PROJECT HSE EXECUTION PLAN

TABLE OF CONTENT

13.0 HSE MANAGEMENT

13.1. HSE Framework
13.2 HSE Philosophies, Objectives and Goals
13.3. HSE Management System
13.4. HSE Regulatory and Compliance
13.5. HSE Resource, Roles and Responsibility
13.6 HSE Plan
13.7. Technical Safety Studies and Verification
13.8. Design HSE Plan
13.9. Project Team HSE Activities during construction phase
13.10. Fabrication HSE Activities during construction phase
13.11. Environment Plan
13.12. Waste Management
13.13. HSE Assurance

13.0 HSE MANAGEMENT

13.1 HSE Framework

The HSE Mandatory Control Framework (MCF) contains the mandatory
requirements to be implemented in BOKOR Project. Its main objective is to
strengthen Health, Safety and Environment (HSE) governance through:

Clear HSE requirements for effective implementation

Consistent implementation of the HSE Management System
Expediting the implementation of Process Safety
Effective implementation of HSE assurance

The MCF supports the BOKOR Policy for HSE and provides the high-level framework
for the management of HSE. It covers 10 key elements of significant Health, Safety
 and Environmental risks, including technical and operational integrity of facilities and
equipment. They are:

1. Capability
2. Health
3. Environment
4. Safety & Transportation
5. Process Safety & Asset Integrity
6. Management of Change
7. Safe Operations
8. CONTRACTOR HSE Management
9. Design, Engineering & Construction
10. Incident Management & Emergency Response

The PMT Project Director shall be accountable for the effective and consistent
implementation of MCF in BOKOR. PMT shall provide the necessary resources,
documented systems and processes in place to support this MCF.

Implementation targets shall be set for each of the elements. The PMT shall ensure
the necessary detailed action plans in order to comply with the deadlines of the MCF.
If theres a deviation from the requirements of the MCF, PMT shall get requires
approval from the respective relevant authority.

13.2. HSE Philosophies, Objectives and Goals

Management communicates the HSE philosophy to all employees, customers,
contractors, and third parties associated with our business, and each Petronas
organization must provide positive evidence of conformance to the system.

HSE philosophies:

The facilities shall be designed, operated and maintained to have the lowest
impact practicable on safety, occupational and public health, society and
the environment throughout its life cycle.

Emphasis shall be placed on the prevention of accidents.

 There is a systematic, structured approach and adequately resourced plan
for managing the projects HSE risks and ultimately to demonstrate that
HSE risks and hazards in Total Life Cycle comply with the law and to achieve
continuous performance improvement.

Lead and manage contractors to manage HSE performance in line with

company requirement. Contractor shall at all times comply with the
legislative requirements without holding PMT liable for any transgression or
non-compliance thereon.

The engineering, construction & fabrication, installation, commissioning, start-up and

operation phases shall also abide to:

PETRONAS HSEMS Document

PETRONAS Technical Standard (PTS) and Carigali Standard Procedures

(CSP)

PETRONAS Mandatory Control Framework under Health, Safety and

Environment.

ZeTo Rules Compliances and Consequences Management.

HSE Objectives and Target:

PMT is committed into managing its business and executing projects safely and without
detrimental impact on workplace health, safety and the environment at all times. The
overall HSE aim is to have an Incident and Injury Free workplace. This is in line with
the Projects HSE target of AIM ZeRO. To measure its HSE performance in this
respect, Project Team will report against a system of Key Performance Indicators
(KPIs). Project Team has established HSE objectives for this work scope, these are
seen as overall goals arising from HSE policy that Project has set to achieve and which
is quantified where practical.
 Design facilities that can be commissioned and operated without injury or illness.

Zero Fatality Accident Rate (FAR)

Zero Loss Time Incidents (LTI's) and no long term debilitating illnesses for either
PMT or CONTRACTOR personnel.

Zero Lost of Primary Containment (LOPC)

Zero Major Fire Incident

Compliance to all environmental regulations

Comply with regulatory, PETRONAS and Project requirements.

