Petroleum

Petroleum
Health, Safety, Environment and Community

Controls
Valid until June 2014
BHP Billiton Petroleum HSEC Controls Accountabilities Table
Control
Hazard & Risk Community Crisis & Emergency Management Security Health & Hygiene Aviation Marine Fatal Risk Road Going and Light Vehicles Mobile Equipment Explosives Hazardous Materials Isolation Equipment Safeguarding Working at Height Lifting Operations Dropped Objects Working with Pressure Presence of Hydrogen Sulphide (H2S) Confined Space Entry (CSE) Diving Ground Disturbance & Ground Control Application of Fatal Risk Controls Site Traffic Management Plan Environment HSEC Data Reporting
Control Owner
Safety and Risk Manager Community Manager Asset Protection Manager Asset Protection Manager Occupational Health & Hygiene Manager Principal Aviation Specialist Principal Marine Specialist Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Safety & Risk Manager Environmental Engineering Manager Safety & Risk Manager
Reference #
Element #3 Element # 6 Element #11 Element #11 Element #13 Element #14 Element #14 Element #14 FRC 1 FRC 2 FRC 3 FRC 4 FRC 5 FRC 6 FRC 7 FRC 8 FRC 9 FRC 10 FRC 11 FRC 12 FRC 13 FRC 14 All FRCs FRC 1 and 2 Element #15 Element #16
Revision Number
Revision Date
URL
Comments
Contents
Introduction
Purpose Scope Application Responsibility References BHP Billiton Petroleum HSEC Portal 1 1 1 1 1 1 5 6 7 11 12 13 17 17 18 18 19 19 20 23 23 24 24 25 25 26
Marine Operations Controls

Control 1 Operations Management Control 2 Contracting of Vessels Control 3 Facility Safety Zones Control 4 Personnel Transfer Control 5 Transfer of Supplies Control 6 Off-Take Tanker Operations 39 41 42 43 44 45 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 66 66
Hazard and Risk Management Controls

Control 1 Risk Assessment Control 2 Risk Treatment Control 3 Governance and Compliance
Fatal Risk Controls

Control 1 Road Going and Light Vehicles Control 2 Mobile Equipment Control 3 Explosives Control 4 Hazardous Materials Control 5 Isolation and Permit to Work Control 6 Equipment Safeguarding Control 7 Working at Height Control 8 Lifting Operations Control 9 Dropped Objects Control 10 Working with Pressure Control 11 Presence of Hydrogen Sulphide (H2S) Control 12 Confined Space Entry (CSE) Control 13 Diving Control 14 Ground Disturbance and Ground Control Appendix B: Notes, Application and Inter-Relationship of Fatal Risk Controls Appendix C: Site Traffic Management Plan requirements Appendix D: Transitional Requirements for Existing Light Vehicles
Community Controls
Control 1 Stakeholder Engagement Control 2 Community Development Control 3 Human Rights
Crisis and Emergency Management Controls

Control 1 Risk Assessment Control 2 Emergency Response Structure Control 3 Plans Control 4 Provision of Resources Control 5 Training and Exercises Control 6 Business Continuity Control 7 Review
Security Controls
Control 1 Accountabilities Control 2 Risk Assessment Control 3 Plans Control 4 Use of Public and Private Security Resources Control 5 Firearms and the Use of Force Control 6 Security Training and Awareness Appendix A: Security and Emergency Management Approvals Framework
Environment Controls
Control 1 Land, Marine and Biodiversity Disturbances Control 2 Noise Disturbances Control 3 Hydrocarbon Control 4 Water Sourcing, Use and Discharge Control 5 Air Emissions Control 6 Energy Use and Greenhouse Gas Emissions Control 7 Waste Control 8 Drilling Muds and Drilled Cuttings References 69 70 71 72 73 74 75 76 77 81 82 84
Health and Hygiene Controls

Control 1 Occupational Exposure Control 2 Fit for Work Control 3 Reporting and Management Review Applicability Supplement Associated Documentation 29 29 30 31 31 35
Data Reporting Controls

