1.    PURPOSE

The purpose of this section is to ensure the SON VU CO HSE Policy is clearly identified and integrated into the HSE plans and objectives so that they are consistent and meet the requirements of all governing legislation.

2.    PERFORMANCE MANAGEMENT 

2.1.    SON VU CO Policy, Planning and Objectives

• 2.1.1.    There is a set of HSE Management Policy endorsed by the SON VU CO Management that is regularly updated and is clearly communicated. The documented HSE Policy clearly states the HSE objectives and a commitment to improving HSE performance (see attached).
• 2.1.2.    Where required, specialized policies are developed for specific HSE and other matters being of similar priority.
• 2.1.3.    Measurable and achievable HSE objectives are established annually and include the require to:
  •    – Provide a safe place of work and systems of work to minimize work-related injury;
  •    – Provide a mechanism that provides for continuous, sustainable improvements in health, safety, and environmental protection; and
  •    – Provide a system to ensure that the SON VU CO operation is fully compliant with applicable legislation, standards, codes of practice and SON VU CO requirements itself.
• 2.1.4.    These HSE objectives outline the roles and responsibilities of SON VU CO personnel in relation to HSE protection.
• 2.1.5.    Management shall develop a plan of action regarding personnel participation in achieving policy objectives and improving operating performance.
• 2.1.6.    HSE goals are incorporated in the approved Annual Business Plan.
• 2.1.7.    Goals and KPI’s encompass management system implementation, improvement and performance effectiveness, and compliance with regulations and codes.
• 2.1.8.    The goals, KPI’s and targets are a balance of lead and lag indicators.
• 2.1.9.    There are specific documents in place, which include the SON VU CO policies, objectives, plans and procedures

2.2.    HSE Management System (HSEMS)

• 2.2.1.    HSEMS performance expectations (standards) are established and communicated.
• 2.2.2.    There is a process to develop and maintain procedures and practices from the HSEMS.
• 2.2.3.    Stewardship by Management involves the scheduled review and approval of plans and resources to ensure that they are sufficient to implement, maintain and improve the HSEMS.
• 2.2.4.    Management shall support and demonstrate their commitment to the HSEMS.

2.3.    Regulatory Compliance

• 2.3.1.    All applicable laws, regulations, codes and standards are identified and listed. The list is kept current within a Compliance Register.
• 2.3.2.    All personnel affected by the need to comply with these laws are informed and are made aware of their role in compliance. Responsibility for the maintenance and distribution of this information is assigned.
• 2.3.3.    The requirements within the laws are incorporated into the procedures, plans and registers.
• 2.3.4.    Changes to legislation, standards and codes of practice lead to a review of procedures and work instructions.
• 2.3.5.    Essential regulatory documents are developed and updated or revised as per specified objectives.
• 2.3.6.    A compliance plan is developed at affected operations to ensure regulatory compliance over the lifecycle of the operation.
• 2.3.7.    There are procedures and responsibilities in place for managing the SON VU CO interface with Regulatory Authorities, including the reporting of required information.
• 2.3.8.    There is a scheduled review and interpretation of new laws and the subsequent changes to existing regulatory requirements.
• 2.3.9.    There is an objective to have an active role in the development of new or revised regulations, which shall impact upon the operations.

1.    PURPOSE

The purpose of this Section is to ensure an effective organizational structure is in place to implement and maintain policies and objectives and that there are seamless and clear lines of reporting in determining ultimate responsibility to senior management within SON VU CO.

2.    PERFORMANCE MANAGEMENT 

2.1.    Management and Facility Organization Structure

• 2.1.1.    SON VU CO maintains an organizational structure, through required levels of personnel with the appropriate skills available to manage the business operations in an HSE responsible manner during normal operating and emergency situations.
• 2.1.2.    The organization structures for SON VU CO have a review schedule to ensure that they achieve the objectives of the SON VU CO HSEMS and that overall management system performance is maintained.
• 2.1.3.    Levels of management are commensurate with the level of risk associated with the tasks being performed and management is held accountable for the performance in their area of control.
• 2.1.4.    The organization obtains HSE advice from nominated persons.

2.2.    Roles and Responsibilities

• 2.2.1.    The HSE responsibilities for ongoing operations and technical support are commensurate with the hazards and risks of the operation. This covers the responsibilities for the ongoing management of each hazard and risk and includes roles and responsibilities of individual personnel in hazard identification, risk assessment and management and emergency response.
• 2.2.2.    All SON VU CO roles and responsibilities are outlined to ensure that accountabilities, including statutory accountabilities, are clearly identified, communicated to all personnel and that they are documented.
• 2.2.3.    Roles and responsibilities are applied to all activities whether carried out by SON VU CO employees or contractors.
• 2.2.4.    The responsibilities and authorities, reporting lines, including contractors and other third parties, are officially documented, communicated and are identified within the organizational charts.
• 2.2.5.    The positions and duties of the persons responsible for the implementation and effectiveness of the SON VU CO HSEMS are specified.
• 2.2.6.    For details of each individual’s roles and responsibilities please refer to Job Descriptions

2.3.    Duty of Care

• 2.3.1.    SON VU CO personnel shall be responsible for their personal health and safety and for that of persons reporting to them.

1.    PURPOSE

The purpose of this Section is to ensure risks are managed and laws and regulations are complied with in regard to the management and control of information. HSE hazards; business critical matters and regulatory requirements, together with accessible and available information processes to personnel where required.

2.    PERFORMANCE MANAGEMENT 

2.1.    HSE Information Management

• 2.1.1.    All SON VU CO policies, objectives, HSEMS, manuals, procedures (operating, safety, environmental and business critical) and work instructions are documented and maintained in a controlled manner (see 2.2).
• 2.1.2.    Facility and process information required managing HSE, operational and business risks are documented and maintained. This includes technical data, records, reports, studies, drawings, diagrams, industry standards, regulatory documents and other related documentation.
• 2.1.3.    The properties and hazards of materials used or produced by the process are identified; documented and involved parties are informed. A register is maintained of chemical, physical and biological agents and radioactive materials in conjunction with material safety data sheet for each hazardous material.
• 2.1.4.    The document system shall ensure that:
•     – Documents have a review schedule, are revised and approved for adequacy by authorized personnel;
•     – Current versions of applicable documentation are available at all locations where operations essential to the effective functioning of the system are performed;
•     – Where required, persons are informed of new documents and changes to existing;
•     – Superseded and obsolete documents are promptly removed from all points of issue and points of use and communicated to those affected; and
•     – Documents to be retained for legal purposes are identified and stored.

