviewing for Continual Improvements. The fundamental different is that
HSG 65 H&S-MS is not a specification nor it is an approved code of practice. It does not
provide detailed requirements for compliance with the legal requirements for key
management activities such as planning, monitoring, measuring, audit and review. However
it does state that following the guidance will normally be enough to secure compliance with
the law (2) Successful health and safety management.

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Nevertheless HSG 65 H&S-MS provides guidance and advice on good practice and raises
the importance of leadership, employee involvement and gave significant important to health
and safety culture.

3.2 Gap Analysis

Gap Analysis was based on OHSAS 18001 2007 which defines a set of occupational health
and safety management system requirements, review mainly based on sections 4.1 to 4.6 of
these requirements(3) Institution OHSAS 18001 2007OH&S.
This was accomplished by various means of initiative, starting with advance notification
followed up with initial meeting with Tadmur Project Management and Work Supervisors to
discuss the scope, objectives, and activities and schedule to review Tadmur level of
compliances to HSE Management System. The review process was conducted between 3rd
of August to 7th August, 2013. The exercise was scheduled and completed within 5 working
days as planned. Document review mainly conducted in office environment except for
selected document such as Permit to work and its attachments reviewed and audited at work
sites. An on-site review was conducted by interviewing 21 Tadmur full-time personnel
throughout the organization including the Projects Manager and Constructions Manager,
discipline Engineer, Supervisors, Foreman, Permit Holders and all trade employees at office
& work front. The process also included significant numbers of physical workplace visits,
participations in scheduled Management Safety walkthrough, Site Inspection including
checklist based inspections.

Perceptions of the H&S-MS system components currently in place were discussed and
significant important was given in reviewing Tadmur previous internal & external audit
reports. Tadmur satisfactorily demonstrates that they have established policies and
processes, to adequately manage the work. In most fields they exceed the minimum
requirements set by OSHAS 18001 and compatible with Client H&S-MS. Occupational
Health and Safety has Clear policies, documented system in place for continuous
improvement and Leadership commitment found very visible. It describe adequately on how
hazards and effects are to be identified, assessed, controlled and how recovery in the event
of loss of control will be carried out. It also describes how the adequacy of existing controls
is evaluated and additional methods for managing / minimizing the HSE risks are identified
and implemented.

Tadmur define the responsibility for developing and maintaining the H&S-MS and for
establishing H&S accountabilities at each level of the organization. H&S competency levels
defined and training provided to ensure that all employees are aware of, and understand,
their H&S Policy. Implementations of corrective action system are in place to monitor and
measure performance against compliance. Tadmur adopt a structured approach and ensure
that activities and tasks are always conducted according to procedures and work
instructions. Performance monitoring includes both leading and lagging indicators. There is
system in place on efficient communication and consultation on H&S performance as well as
document and data control. Personal who execute this task found Competent. Management
Review system in place to ensure continuous improvement on all aspect of H&S-MS, noted
effective system to develop workforce capability including in-house dedicated training center.
There are audit plans, protocols for conducting the audit, reporting of findings, and tracking
of recommendations for improvement.

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Nevertheless there area of improvement or gap identified during HSE-MS review process.
The Gap Analysis is presented in table format under 8.0 Action Plan heading page 28 for
easy reference, understanding and tracking for close out.

4.0 Hazard s Identification

The workers while carrying out their activity are exposed to wide range of type hazards.
Exposure levels are different depending on their locations and nature of work. Overall the
hazards involved in the workplace can be beaked down to categories such as chemical,
physical, biological, psychosocial, mechanical ergonomics, stress, electrical, fire &
explosions, and traffic.
These hazards identified from workplace through inspections, consultation between
employees and Tadmur Supervisors, monitoring injury & near miss records, recoded
complaints and finally trend analysis from safety unsafe act & unsafe condition observation
program.
Hazard prioritization based on how likely an Injury will happen, how many people could be
affected or exposed. Identify different situations or conditions that may exist could increase
the risk, thinking about the consequences of each hazard Attend most serious risks as
priority e.g. immediately. Minor risks more time is acceptable if required. Finally use existing
RasGas Risk rating register as reference as attached in table below.

4.1 Physical Hazards

The labeling points either on pipes or equipment located at various heights range from
ground level at lowest & approximately 10 meters at highest. The type of ladder used mainly
are twin step A frame ladder which provides rungs on either side of the ladder allowing
one to climb up whichever side is more convenient.

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At about six hundred labelling location at height between 5 to 10 meters the site conditions
congested with piping and structure beam obstructions. This doesnt allow access for mobile
elevating work platform or scaffold platform erections. Since the task is of the short duration,
work ladders are the only realistic option; special design scaffolding will be expensive & not
cost effective. Workers will be working on this A frame step ladder by engaging both of
their hand on the task, as it is not possible to wrap the label using single hand. This exposed
workers to fall from heights hazards & the risk of falling is considerably high & the
consequences will be serious injury or even fatal.
The existing control measures incorporate strict regime of safe work practices while working
on ladders. (4) Safety in window cleaning using portable ladders (5) Safe use of ladders and stepladders
Any work that is identified as meeting the Working at Height criteria will be managed within
the "Permit Pack" as required by the client permit to work system. Ladders only are used for
light work of short duration at area not practical for man lift & not cost effective for scaffold
platform. Ladders inspected by competent person with inspection tag, has a suitable load
rating for the job, daily pre-use check, personnel trained with competency assessed for
working with ladder and Work at Heights. An approved rescue plan is in place, Second &
third person will hold ladder firmly at bottom while third person climbing. A shoulder bag will
be provided for carrying labels while climbing ladder. No other equipment required for the
task. Personnel will not stand on the top three rungs of steps of a stepladder, supervision,
training & instructions.
However due to task nature and site conditions following control measures seen as not
practical and effective.
Using personal fall protection equipment (PFPE)
Maintaining three contact points while working on ladder.
Use of collective fall protection equipment such as air bag or net is also not feasible
due to site conditions.
These hazards shall be further discussed under high priority physical hazards.

Ignitions source -To gained access to height for labeling Man Lift, scissors lifts & similar
type aerial work equipments run by diesel is widely used in this project. The use of such
equipment is rated as high risk fire and explosions hazards in live plant. Operation of this
mechanical equipment strictly control by client operated Permit to work system. Addition
control measures include use of flame arrester on exhaust and boom gate blocking strictly
no go area.

Heat Stress - The summer climate in Qatar is very hot and humid, with summer
temperatures ranging from 30 to 50 C and average relative humidity of 25 to 75%. The
climate creates a potentially dangerous situation (high risk) for personnel exposed to the
heat and humidity. As most of activity involves working at height this significantly increase
the risks secondary effects such as fall from heights. Workers are trained to recognize heat
stress signs and symptoms, as well as environmental conditions, to protect themselves and
others. They are briefed on factors such as age, weight, degree of physical fitness; degree of
acclimatization, metabolism, clothing type use of alcohol or drugs and a variety of medical is
contributing factor.
Administration control includes Work Scheduling, Work-Rest Intervals, Employee Rotation,
Fluid Replacement (provision of coo water & need to carry water bottle while working),
Buddy System, Acclimatization, Reduce Internal Heat Generated by Workers & advisory on
applicable diets. Finally Clothing and PPE as a last resort.

