NFPS Offshore Compression Complexes Project COMP2

COMPANY Contract No.: LTC/C/NFP/5128/20

CONTRACTOR Project No.: 033734

Document Title

:

HSE MANAGEMENT OF VENDORS AND SUBCONTRACTORS PROCEDURE

COMPANY Document No.

: COMP2-SPM-SH-PRC-00004

Saipem Document No.

: 033734-Z-Z-00-SPM-HS-P-10017

Discipline

: HSE&Q

Document Type

: PROCEDURE

Document Category

: 1

Document Classification

: Internal

00

17-APR-2023 Approved For Construction Samuel Okorie

B

A

09-APR-2023

Issued For Approval

Samuel Okorie

26-MAR-2023

Issued For Review

Samuel Okorie

Alessandro Colanzi

Matteo Palazzolo

Matteo Palazzolo

Ennore

Paoli

Ennore

Paoli

Ennore

Paoli

REV DATE

DESCRIPTION OF REVISION

PREPARED BY

CHECKED BY

APPROVED BY

Saipem S.p.A.

Company No. COMP2-SPM-SH-PRC-00004_00

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REVISION HISTORY

Revision

Date of Revision

Revision Description

A1

A

B

00

13-JAN-2023

Issued for Inter-Discipline Check

26-MAR-2023

09-APR-2023

17-APR-2023

Issued for Review

Issued For Approval

Approved For Construction

HOLDS LIST

Hold No

Hold Description

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TABLE OF CONTENTS

1

INTRODUCTION … 6

1.1 PROJECT OBJECTIVE … 6 1.2 PROJECT SCOPE … 6 1.3 PURPOSE AND SCOPE OF THE DOCUMENT … 8

DEFINITIONS AND ABBREVIATIONS … 8

2.1 DEFINITIONS … 8 2.2 ABBREVIATIONS … 10

REFERENCE … 12

2

3

3.1 COMPANY DOCUMENTS … 12 3.2 PROJECT DOCUMENTS … 12 3.3 CONTRACTOR DOCUMENTS … 13 INTERNATIONAL CODES AND STANDARDS … 14 3.4

4

ROLES & RESPONSIBILITIES … 15

4.1 PROJECT MANAGER… 15 4.2 PROJECT PROCUREMENT MANAGER… 15 4.3 BID INITIATOR … 15 4.4 PROJECT HSE MANAGER … 15 4.5 HSE MANAGER FOR SUBCONTRACTOR YARDS … 16 4.6 CONSTRUCTION MANAGER / SITE MANAGER … 17 4.7 SITE HSE PERSONNEL … 17 4.8 SUBCONTRACTOR PROJECT MANAGER … 18 4.9 SUBCONTRACTORS … 18

5

SUBCONTRACTORS MANAGEMENT AND EVALUATION … 19

5.1 EVALUATION OF THE HSE REQUIREMENTS IN THE QUALIFICATION PHASE OF SUBCONTRACTORS AND VENDORS … 20 5.1.1 EVALUATION RESULTS … 21 5.2 MANAGEMENT OF SUBCONTRACTORS IN THE ACTIVITIES/SERVICES ASSIGNMENT PHASE … 22 5.2.1 IDENTIFICATION OF APPLICABLE HSE REQUIREMENTS FOR VENDORS AND SUBCONTRACTORS … 22 5.2.2 DEFINITION OF THE SCOPE OF SERVICE AND SELECTION OF HSE REQUIREMENTS … 24 5.2.3 EVALUATION OF THE HSE REQUIREMENTS FOR SUBCONTRACTORS DURING THE BID PHASE … 24 5.2.4 RESULT OF EVALUATION OF HSE REQUIREMENTS … 24

6

MONITORING AND SUPERVISION DURING THE EXECUTION OF WORKS … 26

6.1 KOM HSE (HSE KICK OFF MEETING) … 26 6.2 HSE MEETINGS … 26 6.3 HSE AUDITS, INSPECTIONS & SITE VERIFICATION … 26 6.4 FEEDBACK ON SUBCONTRACTOR PERFORMANCE AND USE OF THIS FEEDBACK IN FUTURE INVOLVEMENTS… 27

7

8

GENERAL HSE REQUIREMENTS … 28

SPECIFIC HSE REQUIREMENTS … 30

8.1 CATEGORY “1” – FULL CONTROL … 30 8.1.1 PROJECT HSE REQUIREMENTS FOR CATEGORY “1” SUBCONTRACTORS … 30

8.1.1.1 8.1.1.2 8.1.1.3 8.1.1.4 8.1.1.5

HSE Policy and Commitment … 30 HSE Management system … 30 Life-Saving Rules … 30 Compliance with Law and Regulations … 31 HSE Plan … 31

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SUBCONTRACTOR(s) minimum HSE organization … 31 8.1.1.6 HSE Risk Management … 31 8.1.1.7 HSE Performance Reporting … 32 8.1.1.8 8.1.1.9 Meetings and communication … 32 8.1.1.10 Monitoring and activities control … 32 8.1.1.11 HSE Performance Review … 33 8.1.1.12 Permit to Work (PTW) system … 33 8.1.1.13 Work at Height … 33 8.1.1.14 Confined Space … 34 8.1.1.15 Personal Protective Equipment … 34 8.1.1.16 Hazardous Material Management … 35 8.1.1.17 Tools, Machines and Equipment … 36 8.1.1.18 Health Surveillance … 37 8.1.1.19 Medical Insurance and Medical Fitness Certificate … 37 8.1.1.20 Medical Organization and Facilities … 38 8.1.1.21 Health Awareness and Prophylaxis … 38 8.1.1.22 Drug and Alcohol Policy … 39 8.1.1.23 Medical Emergency … 39 8.1.1.24 Environmental Management Plan … 39 8.1.1.25 Spills … 40 8.1.1.26 Waste Management … 40 8.1.1.27 HSE Training program … 40 8.1.1.28 Competence … 41 8.1.1.29 Industrial Hygiene … 41 8.1.1.30 Emergency Preparedness … 41 8.1.1.31 Emergency Preparedness training … 41 8.1.1.32 Lifting … 42 8.1.1.33 Selection of SUBCONTRACTOR(s) … 43 8.1.1.34 Transportation Safety … 43 8.1.1.35 Incident Notification, Investigation and Reporting … 44 8.1.1.36 Worker identification system … 44 8.1.1.37 Site Facilities and Equipment … 44 8.1.1.38 Heat Stress Management … 44 8.1.1.39 Participation in HSE programs … 44 8.1.1.40 HSE Requirements for Diving SUBCONTRACTORS … 45 8.1.1.41 HSE Requirements for NDT radiographic activities SUBCONTRACTORS … 45 8.1.1.42 HSE Objectives and Targets for SUBCONTRACTORS/VENDORS … 45 8.1.2 OFFSHORE SPECIFIC HSE REQUIREMENTS … 46 Medical Fitness … 46 Training, Competence, Certifications … 46 Permit to Work System … 48

8.1.2.1 8.1.2.2 8.1.2.3

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8.1.2.4 8.1.2.5 8.1.2.6 8.1.2.7 8.1.2.8 8.1.2.9

Access to WORKSITE … 48 Transfer of personnel … 48 Inspections and Audits … 48 Hazardous Material Management … 48 SIMOPS … 49 Environmental Compliance … 49 8.2 CATEGORY “2” – DIRECT INFLUENCE … 50 8.3 CATEGORY “3” – LIMITED INFLUENCE … 51

HSE Policy and Commitment … 51 8.3.1.1 HSE Risk Management … 51 8.3.1.2 HSE Management system … 51 8.3.1.3 Compliance with Law and Regulations … 52 8.3.1.4 8.3.1.5 HSE Performance Reporting … 52 8.3.1.6 Waste Management … 52 Incident Notification, Investigation and Reporting … 52 8.3.1.7 Health Management … 52 8.3.1.8 8.4 CATEGORY “4” – LIMITED INFLUENCE … 53

HSE Policy and Commitment … 53 8.4.1.1 HSE Risk Management … 53 8.4.1.2 HSE Management system … 53 8.4.1.3 Compliance with Law and Regulations … 53 8.4.1.4 8.4.1.5 HSE Performance Reporting … 54 8.4.1.6 Waste Management … 54 Incident Notification, Investigation and Reporting … 54 8.4.1.7 8.4.2 OFFSHORE SPECIFIC HSE REQUIREMENTS … 54

8.4.2.1 8.4.2.2 8.4.2.3 8.4.2.4 8.4.2.5 8.4.2.6 8.4.2.7

Medical Fitness … 54 Training, Competence, Certifications … 55 Access to WORKSITE … 56 Transfer of personnel … 56 Hazardous Material Management … 56 SIMOPS … 56 Environmental Compliance … 56

9

APPENDICES … 57

9.1 APPENDIX 1 – SUMMARY OF HSE REQUIREMENTS FOR VENDORS AND SUBCONTRACTORS – CATEGORY ‘1’ – FULL CONTROL … 57 9.2 APPENDIX 2 – SUMMARY OF HSE REQUIREMENTS FOR VENDORS AND SUBCONTRACTORS – CATEGORY ‘2’ – DIRECT INFLUENCE … 60 9.3 APPENDIX 3 – SUMMARY OF HSE REQUIREMENTS FOR VENDORS AND SUBCONTRACTORS – CATEGORY ‘3’ – LIMITED INFLUENCE … 62 9.4 APPENDIX 4 – SUMMARY OF HSE REQUIREMENTS FOR VENDORS AND SUBCONTRACTORS – CATEGORY ‘4’ – LIMITED INFLUENCE … 63

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1

INTRODUCTION

The North Field is the world’s largest natural gas field and accounts for nearly all of the state of Qatar’s gas production. The reservoir pressure in the North Field has been declining due to continuous production since the early 1990s. The principal objective of the NFPS Project is to sustain the plateau from existing QG South Operation (RL Dry Gas, RGE Wet gas) and existing QG North Operation (QG1 & QG2) production areas by implementing an integrated and optimum investment program consisting of subsurface development, pressure drop reduction steps and compression. Refer to the figure below for a schematic of the North Field.

Qatargas Operating Company Limited is leading the development of the North Field Production Sustainability (NFPS) Project.

1.1 Project Objective

The objective of this Project includes:

• Achieve standards of global excellence in Safety, Health, Environment, Security and Quality

performance.

• Sustain the Qatargas North Field Production Plateau by installing new Compression Complex facilities CP6S & CP7S in QG south with integration to the existing facilities under Investment #3 program.

• Facility development shall be safe, high quality, reliable, maintainable, accessible, operable,

and efficient throughout their required life.

1.2 Project Scope

The Project Scope includes detailed engineering, procurement, construction, transportation & installation, hook-up and commissioning, tie-in to EXISTING PROPERTY and provide support for start-up activities of the following facilities and provisions for future development. The WORK shall be following the specified regulations, codes, specifications and standards, achieves the specified performance, and is safe and fit‐for‐purpose in all respects.

Offshore

CP6S and CP7S Compression Complexes that are part of QG-S RGE facilities as follows:

• CP6S Compression Complex • Compression Platform CP6S, Living Quarters LQ6S, Flare FL6S • Bridges BR6S-2, BR6S-3, BR6S-4, BR6S-5 • Bridge linked Tie-in to RP6S

Production from existing wellheads (WHP6S & WHP10S) and new wellhead (WHP14S) are routed via riser platform RP6S to compression platform CP6S to boost pressure and export to onshore via two export lines through the existing WHP6S pipeline and a new 38” carbon steel looping trunkline from RP6S (installed by EPCOL). CP6S is bridge-linked to RP6S.

• CP7S Compression Complex • Compression Platform CP7S, Living Quarters LQ7S, Flare FL7S • Bridges BR7S-2, BR7S-3, BR7S-4, BR7S-5 • Bridge linked Tie-in to RP7S

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CP7S shall receive production from existing wellheads (WHP5S & WHP7S) and new wellhead (WHP13S). There is only one export line for CP7S through the existing export pipeline from WHP7S. CP7S is bridge-linked to RP7S.

RGA Complex Destressing

Migration of the Electrical power source, Telecoms, Instrumentation and Control systems from WHPs and RHPs hosted by RGA to the respective Compression Complexes listed below:

• WHP6S, WHP10S, WHP14S, RP6S and RP10S to CP6S Compression Complex • WHP5S, WHP7S, WHP13S and RP7S to CP7S Compression Complex

Destressing of Telecoms, Instrumentation and Control system in RGA Complex Control Room, which would include decommissioning and removal of telecom system devices and equipment that would no longer be required post migration and destressing activity.

Onshore

An Onshore Collaborative Center (OCC) will be built under EPC-9, which will enable onshore based engineering teams to conduct full engineering surveillance of all the offshore facilities. The OCC Building will be located in Ras Laffan Industrial City (RLIC) within the Qatar Gas South Plot. MICC & Telecommunication, ELICS related scope will be performed in the OCC building.

Figure 1.2.1: NFPS Compression Project COMP2 Scope

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1.3 Purpose and scope of the document

In line with the principles of the HSE and the Procurement management system and without prejudice to applicable HSE regulations, the purpose of this procedure is to:

• Provide general guidelines for the evaluation, management and compliance with HSE requirements of VENDORs/SUBCONTRACTORs during the qualification phase and the assignment of required activities/services;

• Provide

reference policies

for coordinating and monitoring activities performed by

VENDORs/SUBCONTRACTORs on sites operated by CONTRACTOR.

this document

The objective of the evaluation, monitoring and control of VENDORs/SUBCONTRACTORs more efficient, improve their HSE performance and contribute to reducing the number of near misses, accidents and injuries in all project areas and as well to guarantee environmental protection.

to make

is

2 DEFINITIONS AND ABBREVIATIONS

2.1 DEFINITIONS

DEFINITION

DESCRIPTION

ANOMALY OR UNSAFE ACT OR UNSAFE CONDITION

Any unsafe condition or act having the potential to lead to or contribute to an incident.

COMPANY

Qatargas Operating Company Limited.

COMPANY ITEM(S)

Means any itemised and non-itemised equipment and materials expressly specified as being supplied to CONTRACTOR by COMPANY

CONTRACTOR

Saipem S.p.A.

All machinery, apparatus, materials, articles, components, systems and items of all kinds to be designed, engineered, procured, manufactured, constructed, supplied, fabricated, tested and permanently installed by CONTRACTOR at SITE in connection with the NFPS Project as further described in Exhibit 6.

FACILITIES

HIGH POTENTIAL INCIDENT FREQUENCY

LOST FREQUENCY RATE

TIME

INJURY

PROJECT

NFPS Offshore Compression Complexes Project COMP2

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edManHoursTotal WorkFATNLTINLTIFR000,000,1)..(+=

NFPS Offshore Compression Complexes Project COMP2

HSE MANAGEMENT OF VENDORS AND SUBCONTRACTORS PROCEDURE

DEFINITION

DESCRIPTION

SITE

SUBCONTRACT

SUBCONTRACTOR

TOTAL INCIDENT RATE

RECORDABLE

VENDOR

(i) any area where Engineering, Procurement, and Fabrication of the FACILITIES related to the CPS6S and CP7s Compression Complexes are being carried out and (ii) the area offshore required for installation of the FACILITIES in the State of Qatar. and signed Contract CONTRACTOR for the performance of a certain portion of the WORK within the Project. Any organization selected and awarded by CONTRACTOR to supply certain Project materials or equipment or for whom a part of the WORK has been Subcontracted.