2.2.    Communications

• 2.2.1.    All regulations, codes, permits, standards, and practices are identified, documented and communicated to those affected.
• 2.2.2.    Prescribed methods of communication are used to inform personnel of important issues and minimum acceptable performances.
• 2.2.3.    HSE information is posted electronically on the network and on site on a notice board dedicated to safety issues.
• 2.2.4.    Toolbox meetings are provided as a means to convey any operational, HSE concerns or information.
• 2.2.5.    HSE issues are included on the agenda item at management review meetings.

2.3.    Document Control

• 2.3.1.    documents and/or data are those which personnel need to follow or utilize in order to ensure that SON VU CO:
•     – Achieves satisfactory health and safety performance;
•     – Operates with environmental accountability;
•     – Understands and satisfies legitimate customer expectations;
•     – Operates within financial controls; and
•     – Complies with legislative requirements.
• 2.3.2.    All applicable documentation including records, drawings, and procedures are controlled with the status, authorization, date of issue, date of modification and the intended distribution specified on the documents.
• 2.3.3.    A master list is maintained that identifies the latest revision.

2.4.    Documentation Availability

• 2.4.1.    The documents are accessible to those that require them and are current, accurate and secure.
• 2.4.2.    All HSE management information including correspondence, minutes of meetings shall be maintained in dedicated files and as appropriate made accessible to all personnel.
• 2.4.3.    Records are maintained covering operations, maintenance and inspection and facility changes to verify that the equipment is designed, maintained, inspected, tested and operated in a healthy, safe and environmentally accountable manner.
• 2.4.4.    Records demonstrating compliance with all Regulations and Acts are maintained.

1.    PURPOSE

The purpose of this Section is to ensure that the systematic identification of hazards, the assessment and management of the risk associated with those hazards and the effective management of risk throughout SON VU CO operations can be executed.
Hazard identification assessment process prevents and/or minimizes the likelihood of a hazardous event occurring during the operations. Where a hazard is identified the risk of injury or harm to a person, damage, loss or activity interruption at the operation and environmental effect is assessed.

2.    PERFORMANCE MANAGEMENT 

2.1.    Hazard Identification

• 2.1.1.    Procedures shall be in place to identify the hazards in order to analyze the risks and develop treatment options to eliminate, reduce or manage the risk. The identified hazards are recorded in a register.

2.2.    Risk Assessment

• 2.2.1.    Hazard analyses and risk assessments are undertaken for on-going operations. These may be carried out using external resources and/or SON VU CO personnel, depending on the complexity and type of hazard.
• 2.2.2.    Hazard analyses and risk assessments are undertaken for new products and projects and may also be applied at specified intervals.
• 2.2.3.    Project Management prior to the commencement of the task shall conduct a risk or safety analysis of all non-routine activities. HSE issues identified shall be captured and assessed through the routine processes.
• 2.2.4.    For all non-routine activities for which HSE issues have been identified, a corresponding procedure shall be developed. The SON VU CO Project Management shall agree on the procedure(s) developed, prior to the conduct of the work.
• 2.2.5.    Hazards are analyzed and risks are assessed based upon a thorough understanding of the applicable operation and the associated hazard(s). The process shall address:
• –    All the hazards of the process;
• –   Identification of any previous incidents with potential for serious consequences;
• –    Impact of any failure of the control measures, especially the effect upon personnel;
• –    Facility siting; and
• –    Human factors.
• 2.2.6.    The evaluation of the level of the risk is based on the likelihood of the hazard occurring and its associated consequences.
• 2.2.7.    Hazard analyses and risk assessments provide input into the optimization of normal operations, maintenance and/or inspection and emergency procedures, and the development of appropriate HSE plans.

2.3.    Risk Management Processes

• 2.3.1.    Risks are assessed by qualified personnel and the reasons, assumptions and methods documented. The risk assessment team shall include those with expertise in engineering and process operations and at least one person with experience and knowledge of the specific process being evaluated. At least one team member must be knowledgeable in the specific hazard analysis and/or risk assessment process being used.
• 2.3.2.    A plan is established to monitor and update the hazard analyses and/or risk assessments on a scheduled basis as changes occur.
• 2.3.3.    There shall be a documented plan to eliminate, reduce or manage risks approved by senior level management depending upon the nature and magnitude of the risk. The plan incorporates objectives, priorities, and the allocation of resources and responsibilities.
• 2.3.4.    The results of the hazard analyses and risk assessments are documented and communicated to all personnel through HSE meetings and Toolbox meetings.
• 2.3.5.    All hazard analyses and risk assessments are monitored to ensure that the decisions arising have been scheduled for implementation. The recommendations and actions are reviewed to ensure that the actions implemented have met the objectives and time frames put in place to mitigate or manage the risks.

2.4.    Risk Reduction Measures

• 2.4.1.    Reasonable measures shall be taken to reduce the risk to as low as reasonably practicable (ALARP).
• 2.4.2.    Where HSE Legislation provides specific control measures these shall be followed.
• 2.4.3.    Risk reduction measures are documented, and their effectiveness monitored, assessed and recorded.

1.    PURPOSE

The purpose of this Section is to ensure the establishment of well-defined procedures to regulate the way in which work is conducted. This includes generic practices and procedures and facility specific operating procedures. It sets the standards and encourages a healthy, safe, environmentally responsible and business efficient operation.