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Hot surface and cold surface of pipelines and equipments has high probability for workers
to come in direct contact with of these hazards. Existence of such hazards cannot be
completely eliminated due to the nature of natural gas processing. In some area pipelines is
insulated with insulation materials however in other area it is without any insulations.
Advertent contact with these surfaces can cause burn to skin (hot) or cold burn (frostbite)
injuries to workers engage in labeling tasks. Two such cold burn reported as first aid
treatment case in past six months. Surveying the area with plant operator and identify such
hazards before work commence is established in work system. If the condition permit heat
retardant barrier sheet utilized. In other are it is area marked with temporary caution signs.
Other mitigations include maintaining adequate distance from the hazards and as last resort
use of hand gloves.

Noise hazards in operating plant is of continuous magnitude rather that intermittent or

impulsive, the source is from equipment such turbine compressor and generator in the
vicinity of work. Noise is considered significant hazards since the decibel involve is about
85db to 98 (dB) decibels. It can cause noise-induced hearing loss, it can affect workers by
damaging damage the hair cells and nerve endings in the cochlea. One of the most common
types of hearing loss is called tinnitus. Damage to the cochlea or any part of the inner ear
often leads permanent hearing loss is more significant. Noise also can cause other effects
such as speech interference, lack of concentration, and annoyance, these conditions is more
harmful to susceptibility individual.
The existing noise level is a residue after engineering control measure already incorporated
in the equipment design hence nothing much can be done to mitigate other than
administration & PPE controls. Existing control including permanent signage posted on level
of noise & mandatory PPE requirements. Some area requires ear plug while other area
require ear muff and there is area where dB is more than 95 double hearing protections is
required. Workers are trained in use of hearing protection equipments, and managing
exposure time. Workers also provided information in noise hazards & its effects of hearing
loss potentials on continuous or prolong exposure without adequate hearing protections. As
part of pre-employment medical assessment Audiometric test is conducted to ensure there
no existing condition, which can be made worse on continuous exposure.

Hazards associated with operating Man Lift and similar type aerial work equipments
common dangers of operating a man lift involve more than just fall from heights. Scissor lifts
hazards including body party or limb getting caught and crushed in the scissor arms. This
could occur when the scissor lift lowers and the arms compress over each other.
Danger of electrocution when come into contact of power line, checking for power lines or
electrical hazards in the work area before operating a man lift is essential. Loading too much
weight into the basket of the man lift could result in the man lift collapsing or being
overturned. Overturning could also result when the base of the man lift is set on uneven
ground or slopes. Potential workers falling off the man lift drop an object from up high on the
man lift and could cause bodily harm to individuals below. This is why most workers with a
man lift are required to put up safety signs or caution around the perimeter of their
workspace. Uses of full-body harness where workers need to be train on it use e.g. never
hook the lanyard snap hook outside the basket, there is lanyard securing point designed in
the basket itself.
Other Mechanical hazards are from labeling work which takes place near compressor or
generators under maintenance or repair. The guarding for rotating part removed in generator

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to accommodate such work. There is potential this equipment switch on without knowing
labeling activity is taking place near or on the equipments. We mitigate such hazards mainly
using Permit to Work System by not allowing any labeling near the equipment under
maintenance regime. Other barrier in place is by placing rigid barricade, signage posted,
Supervisions & good communication between different work party or different company
coordinated by client.

Traffic hazards such as vehicle, man lift or pick-up truck struck personal, permanent
structures and collisions between other equipments. Loss of stability is another high risk
hazards, it can cause significant harm to operator & to other person the vicinity nevertheless
can damage the plant equipments and as secondary impact on this is potential fire or loss of
containment of product e.g. LNG due to line or equipment rupture. Engineering control
measure mainly incorporated in design of equipment. The cage would need to be of
adequate design and construction and provided with guard rails and toe boards, and its total
weight including that of the person or persons allowed to work clearly rated safe working
load of the have to be clearly marked on the cage. Administration control in important for
safe operation of such equipments both the cage and truck should have been thoroughly
examined and tested in accordance with the requirements of LOLER. Communication
between the driver and the person in the cage (if not controlled from cage) should be
maintained. Barriers need to be positioned round the working area to protect from collision
and to prevent passers get into line of fire.
Training for operator includes combination of documented instruction using lecture,
discussion and written material. They shall be engage in practical training such as
demonstrations performed by the qualified Instructor and finally he shall undergo practical
exercises, assessments & evaluation when operating at the workplace.

4.2 Health & Welfare Hazards

Sulfur Dioxide Health Effects is significant hazards as work is carried out at live operating
LNG plant. SO2 is by product during sulfur recovery in LNG liquidation process. It has no
monetary value and incinerated before released to atmosphere. Loss of containment is the
main cause of accidental release, mainly caused by leaks in valve. Workers are exposed
through inhalation or skin contact; it mostly affects the nose, throat if high concentrations or
breathing heavily through the mouth will significantly impact on the lungs. It Sensitivity varies
among people. Corrosive effects on skin eyes and lungs may be delayed and damage may
occur without the sensation or onset. Repeated exposure may lead to contact dermatitis,
may cause bronchitis with cough shortness of breath and emphysema (chronic runny nose,
nose bleeds, tearing of eyes & stomach upset)
Existing medical conditions possible aggravated by exposure (existing skin lesions, person
subject to asthma attack may experience asthmatic paroxysm, cardiovascular disease.
(5)NIOSH & Centre of Disease Control & Prevention
Existing control measure including continuous gas
monitoring, 4 fixed gas monitor at various location in plant, wind socks erected & visible from
work locations, all personal provided with SO2 toxic clips, SO2 awareness sessions
conducted, restricted access to high risk area of AKG via signage and barricades and
standing instruction was created which covered strict emergency response, evacuation to
identified temporary refuge building in the vicinity.

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 Biological hazards is not significant but still need to be addressed virus infections such as
Hepatitis A is usually spread when a person ingests fecal matter even in microscopic
amounts from contact with objects, food, or drinks contaminated by the feces, or stool, of an
infected person. This health illness potential arising from poorly maintained personal hygiene
and portable toilet mobilized for workers use at various locations at worksite. Portable toilet
is not easy to be maintained in tip top condition or at high level cleanliness at all time. This
due to the nature they are spread out in large area & limitation on water storage. Mitigation
measure are by providing pre determine schedule to clean it more frequently & system in
place to arrange for sewage removal when required or as per scheduled. Other main
mitigation is by practicing good hygiene e.g. washing hand after visiting toilets, before
handling food or before taking lunch breaks & end of shift.