Zero Compound and Penalty from authority on Environment non-compliance

BOKOR PMT has established HSE KPI for the execution of this project as follows;

Target
No. KPI PROJECT X
Leading KPIs

1
Project Progress % Completion
2 HSE Plan Progress
% Completion
(monthly)
3 Management Walkabout
100%
(Plan vs. Actual) (monthly)
4
UAUC:Manhours (monthly) 1:250
6
ZeTo Rules Audit 1:5000
7
PTW Verification 1:5
8 Project Regulatory
100 %
Register
Commented [MRBO(1]: Number terlajak satu and
80 % (Based on
9 Touch The Heart Session tak allign
SPOT Scorecard)
Lagging KPIs

1 0
Fatality Accident Rate
2 Lost Time Injury
0
Frequency (LTIF)
3 0
Major Fire
4 Major Loss of Primary
0
Containment(LOPC)
 PSM KPIs

Project PSM
1 3.0/4.0
Implementation Review
score
PHA and PSM
2 Implementation Review
100%
recommendations close-
out by PMT/Contractor
PSM Roadshow and PHA
3 80%
Tools Training
attendance by PMT

BOKOR PMT shall demonstrate our responsibility through daily commitment towards
HSE principles:

STOP WORK if it is unsafe;

TAKE TIME to assess risks and work safe;

INTERVENE if a hazard is seen;

FOLLOW corporate guidelines and procedures;

PROCEED only if you are TRAINED, PROTECTED, have a PLAN and are in the right
State of Mind; and

REPORT all incidents or near misses immediately and INVESTIGATE

13.3. HSE Management System

In line with PETRONAS HSE Mandatory Control Framework (MCF) and PTS18.00.01
Health, Safety & Environment Management System, the project will adopt similar HSE-
MS elements to demonstrate a systematic approach for the management of HSE
matters, and form a basis for continuous improvement in HSE performance.

13.4. HSE Regulatory and Compliance

This section is covered in the next section 17, Compliance Related Matter. The national
laws that govern the project among others are:
 Factory and Machinery Act [1967]
Environmental Quality Act [1974]
Atomic Energy Licensing Act [1984]
Petroleum (Safety Measure) Act [1984]
Occupational Safety and Health Act [1994]
Marine Accords (SOLAS, MARPOL, EEZ)

Below are some of regulatory requirement which are applicable to the project.

a) EIA requirement The project team has engaged DOE, Kuching and was
advised that no new EIA study need to be done for the project. The EIA approval will
ride onto the previously approved Bokor Phase 3 EOR development project. The
project team will however, need to develop and submit a revised Environment
Management Plan (EMP) Study report for DOE, Kuching approval prior to project
execution.

b) EMP - No new EIA Report submission is required but an update of the Bokor
Phase 3 EOR Environmental Management Plan (EMP) with Betty integration is required
as per Letter by DOE(Ref: AS (SWK) (B): 50/013/802. PMT will engage environmental
consultant to update the existing EMP to address environment and social related issues
and concerns of the project. PMT will ensure compliance with the Bokor EIA Approval
Condition, relevant Malaysian laws and regulations and PSCB Guidelines and policies
on the environment during design, construction, commissioning/start-up and
operation.

c) MDTCC Approval Project Team via PCSBs P&E HSE and MPA will apply for
approval from Ministry of Domestic Trade, Co-operatives and Consumerism (MDTCC)
prior any installation being done offshore (in EEZ). Preparation for this submission
should be done 6 months prior to the installation.
d) PTI & PTO requirement The project team will apply PTI/PTO to DOSH, for
any new hydrocarbon service pipelines. Project Team is required to apply for PTI 2
months prior to installation. Hydrotest for the new hydrocarbon pipeline must be
witnessed by officer from Department of Occupational Safety and Health Malaysia
(DOSH) with a minimum 2 weeks notification. For commissioning and start-up, PMT
shall apply for Permit To Operate (PTO) with a minimum of 2 months prior to the
planned date.

e) Crossing Agreement (if needed) - clearance for this shall be obtain from
relevant parties (e.g. Telekom Malaysia) with a minimum of 6 months prior to
execution.

f) FMA requirement for pressure vessel (above 1 atm bar) MPM requires
the project team to execute Offshore Self-Regulatory (OSR) and documents all the
design data and relevant drawings. Pressure vessel/unfired pressure vessel for
offshore installation has been waived for application of Perakuan Mesin Tekanan (PMT)
from DOSH. This is according to FMA (Exemption To PETROLIAM Nasional Berhad)
2013. Hence, with that exemption, PMT have to follow OSR-Management System, May
2013, Rev 3. The custodian is MPM.