2.    PERFORMANCE MANAGEMENT

2.1.    Operating Procedures

• 2.1.1.    The procedures are consistent with all applicable regulatory requirements, and include SON VU CO and workplace standards and policies.
• 2.1.2.    The operations are supported by a structure of manuals including:
  •     HSE;
  •     Engineering;
  •     Business administration;
  •     Maintenance;
  •     System processes; and
  •     Procurement and logistics.
• 2.1.3.    All procedures are controlled documents, review and approved by the Management taking into account:
  •     HSE considerations;
  •     Consistency with other operations in SON VU CO;
  •     Compatibility with design, operational limitations and with the applicable legislation, codes of practice and standards; and
  •     Review by suitably qualified and skilled personnel.
• 2.1.4.    Standard operating procedures are required for all operating activities throughout the facilities lifecycle, whether routine, occasional, stand alone or emergency.
• 2.1.5.    Maintenance procedures required to maintain the on-going integrity of operating equipment include:
  •     Work on in-service facilities and equipment;
  •     Temporary repairs;
  •     Safety critical equipment; and
  •     Jobs that require more than one maintenance skill.
• 2.1.6.    Safety critical procedures are developed to control or mitigate specific major hazards and are focused on an activity associated with that major hazard. They are derived from an analysis of major hazards.
• 2.1.7.    For non-routine tasks with a potential risk, a JSA is developed which outlines the steps to carry out the task, the personnel and equipment requirements, and any special HSE requirements.
• 2.1.8.    A standard format for the procedures and work instructions exists, that includes the objective(s), the steps required to enact the procedure or work instruction and the HSE issues which are applicable. They include:
  •     Physical and other hazards present in the procedure or work instruction;
  •     Central management of equipment isolation;
  •     Restrictions on simultaneous activities; and
  •     Contingency procedures.
• 2.1.9.    Each work permit document contains at least the following details:
  •     A discrete identification number;
  •     Description of the work;
  •     Location of the work;
  •     Confirmation that the site and/or equipment is appropriately prepared for the task;
  •     Identifies isolations, bypasses and removals prior to the work permit being issued;
  •     Time limits of the work permit;
  •     Precautions and/or control measures that are in place to protect personnel, the environment and equipment from potential hazards;
  •     Any interfaces which are identified and the affected personnel notified;
  •     All equipment and personnel required to safely execute the task covered by the work permit is available; and
  •     The appropriate approvals for issuing the work permit and for close out.
  • 2.1.10.    The permit system includes procedures for the close out and checking of tasks to ensure that:
  •     The task has been performed satisfactorily and meets the requirements of SON VU CO
  •     All isolations and temporary bypasses have been restored
  •     The workplace has been restored to a safe working condition; and
  •     Task completion is documented, checked and formally signed off by the responsible supervisor, and communicated to affected personnel (ie, personnel working on interfacing tasks).
• 2.1.11.    All personnel involved in the task covered by the work permit are informed and are made aware of the requirements of the work permit.
• 2.1.12.    The authority to issue, approve and close out work permits is designated and documented.
• 2.1.13.    Training is undertaken and refreshments are scheduled for all personnel on site with a role in the work permit procedures.
• 2.1.14.    Procedures are established as to when hazardous material monitoring is required.
• 2.1.15.    Specific criteria are established for acceptable hazardous limits, (eg. oxygen content, toxicity, and flammability).
• 2.1.16.    Work permits shall be kept on file until completion of the work and for future assessment.
• 2.1.17.    The area for which the work permit is required is defined, including the responsibilities of those personnel working in the area.
• 2.1.18.    In an Emergency situation, permit holders shall be made aware that all work permits are cancelled and the permits shall be re-validated before work can recommence after the All Clear’.
• 2.1.19.    Isolation and tagging procedures ensure that plant and equipment are adequately identified, isolated and tags are in place prior to work commencing.
• 2.1.20.    Where a potential hazard or an area must be isolated, safety signs and/or barricading shall be erected around the location, to limit access in accordance with SON VU CO procedures, legislation, standards and codes of practice.
• 2.1.21.    When working on Customer’s site, if possible, Customer Work control system should be followed as required but clear instruction must be given.

1.    PURPOSE

The purpose of this Section is to promote active communication and involvement of personnel in the management of HSE. This includes the control of workplace hazards and risk, the development of the Operation Plan and the efficient management of the business. This ensures and encourages effective participation and that consultative mechanisms are in place to enable a response to community expectations and concerns.

2.    PERFORMANCE MANAGEMENT

2.1.    Employee Involvement

• 2.1.1.    Prescribed consultative mechanisms are established such as:
  •     HSE meetings, including Operations, site HSE Committee and Toolbox;
  •     Workplace inspections;
  •     Incident investigation;
  •     Communication meetings;
  •     Workplace orientation; and;
  •     Training programs and emergency exercises.
  • The mechanisms are such that all personnel shall be made aware of the hazards and risks to which they, and the business, are exposed to, and their role in identifying and managing those hazards and risks.
• 2.1.2.    Procedures are developed for all official and community meetings, and include:
  •     Scope and purpose;
  •     Attendees and meeting frequency;
  •     Responsibilities and accountabilities;
  •     Documentation of minutes and distribution; and
  •     How issues or follow ups are to be actioned.
• 2.1.3.    All personnel have an opportunity to contribute to HSE Policy and objectives development and review via the Safety and Environmental meetings.
• 2.1.4.    All personnel involved in HSE activities shall be trained to competently perform those duties.
• 2.1.5.    Clearly defined issue resolution procedures are to be in place and these shall be communicated to all concerned parties along with the outcomes.
• 2.1.6.    Personnel as selected by senior management are involved in the development and implementation of the Operation Plan.
• 2.1.7.    Through work planning, safety meetings, KPI monitoring, incident investigations, inspections, audits, reviews and decision making activities, ownership of improvements to the HSE and business performance is promoted amongst personnel.
• 2.1.8.    Employees and contractors are required to participate in the development and implementation of personnel safety programs. Those personnel normally located at site are required to attend monthly safety meetings where they can raise issues related to workplace safety. This arrangement meets the requirements for employee health and safety representation as required by Legislation.