Manual handling hazards arises when workers carrying boxes of stickers, ladders and
scaffold materials to and from storage area to work locations. This involves lifting, pushing,
pulling, carrying or moving of various size and weights of load. Poor posture arises from
everyday activities aggravating back pain and damaging spinal structures. Effective
ergonomics & correct manual handling technic are within our control and not difficult to
mitigate, by conducting ergonomic risk assessments we identify ways to improve posture
especially for target workers who are more exposed to such hazards than others. These
hazards rated as medium since there is no reported case for last 3 years. This not only
implemented at work site but in office environments as well (contractor site office). Workers
are trained to identify good and bad working posture & they are made aware of warning
signs of back pain caused by poor ergonomics and posture.
Among other control measures incorporate body in alignment while sitting and while
standing, distribution of body weight, regular exercise, lift with leg strength rather that back,
keep back straight while lifting material, limit the weight one can carry, keep load close to
body and continuous.

Work related stress hazards arising from range of work related activity rated as medium risk
hazards. Fatigue is a concern as at a time in project phase working in access of 12 hours
shift cannot be avoided. Prolong exposure to the elements e.g. extreme summer heat
combine with peer pressure to coup up with strict schedules. Supervisor is subjected to work
related stress mainly due to having too much to do with too little time. They are made
accountable on safety & progress of multi group workers. They are also accountable or and
responsible on workers traveling or commuting arrangement within multiple project site
within Ras Laffan. Stress involving lower ranks such as semi skill & unskilled workers
includes excessive demands impose by Supervisor to achieve target on how many number
of labels completed daily.
Hazards related to life style such as drug abuse & alcohol is negligible (low) based on
previous history and the culture of state of Qatar which is a Muslim nations.

4.3 High Priority Physical Hazards is falling from height while working on
ladder.
My high priority physical hazards selections is falling from heights while working on A frame
ladder. Detail of these hazards was captured on physical hazards headings. The hazard
selected due to project recoded four near misses on falling from heights, on top of that the
project safety observation trend analysis continue to show uptrend on non- compliance on 3
contact points requirements when working on ladder. Feedback from workers engaged in the

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labeling activity shows their frustration when explaining it is practically impossible to use
single hand to wrap the label around large pipes. To get the job done they simply has no
other options other than use two hands to work where this placed them at risk of falling from
heights. Existing mitigations does not satisfy the duty of care obligations by employer to
bring the hazards as low as reasonably practicable (ALARP) as per State of Qatar applicable
legal requirement. It did meet RasGas procedural requirements on working on ladders and
suitable and sufficient risk assessments.

Legal requirement applicable includes SAMA Article 2.3.12 Control of Working at Heights -
When considering what precautions are necessary to control risks associated with a project,
everyone who has a duty under these Regulations must take account of the general
principles of prevention in line with SAMAS Article 2.3.1 Risk Identification & Management.
The risk arising from these hazards shall be evaluated and mitigated further to reduce the
risk to as low as reasonably practicable under the heading of Risk Assessment.

4.4 High Priority Health Hazards -Sulfur Dioxide (SO2) exposure to plant
labeling crew.
SO2 is selected as high priority health hazards due increase reported case of SO2
uncontrolled releases at AKG area. SO2 were being released. There is evidence of client
Engineering design failure in SRU incinerator located near work locations at AKG. This
product is listed in as a highly hazardous and can cause severe health effect both chronic
and acute. (6) SO2 Material Safety Data It can be exposed to large number of workers at any given
time. Existing control measures on SO2 health hazards found to be inadequate and the risk
level is rated high. Current Risk assessment did not satisfy Qatar legal requirements and
finally to further reduce the risk as low as reasonably practical. Similar to physical hazards
the evaluation of this health hazard shall be addressed under the heading of Risk
assessments.

5.0 Risk Assessment (RA)

5.1 Methodology of Risk assessment - RA
My RA shall be Scenario Based Risk Analysis (SBRA) it is Qualitative and it employs
structured brain-storming in which the RA Team uses its knowledge and experience to
identify potential hazards.
Qualitatively assess the risks associated with those hazards. The hazard identification
process focuses on human action/inaction, work process, equipment used and external
factors that may cause an incident to occur. Hazards are identified using one or more
methodologies such as brainstorming, What-if/Checklist, workplace inspections, consultation
between employees and employers, monitoring injury and illness records and observation.
Once hazards have been identified along with their possible causes, consequences and
safeguards, risk scenarios are developed to describe how each event may occur. The Risk
Matrix provides a means to estimate and convey the probability category and
consequence(s) of a potential incident as regards the safety and health of workers and the
public, the environment, public disruption and financial loss.
The position of a risk scenario on the risk matrix helps to determine the priority for risk
reduction measures, as well as the level of management approval required for those
measures or for continued operation.

14
The RA methodology is based on client Risk Management System (RasGas managements
expectations regarding the role and use of the RasGas Risk Matrix and its classification
system).
5.2 Risk Assessment for hazards falling from heights while working on ladder
5.2.1 Identify the Hazards
As identified in Risk Assessment Methodology section various means has been used to
identify the hazards this includes , inspection, hazards hunting, list all work activities and
look at each step, look at the ways different tasks could interact and create hazard. I also
review past near misses incident, safety information and most importantly the detail of
hazards surfaces when talk to people who involved in the tasks. I obtained additional
information by referring to OSHA, HSE UK and other relevant publications or website.

5.2.2 Decide who might be harmed and how

Most all plant labeling operatives engaged in work on ladder is exposed to harm falling from
heights. Detail of who might be harmed discussed with Tadmur Supervisor to identify
whether any new or young workers involve in the activity. It was established only 2 persons
from each group allowed to work on ladders; all of these workers are adequately trained and
has good knowledge on work area environments.
Period of Exposure based on work expected completion for AKG in 6 months, shift working
hours 8 hours per day, 6 days week is 2,160 hours. Calculations breakdown as follows:
Per day 1 person actual exposure to falling from heights (ascending + descending +
working), for placing 6 label is 20 minutes x 6 labels = 120 minutes
Per day 6 persons actual exposure to falling from heights per 8 hour shift is 720
minutes (12 hours)
Per month exposure for 6 personal 720 minutes x 30 days = 21,600 minutes (360
hours)
Per 6 months 21,600 minutes x 6 months = 129,600 minutes (2,160 hours)
Note:
60 minutes required shifting and assembling the ladder at each work locations,
working with ladder requires 20 minutes. Means actual time for completion of each
label using one ladder is approximately 80 minutes.
Work descriptions using 6 ladder involving 6 personal (Each ladder group consist of 8
to 10 personal but only one personal working on ladder at a time).