SUBCONTRACTOR

by

Means any CONTRACTOR’s and/or SUBCONTRACTORS’ ITEM(S). VENDORS’ supplier(s) of CONTRACTOR to assist presence on WORKSITE may be required CONTRACTOR and/or COMPANY installation, commissioning and start-up of such CONTRACTOR ITEMS and during the PERFORMANCE TESTS

the

for

WORK

Any activity related to or pertaining to the Contract

WORKSITE

Means the SITE and/or all and any construction location(s), as listed in the EXHIBIT, where any major parts of the PLANT shall be fabricated and assembled, excluding all of other CONTRACTOR and SUBCONTRACTORS

and WORKSHOPs

premises

offices,

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edManHoursTotal WorkMTCNRWDCNFATNLTINTRIR000,000,1)…(+++=

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2.2 ABBREVIATIONS

Code

COMP-2

COSHH

IH

H2S

HIRA

HSE

Definition

NFPS Offshore Compression Complexes Project EPC 2

Control of Substances Hazardous to Health

Industrial Hygiene

Hydrogen Sulphide

Hazard Identification Risk Assessment

Health, Safety and Environment

HSE-MS

Health, Safety and Environment Management System

ISO

IVMS

JSA

KOM

LiHS

LSR

LTI

LTIFR

MFC

MOSI

MS

MSDS

MTC

NFPS

OPITO

PoB

International Organization for Standardization

In-Vehicle Monitoring System

Job Safety Analysis

Kick Off Meeting

Leadership In Health and Safety

Life-Saving Rules

Lost Time Injury

Lost Time Injury Frequency Rate

Medical Fitness Certificate

Marine Offshore Safety Induction

Management System

Material Safety Data Sheet

Medical Treatment Case

North Field Production Sustainability

Offshore Petroleum Industry Training Organization

Personnel on Board

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Definition

Personal Protective Equipment

Permit To Work

Qatar Gas North

Qatar Gas South

Ras Laffan Industrial City

Restricted Work Day Case

Safety Health Environmental and Security

Code

PPE

PTW

QGN

QGS

RLIC

RWDC

SHES

SIMOPS

Simultaneous Operations

SoS

SoW

TBT

Scope of Service

Scope Of Work

Tool Box Talk

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3 REFERENCE

3.1 Company Documents

S. No

Document Number

Title

EXHIBIT 5

Project Instructions

EXHIBIT 8

Safety Health Environment & Security Instructions

(SHES)

COMP-QG-SH-PLN-00001

Project Safety Plan

OGO-OPS-OVR-001

Permit to Work System Operating Procedure

P36-X03-003

Marine Operation Manual

PRT-PSF-PRC-008

Life-Saving Rules Procedure

PRT-PSF-PRC-012

Personal Protective Equipment

PRT-PSF-PRC-016

Contractor HSE&Q Management System Procedure

PRT-RMI-PRC-002

HSE Incidents Reporting & Management

3.2 Project Documents

S. No

Document Number

Title

COMP2-SPM-MO-PRC-00001 MARINE OPERATIONS PROCEDURE

COMP2-SPM-SH-PLN-00001

PROJECT HSE PLAN

COMP2-SPM-SH-PLN-00002

REGULATORY HSE COMPLIANCE PLAN

COMP2-SPM-SH-PLN-00003

HSE COMMUNICATION PLAN

COMP2-SPM-SH-PLN-00004

COMP2-SPM-SH-PLN-00005

PROJECT MEASUREMENT AND REPORTING OF PERFORMANCE PROGRAM

EMERGENCY RESPONSE AND PREPAREDNESS PLAN

COMP2-SPM-SH-PLN-00006

SECURITY MANAGEMENT PLAN

COMP2-SPM-SH-PLN-00007

PROJECT HSE INCENTIVE PLAN

COMP2-SPM-SH-PLN-00011

HSE RISK MANAGEMENT PLAN

COMP2-SPM-SH-PLN-00012

LIHS IMPLEMENTATION PLAN

COMP2-SPM-SH-PLN-00013

HSE TRAINING PLAN

COMP2-SPM-SH-PLN-00014

DROPPED OBJECTS PREVENTION PROGRAM

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COMP2-SPM-SH-PLN-00017

HEALTH MANAGEMENT PLAN

COMP2-SPM-SH-PLN-00019

ENVIRONMENTAL MANAGEMENT PLAN

COMP2-SPM-SH-PLN-00021 WASTE MANAGEMENT PLAN

COMP2-SPM-SH-PRC-00001

INCIDENT PROCEDURE

INVESTIGATION AND REPORTING

COMP2-SPM-SH-PRC-00008

SAFE DRIVING PROGRAM

COMP2-SPM-SH-PRC-00009

ONSHORE HSE MANUAL

COMP2-SPM-SH-PRC-00010

OFFSHORE HSE MANUAL

COMP2-SPM-SH-SCH-00001

HSE WORK ACTIVITY SCHEDULE

3.3 Contractor Documents

S. No

Document Number

Title

STD_GR-GROUP-SC-001

VENDOR QUALIFICATION

STD_GR-GROUP-SC-007

MANAGEMENT OF VENDOR FEEDBACK

STD_OF-SCTOF-HSE-001

Project HSE Management

STD_OF-SCTOF-HSE-007

OFFSHORE TRANSFER OF PERSONNEL

CR_OF-SCTOF-HSE-007

HSE Requirements for Work Equipment and Work Areas

CR_OF-SCTOF-HSE-010

HSE Management of vendors

OPR-COR-CIO-OIO-001-E

Offshore Lifting Equipment and Operations

SPC-COR-HSE-001

SPC-COR-HSE-002

HSE Requirements for SUBCONTRACTORs (Low HSE Risk) HSE Requirements for SUBCONTRACTORs (High HSE Risk)

SPC_OF-SCTOF-HSE-002

HSE Requirements for Diving SUBCONTRACTORs

SPC_OF-SCTOF-HSE-004

HSE Requirements for NDT Radiographic Activity

SPC_OF-SCTOF-HSE-005

SPC_OF-SCTOF-HSE-020

for SUBCONTRACTORs HSE Requirements Fabrication Works at SUBCONTRACTORs Premises Minimum Safety Requirements for Contracting Vehicles and Drivers

for

FORM_OF-SCTOF-HSE-047 HSE REQUIREMENTS FOR VENDORS

FORM_OF-SCTOF-HSE-050 VENDOR HSE EVALUATION

FORM_OF-SCTOF-HSE-051 VENDOR HSE PERFORMANCE FEEDBACK

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3.4

INTERNATIONAL CODES AND STANDARDS

S. No

Document Number

Title

1. DNVGL-RP-N101

IMCA

IOGP Report No. 343

In Marine And Subsea

Risk Management Operations International Marine CONTRACTORs Association Managing Health for field operations in oil and gas activities Report

IOGP Report No. 411

Diving Recommended Practice Report

IOGP Report No. 435

IOGP Report No. 453

A guide to selecting appropriate tools to improve HSE culture Safety Leadership managers

in Practice: A Guide

for

IOGP Report No. 459

Life-Saving Rules

IOGP Report No. 577

IOGP Report No. 597

Fabrication site construction safety recommended practice – Hazardous activities Fabrication site construction safety recommended practice – Enabling activities

ISM Code

International Safety Management Code

ISO 14001:2018

Environmental Management Systems

ISO 19011:2018

Guidelines for Auditing Management Systems

ISO 45001:2018

ISPS Code

Occupational Health And Safety Management System International Ship and Port Facility Security Code

15. MARPOL

MARPOL Annexes I – VI and applicable Codes

16. SOLAS

SOLAS Chapter I-XIII

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4 ROLES & RESPONSIBILITIES

4.1 Project Manager

The Project Manager(s) with the assistance of the Project HSE function provides the necessary support to the Procurement Function.

Supported by the Project HSE Function, he/she will:

• Organize kick-off meetings with SUBCONTRACTORs to guarantee clarity regarding HSE

issues.

Investigate, record and monitor behaviors of SUBCONTRACTORs.

• Schedule and participate in HSE inspections. • • Monitor the progress of any established corrective actions and ensure their implementation. • Provide all the necessary personnel and economical resources for the correct implementation

of the HSE Management System, including the worksite.

• Report any HSE criticalities encountered and/or information on any non-compliance with HSE norms and rules (laid down in the approved contract) to the “Performance and Feedback Management” [CONTRACTOR Corporate Function].

4.2 Project Procurement Manager

The Procurement manager is responsible for the implementation of the HSEMS during the procurement process. The manager will ensure that the Project HSE requirements are known to all potential SUBCONTRACTORs, Suppliers at the bid stage and adequate HSE resource is accounted for in the proposal. The manager will ensure that requested HSE information is provided and fed back to the Project HSE Manager for comment and review.

4.3 BID Initiator

The Bid Initiator is responsible for the involvement of the HSE team during the bid phase preparation of the subcontracted Scope of Work and bid process. The Bid Initiator will ensure that the Project HSE requirements are known to all potential SUBCONTRACTORs, Suppliers at the bid stage and adequate HSE resource is accounted for in the proposal. As well, he/she will ensure that the requested HSE information is provided and fed back to the Project HSE Manager for comment and review.

4.4 Project HSE Manager

The Project HSE Manager, assisted by HSE team members, is responsible for:

• Specifying HSE requirements in the General Terms and Conditions for relevant contracts and

tenders;

• Evaluation of SUBCONTRACTOR capabilities concerning their management of HSE and the ability to fulfil the specified HSE requirements of the project. These evaluations may take the form of a formal assessment by CONTRACTOR, 3rd Party assessment or COMPANY recommendation and/or satisfactory performance on a previous project;

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• Selectively

inspecting sub-contractor’s premises

for compliance with project HSE

requirements;

• Adherence to the CONTRACTOR HSE Management System in all aspects of procurement

concerning the approved SUBCONTRACTOR’s list;

• Preparation of the HSE requirements for Sub-contractors according to the required service(s)

using the List of HSE Requirements;

• Review of the SUBCONTRACTORs’ HSE Management system documentation; • Ensuring that the system is in place for the SUBCONTRACTORs’ personnel assigned to work induction and site

in CONTRACTOR-operated sites the project-specific familiarization and specific HSE training in accordance with their duties;

to receive

• Distributing the incident notifications to the Project Team and Sub-contractors; • Ensuring that all high-risk subcontracted activities will be subject to the evaluation of their HSE

Management System during the bid phase;

• Preparing the annual HSE Audit Plan, including the audits to be carried out on Sub-contractors and appointing the HSE Audit Team Leader from amongst the available resources who have the necessary qualifications.

4.5 HSE Manager for subcontractor yards

The HSE Manager for subcontractor yards (CONTRACTOR role) is responsible for monitoring the implementation of the Project Health, Safety, and Environment system described in this procedure for the project’s SUBCONTRACTOR Fabrication scope of work.

His responsibilities will be, but not limited to:

• Monitor the HSE Management System effectiveness and acts as the focal point for

SUBCONTRACTOR Fabrication Site(s) HSE documentation;

• Ensuring the development and implementation of the required Project Fabrication HSE procedures, in compliance with the COMPANY/CONTRACTOR HSE Requirements, SUBCONTRACTOR HSE Standards, applicable local legislation, International Standards and regulations and this HSE Plan;

• Ensuring the implementation of the Fabrication HSE Risk Management process, and that

every activity is covered by the relevant Risk Assessment and Job Safety Analysis;

• Acting as HSE focal point for the work developed at the Fabrication site/field level and providing HSE support and advice to the Project Manager and SUBCONTRACTOR Management Team;

• Monitoring the HSE performance of SUBCONTRACTORs and providing proposals for

improvement;

• Ensuring Project’s Fabrication HSE training and Induction programs implementation at the

SUBCONTRACTOR level.

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4.6 Construction Manager / Site Manager

CM /Site Manager is responsible for:

• Supervising and monitoring SUBCONTRACTOR’s Work performance, ensuring compliance

with COMPANY and CONTRACTOR’s HSE standards, procedures and requirements.

• Monitoring Sub-contractor’s personnel competence and safe work practices. • Scheduling and carrying out HSE inspections; • • Monitoring

Investigating, recording and monitoring behaviours of SUBCONTRACTORs;

the progress of any established corrective actions and ensuring

their

implementation;

• Reporting any HSE criticalities encountered and/or information on any non-compliance with HSE norms and rules (laid down in the approved contract) to the “Performance and Feedback Management” (CONTRACTOR Corporate function), in compliance with specific company regulatory instruments set out for that purpose;

• Acting as a safety leader, promoting an open and proactive HSE culture among the

organization and the site;

• Actively participating and supporting the HSE risk management process; • Checking that SUBCONTRACTOR’s personnel possess the required training (certificates) and are provided with suitable Personal Protective Equipment to be able to safely carry out the work assigned by CONTRACTOR.

• Checking that SUBCONTRACTOR’s plant, equipment and materials brought to the worksite are in good safe working order, possess valid certification and follow generally accepted international standards.

4.7 Site HSE Personnel

Site HSE Personnel are responsible for:

• Ensuring SUBCONTRACTOR personnel receive timely full inductions and are familiar with

COMPANY and CONTRACTOR HSE standards, procedures and requirements;

• Ensuring that SUBCONTRACTORs’ supervisor(s) perform effective Tool Box Talks upon obtaining PTW and before starting the work. JSA (Job Safety Analysis) and/or Last-minute Risk Assessment is also to be conducted, by the entire work group, and correctly documented before work commencement.

• Supervising and monitoring whether the SUBCONTRACTOR’s performance of the work is following COMPANY and CONTRACTOR HSE standards, procedures and requirements. • Monitoring whether Sub-contractor’s personnel possess the required training (certificates) and are provided with suitable Personal Protective Equipment to be able to safely carry out the assigned work on the Site.

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4.8 SUBCONTRACTOR Project Manager

The SUBCONTRACTOR Project Manager has the role and responsibility to:

• Ensure that all works executed by SUBCONTRACTOR are in line with the Project HSE

Requirements and allocate the necessary resources accordingly

• Participate in the kick-off meetings with CONTRACTOR to guarantee clarity regarding HSE

issues;

Investigate, record and monitor behaviours of its SUBCONTRACTORs;

• Schedule and carry out HSE inspections, taking the lead in the same; • • Monitor the progress of any established corrective actions and ensures their implementation; • Act as a safety leader promoting an open and proactive HSE culture among the organization

and the site;

• Actively participate and support the HSE risk management process;

4.9 SUBCONTRACTORs

The SUBCONTRACTOR is responsible for respecting these criteria and to:

• Comply with the Project HSE documents and requirements; • Promote a high safety level and have in place proper systems for planning, implementation, maintenance and improvement of HSE issues. Also, the SUBCONTRACTOR shall operate with the highest regard for the health and safety of its personnel and ensure that its activities do not endanger site personnel, local communities and/or the environment;

• Be responsible, through its organization, for implementing the necessary regulations and practices required to safely carry out the work assigned by CONTRACTOR and to prevent any accident or incident that may endanger the safety of personnel or may produce damage to property and/or the environment;

• Adopt appropriate management tools, technical know-how, and work practices to reduce the environmental impact of its work (e.g. waste and noise production, air emissions, water discharges, etc.) and prevent possible accidents and injuries. The SUBCONTRACTOR shall encourage and support the elimination of waste of environmental resources (e.g. water, power etc.);

• Fully cooperate with COMPANY/CONTRACTOR HSE, Project / Site Management and Site

Staff;

• Provide competent HSE staff and resources to manage risks; and • Ensure compliance and implementation of the Environment Management Plan. • Ensure that its SUBCONTRACTORs are aligned and implement Project HSE requirements.