2.2.    Community Involvement

• 2.2.1.    A program is in place to keep all personnel, including the community, informed regarding applicable HSE and operational issues of which a primary tool is the HSE Review Committee.
• 2.2.2.    Arrangements are made and priorities established when responding to questions and concerns raised by personnel and the community in relation to SON VU CO’s operations.
• 2.2.3.    Applicable Government authorities, community groups and the community in general, are informed of SON VU CO emergency response procedures.
• 2.2.4.    The performance measures of the community awareness program are evaluated and monitored within scheduled timeframes.
• 2.2.5.    Identification and notification procedures are in place for SON VU CO operation and equipment which are in the community, or which the community are exposed to.

1.    PURPOSE

The purpose of this Section is to ensure that SON VU CO operations comply with all laws and regulations and that the operations are safe, environmentally responsible, protect health and meet business requirements.
The Standard also identifies that the process of selection, placement, training and ongoing assessment of personnel at SON VU CO is managed accordingly.

2.    PERFORMANCE MANAGEMENT

2.1.    Employee Selection

• 2.1.1.    The necessary qualifications, knowledge, skills, competencies and experience to undertake the assigned functions at SON VU CO are detailed within the position descriptions.
• 2.1.2.    Documented job criteria are developed for all positions where personnel undertake HSE or business critical work.
• 2.1.3.    The position description and competence requirements have a review schedule to ensure compliance with legislation and consistency with SON VU CO policies.
• 2.1.4.    Procedures exist for the specification, selection and placement of skilled personnel and involve a detailed assessment with reference to the position description and the identification of performance criteria required for the position.
• 2.1.5.    A system is in place to ensure that the necessary levels of individual and collective skills, knowledge and experience are met when personnel changes are made.

2.2.    Training

• 2.2.1.    A training needs analysis is undertaken to identify the minimum skills, knowledge and experience required to operate and manage the business activities and processes. At a minimum, this covers all HSE critical work and those positions with HSE responsibilities.
• 2.2.2.    Appropriate Induction training is given to all personnel entering the site covering:
  •     New SON VU CO personnel;
  •     Personnel from associated and their subcontractors;
  •     Contractors and maintenance team; and
  •     Visitors.
• 2.2.3.    All Induction training is documented within a register indicating each person’s attendance. The induction training includes key information on safety protocol, HSE policies and procedures, personal protective equipment requirements, site and work rules, equipment requirements, and certification requirements.
• 2.2.4.    New and re-assigned personnel receive training, appropriate to their responsibilities and accountabilities, at the start of their new role and which includes:
  •     The overview of the process;
  •     The HSEMS;
  •     Operating and maintenance procedures;
  •     Emergency procedures;
  •     HSE and other critical procedures;
  •     Senior first aid course for those who work permanently onsite; and
  •     All applicable laws and regulations.
• 2.2.5.    Appropriate core knowledge and skills training programs, as well as position training programs are documented in a training matrix. The matrix identifies the training course and modules to be completed by personnel, to enable them to perform their roles without risks to their health, safety or environment and prior to being permitted to work without direct supervision.
• 2.2.6.    Personnel assigned to undertake HSE critical work or tasks and their stand-ins, receive training on the necessary HSE aspects of their work or tasks, prior to assuming their responsibilities.
• 2.2.7.    Training requirements are reviewed for refresher and update, and the appropriate frequency assigned.
• 2.2.8.    All trainees are assessed to ensure that the knowledge and skills have been attained and the assessment results are reviewed with individual trainees and appropriate feedback provided.
• 2.2.9.    Training programs are conducted by Trainers with the appropriate knowledge, skills and experience, and take into account the differing levels of the trainee’s ability and literacy.
• 2.2.10.    The content and method of all training programs are documented, and are assessed as required or when changes occur to ensure their effectiveness.
• 2.2.11.    Training records are kept of attendance and satisfactory completion.

2.3.    Competency

• 2.3.1.    Systems are in place to monitor, assess, document and provide feedback on personnel competence and performance. These systems include actions to be taken to remedy any performance deficiencies. Information on certification of personnel shall be officially documented under the SON VU CO competency based training matrix.
• 2.3.2.    The assessment includes appraisal against specific targets, objectives and the HSE critical tasks that they are expected to perform.
• 2.3.3.    System is in place to ensure and confirm that personnel hold the necessary licenses, permits and competency training qualifications and the status of these are reviewed annually by SON VU CO to confirm the continuing competence of SON VU CO operational personnel.
• 2.3.4.    The results of the appraisal are updated in the training requirements for the individuals and the training matrix is updated to reflect any changes.

1.    PURPOSE

The purpose of this Section is to protect the health of all employees, contractors and the public. It is paramount that SON VU CO operations and/or products do not adversely affect personnel as a result of their performance.

2.    PERFORMANCE MANAGEMENT

2.1.    Health Management

• 2.1.1.    For all chemical, physical and biological agents and radioactive materials, the hazard information and exposure control requirements are made available to all personnel likely to be exposed.
• 2.1.2.    The design of the workplace shall cover the health and performance of personnel where hazardous areas and sources of risk to health have been identified.
• 2.1.3.    All jobs and/or tasks, procedures, new projects and materials are reviewed for potential health hazards and the appropriate remedial action enacted. This includes the:
  •     Changes in work procedures and practices;
  •     Wearing of personal protective equipment (PPE);
  •     Cancellation of the job or task;
  •     Changes in the agents and materials used; and
  •     Changes to the workplace facilities.
• 2.1.4.    Where pre-handling and post-handling of, or exposure to, chemical substances exists, personnel shall refer to the appropriate material safety data sheet (MSDS) to identify specific PPE requirements.
• 2.1.5.    All personnel at the facility are required to use the appropriate items of PPE that meet SON VU CO standards and the Legislation.
• 2.1.6.    Safety equipment shall be worn in any area where indicated by warning signs and/or where hazards have been identified through JSA or specified as a Permit to Work requirement. The wearing of PPE provided is monitored to ensure it is used correctly and maintained in a serviceable condition.
• 2.1.7.    All industrial hygiene and medical recommendations are documented, communicated and stewarded as appropriate.
• 2.1.8.    All personnel are trained on the nature of the health hazard to which they are exposed and the protective mechanisms in place to control that hazard. This includes the correct fitting and use of PPE.
• 2.1.9.    All Medical records are retained and are confidential.