The operatives can fall from heights while working on ladder using both hands for placing
labels on the pipe spools and equipments when loose his balance, try to overreach, person
holding the ladder fail to keep the ladder firmly upright, or ladder assembly fault. They also
can fall when ascending and descending from ladder due to damage rug, slippery due to oil
or poor footwear sole, carrying material on hand and fail to maintain three point contacts on
ladders. Other possibility includes fatigue, secondary effects from heat stress, horse paly
and finally rushing to come down from ladder to react to gas emergency alarm.
The consequences of fall can be severe bodily injury or even fatality.
.
5.2.3 Evaluate the risks and decide on precaution
Current risk rating is CI fall under high risk region in as the Consequence lead to one or
more fatality and Probability is measured as Possibility of Occurring Sometime. Refer to
Table 01 Risk Rating.
Risk rating evaluations based on the effectiveness of existing control measures by
observation of actual task and taking feedback from workers engaged in the activity and with
following considerations.

15
 Working on normal twin step A frame ladder height about 10 meters, not practical to
achieve 3 contact points while working on ladder due to both hands required to place
the label.
Ladder cannot be secured at top & bottom, it is firmly held by two people to maintain
stability. Persons holding the ladder potential to be off-guard momentarily or leave only
one person for the job which is inadequate.
Provision of Personal Fall Protection Equipment not practical since there is no firm
anchoring point.
No collectives fall protection equipment use due to site conditions
Ladder use strictly limited within those areas where MEWP have limited maneuvering
space and scaffolding erection not feasible due to site conditions
Provision of ladder inspections by competent person & pre-use user inspections in
place
All operatives adequately trained in working at heights & working on ladders
Provision of Safe work practice on ladder fully adopted & robustly maintained by full
time Supervisions e.g. not stepping on last 3 rugs, tool belt, not carrying material while
ascending & descending, no overreaching, work short duration not to exceed 10 minute
for each label.
Work control by Work Permits, Job safety analysis capturing hazards & control
measures of all work sequences. The existing control measures incorporate strict
regime of safe work practices while working on ladders. (4) Safety in window cleaning using portable ladders
(5) Safe use of ladders and stepladders
. Reference also made from HSE UK Publications 5 Step Risk
Assessment

Proposal to mitigate the hazards with new Engineering hierarchy of control measures to
further reduce the risk associated with the same scenario.
Risk rating evaluations based on the effectiveness of new control measures obtained from
Consultations with Tadmur Management and workforce. Further details obtained from
manufacturer through their supplier at Qatar who provided work at height on ladder,
assembly & disassembly demonstrations video, appraisal by three existing user of the
platform ladder and reference made to approval of the platform ladder by recognized
certification body. New Risk rating based on following consideration & control measures:

Use of Specialist ladders make (Zarges Germany) and internationally certified and are
highly reliable for working on heights with engineering arrangement for stability and fall
protection. Appendix 2 Zarges Platform Ladder Specifications & image
o The areas for ladder use to be identified listed and agreed on by Operations Assets
owners.
o The Specialist ladders have robust engineering arrangements and are reliable for
use with no break downs or fault.
o Use of Manufacturer provided competent Person Inspection and Safety Pre-sue
checklists.
o The ladder placement shall be limited on only firm and rigid ground surface.
o Ladder designed with wheel for easy mobilization within work areas
o The personnel shall work on ladder platform provided fall arrest inertia reels attached
to ladders.

16
o The mock up test shall be conducted in presence of all agreed parties prior to use of
ladders.
o The regular use and maintenance log to be maintained.
o Only trained (2 days training by ladder regional distributor at work site) & experience
fitters shall be authorized to use the ladder for placing labels.
o The manufacturers recommendations shall be included within Method statement and
JSA prior to use.
o No alterations to be made on ladder that affects its integrity for use.
o Labels and tools kits accessories shall be attached along ladders (lifting rope using
gin Wheel provided on ladder) to avoid carrying material while ascending &
descending ladders.

New risk rating after the applications of new control measures is DIV fall under Low
region in safety category as Consequence could lead to minor impact on personnel such
as First aid only and Probability assessment indicate that falling from height not likely to
occur- Refer to Table 01 Risk Rating & Table 02 RasGas Risk Matrix.

17
 5.2.4 Record findings and implement
The actual practical applications of risk assessment new control measures cannot be
demonstrated at sites as the required equipment in not in place. However extensive
knowledge obtained from watching video of operation of platform provided by manufacturer
through their supplier in Qatar.
The results of risk assessment captured in RasGas Risk assessments template and shall be
transferred to Job safety Analysis (JSA) format which is more simplified easy to understand
versions similar to Health and Safety Executive published risk assessment template. Appendix 1
Working on Ladder at Heights of 10 meter Detail Risk Assessment Template

The shall be briefed to work force and attached to work permit as quick reference for work
group to use as checklist on identifying hazards and verify the implementations of control
measures.

5.2.5 Review risk assessment and update if necessary

Review assessment and update if there are any incident, complaints, Gap identified during
safety Audit, Inspections, change in work process, change in plant conditions, change in
existing legislations or if it is discovered that the existing risk assessment or control
measures are insufficient to protect the workers from the falling or other hazards. Review
updated to project team during monthly safety meeting on 14/11/2013. Action by Tadmur
Project Engineer Wilson.

5.3 Risk Assessment for health hazards Exposure to SO2

The Methodology of Health risk assessment of employees exposed to SO2 during engaging
in plant labeling activity at AKG was assessed using the steps in RasGas Health Risk
Assessment Methodology E07-X09-002. Existing controls are reviewed and potential
monitoring, control and remedial action are proposed based on the health risk rating. Each
hazard associated with a task is assigned a health risk rating. A health risk record will
summarize information gathered through the health risk assessment process.
The final health risk rating identifies the levels of health risks associated with tasks
performed.

5.3.1 Finding out what the problems are (information gathering)

Health effects attributed to SO2 have been reported by some members of the workforce over
the last several months. These effects include complaints of sore throats, eye irritation, and
coughing as revealed in interviews with exposed workers. RasGas initial investigation
identify SO2 were being released due to Engineering design failure in SRU incinerator
Personal monitoring was done using Drager Pac 7000 personal monitors which recorded
peak measurements, short term measurements, and time weighted averages. Overall range
of measurements was 0.1 to 8.0 ppm. Locations where 0.25 ppm 15 minute time weighted
averages could be exceeded were in the plant labeling area at AKG and production upper
decks downwind from Sulfur Recovery Unit (SRU) incinerator stack. Area monitoring on from
April to June 2013 was typically 2-4 ppm on the upper deck AKG during the morning hours.
(Measured via BM25.)

(Quote from RasGas Asset Engineering Team investigations finding) Several factors contribute to the dispersion of
SO2 to ground level. Based on the data presented significant levels of SO 2 were being
released by each SRU incinerator. All of the SRU incinerators are located at the south end

18
of AKG. The stack height of all the SRU incinerators (48 meters), is technically low. Stack
height is important for proper dispersion of pollutants. The exhaust gas will be most likely to
hit the ground at a shorter distance compared to those sources with higher stack height
unquote
.