Legal and other regulatory compliance requirements shall be identified and assessed
to determine those that are applicable in relation to Health, Safety, Environmental
impacts to BOKOR. PMT shall ensure that the CONTRACTOR maintains a HSE
Regulatory Compliance Register, relevant to the project scope of work, which is
monitored, reviewed and maintained on an annual basis, to ensure any legislative
change does not adversely affect the project. The Legal Register and compliance
register (BOKOR Regulatory Register) will be tracked and monitored monthly.

13.5. HSE Resources, Roles and Responsibilities

PMT shall populate the Organization Chart with key personnel such as Company Site
Representative/Senior Resident Engineer, Resident Engineer and HSE Officers to
undertake the contract administration and provide HSE leadership to the Contractor
project team.

The roles and responsibility of each personnel at all level shall be identified and
communicated. PMT shall provide the necessary resources, documented systems and
processes in place to support the execution of HSE strategy
13.6. HSE Plan

Contractors HSE Plan will be reviewed and approved by PMT after taking comments
from HSE team . Upon approval, Contractor shall cascade the HSE Plan to all sub-
contractors hired by the Contractor. A copy of the approved HSE plan will be forwarded
to HSE PD&T for performance monitoring.

In order to achieve project HSE objectives stated at the HSE Plan the following actions
shall be taken:
Ensure that Contractors comply with all aspects of the design and are in
compliance with the project specifications and drawings and relevant
industrial standards.
Ensure that Contractors fully comply with all the HSE procedures (PTW, JHA
etc.) and safety work practices as stipulated in the existing contract
documents such as HSE Policies, ZeTo rules, HSE MCF and HSEMS, Manual
etc.
Ensure that the requirements outlined inside the approved Contractors' HSE
Plan are implemented such as HSE briefing to workers prior to mobilization,
HSE meetings, HSE trainings, HSE inspections & audits, wearing of Personal
Protective Equipment (PPE), availability of work procedures prior to
commencement of work etc.
Ensure that Contractor has well established Emergency Response Plans. The
ERP shall be bridged when there is concurrent activities/involve multiple
parties i.e. Operations and/ or Drilling.
Ensure that Contractor has adequate medical facilities and medical
evacuation (MEDEVAC) procedures in place.
SK-Oil Asset shall lead the Pre-Activity Safety Review (PASR) with the
involvement of offshore Operations, P&E HSE , and PMT prior to the
introduction of hydrocarbon into the system.
SKO Operation Readiness, Strategy and Assurance (ORSA) shall lead the
Pre-Activity Safety Review (PASR) with the involvement of offshore
Operations, P&E HSE , and PMT prior to the introduction of hydrocarbon into
the system.
 Undertake PPMS stage gate reviews e.g. Project Integrated Reviews (PIR),
Project Risk Assessment and Pre-start-up Audit by independent parties from
P&E Line Departments.
PMT site representatives will supervise daily activities to ensure that the
work is performed in a safe and efficient manner and is in accordance with
the specifications and job scope requirements.
Establish a site specific Emergency Response Plan (ERP) prior to mobilization
and covering all activities as specified in the Work Breakdown Structure. This
ERP shall bridge all parties having concurrent activities at site e.g.
Operations, Drilling, Pipe laying.

CONTRACTOR is accountable and responsible for all HSE activities throughout the
duration of the project and shall manage in accordance with their HSE Management
System to be in line with COMPANY HSE Management System (HSEMS).

It is the aspiration and commitment by the PMT that the BOKOR Project will be
completed with the high standard of the HSE practice with no Lost Time Injury
(LTI) case or any Fire/Explosion incident and non-compliance to the environmental
requirements.

13.7. Technical Safety Studies and Verification

The project shall conduct the following workshops/studies to develop HSE deliverable
as per PPMS requirement. As minimum, the following are:

a) HSE and Fire Protection Philosophy

b) Hazard Identification (HAZID)
c) Hazard and Operability (HAZOP)
d) Quantitative Risk Assessment (QRA)
e) Fire Explosion Analysis (FEA)
f) Escape, Evaluation and Rescue Analysis (EERA)
g) Emergency System Survivability Assessment (ESSA)
h) Temporary Refuge Impairment Analysis (TRIA)
i) Smoke & Gas Ingress Analysis (SGIA)
j) Thermal Radiation, Gas Dispersion and Plume Study
 k) Fire Safety Assessment (FSA)
l) Noise and Vibration Study
m) ALARP Demonstration Workshop
n) Human Factor Engineering (HFE)
o) Design HSE Case
p) Operation HSE Case
q) Safety Critical Equipment (SCE) & Performance Standard (PS)