Control 1 General Requirements Control 2 Reporting Requirements Control 3 Significant Events
Aviation Controls
Control 1 General Requirements
D Health, Safety, Environment and Community Management System Framework
Introduction
Purpose
BHP Billiton Petroleum corporate mandatory HSEC requirements as described in the HSEC related Group Level Documents (GLDs) are met through implementation of the BHP Billiton Petroleum HSEC Management System Framework, associated BHP Billiton Petroleum HSEC Controls and related procedures.
Responsibility
Unless otherwise stated, managers responsible for BHP Billiton Petroleum activities are accountable for the implementation of the performance requirements outlined in this document. Personnel must comply with the letter and spirit of the performance requirements in the BHP Billiton Petroleum HSEC Controls including associated documentation.
Scope
The BHP Billiton Petroleum HSEC Controls cover BHP Billiton Petroleum activities that affect or have the potential to materially affect, beneficially or adversely, the health, safety and security of people, the physical environment and protection of assets.
References
The HSEC Controls document must be used in conjunction with the associated BHP Billiton Petroleum HSEC Controls Compliance Workbook. Each workbook provides additional details associated with each requirement (responsibilities, approvals, endorsements, evidence of compliance, frequency of execution and supporting documentation. BHP Billiton Petroleum HSEC Glossary of Terms BHP Billiton Petroleum HSEC Management System Framework
Application
The BHP Billiton Petroleum HSEC Controls apply to the entire lifecycle of BHP Billiton Petroleum activities, processes and products. Contractors must comply with relevant aspects of the BHP Billiton Petroleum HSEC Controls. Partners and suppliers are encouraged to adopt the intent and nature of the performance requirements in this document. Where there is a conflict between legislation and BHP Billiton Petroleum requirements, the more stringent standard prevails while ensuring legal compliance requirements are met. A BHP Billiton Petroleum variance form must be completed and submitted to BHP Billiton Petroleum HSEC Systems Support where applicable requirements cannot be met and are assessed as a material gap. Where the gap is associated with a Group Level Document (GLD), the purpose of the variance form will be to ensure visibility of the issue at the appropriate level within BHP Billiton Petroleum. For BHP Billiton Petroleum specific requirements, the variance form will be reviewed and addressed by the relevant functional owner.
BHP Billiton Petroleum HSEC Portal

Consistent with the principles of continuous improvement, the BHP Billiton Petroleum HSEC Controls and other related documents will be periodically updated therefore: The BHP Billiton Petroleum HSEC Portal must be used to access the governing current version of this document. HSEC Control References in the electronic copy are italicized and hyperlinked as appropriate within the HSEC Portal.
Controls 1
Hazard and Risk Mangement
BHP Billiton Petroleum Controls
Hazard and Risk Control 1
Risk Assessment
Intent
Identify and assess HSEC Hazards associated with BHP Billiton Petroleum activities and manage HSEC Material Risks
Performance Requirements
1.1 1.2 Identify sources of hazards, possible causes and impacts as a result of the risk. Conduct Process Hazard Analysis (PHA) workshops across all phases of the life cycle of a facility in accordance with the PHA Management procedure to identify HSEC Hazards. Involve appropriate technical and functional representation in the Process Hazard Analysis (PHA) workshops. Conduct Hazard and Operability (HAZOP) studies for all new developments in accordance with the BHP Billiton Petroleum HAZOP procedure. Conduct a revalidation Process Hazard Analysis (PHA) for operating sites in accordance with the frequencies as defined in the PHA Management procedure. Conduct a Risk Analysis to determine severity and likelihood for each hazard event identified utilizing the BHP Billiton Petroleum HSEC Risk Matrix.
1.7
1.8
1.3 1.4
1.9 1.10 1.11
1.5
1.12
1.6
1.13 .
Identify all HSEC Material Risks in accordance with BHP Billiton Petroleum criteria, established by the Risk Management Procedure. Manage actions from Process Hazard Analysis (PHA) workshops to completion in accordance with PHA Management procedure. Document HSEC Material Risks in a controlled Risk Register in accordance with the Risk Management procedure. Communicate HSEC Material Risks to personnel involved in the activities. Develop and make available Bowtie diagrams for all HSEC Material Risks identified in accordance with the Management of Critical Controls procedure. Use Bowtie diagrams to describe credible causes, consequences and Controls and ensure they form part of the Safety Case. Maintain Bowtie diagrams to ensure alignment with current HSEC Material Risk Register.
Controls 5
Risk Treatment
Intent
Identify, establish and evaluate Critical Controls that are required to manage HSEC Material Risks and demonstrate to BHP Billiton Petroleum stakeholders that facilities have been selected, designed, constructed, commissioned and can be operated in a manner such that residual risk levels are ALARP
2.1 Identify Critical Controls for Material HSEC Risk in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure. Identify Critical Equipment, required to satisfy the objective of the Critical Controls, in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure. Develop and maintain a Critical Equipment Register. Develop Performance Standards for each Critical Control (Equipment and Non Equipment) in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure. Manage Critical Controls that do not meet their Performance Standard via the BHP Billiton Petroleum Case to Operate Procedure. Review Performance Standards as per the relevant procedure and update in accordance with the Management of Change Procedure. Verify Critical Control effectiveness through Control Self Assessment in accordance with the Risk Management procedure.
2.8
2.2
2.3 2.4
2.5
2.6
2.7
Develop a Safety Case in accordance with the Development Phase and/or operations lifecycle that includes all HSEC Material Risks, Bowties, Critical Controls, Critical Equipment and Performance Standards and verification procedures to demonstrate how the facility manages risk. 2.9 Review and update Safety Case in accordance with the Safety Case procedure. It shall be reviewed at least every 5 years, per local regulatory requirement or when there are material changes that might change the facility/project risk profile whichever is sooner. 2.10 Develop a Safety Case for Drilling Operations for activities that extend beyond 180 days per year and /or for well campaigns that present high risk e.g., HPHT wells. 2.11 Develop a bridging document to address a combined Operations Safety Case and for the interaction of critical controls when 2 or more facilities interact in combined operations. 2.12 Involve appropriate technical and functional representation endorsed by the HSEC function to review the Safety Case.
6 Health, Safety, Environment and Community
Governance and Compliance