Considering all the factors above AKG area was primarily affected with intermittent exposure
to SO2 on the days when wind was from the north-west.

5.3.2 Evaluate the Health Risks

In deciding who might be harmed, this initial study focus on Tadmur plant labeling team
engaged at AKG. Workers in this portion of the plant have the highest probability of being
exposed to SO2 emissions. This involves forty eight persons working eight hour shift at
AKG. The number of personnel at risk of exposure to SO2 was considered likely to be more
than just plant labeling team due to the spread and depending on concentration at source
and wind turbulence, enough dilution might not have occurred over wide area. RasGas plant
Operator and other contractor personnel engaging work at adjacent plant not considered in
the Risk assessment process.

Other people at risk of exposure are visitors to the work area such as supervisors and safety
officers on routine inspections of work area. If the concentration of the vapors is high enough
to exceed the short term (15 minutes) exposure limit value, then these categories of people
might be harmed. Personnel with existing health condition such as asthma are also at higher
risk. This could be respiratory condition that may be made worse by exposure, or it may be
previous exposure to SO2 or other substances from other sources which may have
synergistic effect with exposure to this gas.

Age is another factor that could affect exposure. Elderly people may not have an efficient
metabolic mechanism if exposed even at lower concentration. Exposure to this substance is
intermittent but could be significant when it occurs. Exposure time for workers involved in
plant labeling could be up to 8 hours Time Weighted Average (TWA) daily for about 6 days
per week. Based on the available data from measurement taken by Industrial hygiene team
throughout AKG plant, exposure to levels detected is significant enough to cause damage to
workers health if not controlled. This risk assessment referring specific health exposure to
Tadmur Plant labeling worker involving 6 group consisting of 8 persons in a group. Working
in day shift of 8 hours, 6 days a week, exposure is intermittent but daily and cannot be
precisely calculated.

5.3.3 Evaluation of Existing Controls

A combination of control measures are already in place in view of known hazards of SO2
leakage, they have failed to adequately protect the workers from its health exposure,
Judging from records of few near misses where significant number of workers was exposed.
It is fortunate no recorded acute illness to health results from SO2 exposure.

The SO2 Occupational Exposure Limit (OEL) of 0.25 ppm 15 minute time weighted average
(TWA) can be exceeded in the plant labelling activity area Facility and upper deck areas in
AKG. It can also be exceeded in the adjacent plants at infrequent intervals. We conclude
that the existing controls are not adequate to safeguard the health and safety of the workers
at AKG area.

19
The existing control measure in place includes:
No work activity if SO2 traced in the vicinity regardless the concentrations. Zero toxic gas
policy.
AKG-2 has four Fixed Detectors aligned to the PAGA System
Ensure all non-essential personal keep off limit near plant labelling activity.
Verify that workers in engaged in any activity in danger zone are asthma free by
medical evaluation.
All engaged it the activity provided with emergency escape respiratory mask (parat
mask)
Personal toxic clip or gas batch (SO2, H2S) worn at all time at breathing region,
calibrated & not expired.
Enter & work at AKG with Permit to Work only, job Safety Analysis & tool box to cover
hazards of SO2 & emergency response in the event of gas alarm sounded
All personal trained in use, maintenance & storing of personal protective equipment
(emergency escape respirators use for escape only not for working)
In the event of SO2 high alarm all personnel in the affected area to evacuate and muster
at Safe Location away from the SO2 atmosphere. Wind socks installed at all work
locations to identify wind directions
All work group to be provided with communication device intrinsically walkie talkie or
mobile phone (IS)
No work alone (buddy system) & without Supervisions
Notify adjacent plant of potential SO2 emissions from other plants that could be
contributing to RasGas worker exposure.
SO2 hazard communication for all site workers via dedicated safety induction specific for
working at AKG.
AKG Asset Plant Operators to donning BA sets when responding to initial SO2 Alarm to
verify SO2 Levels (if any), confirm the presence of SO2 via a hand held SO2 gas monitor.

Administrative controls such as Safe System of Work system including developing method
statement, Job safety analysis and MSDS for all activities which breaks down the activities
down to task during which hazards inherent in each task is carefully identified. All workers
engaged in activity inside live plant have to undergo Mandatory Safety Inductions, Specific
Training on hazards at AKG asset and trade specific training e. fire watcher, safety watch
and etc. A Permit to Work is required for any activity in live plant and finally before engaging
in the task a Job specific tool box talk is a must and checklist to be dully filled by Permit
Holder to verify all JSA control measures fully implemented. Overall good training and
practical exercise (drills) to workers on emergency respond on sudden release of SO2 and
effective awareness on hazards and control measures associated with SO2 exposure
increase their alertness on the prevailing SO2 hazards.

Personal Protective Equipment (PPE), in addition to the mandatory PPE for plant access,
additional PPE such as suitable respiratory protections are provided & training provided for
workers to wear it correctly, is an effective control but since only a fraction of exposed
personnel uses this, it cannot be said to be effective control measure. Based on the review
of the existing control measures, certain gaps and drawbacks are identified such as training
tends to have limited effect unless reinforced by adequate supervision and reminder. The

20
fact that project tied to tight schedule means work rest cycle may not be observed so as to
meet target so this control cannot be relied upon.

The effective use of PPE depends on other factors such as fit with the user, compatibility
with other mandatory PPE worn by user and how comfortable the wearer feel wearing them.
In addition, routine inspection and maintenance is required for reusable PPE as well as need
for replacement when it becomes worn or less effective, these depends on the competence
of the user

5.3.4 Recording Risk Assessment findings and implementation

The outcome of the risk assessment is detailed in table 04 on next page (Health Effects &
Exposure Rating).The existing control measures are not adequate to protect the health and
safety of the workers involved in in plant labeling activity at AKG Area. The controls have,
however failed to offer protection against such toxic gas exposure which is significant
enough to cause both acute and chronic ill-health. Current health risk rating is 3 for health
effects & 4 for exposure rating, this fall under high region as per RasGas health Risk Matrix
Table 04. Appendix 3 Workers Exposure to SO2 Detail Health Risk Assessment RasGas Template

The danger is significant as the release of SO2 can happen anytime without prior warning,
this has been proven during data collections. The personal gas monitor & their training is the
last line of defense and it wont help much in the event of high concentrations sudden
release. The risk increase as SO2 gas is colorless gas, suffocating odor and corrosive to the
respiratory tract. A severe short-term exposure may cause long-term respiratory effects
(e.g., reactive airways dysfunction (rads) corrosive causes severe skin burns and eye
damage may cause frostbite and even suspect mutagen. suspected of causing genetic
defects.