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5 SUBCONTRACTORS MANAGEMENT AND EVALUATION

The control and management process of HSE aspects of SUBCONTRACTORs is implemented throughout all the phases of the process:

• Qualification process of the SUBCONTRACTOR concerning their classification for commodity

codes;

• Assignment of activities/services and evaluation of the HSE requirements; • Management of SUBCONTRACTOR HSE performance; On-site monitoring and supervision of

the SUBCONTRACTOR;

• Feedback on the SUBCONTRACTOR’s performance and use of that feedback in their future

involvement. Integration of SUBCONTRACTOR HSE systems with CONTRACTOR HSE system.

•

The following activities and services are considered HSE critical and shall be subject to specific controls:

• Pre-Fabrication of components

• Assembly of any selected items (subject to COMPANY APPROVAL), if subcontracted

• HVAC/ Architectural scope

• Load-out and Transportation

• Heavy lifting and Lifting equipment

• CONSTRUCTION EQUIPMENT and Machinery – Operation and Maintenance

• Electrical Utility Supply – Operation and Maintenance

• Forklifts, Graders, Rollers and Front-end Loaders – Operation and Maintenance

• Bus Transportation – Operation and Maintenance

• Camp – Operation and Maintenance

• Security Services

• Health and Medical Services

• Environmental Services

• Any other HSE critical activities, identified during the execution phase.

Safety Critical activities and services will not be subcontracted without prior written APPROVAL from COMPANY.

Such APPROVAL will only be granted based on a satisfactory CONTRACTOR and COMPANY assessment of the SUBCONTRACTOR and their ability to perform the activity and or services to COMPANY HSE performance requirements.

Project-specific HSE requirements for vendors and SUBCONTRACTORs are defined at project level considering the instructions provided by the appropriate regulatory instruments issued at a Corporate level (Ref. Section 3.3), updated and integrated to meet the standards and laws existing at a local level as well as COMPANY contractual requirements.

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Management of HSE aspects related to the procurement of “off-the-shelves” goods and materials is excluded from the area of application of this procedure since these are considered fulfilled by complying with the relevant technical standards:

o

o

work machinery and equipment with an impact on safety must comply with the norms and standards defined both locally and internationally safety equipment procured on behalf of the CONTRACTOR (e.g. fire safety equipment) shall be compliant with specifications as defined by CONTRACTOR.

5.1 Evaluation of the HSE requirements in the Qualification Phase of SUBCONTRACTORs

and Vendors

The qualification of SUBCONTRACTORS involved in the bids shall comply with Project Procurement Procedure (ref. COMP2-SPM-PO-PRC-00002 PROJECT VENDORS AND SUB-CONTRACTORS QUALIFICATION PROCEDURE) and with the requirements of contract agreement EXHIBIT 5 and in particular:

• Demonstrated ability to meet the schedule required by the PROJECT. • Demonstrated ability to meet the overall PROJECT HSE and Quality requirements. • Demonstrated technical competence and quality management of construction equipment,

materials and services provided.

• Demonstrated experience in providing construction equipment, materials and services for the

particular application or SOW in the Arabian Gulf Region and Qatar in particular.

• Demonstrated ability of the SUBCONTRACTOR’s specific fabrication shop (as applicable)

including shop load and shop capacity.

• CONTRACTOR’s and/or COMPANY’s prior experience and history with any potential

SUBCONTRACTOR.

• Demonstrated capability and acceptability of the SUBCONTRACTORS’ commonly used the qualification of all

secondary SUBCONTRACTORs. CONTRACTOR shall verify SUBCONTRACTORS and their secondary SUBCONTRACTORs.

• Demonstrated financial conditions.

The evaluation process of vendors and SUBCONTRACTORs is managed by the Procurement department and it is normally composed of a Bid originator and experts from other involved functions (Technical Units, HSE, Quality, Business Units, Organization, Finance, etc.), depending on the purpose of the Scope of Work.

The evaluation process takes several factors into account, including the type of Vendor, the type and Category of Qualification required, the criticality of the Commodity Codes compared with the technical requirements and the HSE requirements (each commodity code can indeed be critical or non-critical due to the associated HSE aspects).

When a SUBCONTRACTOR has to qualify for one or more critical commodity codes because of their HSE aspects, it receives a specific questionnaire from the Procurement/ Bid originator (“Specific Questionnaire for Health, Safety and Environment – ref. FORM-COR-PRO-009”), in line with Corporate requirements. The HSE function ensures adequate support to the Procurement/ Bid originator evaluating the HSE requirements included in the questionnaire.

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The Questionnaire consists of several sections that take different aspects of HSE into account, including (non-exhaustive list):

• Management commitment to adopting specific company programmes aimed at disseminating

the culture and knowledge of Health, Safety and the Environment;

• Organizational structure (Organization chart); • Structure of the Document Management System; • Monitoring of HSE performances, including injuries and environmental accidents; • Certification of the HSE management system following the ISO 14001, ISO 45001 and BS-

OHSAS 18001 international standards.

The HSE evaluation methodology is based on the verification of the adequacy of the management system, with a focus on the evaluation and management of risks, environmental aspects, the performance of this system, accidents that occurred in recent years (where present) and on the improvement actions implemented as a result of fatalities.

5.1.1 Evaluation Results

Based on the analysis of the answers and the documentation provided the HSE evaluator may then express:

• a positive evaluation; • a negative evaluation; •

if the information received is deemed insufficient or unreliable (existing elements of uncertainty), the evaluator will request additional information.

The possible lack of documentation cannot justify an immediate negative evaluation in the qualification process. In this case, the HSE evaluator shall contact the SUBCONTRACTOR to request all the information required to perform the evaluation. If as a result of this contact, the documentation is not made available by the SUBCONTRACTOR within a time frame deemed suitable by the HSE evaluator, qualification for the commodity code(s) deemed critical for their HSE aspects will be suspended.

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5.2 Management of SUBCONTRACTORs in the activities/services assignment phase

The moment services/activities, classified as critical due to the nature of their associated HSE aspects, should be assigned to third parties, the Procurement Function requires the intervention of the relevant HSE Function concerning the selection, identification and evaluation of the applicable HSE requirements.

5.2.1

Identification of applicable HSE requirements for vendors and SUBCONTRACTORs

HSE requirements are identified based on:

locally and internationally applicable laws and regulations;

• • specific regulatory instruments defined at the Corporate level, such as Corporate HSE

specifications, which define them based on: ✓ HSE risk classification (High or Low); ✓ specific activities deemed critical by CONTRACTOR compared with their associated HSE risks

• Requirements of Exhibit 8, COMPANY procedures as per Exhibit 5 – Appendix I,

CONTRACTOR Project Documents

• Contractual requirements of COMPANY in the field of HSE, or contractual requirements that the SUBCONTRACTOR undertakes to meet during the term of the contract, and that if disregarded may result in various actions by CONTRACTOR, including termination of the contract. The contractual HSE requirements may be: ✓ “general”, i.e. concern the aspects of the protection of health and safety of workers and

environmental protection, or;

✓ specific by activities, e.g. transport of dangerous goods, running or renting vessels, etc.

HSE requirements applicable to each SUBCONTRACTOR depend on the criticality of the work scope, on the areas/sites where they operate, and on the level of control that can be exercised by CONTRACTOR in terms of enforcement of the Project HSE Management System.

The table on the next page summarizes the criteria for the definition of SUBCONTRACTOR stewardship, in line with worksite categories as defined in Par.7.5 of the Project HSE Plan.

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Table 5.1 –SUBCONTRACTOR/VENDOR CATEGORIZATION TABLE

VENDOR / SUBCONTRACTOR CATEGORY

WORKSITE CATEGORY

APPLICABLE HSE- MS

EXAMPLES

REPORTING & RECORDING

Category 1 – Full Control

Category A or B worksites

CONTRACTOR- owned worksites

Project Management System

HSE

• Activities performed on Category A or B worksites OR CONTRACTOR-owned facilities (e.g. CPY facilities, Karimun Fabrication Yard, Construction Vessel De-He, etc.)

All incidents related to NFPS COMP 2 Project are to be reported promptly in writing the Site Manager. to

HSE statistics are included in reporting boundaries

the Project

Category 2 – Direct influence

C Category worksites, where contractor has a direct influence

SUBCONTRACTOR procedures aligned with Project HSE Requirements

• Activities performed COOEC Fabrication Yard

in

• Activities performed in QCON Fabrication Yard

• Activities performed in Living Quarters Fabrication Yard

All incidents related to NFPS COMP 2 Project are to be reported promptly in writing the Site Manager. to

HSE statistics are included in reporting boundaries

the Project

Category 3 – Limited influence (*)

Category worksites, contractor limited influence

C where has

/ VENDOR SUBCONTRACTOR HSE Management System

• Activities performed by vendors/SUBCONTRACTORs in their worksite, using their own HSE-MS (*)

Sub-subcontracted

activities, fabrication performed sub- on SUBCONTRACTOR worksite following their own HSE-MS

the

Category 4 – Limited influence

Category C offshore where worksites, contractor has limited influence

Bridging document between CONTRACTOR and SUBCONTRACTOR HSE-MS

• Offshore spread (e.g. crew service vessel, Tug and supply vessel, etc.)
• Transportation Vessels

Surfer,

statistics

Site are not included in CONTRACTOR and Project statistics, except for activities performed on a Project WORKSITE

during

Site statistics recorded in CONTRACTOR and Project statistics the execution of the project only when working within the 500m zone or within the boundaries defined by the relevant bridging HSE documents

*Note: If a “Category ‘3’ – Limited Influence” SUBCONTRACTOR / VENDOR personnel is required to work on a fabrication/construction / offshore Worksite, then the SUBCONTRACTOR / VENDOR SHALL comply with ALL the requirements of Category “1” or Category “2” depending on the location of works.

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5.2.2 Definition of the Scope of Service and Selection of HSE Requirements

The requesting department shall define the specific Scope of Service/ Work (SoS/ SoW) in which all the activities/services requested of the SUBCONTRACTOR are detailed as well as how they shall be carried out.

The HSE department will define the HSE requirements that shall be part of the SoS/SoW. Such requirements are based on the type of activities/services to be contracted, considering the level of Stewardship to which the Vendor / SUBCONTRACTOR belongs (SUBCONTRACTOR category).

The HSE requirements applicable for the different SUBCONTRACTOR categories are detailed in Par. 7 and Par.8 of this procedure. Additional HSE requirements to be part of the SoS/SoW based on the specific work scope to be subcontracted may be identified by the HSE department using FORM_OF- SCTOF-HSE-047 – “HSE Requirements for Vendors”.

Summary tables are included in Par. 9 (appendices).

5.2.3 Evaluation of the HSE Requirements for SUBCONTRACTORS during the bid phase

The HSE department shall proceed in evaluating compliance with HSE requirements by reviewing the information and documentation submitted by SUBCONTRACTOR, based on the requirements specified in the scope of work.

For the SUBCONTRACTOR Fabrication Yards, the evaluation shall be performed using the form developed specifically for COMP2 Project. The HSE Evaluation table is part of the technical bid evaluation package to be submitted to COMPANY.

5.2.4 Result of Evaluation of HSE requirements

The HSE acceptability shall be defined by Project HSE Department involved in the Bid and shall be supported by the “SUBCONTRACTOR HSE Evaluation” Form (Doc. no. FORM_OF-SCTOF-HSE- 050-E) which shall always be attached to the “Technical Bid Evaluation” Form (FORM_OF-SCTOF- SC-PRO-028-E).

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The SUBCONTRACTOR documentation received shall be evaluated and assessed based on the guidance in the following table.

Description

Evaluation result

No information provided or HSE requirements completely unsatisfied:

Documentation not provided and/or information not available.

Some or all of the documentation provided is mainly incomplete and/or does not comply with CONTRACTOR HSE requirements, local and international legislation, as well as applicable rules and regulations.

Not acceptable

Some or all of the information provided is mainly incomplete and does not meet the requirements regarding the specific topics.

HSE Requirements are partially satisfied, but are not compliant:

Documentation provided partially meets the HSE requirements.

A condition should be set to meet the HSE requirement.

The condition (e.g. SUBCONTRACTOR shall provide further documentation and clarification) can be verified before contract award or, in case, can be outlined in the vendor contract.

The condition shall be outlined in the “SUBCONTRACTOR HSE Evaluation” Form (Doc. no. FORM_OF-SCTOF-HSE-050-E).

HSE Requirements are satisfied:

Accepted condition

with

SUBCONTRACTOR documentation and in accordance with the HSE requirements as well as with both local and international laws, and applicable rules and regulations.

information provided are

Acceptable

As well, it is required from SUBCONTRACTORs and Vendors the confirmation in writing of the full acceptance of CPY HSES requirements, Terms & Conditions, Exhibit 8 part 1-5 SAFETY HEALTH ENVIRONMENT & SECURITY (SHES) INSTRUCTIONS.

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6 MONITORING AND SUPERVISION DURING THE EXECUTION OF WORKS

To ensure the efficient management and monitoring of all subcontracted works and services in line with a uniform reference model, the following activities shall be performed:

• KOM HSE (HSE Kick Off Meeting); • HSE Meetings; • HSE Audits & site verification; • HSE Inspections.

The principles that must be followed to guarantee correct implementation for each action/measure are described below. All interested parties, including employees, are involved, based on their specific responsibilities and skills, in defining time frames and methods of coordinating and monitoring as well as the responsibility for their performance.

The Project HSE department shall define further actions/measures for monitoring and controlling the SUBCONTRACTOR taking into account the specific nature of the activities /services performed, the area/site, as well as other existing specific regulatory instruments.

6.1 KOM HSE (HSE Kick Off Meeting)

Within thirty calendar days of their subcontract award, specific HSE kick-off meetings must take place between CONTRACTOR and each of its familiar with and compliant with the Project HSE Requirements. SUBCONTRACTORs are CONTRACTOR’s management shall communicate safety expectations and requirements to each SUBCONTRACTOR’s management and Project Management Team. For more information refer to Doc. No. COMP2-SPM-SH-PLN-00003 – “HSE Communication Plan”

the SUBCONTRACTORs

to ensure

that

6.2 HSE Meetings

HSE Meetings are organised to promote the dissemination of the health, safety and environment culture and to ensure coordination between CONTRACTOR, SUBCONTRACTOR and COMPANY to ensure the implementation and monitoring of Project HSE Requirements.

information as well as

For more information refer to Doc. No. COMP2-SPM-SH-PLN-00003 – “HSE Communication Plan”

6.3 HSE Audits, inspections & site verification

Project HSE Audits will be planned and conducted, at each separate site, in line with the Project HSE audit plan with the following guideline:

The HSE audits will:

•

Investigate the effective implementation of any corrective actions raised during the previous audit(s);

• Address any potential new issue that is found to be of interest to the HSE auditing process and

the overall continual improvement process.

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Verifications and inspections will be also performed on-site to confirm that specified requirements have been met.

For more information on Audits and Inspections refer to Doc. No. COMP2-SPM-SH-PLN-00010 “HSE Audit and Inspection Plan”.