2.2.    Injury and/or Illness Management

• 2.2.1.    All SON VU CO site personnel are trained to the Senior First Aid level.
• 2.2.2.    A minimum of one basic first aid kit is available at the workplace with the contents having regard to the identified hazards in the workplace. The first aid kit is checked and maintained in accordance with a scheduled timeframe.
• 2.2.3.    A system is in place to ensure that all workplace illnesses and injuries are reported and treated, followed up and any trends or patterns are evaluated to assess possible long-term problems.
• 2.2.4.    The involvement of the local community Medical Practitioners, Ambulance Service and Hospitals for the provision of emergency assistance is determined, documented and tested.
• 2.2.5.    A system is in place to co-ordinate the return to work following an injury or illness.
• 2.2.6.    In the case of personnel impairment or disability, their ability to perform their job safely without risk to their health is evaluated and the necessary precautions implemented.
• 2.2.7.    A system is in place to assist personnel who are exposed to critical incidents at work.
• 2.2.8.    Signage is installed in areas of health risk to warn personnel.

2.3.    Monitoring

• 2.3.1.    Situations where personnel health surveillance should occur are identified and systems implemented to conduct this surveillance.
• 2.3.2.    Any personnel involved in the following activities are monitored to ensure that the required suitable PPE is being worn:
  •     Spraying or handling material which creates an airborne hazard and is detrimental to the respiratory system;
  •     Entering an area containing harmful or toxic atmospheric contaminants or where oxygen content is below 21% or above 25% by volume or where either of these conditions could exist.
• 2.3.3.    Where noise emissions are expected to, or do, exceed statutory or recommended levels, a prescribed sound level measurement shall be carried out and appropriate immediate and long-term control measures initiated and monitored.
• 2.3.4.    A scheduled program where appropriate of personnel health hazard monitoring is conducted to measure the exposure of personnel to hazards including:
  •     The exposure of personnel to toxic or hazardous chemicals;
  •     Hearing and eyesight hazards;
  •     Effects of heat and UV; and
  •     Those specified by legislation.
• 2.3.5.    Monitoring records of personnel exposures and job histories are documented and scheduled for reviewed.
• 2.3.6.    When working at Customer site, if required, the higher level of PPE is subject to follow.

1.    PURPOSE

The purpose of this Section is to ensure procedures undertaken by contractors are performed in a healthy, safe and environmentally sound manner and that they comply and are compatible with SON VU CO policies and objectives.

2.    PERFORMANCE MANAGEMENT

2.1.    Contractor Selection

• 2.1.1.    Contractors are selected based upon an assessment of the capabilities to perform the work in a healthy, safe and environmentally sound manner and that they are compatible with SON VU CO’s policies and objectives.
• 2.1.2.    For each contract, the minimum HSE requirements to be met are documented, commensurate with the hazards and risks associated with the service being provided. These requirements include:
  •     Compliance with applicable HSE regulations and SON VU CO standards;
  •     A HSE program and the applicable training and performance monitoring;
  •     A safety management system which is acceptable to and compatible with, the SON VU CO HSEMS;
  •     An acceptable HSE record;
  •     Appropriate resources and competence in the services to be provided; and
  •     The equipment to be used in the service to meet all SON VU CO regulations and standards as well as all required certificates and tests are available and verified.
• 2.1.3.    Before the contract is let, there is an evaluation of the Contractors competence, and their safety performance and programs to ensure compliance with SON VU CO’s contract requirements and applicable HSE legislation.
• 2.1.4.    Contracts are classified into four categories, which indicate the level of HSE risk exposure, and hence the commensurate level of HSE management required. Four categories are defined and responsibility assigned for each classification. The four categories are:
  •     Contractors operating under the SON VU CO HSEMS;
  •     Contractors working to an accepted HSE Management System;
  •     Contracts for service; and
  •     Supply only, where no HSE management system directly interfaces with SON VU CO during delivery of the contractor’s product to SON VU CO.
• 2.1.5.    SON VU CO policy ensures that the Contractor:
  •     Is made aware of the known hazards and risks related to the Contractor’s work;
  •     Is inducted and trained in the emergency procedures applicable to that contractor;
  •     Has safe work practices for Contractor employee access; and
  •     Supplied goods and services are subject to hazard identification and risk assessment prior to use.
• 2.1.6.    The system defines the approval process and levels for final selection of the Contractors.
• 2.1.7.    The Contractor shall ensure that their employees (including their sub-contractors):
  •     Have been trained in the work practices to perform their job or task in a healthy, safe and environmentally responsible manner;
  •     Have been instructed in the hazards and risks associated with their job or task;
  •     Have a documented training record;
  •     Follow the HSE and operational rules of the workplace; and
  •     Notify SON VU CO of any hazards or risks associated with their job or task.
• 2.1.8.    A register is maintained of qualified service providers, and the rationale for their selection. This list is regularly reviewed and updated and readily accessible.
• 2.1.9.    A register is maintained of all service providers that are not qualified to work for SON VU CO, and the rationale behind their exclusion.
• 2.1.10.    For each contract, contact personnel are identified for both SON VU CO and the Contractor.