5.3.5 Proposed New Control measures

The under listed actions are some further actions which would provide adequate protection
and control the risk. Elimination or substitutions is not possible in this case but with current
technology risk of exposure to such health hazards can minimised. The additional controls
proposed focus still on administrations hierarchy of control as this is offer more reactions
time to take refuge at safe area from toxic gas exposure. This new control measure is
collective measures rather than depending on personal toxic clips.

Provide additional 4 portable SO2 Detector (BM 25 model), alarm capacity level at 110 dB (to
be audible at noisy area) and rotating blue beacon light and with integrated infrared
functional system e.g. one device sensor the gas it will activate all other portable device in
the vicinity. This device to be place near the source of SO2 in addition to fixed SO2 detector
which is not strategically positioned near the SO2 sources.

Immediate actions.
As to address the root cause Initiate Engineering feasibility study to improve the design
of SRU incinerators heights from current 48 meters to higher as engineering possible
and allow proper dispersion of pollutants -As proposal
Utilize scrubber to reduce emissions from incinerators and/or manage processes to
reduce SO2 emissions

21
With the application of new control measures the health risk rating shall be brought to as low
as reasonably practical & proportionate with the hazards and risk. At the same time it shall
comply with applicable local legal requirement as well comply with international best
practices. The new health risk rating shall be drastically reduced to 2 for health effects & 2
for exposure rating, this fall under low region as per RasGas health Risk Matrix.
Recommendations

6.0 Conclusions
Review of Tadmur health and safety performance of a work place results can be concluded
the organization is committed to the fundamental requirement that anyone working must
have a safe environment in which to perform assigned Work. They have internationally
recognized standard an assessment series for the Health and Safety part and it was manage
as intended and desired outcome was achieved.

The assignment aim to identify workplace existing hazards, who might be harmed, its effects
to safety & ill-health and present mitigations in place was successfully identified. One
physical and one health hazard which high potential to cause injury & ill-health to worker
selected for detail risk assessments to further mitigate to ALARP. Both hazards risk from
high brought to low with introductions of new control measures. The exercise completed with
the reference to various AcoPS OSHA, HSE UK, Manufacturers & etc.

The ultimate goal to identify specific action plans described in detail in next section by taking
into account Qatar legal requirements and best practice in the industry concluded
successfully. This action plan which is Specific Measurable, Accountability assigned,
Realistic, Timely (SMART), and cost effective. In the recommendation section this action
plan shall be detailed for implementations.

22
7.0 Recommendations
As concluded above the physical hazards associated with working at heights on twin step
A frame ladder using both hands during plant labeling activity is assessed as high. Client
standing instruction clearly indicates that failure to maintain 3 contact points while working
on twin step A frame ladder at heights is not acceptable. The risk rating outcome on initial
risk assessment is seen as not satisfy Qatar related legal requirements & industrial best
practices. The clear message from client Senior Management is that the concern related to
project progress is secondary considerations compared to safety, client Safety philosophy
that No work is so urgent that it cannot be done safely is literally applicable to this scenario.

As concluded in the selected physical hazards risk assessment with practical engineering
solutions as new control measures to purchase two unit of specially Engineered Ladder
(ZAP Telescopic Platform Ladder) where worker can operate or carry out his task from the
safe position on platform on top of the ladder. This platform has built-in fall protection system
with middle rail & guard rails. This is further reinforced with full body safety harness
anchorage points. During ascending & descending workers are secured to fall restrainer
fixed to vertical anchorage life line also build-in the ladder design. The ladder is tested and
internationally certified and proven highly reliable with unique engineering design for stability
even when a fall take at highest point. The outrigger system further reinforced the stability
where there is no need for securing at top or bottom of the ladder. There is no requirement
for additional hand to hold the ladder in place.

On the second health hazards selected, the health risk assessment without any doubt
showing the risk of workers exposed of such hazards is high and the proposed new control
measure it paramount to reduce the risk to ALARP or low. The risk assessment proposal for
Tadmur to purchase four new portable unit of BM 25 SO2 Gas detector to safe guard
workers health & safety while engaged in activity at AKG area is an interim measures. As a
permanent solution client already initiated engineering feasibility study to improve the design
of SRU incinerators heights from current 48 meters to higher structure Utilize scrubber to
reduce emissions from incinerators and/or manage processes to reduce SO2 emissions.

The SO2 detector could not eliminate or block the SO2 exposure risk however it serve as
early warnings system for workers to initiate their emergency response the evacuate the
area. The engineering inspections by plant subject matter expert has ascertained that SO2
source is from flair stack at 28 meter heights and this gas travel to lower or ground level with
the help of prevailing wind.

The existing plant fixed SO2 detector scattered throughout the plant but none of them are
strategically located in-between the source of hazards and plant labeling workers locations.
As there is no fixed or portable gas detector between the source of hazards & workers, the
risk was rated as high. The last line of defense currently sole rely on workers personal gas
batch or monitor, in high concentration the warning from personal gas monitor might be too
late leaving little time to evacuate or to don their emergency escape respirator. By
positioning the proposed portable SO2 gas monitor at interval heights & location between
source of hazards and workers, this will drastically increase warning time & shall provide
adequate reaction time to proceed to safe area.

23
The additional few minutes provided by this devise drastically reduce the risk from high to
low; the additional time gained might be the difference between live & fatal exposures.

The cost benefit table below will demonstrate the benefit outweigh the cost, such investment
on new technology is good for business.

Cost and Benefit of Proposed additional Controls

The table 05 & 06 below summarizes the cost and benefit associated with implementing the
control measures proposed on both selected hazards. The following assumptions were
made in the cost and benefit estimates below.
Cost does not include value of people life as it value cannot be justified with
monetary figures
The cost of delay in specific labelling project due to stoppage of work using twin step
A frame ladder at AKG area not included as the same workers are utilized for
activity in other location working with man lift & scaffold platform at AKG on same
project.
Risk assessment conducted specific for total number of Tadmur employees engaged
at AKG area only (Client & other contractor engaged in the area not included).
Cost related to personal administrations such salary, office, transport, health
surveillance, gas monitoring or any other activity involved in Risk assessment
process not included as the exercise concluded with client & Tadmur personal only.
Salary cost is marginal as they are also engaged in other their specific routine tasks.
Labour cost for Maintenance and cost for spare purchase for the item proposed is not
included, however crucial spares for initial effective operation is included e.g. spare
battery and consumable spares is included.
Continuous monitoring and supervision of personnel is part of normal job procedure,
so no additional cost.
Periodic health surveillance of at risk workers will attract marginal extra cost as there
is an existing health monitoring programme by the Occupational Health team in
RasGas. This cost is not included as well.
Assumption on cost figure based on communication with only one respective supplier
for both risk assessments, as at the time only the base estimation is required. With
more company participate in quotation shall bring the cost down.
Cost of training & loss of work during training and awareness session mentioned in
risk assessment control measures shall be included in action plan section of the
report (basically all training provided free of charge by client, supplier who shall
provide the material & Tadmur In-house training regime time however workers
attending training cannot carry out their normal duties. Production based on number
of label installed is also lost).
Cost reflection on special design scaffold, this is the only available safe means of
work options other than as proposed in RA new control measure ZAP Telescopic
Platform Ladder.
Calculation of Special design scaffold based on Middle East region approximate
costs. Cost reflected in United states dollars
Cost for scaffold installation and removal is UDS 16 per meter square, 10% of the
overall cost is applied as rental costs per week.