6.4 Feedback on SUBCONTRACTOR performance and use of this feedback in future

involvements

Whereas feedback activities are managed by the Procurement Unit, following the defined specific regulatory instruments, all the HSE functions shall ensure the appropriate management of these feedback activities, each to the extent of their responsibilities.

Feedback activities consist of the analysis and monitoring of performance in the field of suppliers / SUBCONTRACTORs the capabilities/reliability of SUBCONTRACTORs, that may be used by different company functions.

to produce an objective evaluation of

Based on their performance, feedback can thus be positive or negative.

In case of Negative Feedback, different measures may be taken on the SUBCONTRACTOR and can vary depending on the degree of negative feedback and the results of analyses carried out by the CONTRACTOR Corporate the SUBCONTRACTOR, including:

function, which can propose several actions against

• being issued a Warning; • proceeding with direct intervention on the SUBCONTRACTOR (e.g. application of penalties,

convening the sub-contractor, planning assessment visits);

• Deciding whether to keep the SUBCONTRACTOR in the Data Base (e.g. temporary

suspension, disqualification of the SUBCONTRACTOR).

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7 GENERAL HSE REQUIREMENTS

The main rules which govern the CONTRACTOR – SUBCONTRACTOR relationship on HSE-related aspects are established in the following sections.

The general HSE requirements that SUBCONTRACTORS must comply with are the following, but not limited to:

• SUBCONTRACTOR shall be responsible for all Safety, Health, Environment and Security laws and regulations of the country where the work is being performed, including its ministries, agencies, or subdivisions thereof. SUBCONTRACTOR shall be responsible for all aspects of safety to protect the personnel, the work, the property of CONTRACTOR, and all third parties the work, and shall perform all works per CONTRACTOR-specific associated with requirements.

• All SUBCONTRACTORs shall mandatorily follow the Life-Saving Rules as described in Doc.

No. COMP2-SPM-SH-PLN-00001- “Project HSE Plan”

• Activities performed at height or elevated work locations shall be carried out by implementing the necessary dropped object prevention measures. These measures shall be defined following a risk-based approach and documented in a specific dropped object prevention program. Such measures may include specific training in dropped object prevention, storage boxes for storing small materials & tools at elevated areas, the definition of permanent exclusion zones at ground level, safety netting, tool-tethers & tool-belts to be provided for work at height.

• Tools tethering is mandatory for any scaffold erection and dismantling activities. Dropped

object prevention systems and tools shall be in line with the Contractor’s requirements.

• SUBCONTRACTOR Project HSE Management System shall be planned, developed and implemented in full compliance with all applicable Local and International laws and regulations, codes, guidelines and standards and with industry-accepted best HSE practices applicable to their activities. In case of discrepancies between the above-mentioned procedures and any requirement included in Exhibit 8, the most stringent requirement shall apply.

• SUBCONTRACTOR shall be responsible,

timely implementation of all necessary measures for the protection of people who might be affected by their acts and omissions, and the environment.

their organization,

through

the

for

• SUBCONTRACTOR is required to report on a monthly and weekly basis all the HSE

information pertinent to their activities.

• The SUBCONTRACTOR shall define and apply an HSE Policy that demonstrates its commitment to Health, Safety and Environment within all its business activities and subcontracted scope of work. This Policy statement shall be dated and signed by the top management and regularly revised/updated;

• The SUBCONTRACTOR shall establish, implement and maintain an HSE Management System for the subcontracted activities, which shall include the elements (organizational structure, planning activities, responsibilities, practices, procedures, processes and resources) to establish HSE policy and objectives and to achieve those objectives;

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• CONTRACTOR reserves the right to conduct HSE audits on SUBCONTRACTOR’s working procedures and equipment at any time, upon previous notification given sufficiently in advance. At the time of such audits of the HSE Management System, the SUBCONTRACTOR shall provide to CONTRACTOR any assistance necessary to allow checking of the used organizational HSE procedures, their efficiency and adequacy to work methods, machinery, equipment and legal regulations;

• SUBCONTRACTORS are contractually obliged to observe and comply with all current applicable legislative requirements and guidance concerning the HSE and the Welfare of personnel. All documents required by law shall be at the site and made available to Control Authorities and CONTRACTOR;

• The SUBCONTRACTOR shall make obvious and proof he promotes a high HSE level and has in place proper systems for planning, implementation, maintenance and improvement of HSE issues. Also, the SUBCONTRACTOR shall operate with the highest regard for the health and safety of its personnel and of the environment and ensure that its activities do not endanger the safety of either site personnel or local communities;

• The SUBCONTRACTOR is responsible, as well, for the appropriate selection of personnel

who are suitable for the work;

• Whilst undertaking any activity in COMPANY facility, CONTRACTOR shall ensure compliance with any necessary COMPANY standard or policy requirement regarding Drugs and Alcohol, including random testing;

• SUBCONTRACTOR personnel and their SUBCONTRACTORs shall have a valid medical fitness certificate that is comprehensive and also the full disclosure of each employee’s medical history.

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8 SPECIFIC HSE REQUIREMENTS

8.1 Category “1” – Full Control

VENDOR/SUBCONTRACTOR is responsible for complying with all the applicable requirements stated in this specification, Project HSE Plan and associated documents, Exhibit 5 Project Instructions Appendix I – “COMPANY provided procedures”, and Exhibit 8.

8.1.1 Project HSE Requirements for Category “1” SUBCONTRACTORs

VENDOR/SUBCONTRACTOR shall comply with the requirements detailed in the following sections. Additional requirements may be specified by CONTRACTOR using FORM_OF-SCTOF-HSE-047

8.1.1.1 HSE Policy and Commitment

VENDOR/SUBCONTRACTOR shall have an HSE Policy updated and signed by management that demonstrates its commitment to Health, Safety and Environment within all its business activities and Subcontracted scope of work.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its HSE policy, Organization Chart and HSE Organization Chart. with During CONTRACTOR/Project’s HSE policy and commitment at CONTRACTOR/Project worksite locations, and COMPANY’s HSE policy whilst at COMPANY Category A and B worksite locations.

VENDOR/SUBCONTRACTOR

execution

comply

phase:

shall

the

8.1.1.2 HSE Management system

VENDOR/SUBCONTRACTOR shall operate with the highest regard for the health and safety of its personnel and of the environment and ensure that its activities do not endanger the safety of either site personnel or local communities. VENDOR/SUBCONTRACTOR is responsible for the appropriate selection of personnel who are suitable for the work.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its HSE manual, and HSEMS Certificates.

During the execution phase: VENDOR/SUBCONTRACTOR shall follow the CONTRACTOR/Project HSE management system at CTR-owned worksite or the approved specific Project HSE procedures during the execution of the scope and COMPANY’s HSE policy whilst at COMPANY Category A and B worksite locations.

8.1.1.3 Life-Saving Rules

VENDOR/SUBCONTRACTOR shall implement the Project Life Saving Rules and shall have consequence management for Life Saving Rules breach in place. Any violation of the Life-Saving Rules at CONTRACTOR premises will lead to a “Just Culture” investigation.

Each VENDOR/SUBCONTRACTOR shall describe in the project-specific HSE Plan, its consequence management process in case of Life-Saving Rules violation.

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8.1.1.4 Compliance with Law and Regulations

VENDOR/SUBCONTRACTOR is contractually obliged to observe and comply with all current applicable legislative requirements and guidance concerning the HSE and the Welfare of personnel. All documents required by law shall be at the site and made available to Control Authorities and CONTRACTOR.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Legal compliance procedure and Legal compliance register.

8.1.1.5 HSE Plan

VENDOR/SUBCONTRACTOR shall prepare a project-specific HSE plan in line with CONTRACTOR HSEMS requirements and Exhibit 8 applicable for the contract Scope of work and reflecting the information detailed in Doc. No. COMP2-SPM-SH-PLN-00001 – “Project HSE Plan”

Each SUBCONTRACTOR/VENDOR is required to submit the project-specific HSE Plan at least 120 days before the commencement of the Work.

During the BID Phase: VENDOR/SUBCONTRACTOR shall provide a typical Project HSE Plan for a similar scope of work. After contract award: VENDOR/SUBCONTRACTOR shall provide a project-specific HSE plan covering the Contract scope of work.

8.1.1.6 SUBCONTRACTOR(s) minimum HSE organization

Refer to Doc. No. COMP2-SPM-SH-PLN-00001 – “Project HSE Plan” and Doc. No. COMP2-SPM-SH- PLN-00017 – “Health Management Plan” for the descriptions related to SUBCONTRACTOR(s) minimum HSE Organization.

SUBCONTRACTOR HSES organizations must be reviewed and approved by CONTRACTOR before submitting them for approval by COMPANY.

During the project execution: SUBCONTRACTORS/VENDORS shall comply with the Supervision Resource minimum requirements Exhibit 8 – Part 1 – Section 4.8.1. SUBCONTRACTOR shall comply with the requirements related to the SHES Critical Positions as defined in Exhibit 8, Part 2, Par. 4.3 and submit relevant CVs to CONTRACTOR. Acceptance of the resources is based on COMPANY approvals.

8.1.1.7 HSE Risk Management

The VENDOR/SUBCONTRACTOR shall have an HSE Risk Management system in place to manage the risks associated with the Contract SOW and in line with the COMP2-SPM-SH-PLN-00011 - HSE Risk Management Plan.

VENDOR/SUBCONTRACTOR’s site personnel shall comply with existing occupational health and safety procedures.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide an HSE risk management procedure and a typical HSE risk assessment for a similar scope of work: identifying and assessing all the existing hazards and risks (e.g., interference risks, electrical hazards, mechanical hazards, risks of falling from heights, exposure to radioactive sources, health risks, etc.) associated with their activities, standard and additional control measures to be implemented.

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After contract award: VENDOR/SUBCONTRACTOR shall provide a Project-specific HSE risk assessment, prepared in line with Doc. No. COMP2-SPM-SH-PLN-00011 – “HSE Risk Management Plan” During the project execution: VENDOR/SUBCONTRACTOR representatives shall participate in any HSE Risk Management activity deemed necessary by CONTRACTOR. All actions identified shall be closed before commencing the relevant activities.

8.1.1.8 HSE Performance Reporting

VENDOR/SUBCONTRACTOR shall comply with CONTRACTOR HSE performance reporting requirements. HSE performance indicators shall be collected, monitored and reported periodically to CONTRACTOR. The HSE reports shall include but are not limited to HSE statistics, incident reports, including near misses, summaries of HSE activities and areas of concern.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its five years HSE performance data for lagging and leading indicators, as well as the significant HSE incident investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses).

During the project execution: VENDOR/SUBCONTRACTOR shall provide its HSE reports on a weekly and monthly basis. Project-specific HSE KPIs to be monitored by SUBCONTRACTOR during project execution shall be detailed in SUBCONTRACTOR’s project-specific HSE Plan and shall be in line with the Project HSE KPIs included in Doc. No. COMP2-SPM-SH-PLN-00001 – Project HSE Plan.

8.1.1.9 Meetings and communication

VENDOR/SUBCONTRACTOR shall ensure full participation and consultation of workers in HSE- related matters and implement the requirements defined by Doc. No. COMP2-SPM-SH-PLN-00003 – “HSE Communication Plan”

During the project execution: VENDOR/SUBCONTRACTOR shall participate in periodical Project HSE Meetings as required, also to discuss the HSE issues related to work performance.

8.1.1.10 Monitoring and activities control

CONTRACTOR reserves the right to conduct HSE audits on VENDOR/SUBCONTRACTOR’s working procedures, equipment and their major Subs as deemed necessary at any time, upon previous notification given sufficiently in advance. COMPANY may be invited to participate.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its HSE audit procedure and a sample audit report. During the project execution: VENDOR/SUBCONTRACTOR shall comply with Exhibit 8 – Part 2 – Section 4.30 – SHES Audits & Reviews and Project HSE Audit and Inspection Program – COMP2- SPM-SH-PLN-00010.

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8.1.1.11 HSE Performance Review

VENDOR/SUBCONTRACTOR shall ensure that its performance is periodically reviewed and measured to ensure the continual improvement process within the Contract SoW. VENDOR/SUBCONTRACTOR shall implement the actions required as an outcome of an accident investigation.

8.1.1.12 Permit to Work (PTW) system

Based on site categorization, the followed PTW systems shall be used:

• Category A – Company Premises: SUBCONTRACTORS shall comply with the COMPANY

PTW system;

• Category B – Contractor Premises: SUBCONTRACTORS shall comply with

the

CONTRACTOR PTW system;

• Category C – SUBCONTRACTOR Premises: in case of Fabrication Yard activities, the

SUBCONTRACTOR PTW system will be used in line with Project PTW requirements.

For offshore activities, when SUBCONTRACTOR is accommodated on board of CONTRACTOR main vessel, SUBCONTRACTOR will use the CONTRACTOR PTW system. Activities on tugs/supply vessels will be ruled by the SUBCONTRACTOR PTW system.

No personnel is authorized to sign PTW if not duly trained and part of the list of signatories personnel as Performing Authority, Issuing Authority or Approving Authority.

All PTW issued, suspended, and closed are managed and administrated (including the logging) by a dedicated SUBCONTRACTOR PTW coordinator that shall ensure that all permits are in line with the project requirements before opening them, checking and providing coordination of the open/active PTW (and related activities), suspending/opening/closing permits, logging and archiving them.

He/she will advise the area authority/project manager as well in case some SIMOPs operations might cause additional risk to the workgroups for further decision on which PTW has the priority.

VENDOR/SUBCONTRACTOR shall comply with the Project Permit to Work procedure, COMP2-SPM- SH-PRC-00009/10 - HSE MANUAL & Exhibit 8 Part 2 – Section 5.7 – Permit to Work.

8.1.1.13 Work at Height

VENDOR/SUBCONTRACTOR shall have in place a safe system of work addressing Working at Height activities, to be described in the project-specific HSE plan. VENDOR/SUBCONTRACTOR shall use work equipment and other measures to prevent falls, where work at height cannot be avoided. Work restraint systems shall be privileged over fall protection systems, as far as practicable.

VENDOR/SUBCONTRACTOR personnel shall be trained in working at height and relevant certificates shall be submitted to CONTRACTOR before mobilizing personnel at the site. If such certificates are provided following an internal training course delivered by VENDOR/SUBCONTRACTOR, training materials and course syllabus shall be also submitted for CONTRACTOR review. Working at height training shall mandatorily include a practical part. VENDOR/SUBCONTRACTOR personnel shall attend further working at height training at the project location before performing any site activity involving working at height.

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Scaffolding material, design, erection, and inspection shall comply with TG:20 standard, in line with Exhibit 8 requirements. If VENDOR/SUBCONTRACTOR is using a different standard, a gap analysis demonstrating the equivalence with TG:20 shall be provided.

Work at Height equipment shall comply with Exhibit 8 Part 2 – Section 4.14 – Personal Protective Equipment and SPC_GR-GROUP-HSE-039-E – SAFETY REQUIREMENTS FOR SAFETY HARNESS, SPC_GR-GROUP-HSE-099-E – SAFETY REQUIREMENTS FOR HARNESS AND ACCESSORIES, SPC_GR-GROUP-HSE-040-E – SAFETY REQUIREMENTS FOR SAFETY HARNESS WITH BODY BELTS

VENDOR/SUBCONTRACTOR shall prepare a rescue plan for each working at height activity it may perform. Specific descriptions shall be included in the Project-specific HSE plan to be submitted by VENDOR/SUBCONTRACTOR in line with the applicable site emergency response plan.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Work at Height procedure.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide typical Work at Height rescue plan and rescue training certificates as applicable.