13.8. Design HSE Plan

The engineering design shall ensure full compliance to Petroleum (Safety Measures);
Transportation of Petroleum by Pipelines [1985] and meet either the standard Liquid
Petroleum Transportation Piping System [ANSI/ ASME31.4] or Pressure Piping Gas
Transmission and Distribution Piping System [ANSI/ ASME 31.8]. Findings and
recommendations from the following independent reviews and studies will be
incorporated in the project detailed design to ensure design deliverables conform to
PCSB design requirements while also meeting HSE objectives by minimizing potential
risks to as low as reasonably practical. Independent parties from P&E Line
Departments and/or Third Party Consultants will be engaged for the execution of these
reviews and studies with participation from PMT as per PPMS requirements.
The following are technical safety studies planned, and not limited to:
Hazard Identification (HAZID) and Hazard and Operability (HAZOP) Reviews.
Safety Integrity Level (SIL) Study.
Quantitative Risk Assessment (QRA) including Fire Explosion Analysis (FEA).
Perform HSE Case Study.
Project Integrated Reviews (PIR).
Instrumented Protective Function (IPF)
Thermal Radiation, Gas Dispersion and Plume Study
Smoke and Gas Ingress Analysis (SGIA)
Emergency System and Survivability Analysis (ESSA)
Evacuation, Escape and Rescue Analysis (EERA)
Temporary Refuge Impairment Analysis (TRIA)
Hazardous Area Classification (HAC)
Acoustically Induced Vibration (AIV)
Fire and Gas Mapping
Firewater Demand Analysis
 Firewater Hydraulic Study
Safety Critical Equipment (SCE) & Performance Standard (PS)
Line Discipline Review (LDR)

13.9. Project Team HSE Activities during construction phase

Below are the summaries of HSE activities (by project team) during
construction phase

1) Assess contractor HSE capability Evaluate contractor HSE management

system capability

2) Attend site HSE meeting by HSE advisor/lead - to review the performance

of the work sites based on agreed monthly performance indices and to
propose improvement initiatives.

3) HSE policy dissemination - Disseminate Company HSE policy as

appropriate and having them displayed at prominent locations within the
Project Sites area vicinity

4) Set up joint HSE Committees - Establish committees for senior

management, project management, and work sites with meeting protocol
and interfaces.

5) Organise appropriate HSE related training organise and support

contractor(to organise) for HSE related training ie proactive intervention
culture, managing schedule waste, site safety awareness etc

6) Review contractor HSE plan Regular engagement and assign HSE

advisor at site to monitor contractor HSE plan/activities, competency, job
hazard analysis, monitor HSE performance etc

7) Implement HFE during construction develop and implement HFE

Construction plan

8) Audit HSE management conduct HSE site audit, pre-load out inspection
and pre-start up audit

9) Management HSE Visit (MHSEV) - leadership commitment and presence

by project team management and interacting with site workforce.
13.10.Fabrication HSE Activities during construction phase
Below are the summaries of HSE activities (by fabricator) during construction phase:

1) Develop and implement HSE plan HSE plan to spell out how does contractor
apply HSE management system to manage the project activities and HSE
hazard including HSE scorecard, HSE competence assurance, incident reporting
and investigation

2) Newcomer/visitor induction to inform new comer for site HSE requirement

including Zeto Rules, stop work policy, emergency/evacuation procedure etc

3) HSE incentive to initiate an incentive scheme that will enhance safety

awareness and reduce incident rate.

4) Random drug and alcohol check conduct random drug and alcohol check for
site personnel

5) Site emergency drill - Conduct emergency drills based on established scenarios

in the ERP procedure and identify improvement actions.

6) Unsafe Act/condition reporting Encourage site personnel for ACT/UCUA

participation. All reported ACT to be investigated for cause(s) and rectified.
ACT/UCUA to be compiled for trending for lessons learned in the monthly
report.