24
 Calculation based on assumptions number of location identified at AKG as unique is
600 where labeling need to be installed.
The only way forward without using special design ladder is by installing special
design scaffold. This location does not allow access for man lift & construction of
normal scaffold e.g. mobile tower scaffold.
If special scaffold construction is opted at 600 hundred locations, each location need
about 4 meters square at 12 meters heights or 6 stacks heights (4m2 x 6m2 =24m2),
at one location scaffold cost is approximately USD 384 (24 x 16). Total 600 location x
USD 384 = USD 230,400 + 10% weekly rental cost USD 23,040 = USD 253,44

8.0 Action Plan

8.1.1 Cost and Benefit of implementing proposed additional controls on Physical
Hazards Falling from Heights Table format page 27
8.1.2 Cost and Benefit of implementing proposed additional controls for Health
Hazards Exposure to SO2 Table format page 28
8.1.3 Management System Gap Analysis & Gap Closure Action Plan page 29
8.2 Hazards & Risk
8.2.1 Hazards & Risk Physical Hazards - Recommendation use of work equipment
ZAP Telescopic Platform Ladder Table format page 30 & 31
8.2.2 Health Hazards Recommendation to procure & utilize Industrial Scientific
BM25 Multi guard Transportable Multi-Gas Area Monitor for Sulfur Dioxide
Table format Page 32

25
 8.0.1 Cost and Benefit of implementing proposed additional controls on Physical Hazards Falling from Heights
Total
COST BENEFIT Saving
Benefit
Cost in Unit
Total Amount
Control action item USD per Requir Saving element
amount USD
unit ed
ZAP Telescopic Platform Ladder - Improved Safety Saving from Injury fall from
Platform Height 8.10m, Working height & drop object hazards- Potential
Height 9.85m, Extended Length absence, treatment, training for
9.45m , 400mm x 400mm Platform replacement employee, Insurance claim
Made of Embossed Aluminum alloy, (increased premium) and fines by authority USD
32,000
Closed Length 5.65m, weight 86 kg Work Progress delay on overall project
(6
completions (measurable but not
Accessories charges included in workers x
calculated).
one unit price. USD 2,000
USD USD per
Installing Middle rail on the platform 2 Other non-measurable saving such as USD 24,000
4,000.00 8,000.00 person)+
additional to hand rails. improved public image for company.
Job
Vertical life line for anchoring Moral boost and Increased productivity for
stoppage
Personal fall Protections Device workers who see company as caring
10,000 +
Bucket hook fixed on ladder No interruption to client LNG operations.
Other
Hanging tool box (Interruptions involve major cost >1 million
10,000
Tray for ladders with rungs per day).
Set of horizontal stabilizer bar The hazards exposed to scaffold for
Note: Delivery to site in included if building special design scaffold eliminated
purchase more than one unit as there is no need to construct

USD USD
Total cost Total Saving USD 24,000
8.000 32,000

26
 8.0.2 Cost and Benefit of implementing proposed additional controls for Health Hazards Exposure to SO2

Total
COST BENEFIT Saving
Benefit
Cost in Unit
Total Amount
Control action item USD per Requir Saving element
amount USD
unit ed
Industrial Scientific BM25 Multi guard
Transportable Multi-Gas Area Monitor
For LEL, Hydrogen Sulfide, Oxygen
And Sulfur Dioxide With Diffusion
Draw. Interchangeable smart sensor Improved Safety Saving from Health
options that alarm signals transfer from Exposure SO2 hazards - Absence from
one unit to another an intrinsically safe work due to treatment, medical expenses,
trickle charge power. Complete with training for replacement staff, investigation USD
additional accessories. cost, compensation, Insurance claim 96,000
100 meter-long cable and wiring USD USD (increased premium) & fines by authority. (48
4 USD 84,000
arrangements 3,000 12,000 Total 48 workers exposed to SO2 Hazards workers x
at any given time. USD 2,000
High capacity rechargeable nickel Other non-measurable saving such as per person)
metal-hydride spare battery pack Improved public image for company. Moral
boost and Increased productivity for
workers who see company as caring
Industrial Scientific BM25 Multi guard
Total 48 workers exposed to SO2
Hazards at any given time.

USD USD
Total cost Total Saving USD 84,000
12,000 96,000

27
 8.0.3 Management System Gap Analysis & Gap Closure Action Plan

Syste Priorit
m Ref. y Action Taken By:
Characteristic / Gaps Action Required Remarks (H, M, Name Date
Section L)
4.1.1 Respect Legal and There is procedure in Identify applicable laws and Applicable legal requirement on M Ossa 20
Non-legal OH&S place to identify and regulations & non Legal OS& related section 11 - Health & ma Septem
Requirements access the legal List of H requirements that would be Safety: Part 2 Safety & Accident Tadm ber
Qatari laws and applicable to Tadmur working Prevention Management / ur 2013
regulations. However the on ladders tasks. List of Administration System (SAMAS) Projec
legal & non Legal Qatari laws, regulations and 22.3.9 Personal Protective Fall t
requirement pertaining to non-legal pertaining to work Protective Equipments. Manag
work on ladder not on ladder to be updated in HSE Regulations & Enforcement er
adequately captured in the procedures. Directorate HSE Legal
procedure. Framework in Oil and Gas Sector
DG-GEN-39-2011 5th May 2011
Chapter 1 Occupational Health
Section 6 Facilities and Work
Places Risks Article 149 Fixed
Ladder & mobile ladder
As best practice client adopting
Provision and Use of Work
Equipment Regulations 1998
(PUWER).
4.4.8 Establish an OH&S No rescue plan Provision of rescue plan, H Ossa 7
Emergency implementation, including overhung Qatars Penal Code, Labor Law, ma Septem
Management equipments and test syndrome, provision of Civil Defense Law. Violate Tadm ber
Process - provisions (Rescue suitable rescue equipments various H&E, civil & criminal ur 2013
Implement Test, mock exercise) for & trained personal to be legislation, provisions. Projec
Review and revise working at heights established. The need of t
emergency addressed in Tadmur rescue exercise in Manag
management OH&S Emergency appropriate intervals, review er

28
 procedures Management procedures & revise the provisions to be
or address in working at included in Tadmur
heights procedures. Emergency Response
Management Procedures.