2.2.    Contractor Compliance

• 2.2.1.    All contractor work shall be performed in compliance with SON VU CO policy, objectives, procedures, practices and HSE requirements. Contractor personnel are included in all aspects of hazard management including:
  •     Induction training and exercises;
  •     HSE meetings;
  •     Toolbox meetings;
  •     Official and unofficial hazard identification meetings;
  •     Permit to work system;
  •     Job safety analysis;
  •     Workplace inspections and audits; and
  •     Planning of hazardous work.
• The involvement of contractors is recorded through the records of hazard management processes such as minutes of HSE meetings, JSA records and Toolbox meeting records.
• 2.2.2.    All incidents involving contractor personnel, whether on the SON VU CO facility are officially reported and records kept by SON VU CO.
• 2.2.3.    All contractors, including those listed on the SON VU CO Approved Suppliers Register, are subject to a periodic assessment. This includes the assessment of their level of skill and HSE performance and compliance with SON VU CO HSE requirements. Procedures addressing non-compliance are in place.
• 2.2.4.    Supply of Services
• 2.2.5.    Procedures are in place that requires the identification and assessment of potential HSE hazards, including public HSE hazards where it is proposed to supply goods or services under contract.
• 2.2.6.    Where SON VU CO is required to provide services, the HSE issues affecting the SON VU CO personnel are identified, assessed and appropriate controls introduced.

1.    PURPOSE

The purpose of this Section is to ensure temporary and/or permanent changes are managed within established procedures and encompass: the organization, procedures, engineering, facilities and materials.

2.    PERFORMANCE MANAGEMENT

2.1.    General

• 2.1.1.    Responsibilities are specified for review and approval of a change.
• 2.1.2.    Levels of authorization are established, commensurate with the change being implemented.
• 2.1.3.    Changes that affect operations governed by Regulations are managed to ensure prior approvals are obtained as required and any documentation changes are appropriately submitted.
• 2.1.4.    The procedures for managing change also address:
  •     Effect of the change on interrelated operations;
  •     Special precautions required to safely implement the change and operate during the implementation;
  •     Verification that the change has been implemented as per the approval prior to implementation; and
  •     The mechanism for how urgent and out of hour’s changes is to be handled.
• 2.1.5.    All involved personnel are informed and trained as required in the change, prior to the change being implemented or the affected process being started up.
• 2.1.6.    For temporary changes, the following shall be included:
  •     A procedure to ensure that the temporary changes are returned to their normal mode within the authorized time period;
  •     Review and re-authorization by senior management in the event the time period requires extending; and
  •     Special precautions required to safely implement the change and to continue operations during the implementation.

2.2.    Organizational

• 2.2.1.    A system is in place to ensure that the necessary levels of individual and collective skills, knowledge and experience are reviewed when personnel changes are made.
• 2.2.2.    All non-engineering changes that may affect HSE shall be reviewed to identify any hazards, which could arise. The approval is based on the risk assessment and other considerations including, economic and strategic implications. The changes to which this process shall apply include:
  •     Non-operating procedures and practices;
  •     Organizational and position descriptions including for contractors;
  •     Delegation of authority; and
  •     Other non-engineering changes with an HSE or significant business implication.
• 2.2.3.    At job changeovers, procedures are in place to ensure the transfer of all job specific knowledge and information.
• 2.2.4.    The Handover procedure ensures that the succeeding incumbent is fully conversant with their facility responsibility and work status, and this is carried out:
  •     For any personnel absence, planned or unplanned;
  •     When personnel return from a work absence;
  •     When personnel commence work in a new position; and
  •     Prior to shift hand-over.
• The Handover procedure shall be documented.

2.3.    Engineering

• 2.3.1.    The scope of changes that could result in exceeding established safe limits and require management authorization, are defined and documented. These may include changes to:
  •     Programmable controls;
  •     Plant and equipment including safety and monitoring equipment;
  •     Hardware and structures;
  •     Process operating procedures; and
  •     Process design.
• 2.3.2.    The change management system shall assure that the following considerations are addressed prior to any change:
  •     Technical basis for the proposed change;
  •     Modifications to procedures;
  •     Changes to control measures;
  •     Necessary time period for the change;
  •     Suitably skilled person to review the change proposal;
  •     Authorization for the proposed change;
  •     Analysis of HSE implications, including maintenance of structural integrity;
  •     Compliance with regulations and SON VU CO standards;
  •     Rationale for the change;
  •     Cost benefit of the change; and
  •     Outcomes from the change, including potential consequences and compensating measures, which must at a minimum, maintain the control of hazards and risks.
• 2.3.3.    All engineering changes and requests are documented by an Engineering Change Request (ECR). The approval process for ECR’s includes consideration of the potential impact on HSE prior to the change being approved. The ECR process applies to both permanent and temporary changes.

1.    PURPOSE

The purpose of this Section is to ensure established emergency plans and procedures are in place and that they provide adequate safety and protection of employees, contractors, community, environment and assets.

2.    PERFORMANCE MANAGEMENT

2.1.    Emergency Response Plans

• 2.1.1.    Emergency response plans are current, are subject to a review schedule and update and are accessible and communicated to all personnel.
• 2.1.2.    Emergency response plans are based upon an assessment of the hazards and risks, and cover:
  •     Hazards of the process, products and materials;
  •     Service risks;
  •     Levels of response;
  •     Response strategies developed for all identified potential emergency scenarios;
  •     Raising the alarm, mustering and accounting for personnel, and notification of the
  •     Emergency;
  •     Emergency response organization, roles and responsibilities of emergency response team
  •     Members and mobilization of emergency resources;
  •     Site specific environmental risks and impact prevention/mitigation measures;
  •     Integration with emergency services, media, government, relatives and the local community;
  •     Reporting, investigation and close out;
  •     Mitigation of the effects of emergencies such that, as far as reasonably practical, risks are minimized to the safety of the SON VU CO workforce, facilities, the public and their property;
  •     Responsibilities and accountabilities; and
  •     Medical assistance, counselling and follow-up actions.
• 2.1.3.    Responsibility is assigned to ensure emergency response plans, procedures and programs are in place and documented.
• 2.1.4.    A Community Affairs plan is established and personnel are trained in interfacing with the media and the public.
• 2.1.5.    The emergency response plans are appropriately linked with those of the community and emergency services and include provision for the sharing of emergency equipment and resources where appropriate.
• 2.1.6.    The risk assessments are regularly reviewed to ensure that the emergency preparedness and management systems are current.