13.11.Environment Plan
The environment management shall cover the monitoring and measurement of at least
the following key criteria in meeting PCSB targets, regulatory requirements, permits,
licenses and other requirement in order to conform to operational target. These are:
Emission to air
Effluent discharge to sea
Scheduled waste
TENORM waste
Fuel consumption

In accordance to PETRONAS roadmap to carbon management, continuous venting is

not allowed post 2017. SKO is targeting to reduce its Green House Gas (GHG) emission
to 1.5 MtCO2e by implementing all vent-to-flare conversion by 2017. The strategy to
implement this target are through:
 Incorporation of vent-to-flare projects into the project
Identification of additional venting/flaring reduction initiatives throughout year
2018-2019.
Improving data accuracy on volumetric force balance by calibration meter
replacement or where possible new meter installation, hence accurate
reporting.

The project will develop a revised Environment Management Plan (EMP) as part of EIA
approval condition, to be submitted to DOE, Kuching, Sarawak for approval.

13.12. Waste Management

Both hazardous and non-hazardous waste will be generated during the execution
phase. The management and disposal of waste shall follow:
Environmental Quality (Scheduled Waste) Regulation 2005,
PETRONAS HSE Mandatory Control Framework Hazardous Waste &
Environmental Hazardous Substance (EHS)
PTS 18.72.01 Waste Management
WW ALL S04 006 PETRONAS Carigali Waste Management Guide

Below are the summary of the responsibilities of the contractor in managing the waste
but not limited to:

a) Outline, implement and maintain an environmental management system (can be

part of HSEMS) that details the practice, procedures and countermeasure for
effective management of potential environmental impact, as required by the
relevant provisions under the Environmental Quality Act, 1974 all regulations
enacted thereto and PETRONAS Carigalis requirements.

b) Pay due regard to the environment by acting to protect air, water, animal and plant
life from adverse effects of project activities, and to minimise any adverse effects
which may arise from such operations in accordance with the legal requirements
and PETRONAS Carigalis environmental policies.
c) Develop site Environment Management Plan (EMP) by incorporating Environmental
Impact Assessment (EIA) Approval Condition from relevant authority, other
applicable environmental requirements, and PETRONAS Carigali requirements. The
Plan shall address among others, waste management procedure relevant
approval/written permission by DOE (e.g. installation of fuel burning equipment,
waste water treatment system, etc.), implementation of recommended mitigation
measures as per approved EIA and EMP, environmental audit programme and, etc.
The plan shall be available before the commencement of any physical activity at
site and shall be regularly updated as conditions change. Project EMP shall also
be adhered to.

d) Managed the Scheduled Waste (SW) as per Environmental Quality (Scheduled

Waste) Regulation 2005:
Notification on SW generation at site
Segregation of SW
Labelling of SW container with required information
Storage of SW at site
Record keeping of SW information, including SW inventory, Waste
Consignment Notes, Consignment of Goods and Consignment Notes, and any
other relevant documents.
Transportation and disposal of SW to prescribed premises.

e) Only appoint prescribed premises (final disposal facility) approved by DOE to

handle the transportation and disposal of SW from CONTRACTORS site. Any SW
sent for treatment or recovery at other approved facility must be referred to
PETRONAS Carigali or respective state DOE. Before any of these appointment, a
pre-award audit must be conducted to the facility with the participation by
PETRONAS Carigali representative.

f) Ensure dedicated SW temporary storage area must be available and personnel

managing the SW at site must have basic training on SW management.
g) Be liable for any legal actions as a result of not complying to regulatory
requirements in managing and protecting the environment while executing the
Project awarded by PCSB.

13.12 HSE Assurance

The monitoring and measuring of HSE performance will be continually evaluated and
audited throughout the life of the project. This process of evaluating the HSE
performance shall be captured through formal and informal inspection and audits.

The HSE Audits will be developed and scheduled to comply with PETRONAS HSE
Management System. They shall be undertaken to monitor, analyze and record project
compliance with the PETRONAS HSE Management System and PTS. The audit results,
along with nominated correction actions will be forwarded to the CONTRACTOR Project
Manager. Recommended actions from each audit shall be tracked by the Project
Manager.

PMT and CONTRACTOR will develop Tier 1 Audit checklist based on the PETRONAS
GHSED (eg. ZeTo Rules compliance inspection checklist) requirements and program to
comply with BOKOR HSEMS and PTS prior to implementation.

Internal and external audits which may be undertaken during the project will be
documented within the Project HSE Audit Schedule. The HSE management strategy
identified for each project CONTRACTOR will determine the requirements for a formal
audit of their operations and HSE management system.

GPD will carry out a HSE Tier 2 assurance once per year and all the findings will be
reported to the PMT for actions and closeout.