During the project execution: VENDOR/SUBCONTRACTOR shall comply with Exhibit 8 Part 2 – Section 4.25 – Working at Height, Exhibit 8 Part 2 – Section 4.22 – Dropped Object Protection, COMP2-SPM-SH-PRC-00009/10 - HSE MANUAL.

8.1.1.14 Confined Space

VENDOR/SUBCONTRACTOR shall have in place a safe system of work to ensure that confined space entry risks are adequately controlled as far as reasonably practicable.

VENDOR/SUBCONTRACTOR personnel shall be trained and relevant certificates shall be submitted to CONTRACTOR before mobilizing personnel at the site. If such certificates are provided following an internal training course delivered by VENDOR/SUBCONTRACTOR, training materials and course syllabus shall be also submitted for CONTRACTOR review. Confined space entry training shall mandatorily include a practical part. VENDOR/SUBCONTRACTOR personnel shall attend further confined space entry training at the project location before performing any site activity involving confined space entry.

VENDOR/SUBCONTRACTOR shall prepare a rescue plan for each confined space entry activity it may perform. Specific descriptions shall be included in the Project-specific HSE plan to be submitted by VENDOR/SUBCONTRACTOR in line with the applicable site emergency response plan.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Confined Space Entry procedure and a typical Confined Space Entry rescue plan and rescue training certificates as applicable.

During the project execution: VENDOR/SUBCONTRACTOR shall comply with Exhibit 8 Part 2 – Section 4.24 – Confined Space and COMP2-SPM-SH-PRC-00009/10 - HSE MANUAL.

8.1.1.15 Personal Protective Equipment

The VENDOR/SUBCONTRACTOR shall provide its personnel with all the PPE and devices required for carrying out safely the Contract SoW in line with Exhibit 8 – Part 3 – Section 4.14 – Personal Protective Equipment. Additional specific PPE may be required depending on Contract SoW requirements and relevant task risk assessment.

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CONTRACTOR shall review PPE that is to be used by SUBCONTRACTOR before purchase to confirm suitability. The review shall include the data sheet as well as a sample of the PPE. Further approval would then be sought by CONTRACTOR from COMPANY before the purchase and use of PPE, to ensure that it meets the requirements of COMPANY’s PPE procedure.

Where hydrocarbons may be present fire-retardant coveralls must be worn.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide its PPE procedure.

During the project execution: VENDOR/SUBCONTRACTOR shall comply with the Project PPE procedure – COMP2-SPM-SH-PRC-00006 & Exhibit 8 Part 2 – Section 4.14 – Personal Protective Equipment.

8.1.1.16 Hazardous Material Management

To prevent important risks to the Health & Safety of the workers and also to protect the environment from long-term heavy pollution, any substances prohibited from possession or use by law or project restrictions, such as Asbestos or Asbestos containing products shall not be used. [Exhibit 8 – Part 3 – Section 5.12 Hazardous Material Management].

VENDOR/SUBCONTRACTOR shall comply with the Project’s aspects related to Hazardous Material Management and shall have a system to manage substances and goods dangerous to health.

SUBCONTRACTORS/VENDORS shall comply with the mandatory EIA requirements, and all chemical substances shall be provided together with its Material Safety Data Sheet (MSDS). These documents shall comply with the relevant Country and International Laws and regulations. VENDOR/SUBCONTRACTOR shall carefully manage the storage areas for flammable and/or explosive substances.

SUBCONTRACTOR shall comply with the project requirements and all other applicable local and international regulations concerning marking, transportation, handling, labelling and shipment of hazardous and non-hazardous materials.

Before starting any work activity, the VENDOR/SUBCONTRACTOR shall submit to CONTRACTOR its written procedures for any services involving the handling or use of hazardous or toxic substances. The use of any chemical substance shall be preliminarily approved by the CONTRACTOR representative.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide its COSHH (Control of Substances Hazardous to Health) or Chemical Handling procedure. Before mobilization: VENDOR/SUBCONTRACTOR shall provide an asbestos-free certificate as applicable. During the project execution: VENDOR/SUBCONTRACTOR shall comply with Exhibit 8 – Part 3 – Section 5.12 Hazardous Material Management, COMP2-SPM-SH-PLN-00019 - Environmental Management Plan and COMP2-SPM-SH-PLN-00021 - Waste Management Plan

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BANNED SUBSTANCES Polychlorinated Biphenyls (PCB’s; or “Pyralen”) Asbestos

Chlorofluorocarbons (CFCs)

Table 8.1 – Banned substances REASON FOR RESTRICTION Human carcinogen, bioaccumulative.

ALTERNATIVES

Silicones, esters, cast resin.

Inhalation of fibers causes lung damage. Regarded by World Bank as a hazardous substance, use to be avoided. Implicated in stratospheric ozone depletion. Over 125 nations, including the US, agreed to a virtual phase-out of CFC production by 1996.

Alternatives are readily available for insulation and roofing uses.

Depends upon use. USEPA has published lists of accepted alternatives for a variety of uses

Table 8.2 – Discouraged substances REASON FOR RESTRICTION

ALTERNATIVES

DISCOURAGED SUBSTANCES

Leaded Paints

Chlorinated Solvents (carbon tetrachloride, trichloroethylene) Heavy Metals (reverse emulsion breakers)

Mercury (in pressure measuring devices/instrumentation)

Lead Naphthenate (lubricant)

Leaded Thread Compound

Chromate Corrosion Inhibitors

Toxics at relatively low levels, bioaccumulative. May meet World Bank definition of hazardous waste when discarded. May have toxic effects (varies depending upon the compounds). Various adverse effects. May meet the World Bank’s definition of hazardous waste when discarded. Neurotoxic effects. May meet World Bank’s definition of hazardous waste when discarded. Neurotoxic effects. May meet World Bank’s definition of hazardous waste when discarded. Toxics at relatively low levels, bioaccumulative. May meet World Bank definition of hazardous waste when discarded. The hexavalent form of chromium is toxic to humans and many animals.

Chrome Lignosulfonate (as fluid loss controlling agent) All right in small amounts for rheology control

The hexavalent form of chromium is toxic to humans and many animals.

Unleaded paints. Also water based or low-volatility solvent formulations can reduce potential health effects of oil-based paints. Non-chlorinated hydrocarbon based solvents, steam cleaning. Polymer (non-latex) based formulations.

Differential pressure cells / transmitters, pneumatic or electrical instrumentation. Lead-free lubricants.

Lead-free thread compounds such as Bestolife 2000 (for tubing and casing).

Sulfite or organic phosphate corrosion inhibitors, especially those with reduced toxicity amine function. Carboxymethyl starches for fluid loss control. Improved mud control to minimize fluid loss. If used (for rheology), keep the dose small and use formulations with trivalent form complexed in lignin structure.

8.1.1.17 Tools, Machines and Equipment

VENDOR/SUBCONTRACTOR shall have in place a system ensuring that inspections, maintenance and controls are conducted, and records are maintained.

the bid phase: VENDOR/SUBCONTRACTOR shall provide

During its Site Operation and Maintenance of plant and equipment procedure, Preventive Maintenance register, critical spares list, and applicable certificates.

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After the contract award, VENDOR/SUBCONTRACTOR shall include specific descriptions of how they are managing plants and equipment, including routine, non-routine and preventive maintenance requirements in the project-specific HSE plan.

During the project execution: VENDOR/SUBCONTRACTOR shall ensure compliance with Exhibit 8 Part 2 – Section 4.17 – CONSTRUCTION EQUIPMENT and COMP2-SPM-SH-PRC-00009/10 - HSE MANUAL.

8.1.1.18 Health Surveillance

The VENDOR/SUBCONTRACTOR shall implement a health surveillance system for its workers. The system shall provide a correlation between the individual position of personnel and the Medical Protocols used to assess, monitor and safeguard his/her health and fitness for the specific duty or task.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide to CONTRACTOR its periodic medical fitness examination protocol, detailing the list of medical examinations that are part of the medical fitness protocol.

Before mobilization: VENDOR/SUBCONTRACTOR shall adopt and comply with Exhibit 8 – Part 3 – Section 4.5 – Fitness to Work, HSE REQUIREMENTS FOR VENDORS – FORM_OF-SCTOF-HSE- 047-E and COMP2-SPM-SH-PLN-00017 - Health Management Plan.

8.1.1.19 Medical Insurance and Medical Fitness Certificate

VENDOR/SUBCONTRACTOR shall ensure that all its personnel are covered by medical insurance and that they are fit for the work they are assigned to in line with Exhibit 8 – Part 3 – Section 4.5 – Fitness to Work.

The medical certification process for personnel involved in activities on a WORKSITE shall comply with International Oil &Gas Best Practices, local laws in the country of employment and local laws governed by the Country where the services are to take place. The protocols for medical fitness examinations will be based on the respective Health Risk Assessment. As a general guideline, the following protocol may be followed by SUBCONTRACTOR / VENDOR :

Individual questionnaire (anamnesis)

• • General Medical examination • Instrumental Examinations • Chest X-Ray (if recommended/requested) • ECG • Audiogram • Ethylometry (1) • Laboratory Examinations • Full blood count • Glycemia • Urea • Transaminase • Gamma G.T. • Total - Direct Bilirubin • Alkaline Phosphatase • Lipids profile

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• T.P.H.A. • Markers of Hepatitis A-B Anti HCV (1) • ESR • Urine Examination • Tine Test (1) • HIV (1) • Drug Test (1)

• (1) Not mandatory, but could be performed only if expressly required

Medical insurance shall also cover the cost of repatriation with third-party medical assistance if deemed necessary.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide to CONTRACTOR its periodic medical fitness examination protocol, detailing the list of medical examinations that are part of the medical fitness protocol. Before mobilization: VENDOR/SUBCONTRACTOR shall provide its Medical insurance. Before mobilization: VENDOR/SUBCONTRACTOR shall possess valid medical fitness certificates in line with the established Fitness to Work protocols

8.1.1.20 Medical Organization and Facilities

VENDOR/SUBCONTRACTOR shall have in place a retainership clinic/hospital agreement which shall support its medical organization, ensure adequate medical care for their personnel on site and be maintained for the entire duration of the subcontracted activities.

This VENDOR/SUBCONTRACTOR retainership clinic/hospital agreement shall establish agreements with third-party medical structure(s) to ensure treatment of medical cases that require specialist examinations and/or hospital admission.

For subcontractor-owned medical facilities (as applicable), CONTRACTOR shall assess the compliance of such facilities with Exh.8 requirements. CONTRACTOR shall ensure that, for any gap eventually identified, a corrective action is implemented to address the deficiency.

While at the Category C worksite location, VENDOR/SUBCONTRACTOR shall key into the existing CONTRACTOR’s Medical Organization and Facilities which shall meet the minimum requirements in line with COMP2-SPM-SH-PLN-00017 - Health Management Plan and Exhibit 8 – Part 3 – Section 4.1 – Medical Organization & facilities.

After the contract award, VENDOR/SUBCONTRACTOR shall describe its medical organization, including medical staff (if required), first aiders, etc. in the project-specific HSE Plan.

8.1.1.21 Health Awareness and Prophylaxis

Where appropriate and requested, before mobilization, the VENDOR/SUBCONTRACTOR shall ensure that its employees are provided with suitable health awareness training, to inform them regarding the associated Health Risks in the country of assignment. When operating in high Malaria risk areas, VENDOR/SUBCONTRACTOR shall make sure that its personnel are well aware of the disease before mobilization. Upon arriving on site VENDOR / SUBCONTRACTOR’s personnel shall compulsorily attend the Malaria Awareness lecture organized by CONTRACTOR’s medical personnel regularly.

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During the project execution: VENDOR/SUBCONTRACTOR shall comply and compulsorily attend the Health Awareness training/campaigns provided by CONTRACTOR/COMPANY in line with COMP2- SPM-SH-PLN-00013 - HSE Training Plan and COMP2-SPM-SH-PLN-00017 - Health Management Plan.

8.1.1.22 Drug and Alcohol Policy

When on the worksite the VENDOR/SUBCONTRACTOR personnel shall fully comply with COMPANY/CONTRACTOR’s Alcohol and Drug Policy. VENDOR/SUBCONTRACTOR, in accordance with applicable local and international regulations, shall inform its personnel that they can be subjected to random checks to determine the level of alcohol and drugs in their breath or urine.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide its Alcohol and Drug Policy. During the project execution: VENDOR/SUBCONTRACTOR shall comply with Project Alcohol and Drug policy while on the worksite.

8.1.1.23 Medical Emergency

VENDOR/SUBCONTRACTOR’s COMPANY/CONTRACTOR.

personnel

shall

follow

the MEDEVAC

protocols

of

SUBCONTRACTOR shall ensure that all PERSONNEL have access to medical evacuation, and reasonable access to healthcare (first aid, primary and emergency medical care). Each of these shall that be provided by SUBCONTRACTOR unless CONTRACTOR has confirmed CONTRACTOR will provide them. In this Clause, “primary care” refers to the first point of health care for PERSONNEL with a health problem experienced at the Worksite or otherwise during the performance of WORK.

in writing

SUBCONTRATOR shall identify secondary/tertiary health care units to handle medical emergencies that cannot be handled at the WORSITE. Agreements shall be made with those facilities to ensure that the personnel in need is taken care of with no delays.

SUBCONTRACTOR shall have in place adequate arrangements to transfer injured or sick personnel from the work locations to the medical facility and to the secondary/tertiary health care unit. Specific descriptions shall be included in the emergency response bridging document to be provided by SUBCONTRACTOR.

Whether medical evacuation is provided by CONTRACTOR or by SUBCONTRACTOR, in either case, SUBCONTRACTOR shall be responsible for all subsequent medical treatment received by the evacuated person.

During the bid phase and before mobilization: VENDOR/SUBCONTRACTOR shall provide evidence of its retainership clinic agreement. After the contract award, VENDOR/SUBCONTRACTOR shall provide an Emergency Response Bridging document detailing how it will implement the above-mentioned requirements.

8.1.1.24 Environmental Management Plan

VENDOR/SUBCONTRACTOR shall comply with Exhibit 8 – Part 4 – Environmental Management, CONTRACTORs’ Environmental Management Plan – COMP2-SPM-SH-PLN-00019, all applicable environmental laws and any requirement from COMPANY and CTR representative.

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8.1.1.25 Spills

SUBCONTRACTOR shall make every effort to assure the protection of the environment and workers’ health and safety against accidental spillage and potential risks that may occur during site activities. To fulfil the above commitments SUBCONTRACTORs shall implement the Contractor Spill Prevention and Control Plan.

In particular, SUBCONTRACTOR shall ensure that during work execution all operations are conducted to avoid the risk of a spill situation or, whenever an accident occurs, implement measures and actions to prevent its escalation.

To minimize spill effects, appropriate HSE equipment is required for SUBCONTRACTOR to be provided. The following list shall be considered as a minimum:

• Spill kits (absorbent materials, disposal bags, appropriate PPE); • Safety signs & barriers; • Waste drums for waste fluid.

Before the commencement of any construction activities, all involved SUBCONTRACTORs personnel shall be provided with training concerning environmental contingency situations.