Intent
Performance measurement and verification for BHP Billiton Petroleum activities and sites provides assurance that HSEC Hazard and Risk Management is effective.
3.1 Provide assurance that risks are adequately managed by subjecting the Operations Safety Case and Risk Register to an Annual HSEC Material Risk Review in accordance with the Risk Management procedure and BHP Billiton Petroleum HSEC Assurance procedure. Develop and report on Process Safety Key Performance Indicators (KPIs) as part of the Project or Production Unit annual KPIs.
3.3 3.4
3.5
3.2
Review associated actual or potential significant events when evaluating Critical Control effectiveness. Manage Bowtie and Critical Controls Health checks in accordance with the BHP Billiton Petroleum Management of Critical Controls Procedure. Develop risk-based handover certification to ensure assurance activities are conducted and satisfied prior to start-up or continuation of operations after a major shutdown.
Controls 7
Community
Figure 1 Community Requirements by BHP Billiton Petroleum Project Lifecycle

Pre-Development/ HSEC Screening/ Risk Assessment
HSEC Screening/Risk Assessment Acquire Lease
Exploration and Identification Phase
Development
Selection and Definition Phases Financial Investment Decision Execution Phase
Operations
Stakeholder Identification
Evaluate Risk
Go
Stakeholder Engagement and Documentation
Identify Business Opportunity
Social Baseline Study
Social Impact and Opportunities Assessment
Design Community Development Management Plan
Implement Community Development Programs
Evaluate Effectiveness
HSEC Screening includes sociopolitical and human rights
Stakeholder Engagement Management Plan (if critical)
Commence Field Work
Design Local Procurement Plan
Implement Local Procurement Plan
Evaluate Targets
Complaints and Grievances Mechanism
Obtain Broad-based Community Support
Decision to Proceed to Develop
Implement Initial Community Projects
Stakeholder Analysis
Implement Stakeholder Engagement Management Plan
Initial Community Perception Survey
Annual Review Stakeholder Engagement Management Plan
Community Perception Survey 3-yr.
Human Rights Impact Assessment Maplecroft <6.25
Verify/Validate HRIA
Human Rights Impact Assessment
Verify/Validate HRIA
Three-year HRIA Review
Evaluate Material Risk
Evaluate Material Risk
Yes
Yes
Human Rights Management Plan
Yes
Human Rights Training
Human Rights Management Plan
Yes
Human Rights Training
Annual HRMP Review
Note: Dotted line indicates earlier timing of a requirement based on risk. Refer to Community Controls for details.
Community Control 1
Stakeholder Engagement
Intent
A Stakeholder Engagement Management Plan must be implemented and maintained to support regular and ongoing dialogue with stakeholders who could have an impact on, or be impacted by BHP Billiton Petroleum activities.
The timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1. 1.1 Identify those stakeholders who have an interest in the project or operations and who could influence the outcome of the project or operations. Refer to the Stakeholder Engagement Procedure. 1.2 Prepare a Stakeholder Analysis to understand and consider the concerns, interests and relationships of identified stakeholders. Refer to the Stakeholder Engagement Procedure. 1.3 Implement and document consultation activities specific to each stakeholder. Refer to the Stakeholder Engagement Procedure.
1.4
1.5
1.6
1.7
1.8
Prepare, implement and maintain a Stakeholder Engagement Management Plan. Refer to the Stakeholder Engagement Procedure. Document all stakeholder engagement activities, responses to concerns and complaints, outcomes, agreements and commitments. Refer to the Stakeholder Engagement Procedure. Review and update the Stakeholder Engagement Management Plan annually. Refer to the Stakeholder Engagement Procedure. Conduct a community perception survey to identify priority areas for community development. Refer to the Stakeholder Engagement Procedure. Evaluate progress against the objectives documented in the Stakeholder Engagement Management Plan every 3 years based on a community perception survey that includes indicators reflecting community concerns. Refer to the Stakeholder Engagement Procedure.