8.2Hazards & Risk Physical Hazards

8.2.1 Recommendation use of work equipment ZAP Telescopic Platform Ladder
Responsib Success Review
Actions Time scale Cost
ilities Criteria date/format
High
Approva
a) Raise requisition for ZAP Telescopic Platform Ladder - Platform Height 14/09/2013
Tadmur ls is
8.10m, Working Height 9.85m, Extended Length 9.45m , 400mm x Review &
Project expecte
400mm Platform Made of Embossed Aluminum alloy, Closed Length discuss during
01/09/2013 Manager Negligible d
5.65m, weight 86 kg. Delivery in 30 days as per stated in quotations Weekly
Osama consider
initiated by RA team progress
Challak ing the
meeting
risk
ratings
High
Only 14/09/2013
Tadmur need to Review &
b) Develop a safe work guideline and initiate Job Safety analysis for activity
Project update discuss during
using the new proposed ladders. Reference to be made to Manufacturer 01/09/2013 USD 1,000
Engineer from Weekly
manual, legal & best practices.
Wilson relevant progress
publicati meeting
ons
c) Initiate practical training for ZAP Telescopic Platform Ladder assembly, Tadmur USD 4,800 Medium-
disassemble and working conducted by supplier provided trainer as per Safety 48 persons dependi
01/10/2013 14/10/2013
agreement in purchase contract. Must use the actual ladder and training Officer x USD 100 ng on
record provided to client. Working demonstrations shall be presented in Norman Daily equipme

29
 presence of all stake holders (OPD & AKG asset team) prior to actual use salary nt
the equipments delivery
date
Tadmur
d) Rescue & Emergency Plan shall be prepared, reviewed by all project stake Safety 07/09/2013- By
01/09/2013 Negligible High
holders and approved by RasGas emergency Response Services. Officer RasGas EMS
Norman
21/10/2013
Tadmur Review &
e) A drill conducted (Mock up test) on rescue & emergency arrangement while
Safety discuss during
working at heights e.g. workers rescue from overhang from fall personal 14/10/2013 USD 1,000 High
Officer Weekly
protections device.
Norman progress
meeting
Tadmur
14/10/2013
f) Safety assessment conducted on the 30 days operations performance of Project
7/10/2013 Negligible High Review by
the ZAP Telescopic Platform Ladder. Engineer
project team
Wilson
14/11/2013
g) Review assessment and update if there are any incident, complaints, Gap
Tadmur Review
identified during safety Audit, Inspections, change in work process, change 01/11/2013
Project updated to
in plant conditions, change in existing legislations or If it is discovered that or when Negligible High
Engineer project team
the existing risk assessment or control measures are insufficient to protect required
Wilson during monthly
the workers from the falling or other hazards.
safety meeting

30
 8.2.2 Health Hazards Recommendation to procure & utilize Industrial Scientific BM25 Multi guard Transportable Multi-Gas Area
Monitor for Sulfur Dioxide
Responsi Success Review
Actions Time scale Cost
bilities Criteria date/format
h) Raise requisition for Industrial Scientific BM25 Multi guard Transportable
14/09/2013
Multi-Gas Area Monitor For LEL, Hydrogen Sulfide, Oxygen And Sulfur Tadmur
Review &
Dioxide With Diffusion Draw. Interchangeable smart sensor options that Project
discuss during
alarm signals transfer from one unit to another an intrinsically safe trickle 01/09/2013 Manager Negligible High
Weekly
charge power. Complete with additional accessories. Delivery in 30 days as Osama
progress
per stated in quotations initiated by RA team. Initial on job training provided Challak
meeting
by supplier as per sales contract,
14/09/2013
i) Training of dedicated personal & prepare safety guideline for maintenance,
Tadmur Review &
calibrations and initiate to include the new control measure in Job Safety
Project discuss during
analysis for activity at AKG. Advice & guidance can be obtained from client 07/10/2013 USD 2,000 High
Engineer Weekly
operations staff that has good knowledge on the operations of the said
Wilson progress
equipments. Guideline can be obtained from client existing procedures.
meeting
j) A joint survey to be scheduled for Tadmur Project Engineer, OPD
Responsible Person for Labeling Project & Asset Authority for physical visit 07/10/2013
Tadmur
& mapping of suitable locations for placing the portable gas monitors at Review &
Project
AKG. Identified locations by marked in plot plan & clear instruction to discuss during
28/09/2013 Manager USD 500 High
workforce that no activity shall progress without deployment of the said Weekly
Osama
device. The same followed up with official communications to Permit progress
Challak
Issuing office to authorize the device use inside live plant. Use of devise meeting
must be approved by AKG Asset Manager.
k) Review assessment and update if there are any incident, complaints, Gap 14/11/2013
Tadmur
identified during safety Audit, Inspections, change in work process, change 01/11/2013 Review
Project
in plant conditions, change in existing legislations or If it is discovered that or when Negligible High updated on
Engineer
the existing risk assessment or control measures are insufficient to protect required project monthly
Wilson
the workers from the falling or other hazards. safety meeting

31
9.0 Reference / Bibliography
1. Gulf News Qatar sentences five over Villaggio fire Published: 14:40 June 20, 2013 By
Habib Toumi, Bureau Chief http://gulfnews.com/news/gulf/qatar/qatar-sentences-five-
over-villaggio-fire-1.1199728 Assessed 16/08/2013
2. Health and Safety UK Successful health and safety management HSEs Publications
obtained through website: www.hse.gov.uk. Assessed on 16/08/2013
3. Praxiom Research Group Limited OHSAS 18001 2007OH&S TRANSLATED INTO
PLAIN ENGLISH http://www.praxiom.com/ohsas-18001.htm accessed on 18/8/2013
4. Health and Safety UK Safety in window cleaning using portable ladders HSE Information
Sheet MISC613 http://www.hse.gov.uk/pubns/misc613.pdfFirst published 09/03
accessed on 18/8/2013
5. Health and Safety UK Safe use of ladders and stepladders An employers guide HSEs
website: www.hse.gov.uk. accessed on 18/8/2013
6. NIOSH & Centre of Disease Control & Prevention Occupation Health Guideline for sulfur
dioxide (SO2) CDC - Sulfur Dioxide - NIOSH Workplace Safety and Health Topic
accessed on 18/8/2013
7. Air Product SO2 Material Safety Data
Sheethttp://avogadro.chem.iastate.edu/MSDS/sulfur_dioxide.pdf Assessed 18/08/2013

10.0 Appendices
Appendix 1 Working on Ladder at Heights of 10 meter Detail Risk Assessment Template -
RasGas Scenario Based Risk Analysis from main manual Risk Assessment
Management System Manual E01-X01-RAM110
Appendix 2 Zarges Platform Ladder Specifications & Image
Appendix 3 Workers Exposure to SO2 Detail Health Risk Assessment Template RasGas
Health Risk Assessment Methodology E07-X09-002

32
End of Report

33