The SUBCONTRACTOR shall notify to Contractor, within 24 hours from the event, of any spillage of oil, grease, paint, solvent, chemically treated drilling fluids, sewage or any other pollutant or waste.

VENDOR/SUBCONTRACTOR shall comply with Spill Prevention – E02-X03-AAH118, Project’s Spill prevention and response plan COMP2-SPM-SH-PLN-00022 and INCIDENT INVESTIGATION AND REPORTING PROCEDURE – COMP2-SPM-SH-PRC-00001

8.1.1.26 Waste Management

VENDOR/SUBCONTRACTOR shall ensure full compliance with local and Contract SoW requirements regarding Waste management.

the bid phase: VENDOR/SUBCONTRACTOR shall provide

During Plan/procedure During the bid phase: VENDOR/SUBCONTRACTOR shall provide signed waste disposal notes During the project execution: VENDOR/SUBCONTRACTOR shall comply with COMPANY’s Waste Management – PRT-ENV-PRC-002, and the Project Waste Management Plan – COMP2-SPM-SH- PLN-00021

its Waste Management

8.1.1.27 HSE Training program

VENDOR/SUBCONTRACTOR shall guarantee that personnel involved in dangerous activities (e.g., working at a height, activities in confined spaces) are properly informed and trained for the specific activity. Training activities shall include a theoretical (e.g., procedures and work instructions) and a practical session (e.g., use and management of PPE).

VENDOR/SUBCONTRACTOR shall make available its persons to undergo the requisite training as per the Project HSE Training plan [COMP2-SPM-SH-PLN-00013] and matrix for the designated roles [Exhibit 8 – Part 2 – Section 4.1 SHES Training]

During the bid phase: VENDOR/SUBCONTRACTOR shall provide its HSE training program and records/certificates.

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Before mobilization: VENDOR/SUBCONTRACTOR shall ensure its personnel have undergone the dedicated training for hazardous activities. During the project execution: VENDOR/SUBCONTRACTOR shall be subject to the relevant respective site-specific HSE inductions and HSE training at the project location where they are.

8.1.1.28 Competence

The VENDOR/SUBCONTRACTOR shall have in place a system to guarantee that its personnel is competent for the assigned activity. Personnel operating machines and equipment shall be certified as per local and/or international legislation, and in compliance with the Contract SoW.

During the bid phase: VENDOR/SUBCONTRACTOR shall provide certificates of competence for their personnel, including CVs and qualifications of those identified as “SHES Critical Positions” in line with Exh.8 – Part 2 – Par. 4.3.

8.1.1.29 Industrial Hygiene

During the bid phase: if the scope of work envisages the use of VENDOR/SUBCONTRACTOR-owned facilities, VENDOR/SUBCONTRACTOR shall provide its Industrial Hygiene Program applicable to that facility.

During the project execution: VENDOR/SUBCONTRACTOR shall comply with the respective Project Health Management Plan and Industrial Hygiene (IH) programs in place at the different locations following the Contract SoW requirements.

8.1.1.30 Emergency Preparedness

VENDOR/SUBCONTRACTOR shall prepare a project-specific HSE plan embedding and bridging its Emergency Response plan with CONTRACTORS’ arrangements. Emergency contact persons and contact numbers shall be included in the project-specific HSE plan. All parties (whether SUBCONTRACTOR/VENDOR or Sub) must follow the WORKSITE emergency procedures as instructed by COMPANY/CONTRACTOR operating that WORKSITE.

All personnel are required to respond to designated alarms and follow emergency procedures as instructed during the safety induction. Failure to do so shall result in disciplinary action. Personnel should familiarize themselves with emergency exits, the location of muster stations, emergency equipment and escape mean where appropriate.

After contract award: VENDOR/SUBCONTRACTOR shall provide a specific project Emergency Response bridging document to describe how its Emergency plans embed with CTR arrangements. This information shall include emergency resources and equipment, emergency contacts, flowcharts, etc., as per Section 8.1.1.5.

8.1.1.31 Emergency Preparedness training

VENDOR/SUBCONTRACTOR shall ensure its personnel has adequate training and practice for emergency preparedness situations [COMP2-SPM-SH-PLN-00005 - Emergency Response and Preparedness Procedure and COMP2-SPM-SH-PLN-00013 - HSE Training Plan] CONTRACTOR will provide general information relevant to the hazards at the site.

Before mobilization: VENDOR/SUBCONTRACTOR shall provide ER training records/certificates: including Work at Height and confined space rescue training certificates, as applicable.

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During project execution: VENDOR/SUBCONTRACTOR personnel shall participate in the respective Site-specific Emergency Response Team members training as required. During project execution: VENDOR/SUBCONTRACTOR personnel shall participate in drills as required.

8.1.1.32 Lifting

All equipment utilized by VENDOR/SUBCONTRACTOR on COMPANY/CONTRACTOR project worksites under the Contract SoW shall be in line with CONTRACTOR’s Lifting procedure, Exhibit 8 – Part 2 – Section 4.28 – Lifting & Rigging and COMP2-SPM-SH-PRC-00009/10 - HSE MANUAL.

All lifting equipment and accessories must be inspected and certified by a third-party company which shall be on the approved project vendor list.

COMPANY colour code will be applied and communicated before starting the project. VENDOR/SUBCONTRACTOR shall ensure that adequate preventive maintenance is scheduled for all lifting devices to maintain them in a safe condition.

VENDOR/SUBCONTRACTOR shall ensure that all lifting devices under its direct or indirect control are registered and certified and that all operators (i.e. riggers, banksman) hold valid certificates of competency.

CONTRACTOR has the right to verify and hold copies of the certificate of the personnel.

VENDOR/SUBCONTRACTOR shall ensure that all cranes are in good condition and are given a safety to CONTRACTOR Representative.

inspection before mobilization. The reports shall be

forwarded

All identified corrective actions shall be completed before mobilization and supporting documentation attached to the report.

Logbooks detailing all inspections, maintenance, calibration and repairs are to be maintained for all lifting devices.

Lifting devices (and operators) to be used Onshore in Qatar shall have valid Qatar license/registration and other relevant documents recognized by COMPANY. For works executed in other Countries, local regulations shall apply.

All Lifting equipment and tools brought to project work locations shall be inspected by Contractor Authorized Competent personnel before use on-site (including third-party certification) and all inspection records shall be maintained.

VENDOR/SUBCONTRACTOR shall ensure that all lifting appliances have appropriate and load test valid certificates, and comply with the requirements of all relevant legislation, regulations, Standards or codes of practice.

Proper colour coding shall be used to identify that the lifting appliance is in good condition and with a valid certificate. The colour coding scheme shall match the one in use on the worksite.

All identified corrective actions shall be completed before mobilization and supporting documentation attached to the report.

Lifting appliances shall be stored properly and maintained according to the manufacturer’s recommendation. Manufacturer manuals shall be available for any tool and equipment.

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In case of the expiry of the certificate or the lifting appliance is considered unfit for the purpose, the lifting appliance shall be properly segregated and quarantined in a dedicated and controlled quarantine area.

During the project execution: As applicable, VENDOR/SUBCONTRACTOR shall provide third-party certificates, Lifting Equipment and accessories register.

8.1.1.33 Selection of SUBCONTRACTOR(s)

Within one month from contract award, each SUBCONTRACTOR shall provide a list of Subs and relevant work scope description, highlighting those eventually falling under the definition of “SHES critical subcontractor” as defined in Exh.8.

Safety Critical activities and services will not be subcontracted without prior written APPROVAL which will only be granted based on a satisfactory CONTRACTOR and COMPANY assessment of the SUBCONTRACTOR. Where SUBCONTRACTOR has received approval from COMPANY & CONTRACTOR to subcontract safety critical activities and services, SUBCONTRACTOR shall ensure that any LOWER TIER SUBCONTRACTOR engaged to perform any portion of the SCOPE will be performed to at least the same HSE standards and the SUBCONTRACTOR, unless specifically agreed in writing between COMPANY, CONTRACTOR, and SUBCONTRACTOR. [Exhibit 8 – Part 1 – Section 4.7 – Selection of SUBCONTRACTOR(s) and COMP2-SPM-SH-PRC- 00004 HSE Management of Vendors and Subcontractors]

they were activities performed by

requirements as

if

8.1.1.33.1 Subs SUBCONTRACTOR will have procedures identification, assessment, selection, and management of lower tier subcontractors to ensure they can comply with the HSE standards and requirements before the award of all SUBCONTRACTS. SUBCONTRACTORS / VENDORS shall ensure that their major Subs are competent and able to execute the Work safely. Their selection process should address the following considerations:

the

for

• HSE MS Maturity of Subs • Recent experience with Subs • Similar Work experience • Historical safety performance • Ability and willingness of Subs to fulfil the Project HSE Requirements (according to the

Category assigned to the Work).

8.1.1.34 Transportation Safety

SUBCONTRACTORS/VENDORS shall comply with the Project Safe driving program – COMP2-SPM- SH-PRC-00008, Transport Safety requirements as stipulated in Exhibit 8 – Part 2 – Section 4.19 and Section 4.20 for Heavy Duty trucks.

SUBCONTRACTORS/VENDORS shall comply with the IVMS requirements as stipulated in Exhibit 8 Part 2 – Section 4.19.

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8.1.1.35 Incident Notification, Investigation and Reporting

CONTRACTOR operates a ‘No Blame’ culture that requires all personnel to report any accidents, incidents or near misses to the Project as soon as possible.

SUBCONTRACTORS/VENDORS shall comply with the requirements as stated in the Project Incident Investigation and Reporting procedure – COMP2-SPM-SH-PRC-00001 & Exhibit 8 – Part 2 – Section 4.6 – Incident Investigation and Reporting.

8.1.1.36 Worker identification system

SUBCONTRACTORS shall comply with the Project’s worksite unique worker identification system as per COMP2-SPM-SH-PLN-00001 – PROJECT HSE PLAN, COMP2-SPM-SH-PRC-00009/10 HSE MANUAL, Exhibit 8 – Part 2 – Section 4.15 Worker Identification System and the Site-specific Safety Plan.

8.1.1.37 Site Facilities and Equipment

SUBCONTRACTORS shall conduct joint verification checks with CONTRACTOR where temporary facilities have been erected to ensure that the minimum requirements are implemented for all temporary facilities at SITE, WORKSITE and WORKSHOP in line with COMP2-SPM-SH-PRC- 00009/10 – HSE MANUAL and Exhibit 8 – Part 2 – Section 4.16 Site Facilities and Equipment.

8.1.1.38 Heat Stress Management

SUBCONTRACTORS/VENDORS shall comply with the Project Heat Stress Management program – COMP2-SPM-SH-PRC-00013 for the In-country scope in Qatar, as well as Exhibit 8 – Part 3 – Section 5.2 Heat Stress Management. VENDOR/SUBCONTRACTOR shall detail, in the project- specific HSE Plans, the control measures specific and applicable to their scope of work.

8.1.1.39 Participation in HSE programs

When present on site, all SUBCONTRACTOR/VENDOR personnel shall participate in HSE activities such as, but not limited to:

• Drills • Daily pre-job meeting, Toolbox talks • HSE ceremony • JSA review sessions • Training sessions (such as Permit To Work, confined space) • Coordination meetings • LiHS • Working at Height campaign • Hand Injury Free Program • CPY HSE Programs

CTR will reserve in this case the right to ask the SUBCONTRACTORS to implement the following CONTRACTOR programs (as described in the CONTRACTOR HSE PLAN: COMP2-SPM-SH-PLN- 00001; LIHS IMPLEMENTATION PLAN – COMP2-SPM-SH-PLN-00012; HSE TRAINING PLAN – COMP2-SPM-SH-PLN-00013)

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8.1.1.40 HSE Requirements for Diving SUBCONTRACTORS

Diving operations shall be also undertaken in compliance with both OGP “Diving Recommended Practice”, Report NO 411 and COMPANY’s Marine Operations manual– P36-X02-003.

COMP2-SPM-SH-PRC-00009/10 – HSE MANUAL SPC_OF-SCTOF-HSE-002-E – HSE REQUIREMENTS FOR DIVING SUBCONTRACTORS COMP2-SPM-MO-PRC-00001 – MARINE OPERATIONS PROCEDURE

8.1.1.41 HSE Requirements for NDT radiographic activities SUBCONTRACTORS

The below procedure is to be applied: COMP2-SPM-SH-PRC-00009/10 – HSE MANUAL Exhibit 8 – Part 2 – Section 4.31 Radiography. SPC_OF-SCTOF-HSE-004-E – HSE REQUIREMENTS FOR NDT RADIOGRAPHIC ACTIVITY

8.1.1.42 HSE Objectives and Targets for SUBCONTRACTORS/VENDORS

The HSE Objectives for this Category 1 SUBCONTRACTOR will be approved by CONTRACTOR on a case-by-case basis, based on the information provided by SUBCONTRACTOR/VENDOR during the bid phase and in line with the annual Project HSE objectives.

Without any other instruction, SUBCONTRACTOR/VENDOR will follow the set-out objectives as indicated in the Project HSE Plan COMP2-SPM-SH-PLN-00001 – PROJECT HSE KPIs.

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8.1.2 OFFSHORE SPECIFIC HSE Requirements

8.1.2.1 Medical Fitness

SUBCONTRACTOR/VENDOR shall comply with the HEALTH MANAGEMENT PLAN COMP2-SPM- SH-PLN-00017 and Exhibit 8 – Part 3 – Section 4.5 – Fitness to Work (FTW)

Each SUBCONTRACTOR/VENDOR shall ensure that all employees, as well as Sub personnel, are medically fit for the job they are assigned to undertake. All employees working within the WORKSITE must have a valid medical certificate. All costs of medical examinations shall be borne by the SUBCONTRACTOR/VENDOR.

The medical certification process shall comply with the OGP report number 343 “Managing Health for field operations in Oil and Gas activities”, local laws in the country of employment and local laws governed by the Country where the services are to take place. The certificates stating the individual’s medical fitness (Medical Fitness Certificate) shall be made available on-site upon to to CONTRACTOR’s CONTRACTOR’s Medical Officer on site, preferably before their actual involvement in the activities.

representatives and/or

relevant

request

CONTRACTOR’s representatives shall refuse SUBCONTRACTOR’s personnel if not in possession of valid certification.

The QG FTW examination protocols shall apply for offshore personnel working in the QG field, also in compliance with the extant requirements of the Maritime Labour Convention (MLC) 2006 and Standards of Training, Certification and Watchkeeping (STCW) 1998;

For access offshore, SUBCONTRACTOR shall, at its own cost and expense, obtain Company “Offshore Pass” and “Offshore Medical Fitness Card”. SUBCONTRACTOR’s schedule shall take into account the period (typically two (2) to three (3) working days) required to process the applications and issue the Offshore Pass and Offshore Medical Fitness Card.

8.1.2.2 Training, Competence, Certifications

An HSE Induction shall be delivered to all new personnel before they start work.

All SUBCONTRACTOR’s personnel on-board CONTRACTOR or SUBCONTRACTOR’s vessel shall have a valid offshore survival certificate compliant with OPITO and STCW and a valid COMPANY Offshore medical card/ medical fitness certificate.