2.2.    Emergency Preparedness

• 2.2.1.    Systems are established to detect emergency situations and trigger the implementation of the appropriate emergency response.
• 2.2.2.    Emergency response groups are formed and trained to address the potential emergencies as per the emergency response plan.
• 2.2.3.    All personnel, contractors and visitors arriving at the SON VU CO site for the first time shall be inducted in the location of alarms, alarm tones, required responses to be taken on hearing the alarm and alarm testing procedures. Evacuation and assembly points are indicated.
• 2.2.4.    Emergency drills and exercises are conducted and ensure that the emergency response plans are regularly practiced, reviewed and updated as required.
• 2.2.5.    Emergency response equipment is provided to support the activities required by the emergency response plans, to combat the potential emergency and are compatible with the external emergency services. The suitability, location and accessibility of the emergency response equipment have been assessed by suitably qualified and skilled persons.
• 2.2.6.    Local community is informed of the actions to be undertaken in an emergency.
• 2.2.7.    All personnel working on or visiting the SON VU CO facility shall be accounted for in emergency situations, in accordance with SON VU CO requirement for all personnel to register their movements through their immediate Supervisor.
• 2.2.8.    All authorized persons entering the SON VU CO facility are required to comply with the SON VU CO ERP requirements with regards to entering and leaving the facility.

2.3.    Emergency Response

• 2.3.1.    An emergency communication system shall be in place for communications to all personnel within the facility and business, to affected organizations and the community and to the applicable emergency services and regulatory authorities.
• 2.3.2.    The emergency communication system is designed to be protected from the effects of any potential emergency and capable of addressing emergency and operational requirements.
• 2.3.3.    Emergencies are followed up with an incident investigation, which seeks to identify the root causes and the hazards, which led to the incident. Restoration is in two stages:
  •     Immediate action to restore operation; and
  •     Longer term action to prevent a recurrence.

1.    PURPOSE

The purpose of this Section is to ensure that events which have resulted in, or could have resulted in, detrimental effects upon the health and safety of personnel, their work environment or which have a significant impact on the business, are monitored and evaluated. This Standard also ensures the reporting procedures, subsequent investigation and analysis of incidents or near miss incidents are also in place.

2.    PERFORMANCE MANAGEMENT

2.1.    Incident Reporting

• 2.1.1.    Minimum acceptable criteria are established that define the incidents and near misses that are required to be reported and the level to which they are reported. These procedures are communicated to all SON VU CO personnel. The reporting criteria covers the following:
  •     Incidents requiring to be reported to the Regulator;
  •     Incidents required to be reported to SON VU CO management as per the policy;
  •     Other HSE incidents identified as unacceptable;
  •     Other incidents affecting operations or the business that are considered significant; and
  •     Near misses which may have threatened to cause any of these occurrences.
• 2.1.2.    A program is in place to report incidents and near misses, as soon as practicable after the incident occurs.
• 2.1.3.    The system of reporting requires the personnel reporting the incident to provide a completed incident report form to their immediate supervisor.
• 2.1.4.    The incident reporting system must be documented and shall include:
  •     Date and location of the incident;
  •     Description of the incident;
  •     Factors contributing to the incident;
  •     Immediate actions put in place;
  •     Apparent severity level of the incident;
  •     Date of the investigation;
  •     Composition of the investigation team;
  •     Follow up actions resulting from the investigation;
  •     Responsibilities for follow up actions;
  •     Completion dates; and
  •     Approvals.
• 2.1.5.    Contractors operating at the facility are required to retain a separate register of all reported incidents and maintain a separate register of all recommended corrective actions detailing persons responsible for such corrective actions, completion dates and current status.

2.2.    Incident Investigation

• 2.2.1.    An incident investigation shall be initiated immediately following an incident and responsibilities are assigned to approve the scope of the investigation.
• 2.2.2.    Personnel involved in investigations are trained in incident investigation techniques.
• 2.2.3.    Incident investigation procedures are developed to ensure that all incidents are investigated thoroughly and recorded to enable the determination of appropriate actions to be implemented to manage or mitigate the hazard or incident. The investigation seeks to establish:
  •     Immediate causes;
  •     Root causes;
  •     Failure in control;
  •     Corrective actions to reduce or eliminate the causes of the incident; and
  •     Personnel responsible to complete the corrective actions.
• 2.2.4.    In the event of a serious injury or incident involving either SON VU CO personnel or contractor personnel, written signed and dated statements shall be recorded. Those injured (if their condition permits) are interviewed regarding specific details leading up to the incident. The responsible manager is immediately informed of such occurrences.
• 2.2.5.    Corrective actions shall be discussed with personnel affected prior to implementation.
• 2.2.6.    Unless further danger exists, any injury incident scene will not be disturbed until all the information has been recorded and the approval given by the applicable authorities.
• 2.2.7.    Responsibilities shall be assigned to review and approve the incident investigation report findings and recommendations.
• 2.2.8.    The system includes the requirement to involve SON VU CO legal assistance in a review of the investigation report.

2.3.    Incident Analysis and Follow up

• 2.3.1.    The final results from the follow up actions are reviewed and assessed for compliance with the intent of the incident investigation recommendations and their effectiveness.
• 2.3.2.    A database containing information from incident and near miss reports (including the root causes and the recommended actions) is maintained current and used in initiating improvements and stewardship.
• 2.3.3.    The lessons learnt from the incidents and near misses are shared among affiliates and Contractors (as appropriate). Lessons from other facilities and organizations are analyzed for incorporation at the applicable sites.

1.    PURPOSE

The purpose of this section is to ensure that the handling procedures for the use and/or disposal of materials, including process materials, products and wastes that are involved with the SON VU CO operations, are carried out in a healthy, safe and environmentally responsible manner.