Copy of the certificates of personnel scheduled to work offshore within the subcontracted activities shall be issued to CONTRACTOR before embarking. An original copy has to be carried with all the to refuse personnel going on board. CONTRACTOR representatives will have SUBCONTRACTORs’ personnel if not in possession of valid certification.

the right

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8.1.2.2.1 Offshore Statutory HSE Training for the Technical Personnel

Statutory courses for the technical personnel in charge of emergency tasks

Basic Offshore Safety Induction and Emergency Training (BOSIET)

H2S (Basic Hydrogen Sulphide) Training

Offshore Fire / Emergency and Response Team Member

Offshore Fire / Emergency and Response Team Leader

Off-shore Lifeboat Coxswain (recommended for those vessels with minimum maritime manning)

OPITO

OPITO

OPITO

OPITO

OPITO

Statutory courses for the technical personnel not in charge of emergency tasks

Basic Offshore Safety Induction and Emergency Training (BOSIET)

H2S (Basic Hydrogen Sulphide) Training

OPITO

OPITO

8.1.2.2.2 Statutory HSE Training for the Maritime Personnel

Statutory courses for the senior maritime staff (Master, Chief Engineer, and Mate Officers)

Personal Survival Techniques

Fire Prevention and Firefighting

ELEMENTARY FIRST AID

MEDICAL CARE

Advanced Fire Fighting

Survival Crafts and Rescue Boats

Fast Rescue Boats

Helicopter Landing

Basic Offshore Safety Induction and Emergency Training (BOSIET)

H2S (Basic Hydrogen Sulphide) Training

STCW95

STCW95

STCW A-VI/1 - 3

STCW A-VI/4-2

STCW95

STCW95

STCW95

OPITO

OPITO

OPITO

Statutory courses for other personnel (depending on the role/position)

Personal Survival Techniques

MEDICAL FIRST AID

Fire Prevention and Firefighting

ELEMENTARY FIRST AID

BASIC SAFETY FAMILIARISATION

Basic Offshore Safety Induction and Emergency Training (BOSIET)

H2S (Basic Hydrogen Sulphide) Training

STCW95

STCW A-VI/4-1

STCW95

STCW A-VI/1 - 3

STCW95

OPITO

OPITO

For the construction crew, (e.g., crane operators, banksman/rigger, rope-access team members, banksman & slinging, machinery/equipment operators, etc.) training shall be in line with the Project requirements (COMP2-SPM-SH-PLN-00013 – HSE TRAINING PLAN, COMP2-SPM-SH-PRC-00010 – OFFSHORE HSE MANUAL, Exhibit 8 Part 2 – Section 4.3 – SHES Critical Positions) and the MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001.

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In addition, all personnel working offshore, including VENDOR/SUBCONTRACTOR shall:

• have the QP Offshore Pass. • Have a valid Medical fitness certificate + QP “Offshore Medical Fitness Card; copies of the certificates/card shall be carried by all personnel going aboard vessels and be supplied beforehand to the Project.

• Undergo the Marine Operations Safety Induction (MOSI) training by QG marine • Undergo the Heat Stress training by QG Marine. • provide a PoB and list of other valid certificates (crane operators, professional certificates for the medic personnel, certificates of food handlers, scaffolder certificates, etc.), including back- to-back persons.

• have an International passport

8.1.2.3 Permit to Work System

Onboard the vessel, a Permit to Work system shall be implemented to co-ordinate and control high- risk activities, such as Confined Space Entry, Hot Work in Hazardous areas, Live Electrical Work and Isolation Lock out Tag out System, Radiography, Pressure Testing, Diving, Heavy or complex lifts, Work at height, etc.

During Project execution: At SITE, for brownfield areas and handed over areas, COMPANY’s work permit system shall be applied [OGO-OPS-OVR-001 to Work System Operating Procedure].

Permit

8.1.2.4 Access to WORKSITE

SUBCONTRACTOR/VENDOR shall comply with COMPANY rules for access to the Offshore SITE.

8.1.2.5 Transfer of personnel

Transfer of personnel shall be performed following the Marine Operations manual – P36-X02-003, MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001, COMP2-SPM-SH-PRC- 00010 – OFFSHORE HSE MANUAL, OFFSHORE TRANSFER OF PERSONNEL – STD_OF- SCTOF-HSE-007-E.

8.1.2.6

Inspections and Audits

vessel

The Vessel Management Team and HSE Department shall perform every week a walk-around in the various to SUBCONTRACTOR/VENDOR’s activities). This inspection will be done to identify any positive HSE practices and/or non-compliance with the HSE rules [COMP2-SPM-SH-PLN-00010 – HSE Audit and Inspection plan].

areas/locations which may

dedicated

(including

sections

be

8.1.2.7 Hazardous Material Management

The SUBCONTRACTOR/VENDOR shall comply with the MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001, Project Environmental Management Plan COMP2-SPM-SH-PLN- 00019; Project Waste Management Plan COMP2-SPM-SH-PLN-00021; Project Spill Prevention and response plan COMP2-SPM-SH-PLN-00022; and the related actions from the COMP2-SPM-SH- REG-00001 – PROJECT ENVIRONMENTAL ASPECTS IMPACTS REGISTER.

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8.1.2.8 SIMOPS

The SUBCONTRACTOR/VENDOR shall comply with Exhibit 8 Part 2 Section 4.34 – Pre- Commissioning & Commissioning (PCC) & Simultaneous Operations (SIMOPS) and COMP2-SPM- SH-PRC-00010 – OFFSHORE HSE MANUAL.

8.1.2.9 Environmental Compliance

Subcontractor’s HSE Management System shall assess and control all significant environmental aspects against applicable laws and regulations, relevant international standards as well as CONTRACTOR’s relevant environmental documents and environmental project requirements.

In addition to the general requirements, there are specific requirements for the project derived from the Project Consent to Construct permit.

SUBCONTRACTOR shall comply with these Project CTC requirements to ensure the minimisation of adverse environmental impact brought by his activities to the Project.

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8.2 Category “2” – Direct Influence

HSE Requirements of SUBCONTRACTORS FABRICATION YARDS are identified in Doc. No. 033734-Z-Z-00-SPM-HS-P-10047

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8.3 Category “3” – Limited Influence

While working on its premises. SUBCONTRACTOR shall operate under their own HSE Management System. SUBCONTRACTOR / VENDOR shall implement the necessary occupational health and safety procedures and measures to carry out safely the assigned work and to prevent any incident with impact on the safety of the personnel.

A SUBCONTRACTOR of category 3 may be required to provide some personnel on a main project worksite controlled by CONTRACTOR or COMPANY. In this case, while on the worksite, the SUBCONTRACTOR / VENDOR of this category will be required to work under the existing worksite HSE system, complying with ALL the applicable requirements.

In the above-mentioned cases, CONTRACTOR will use FORM_OF-SCTOF-HSE-047 to define the required documentation to be submitted before and after the contract award and any other HSE requirements to be followed by VENDOR/SUBCONTRACTOR.

8.3.1.1 HSE Policy and Commitment

VENDOR/SUBCONTRACTOR shall have an HSE Policy updated and signed by management that demonstrates its commitment to Health, Safety and Environment within all its business activities and Subcontracted scope of work.

During the BID stage, VENDOR/SUBCONTRACTOR shall submit its HSE Policy.

the execution phase,

During for works performed on a main project worksite: VENDOR/SUBCONTRACTOR shall comply with CONTRACTOR/Project’s HSE policy and all other policies at CONTRACTOR/Project worksite locations, and COMPANY’s HSE policy whilst at COMPANY Category A and B worksite locations.

8.3.1.2 HSE Risk Management

VENDOR/SUBCONTRACTOR shall provide an HSE risk assessment (HIRA): identifying and assessing all the existing hazards associated with their activities, standard and additional control measures to be implemented.

During the BID stage, VENDOR/SUBCONTRACTOR shall submit its HSE Risk Management procedure and a typical risk assessment for a similar scope of work

the execution phase,

During for works performed on a main project worksite: VENDOR/SUBCONTRACTOR shall submit a project-specific HSE Risk Assessment relevant to the activities it will perform

8.3.1.3 HSE Management system

VENDOR/SUBCONTRACTOR shall operate with the highest regard for the health and safety of its personnel and of the environment and ensure that its activities do not endanger the safety of either site personnel or local communities. VENDOR/SUBCONTRACTOR is responsible for the appropriate selection of personnel who are suitable for the work.

During the BID stage, VENDOR/SUBCONTRACTOR shall submit any HSE Management System certification, HSE Manual and typical HSE Plan for a similar scope of work.

the execution phase,

During for works performed on a main project worksite: VENDOR/SUBCONTRACTOR shall submit a project-specific HSE Plan relevant to the activities it will perform

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8.3.1.4 Compliance with Law and Regulations

VENDOR/SUBCONTRACTOR is contractually obliged to observe and comply with all current applicable legislative requirements and guidance concerning the HSE and the Welfare of personnel. All documents required by law shall be at the site and made available to Control Authorities and CONTRACTOR.

8.3.1.5 HSE Performance Reporting

During the BID phase, VENDOR/SUBCONTRACTOR shall provide its five years HSE performance data for lagging and leading indicators, as well as the significant HSE incident investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses).

8.3.1.6 Waste Management

VENDOR/SUBCONTRACTOR shall ensure full compliance with local and Contract SoW requirements regarding Waste management.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Waste Management Plan

8.3.1.7

Incident Notification, Investigation and Reporting

CONTRACTOR operates a ‘No Blame’ culture that requires all personnel to report any accidents, incidents or near misses to the Project as soon as possible.

SUBCONTRACTORS/VENDORS shall comply with the requirements as stated in the Project Incident Investigation and Reporting procedure – COMP2-SPM-SH-PRC-00001 & Exhibit 8 – Part 2 – Section 4.6 – Incident Investigation and Reporting.

8.3.1.8 Health Management

SUBCONTRACTOR / VENDOR shall ensure, for all the personnel involved in the subcontracted activities, the proper Fitness to Work Examination to assess their fitness for the assigned tasks.

For its activities accrued in its premises, SUBCONTRACTOR/VENDOR shall develop an Emergency Response Plan, including MEDEVAC, and assist CONTRACTOR if a CONTRACTOR’s employee needs medical attention while on SUBCONTRACTOR/VENDOR premises. A bridging document with CONTRACTOR’s Emergency Evacuation Plan shall be elaborated by SUBCONTRACTOR/VENDOR.

Whenever a SUBCONTRACTOR activates a MEDEVAC Plan it has to inform CONTRACTOR immediately. SUBCONTRACTOR / VENDOR shall communicate to CONTRACTOR, before mobilization of any of their employee, the emergency contact numbers, as well as s MEDEVAC assurance contract number

SUBCONTRACTOR / VENDOR shall establish, implement and manage an adequate “Alcohol and Drugs Policy”. When on a WORKSITE Managed by CONTRACTOR or COMPANY, SUBCONTRACTOR‘s employee shall adhere to the SITE Alcohol and Drugs Policy

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8.4 Category “4” – Limited Influence

CONTRACTOR reserves the right to add, according to the scope of the Work to be done, additional HSE requirements, following the HSE requirements stated in Exhibit 8.

NOTE – A pre-mobilization vessel inspection/audit will be performed by HSE and will form part of the basis for the overall assessment [COMP2-SPM-SH-PLN-00010 – HSE Audit and Inspection plan].

8.4.1.1 HSE Policy and Commitment

VENDOR/SUBCONTRACTOR shall have an HSE Policy updated and signed by management that demonstrates its commitment to Health, Safety and Environment within all its business activities and Subcontracted scope of work.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its HSE policy.

the

During with CONTRACTOR/Project’s HSE policy and all other policies at CONTRACTOR/Project worksite locations, and COMPANY’s HSE policy whilst at COMPANY Category A and B worksite locations.

VENDOR/SUBCONTRACTOR

execution

comply

phase:

shall

8.4.1.2 HSE Risk Management

VENDOR/SUBCONTRACTOR shall provide an HSE risk assessment (HIRA): identifying and assessing all the existing hazards associated with their activities, standard and additional control measures to be implemented [COMP2-SPM-SH-PLN-00011 – HSE RISK MANAGEMENT PLAN].

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its HSE risk assessment/Vessel Safety Case.

8.4.1.3 HSE Management system

VENDOR/SUBCONTRACTOR shall operate with the highest regard for the health and safety of its personnel and of the environment and ensure that its activities do not endanger the safety of either site personnel or local communities. VENDOR/SUBCONTRACTOR is responsible for the appropriate selection of personnel who are suitable for the work.

During Management System certificates and any other relevant International certificates.

the BID phase: VENDOR/SUBCONTRACTOR shall provide

its HSE manual, HSE

After contract award: VENDOR/SUBCONTRACTOR shall provide an HSE Bridging Document based on a template that will be provided by CONTRACTOR. The HSE Bridging Document will define the primacy in the application of the relevant procedures and emergency response arrangements.

8.4.1.4 Compliance with Law and Regulations

VENDOR/SUBCONTRACTOR is contractually obliged to observe and comply with all current applicable legislative requirements and guidance concerning the HSE and the Welfare of personnel. All documents required by law shall be at the site and made available to Control Authorities and CONTRACTOR.

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Legal compliance procedure and Legal compliance register.

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8.4.1.5 HSE Performance Reporting

During the BID phase, VENDOR/SUBCONTRACTOR shall provide its five years HSE performance data for lagging and leading indicators, as well as the significant HSE incident investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses).

8.4.1.6 Waste Management

VENDOR/SUBCONTRACTOR shall ensure full compliance with local and Contract SoW requirements regarding Waste management [COMP2-SPM-SH-PRC-00010 – OFFSHORE HSE MANUAL and COMP2-SPM-SH-PLN-00021 - Waste Management Plan].

During the BID phase: VENDOR/SUBCONTRACTOR shall provide its Waste Management Plan During the BID phase: VENDOR/SUBCONTRACTOR shall provide signed sample waste disposal notes

8.4.1.7

Incident Notification, Investigation and Reporting

CONTRACTOR operates a ‘No Blame’ culture that requires all personnel to report any accidents, incidents or near misses to the Project as soon as possible.

SUBCONTRACTORS/VENDORS shall comply with the requirements as stated in the Project Incident Investigation and Reporting procedure – COMP2-SPM-SH-PRC-00001 & Exhibit 8 – Part 2 – Section 4.6 – Incident Investigation and Reporting.

8.4.2 OFFSHORE SPECIFIC HSE Requirements

8.4.2.1 Medical Fitness

SUBCONTRACTOR/VENDOR shall comply with Exhibit 8 – Part 3 – Section 4.5 – Fitness to Work (FTW) and the COMP2-SPM-SH-PLN-00017 – HEALTH MANAGEMENT PLAN Each SUBCONTRACTOR/VENDOR shall ensure that all employees, as well as Sub personnel, are medically fit for the job they are assigned to undertake. All employees working within the WORKSITE must have a valid medical certificate. All costs of medical examinations shall be borne by the SUBCONTRACTOR/VENDOR.

The medical certification process shall comply with the OGP report number 343 “Managing Health for field operations in Oil and Gas activities”, local laws in the country of employment and local laws governed by the Country where the services are to take place. The certificates stating the individual’s medical fitness (Medical Fitness Certificate) shall be made available on-site upon to to CONTRACTOR’s CONTRACTOR’s Medical Officer on site, preferably before their actual involvement in the activities.

representatives and/or

relevant

request

The QG FTW examination protocols shall apply for offshore personnel working in the QG field, also in compliance with the extant requirements of the Maritime Labour Convention (MLC) 2006 and Standards of Training, Certification and Watchkeeping (STCW) 1998;

For access offshore, SUBCONTRACTOR shall obtain the QP “Offshore Medical Fitness Card”. Any non-compliance with this requirement will lead to forbidding WORKSITE access.

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8.4.2.2 Training, Competence, Certifications

An HSE Induction shall be delivered to all new personnel before they start work.

Copy of the certificates of personnel scheduled to work offshore within the subcontracted activities shall be issued to CONTRACTOR before embarking. An original copy has to be carried with all the personnel going on board. CONTRACTOR representatives will have to refuse VENDOR/SUBCONTRACTOR’s personnel if not in possession of valid certification.

the right

All personnel, who are embarked on a Project vessel or COMPANY vessel/facility shall have a basic knowledge of First Aid and Fire Fighting through attending appropriate Training Courses for these topics. The Master and Crew shall:

• have valid passports or seaman’s books and Original Marine Certificates as per IMO/STCW

’95, regulation I/2 Clause 9 of the Convention;

• be compliant with the MARPOL 73/78; • be fit, free from illness, drugs and alcohol; • have a Tropical Offshore Survival Certificate, be valid and in compliance with OPITO T-

BOSIET, OPITO H2S training, and CA-EBS training when applicable

• be trained to the minimum standard of competence following IMO STCW ’95 - Section “A”

Chapter VI/1 for marine personnel;

• have the QP Offshore Pass. • Have a valid Medical fitness certificate + QP “Offshore Medical Fitness Card; copies of the certificates/card shall be carried by all personnel going aboard vessels and be supplied beforehand to the Project.

• Undergo the Marine Operations Safety Induction (MOSI) training by QG marine • Undergo the Heat Stress training by QG Marine. • provide a PoB and list of other valid certificates (crane operators, professional certificates for the medic personnel, certificates of food handlers, scaffolder certificates, etc.), including back- to-back persons.

• have an International passport

SUBCONTRACTOR/VENDOR personnel shall as a minimum:

• be fit, free from illness, drugs and alcohol; • have a Tropical Offshore Survival Certificate, be valid and in compliance with OPITO T-

BOSIET, OPITO H2S training, and CA-EBS training when applicable

• have the QP Offshore Pass. • Have a valid Medical fitness certificate + QP “Offshore Medical Fitness Card; copies of the certificates/card shall be carried by all personnel going aboard vessels and be supplied beforehand to the Project.

• Undergo the Marine Operations Safety Induction (MOSI) training by QG marine • Undergo the Heat Stress training by QG Marine. • have an International passport

It is VENDOR/SUBCONTRACTOR’s responsibility to verify the validity of the certificates. If the certificate is fake or non-compliant, personnel will be sent out from WORKSITE and all costs related to this will be solely SUBCONTRACTOR / VENDOR’S responsibility. All certificates must be

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sent at least 30 days in advance before commencing the work to allow CONTRACTOR to perform authenticity verification checks.

8.4.2.3 Access to WORKSITE

SUBCONTRACTOR/VENDOR shall comply with COMPANY rules for access to the Offshore SITE.

8.4.2.4 Transfer of personnel

Transfer of personnel shall be performed per the Marine Operations manual – P36-X02-003, MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001, COMP2-SPM-SH-PRC-00010 – OFFSHORE HSE MANUAL, OFFSHORE TRANSFER OF PERSONNEL – STD_OF-SCTOF-HSE- 007-E.

8.4.2.5 Hazardous Material Management

The SUBCONTRACTOR/VENDOR shall comply with the MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001, Project Environmental Management Plan COMP2-SPM-SH-PLN- 00019; Project Waste Management Plan COMP2-SPM-SH-PLN-00021; Project Spill Prevention and response plan COMP2-SPM-SH-PLN-00022; and the related actions from the COMP2-SPM-SH- REG-00001 – PROJECT ENVIRONMENTAL ASPECTS IMPACTS REGISTER.

8.4.2.6 SIMOPS

The SUBCONTRACTOR/VENDOR shall comply with Exhibit 8 Part 2 Section 4.34 – Pre- Commissioning & Commissioning (PCC) & Simultaneous Operations (SIMOPS) and COMP2-SPM- SH-PRC-00010 – OFFSHORE HSE MANUAL.

8.4.2.7 Environmental Compliance

Subcontractor’s HSE Management System shall assess and control all significant environmental aspects against applicable laws and regulations, relevant international standards as well as CONTRACTOR’s relevant environmental documents and environmental project requirements.

In addition to the general requirements, there are specific requirements for the project derived from the Project Consent to Construct permit.

SUBCONTRACTOR shall comply with these Project CTC requirements to ensure the minimisation of Project. adverse

environmental

activities

brought

impact

the

his

by

to

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9 Appendices

9.1 Appendix 1 – Summary of HSE requirements for Vendors and SUBCONTRACTORs – Category ‘1’ – Full Control

CATEGORY ‘1’ – Full Control

Site Type / VENDOR Type

Activities performed on Category A or B worksites OR CONTRACTOR-owned facilities (e.g. CPY facilities, Karimun Fabrication Yard, Construction Vessel De-He, etc.)

Level of reporting

All incidents, near misses and anomalies, shall be reported to CTR

Level of recording

Within the Project recording perimeter For Offshore main construction vessel – within the Project recording perimeter only when at SITE

Project HSE applicable requirements to be sent to SUBCONTRACTOR / VENDOR

• Exhibit 5 – Appendix I • Exhibit 8 • COMPANY “Marine Operation Manual – P36-X03-003, if applicable • Project HSE Plan – COMP2-SPM-SH-PLN-00001, and the documents listed in its section 3 • Project HSE Management of Vendors and SUBCONTRACTORs – COMP2-SPM-SH-PRC-00004 • Environmental Management Plan – COMP2-SPM-SH-PLN-00019. • Project Incident Investigation and Reporting procedure – COMP2-SPM-SH-PRC-00001 • MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001 • HSE REQUIREMENTS FOR DIVING SUBCONTRACTORS – SPC_OF-SCTOF-HSE-002, if

applicable

• HSE REQUIREMENTS FOR VENDORS – FORM_OF-SCTOF-HSE-047-E • Other procedures as applicable depending on the scope of work

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List of minimum documentation to be provided at the bid stage:

• HSE manual and/or Typical HSE plan for a similar work scope • HSE policy, Organization Chart and HSE Organization Chart • Alcohol and Drug Policy • HSEMS Certificates • Legal compliance procedure and register •

five years of HSE performance data for lagging and leading indicators, as well as the significant HSE incident investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses)

• HSE risk management procedure and risk assessment • HSE audit procedure and a sample audit report • Work at Height and Confined Space entry procedure • Typical work at height rescue plan and rescue training certificates • Typical confined space entry rescue plan and rescue training certificates • PPE procedure • COSHH (Control of Substances Hazardous to Health) or Chemical Handling procedure • Operation and Maintenance of plant and equipment procedure, Preventive Maintenance register, critical spares

list, and applicable certificates.

• Periodic medical fitness examination protocol. • Evidence of retainership clinic agreement • Waste Management Plan + Waste disposal notes • HSE training program and records/certificates • Certificates of competence for equipment operators • • Any other document identified in FORM_OF-SCTOF-HSE-047-E • Project-specific HSE plan (HSE and Emergency Bridging Documents) • Project-specific HSE risk assessment • Medical insurance, valid medical fitness certificates, evidence of retainership clinic agreement (before

IH program (as applicable)

mobilization), as

• Work at Height / Confined space rescue plan and rescue training certificates (before mobilization), as applicable • asbestos-free certificate as applicable • HSE reports on a weekly and monthly basis (during project execution)

HSE Deliverables at the bid stage, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

HSE Deliverables after CONTRACT AWARD, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

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• HSE training records/certificates, as applicable based on the project HSE Training Matrix • 3rd party lifting equipment/accessories certificates/register, as applicable • Offshore certifications as described in this document

AUDIT/inspection

The CONTRACTOR reserves the right to conduct HSE audits on the SUBCONTRACTORS’ premises

HSE objectives for SUBCONTRACTORS During the execution phase

Please refer to the Project HSE Plan COMP2-SPM-SH-PLN-00001 – PROJECT HSE KPIs

A

list of Subs with HSE

categorization

is

to be provided one month after

the Contract.

SUBS management

Safety Critical activities and services will not be subcontracted without prior written APPROVAL from COMPANY and CONTRACTOR. Such APPROVAL will only be granted based on a satisfactory CONTRACTOR and COMPANY assessment of the SUBCONTRACTOR and their ability to perform the activity and or services to the Projects’ HSE requirements.

An agreement shall be

reached on a case-by-case basis

for

the HSE categorization of Subs.

The CONTRACTOR reserves the right to conduct HSE audits on major Subs.

SUBCONTRACTORS / VENDORS shall ensure that their major Subs are competent and able to execute the Work considerations: safely.

selection

following

address

process

should

Their

the

SUBS selection

• HSE MS Maturity of Subs, • Recent experience with Subs, • Similar Work experience, • Historical safety performance, • Ability and willingness of Subs to fulfil the Project HSE Requirements (according to the Category assigned to the

Work).

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9.2 Appendix 2 – Summary of HSE requirements for Vendors and SUBCONTRACTORs – Category ‘2’ – Direct Influence

Site Type / VENDOR Type

CATEGORY ‘2’ – Direct Influence

• Activities performed in COOEC Fabrication Yard
• Activities performed in QCON Fabrication Yard
• Activities performed in Living Quarters Fabrication Yard

Level of reporting

All incidents, near misses and anomalies, shall be reported to CTR

Level of recording

Within the Project recording perimeter

Project HSE applicable requirements to be sent to SUBCONTRACTOR / VENDOR

• Exhibit 5 • Exhibit 8 • Project HSE Plan – COMP2-SPM-SH-PLN-00001), and the documents listed in its section

3

• HSE Requirements for SUBCONTRACTOR yards (Doc. No. 033734-Z-Z-00-SPM-HS-P-

• Other procedures as applicable depending on the scope of work

HSE Deliverables after CONTRACT AWARD, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

• Site-specific HSE Plan • Emergency Response Bridging Document • Any other deliverable requested by CONTRACTOR in line with Exhibit 8 and HSE Plan

requirements

AUDIT/inspection

HSE objectives for SUBCONTRACTORS During the execution phase

The CONTRACTOR reserves the right to conduct HSE audits on the SUBCONTRACTORS’ premises

Please refer to the Project HSE Plan COMP2-SPM-SH-PLN-00001 – PROJECT HSE KPIs

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A list of Subs with HSE categorization is to be provided one month after the Contract award to the CONTRACTOR by each SUBCONTRACTOR / VENDOR.

Safety Critical activities and services will not be subcontracted without prior written APPROVAL from COMPANY and CONTRACTOR. Such APPROVAL will only be granted based on a satisfactory CONTRACTOR and COMPANY assessment of the SUBCONTRACTOR and their ability to perform the activity and or services to the Projects’ HSE requirements.

An agreement shall be reached on a case-by-case basis for the HSE categorization of Subs. The CONTRACTOR reserves the right to conduct HSE audits on major Subs.

SUBCONTRACTORS / VENDORS shall ensure that their major Subs are competent and able to execute the Work safely. Their selection process should address the following considerations: HSE MS Maturity of Subs,

• Recent experience with Subs, • Similar Work experience, • Historical safety performance, • Ability and willingness of Subs to fulfil the Project HSE Requirements (according to the

Category assigned to the Work).

SUBS management

SUBS selection

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9.3 Appendix 3 – Summary of HSE requirements for Vendors and SUBCONTRACTORs – Category ‘3’ – Limited Influence

Site Type / VENDOR Type

Level of reporting

Level of recording

CATEGORY ‘3’ – Limited Influence

• Activities performed by vendors/SUBCONTRACTORs in their worksite, using their own HSE-MS
• Sub-subcontracted fabrication activities, performed on the sub-SUBCONTRACTOR worksite following their own HSE-MS

All incidents, near misses and anomalies, shall be notified to CTR.

Outside the Project recording perimeter

Project HSE applicable requirements to be sent to SUBCONTRACTOR / VENDOR

Exhibit 8 Project HSE Plan – COMP2-SPM-SH-PLN-00001), and the documents listed in its section 3 Project HSE Management of Vendors and SUBCONTRACTORs –COMP2-SPM-SH-PRC-00004 Other procedures as applicable depending on the scope of work

HSE Deliverables at the bid stage, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

List of minimum documentation to be provided at the bid stage:

• HSE policy • HSE manual/plan, HSEMS Certificates and any other relevant International certificates •

five years of HSE performance data for lagging and leading indicators, as well as the significant HSE incident investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses)

• HSE risk management procedure + risk assessment • Waste Management Plan • Any other document identified in FORM_OF-SCTOF-HSE-047-E

HSE Deliverables after CONTRACT AWARD, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

If VENDOR/SUBCONTRACTOR is expected to perform any activity of a main project worksite (e.g. assistance with the installation of the equipment, troubleshooting, maintenance, etc.), specific requirements shall be identified using FORM_OF-SCTOF-HSE-047-E. As a minimum:

• Project-specific HSE Plan and Emergency response bridging document • Project-specific HSE risk assessment • Training certificates

AUDIT/inspection

The CONTRACTOR reserves the right to conduct HSE audits on the SUBCONTRACTORS’ premises

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9.4 Appendix 4 – Summary of HSE requirements for Vendors and SUBCONTRACTORs – Category ‘4’ – Limited Influence

Site Type / VENDOR Type

• Offshore spread/transport vessel (e.g. crew service vessel, Tug and supply vessel, Surfer, etc.)

Level of reporting

All incidents, near misses and anomalies, shall be notified to CTR.

Level of recording

Within the Project recording perimeter - only when working within the 500m Marine Exclusion Zone or within the boundaries defined by the relevant HSE bridging documents

CATEGORY ‘4’ – Limited Influence

Project HSE applicable requirements to be sent to SUBCONTRACTOR / VENDOR

HSE Deliverables at the bid stage, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

HSE Deliverables after CONTRACT AWARD, provided by SUBCONTRACTOR / VENDOR to CONTRACTOR

• Exhibit 5 – Appendix I • Exhibit 8 • COMPANY “Marine Operation Manual – P36-X03-003 • Project HSE Plan – COMP2-SPM-SH-PLN-00001), and the documents listed in its section 3 • Project HSE Management of Vendors and SUBCONTRACTORs – COMP2-SPM-SH-PRC-00004 • MARINE OPERATIONS PROCEDURE – COMP2-SPM-MO-PRC-00001 • Other procedures as applicable depending on the scope of work

List of minimum documentation to be provided at the bid stage:

• HSE policy • HSE manual/plan, HSEMS Certificates and any other relevant International certificates • Legal compliance procedure and Legal compliance register • 5 years of HSE performance data for lagging and leading indicators, and the significant HSE incident

investigation reports in the last 5 years (i.e. LTI and High Potential Near Misses)

• HSE risk assessment / Vessel Safety Case • Operation and Maintenance of plant and equipment procedure, Preventive Maintenance register, critical

spares list, and applicable certificates.

• Waste Management Plan • Any other document identified in FORM_OF-SCTOF-HSE-047-E

• HSE Manual • HSE risk assessment / Vessel Safety Case • Offshore certifications as described in this document

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Project: Q-21699 - Saipem COMP2 Folder: RFQ Files