2.    PERFORMANCE MANAGEMENT

2.1.    Managing Materials

• 2.1.1.    The information on the HSE impact of all materials is considered when the materials are to be handled, used or the disposal method selected.
• 2.1.2.    For all hazardous materials, exposure limits are set and actions identified and implemented to ensure the proper handling, use, storage and disposal of the materials.
• 2.1.3.    Hazardous materials shall not be introduced to the facility unless:
  •     SON VU CO management has approved its use;
  •     Its use, presence or production is essential and there is no alternative product or process
  •     Available which is less hazardous but otherwise equivalent; and
  •     The relevant State and/or National chemicals notification and assessment schemes are applied.
• 2.1.4.    Affected personnel are trained in the handling, use and disposal of all materials.
• 2.1.5.    There are systems to specify requirements for the control of materials subject to deterioration or a ‘use by’ date.
• 2.1.6.    Inventories of hazardous materials kept on site are scheduled for review.
• 2.1.7.    Hazardous materials and waste containers, conduits and receptacles are clearly labelled to indicate the nature of the contents.
• 2.1.8.    Customers and contractors are provided with the HSE information on the materials they handle, use or dispose.
• 2.1.9.    Exposure of personnel to hazardous substances shall be kept to minimum acceptable levels. In all cases, exposure levels shall be below the levels set by regulations and applicable Australian and/or international exposure standards taking due account of all precautionary notes on the application of such standards.
• 2.1.10.    All information regarding safety and health hazards of materials stored at the facility shall be documented. Current MSDS’s are made accessible to all personnel with responsibility assigned for ensuring that this information is kept current.
• 2.1.11.    All products used in the production process shall be identified during all stages of production, delivery and installation where there is the potential for HSE concerns arising out of the use of the product.
• 2.1.12.    Where a product is sold and there is the potential for that product to cause public HSE concerns, there are documented procedures in place to enable the product to be tracked.

2.2.    Emissions and Wastes

• 2.2.1.    Emissions and wastes are identified and key controls established for their management. The effectiveness of these controls are subsequently monitored, measured and reported according to SON VU CO and regulatory requirements. This information is subject to a scheduled review process.
• 2.2.2.    Goals and targets are established and programs put in place and stewarded to reduce emissions and wastes.
• 2.2.3.    Response plans including training and equipment requirements are in place to minimize the impact of any accidental releases of emissions and wastes.
• 2.2.4.    A program is in place to identify and resolve past environmental contamination.
• 2.2.5.    Disposal of waste is in accordance with recommendations of Local Authorities, substance manufacturers and legislative requirements.
• 2.2.6.    Contractors that handle emissions and wastes are assessed to ensure that their methods are in accordance with SON VU CO policy. Objectives, regulatory requirements and the Contractors performance are stewarded prior to awarding the contract.

1.    PURPOSE

The purpose of this Section is to ensure a system is established to monitor and assess operating performance and to ensure that processes and systems adopted are effective in meeting SON VU CO policies, objectives and legislative requirements (refer to Quality management system).

2.    PERFORMANCE MANAGEMENT

2.1.    Performance Monitoring and Review

• 2.1.1.    SON VU CO HSEMS performance and compliance with the applicable regulations and policies is monitored by the collection and analysis of HSE, operational and business data. The outcomes from this process are reviewed, reported and actions recommended.
• 2.1.2.    Scheduled monitoring of the work place and work practices and systems are conducted to ensure the ongoing suitability and effectiveness through the identification of hazards and deficiencies leading to the development of improvement actions.
• 2.1.3.    The performance measures are developed to assess operational efficiency and they cover the most important controllable HSE, operational and business parameters where annual targets or KPI’s are set for each performance measure.
• 2.1.4.    Positive performance indicators are developed and shall be used along with accident frequency data to provide an overview of the effect of the HSEMS on the day-to-day activities at the facility.
• 2.1.5.    Performance reports are produced and distributed within the organization and in the SON VU CO annual report or equivalent.
• 2.1.6.    Accountable SON VU CO management periodically reviews the effectiveness of the HSEMS.

2.2.    Audits (including Assessments and Inspections)

• 2.2.1.    Management shall develop a series of annual operational improvement objectives that are scheduled for assessment.
• 2.2.2.    Documented audit programs and schedules are established, implemented and maintained to verify the effectiveness of the HSEMS for all activities within the SON VU CO facility. The audit programs also ensure compliance with the established performance standards and to identify areas of non-conformance.
• 2.2.3.    Corrective actions are identified and responsibilities assigned to rectify any non-conformances leading to a continuing improvement in the operation’s performance.
• 2.2.4.    Corrective actions are monitored by assigned management and/or personnel to ensure that appropriate responses to documented findings are implemented and that they are evaluated to determine their effectiveness.
• 2.2.5.    An audit program is in place to ensure continuing improvement of HSE standards, it covers:
  •     Area self-management investigations;
  •     In-house audits to assess high-risk and low-risk critical activities;
  •     Operational reviews which involve a physical inspection of all activities to determine the level of compliance with standards set by SON VU CO policies and government legislation; and
  •     Compliance reviews to ensure that all operations undertaken by SON VU CO are compliant with all statutory regulations, government requirements and SON VU CO objectives.
• 2.2.6.    Prescribed audits are scheduled, are conducted on all facility-related activities and focus on the implementation and effectiveness of HSE operational and maintenance activities.
• 2.2.7.    All audits are undertaken by either suitably qualified in-house personnel, or externally qualified personnel, approved by senior SON VU CO management. Where in-house audits are being undertaken, appropriate training is provided to the personnel responsible for the audit.
• 2.2.8.    To ensure that a degree of independence is achieved, audits shall be conducted by personnel not directly involved in the operations.
• 2.2.9.    Prescribed audits are led by experienced Assessors, approved by senior SON VU CO management.
• 2.2.10.    All reviews and audits seek input from personnel required to undertake the tasks being inspected.
• 2.2.11.    Specific checklist(s) are developed for use during the reviews and audits.
• 2.2.12.    Reporting requirements are established and are commensurate with the type of audit being conducted.
• 2.2.13.    Records of HSEMS and HSE reviews and audits are maintained.