Controls 11
Community Control 2
Community Development
Intent
A Community Development Management Plan must be implemented, maintained and reviewed to assist BHP Billiton Petroleum to contribute to the livelihoods of people in host communities and enhance BHP Billiton Petroleums license to operate.
The timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1. 2.1 Complete a social baseline study and social impact and opportunity assessment, and select key quality-of-life indicators. Refer to the Community Development Procedure. 2.2 Develop a community development budget, and design, implement, maintain, and annually review a Community Development Management Plan, according to the Community Development Procedure. 2.3 Identify, implement, and document the initial community development projects that are linked to focus areas, according to the Community Development Procedure. 2.4 Identify, implement, and document Community Development Projects linked to the quality-of-life indicators, according to the Community Development Procedure.
2.5
2.6 2.7
2.8
2.9
Evaluate the effectiveness of the Community Development Management Plan every three years, according to the Community Development Procedure. Design and implement a local procurement plan with targets. Refer to the Community Development Procedure. Complete and authorize the Community Development Project or Donation Anti-Corruption Template for all community development projects, donations, and sponsorships. Refer to the Community Development Project or Donation Anti-Corruption Procedure and the Community Development Project or Donation Anti-Corruption Template. Complete and authorize the BHP Billiton Petroleum Community Development Project Quality Assessment Framework Template for community development projects with a total value over US$1 million. Implement and provide access to the Employee Matched Giving program to all employees, in accordance with protocols defined by Group HSEC.
Community Control 3
Human Rights
Intent
Activities must be undertaken so that peoples human rights are respected and BHP Billiton Petroleums human rights commitments are met.
The timing of the following Performance Requirements is based upon the BHP Billiton Petroleum Project Lifecycle phase of a BHP Billiton Petroleum activity indicated by Figure 1. 3.1 Prepare, verify, validate and annually review a Human Rights Impact Assessment. Refer to Human Rights Management Procedure. 3.2 Prepare a Human Rights Management Plan if the Human Rights Impact Assessment identifies a material risk issue. Refer to the Human Rights Management Procedure. 3.3 Where a Human Rights Management Plan is required, train employees and contractors to facilitate compliance with BHP Billiton Petroleums human rights commitments. Refer to the Human Rights Management Procedure. 3.4 Obtain and document broad based community support prior to seeking Execution approval, and document any opposition to the project. Refer to the Human Rights Management Procedure, and the Stakeholder Engagement Procedure.
3.5
3.6
3.7
Investigate and resolve promptly all breaches to the United Nations Declaration of Human Rights. Refer to the Human Rights Management Procedure. Implement a resettlement program (voluntary or involuntary) for BHP Billiton Petroleum activities that require physical or economic displacement, consistent with the requirements of the IFC Performance Standard 5: Land Acquisition and Involuntary Resettlement, excluding the requirements to obtain Free Prior Informed Consent. Refer to the Human Rights Management Procedure. Develop and implement a complaints and grievances mechanism commensurate with the country risk rating, and document through the BHP Billiton Incident Reporting System. Refer to the Human Rights Management Procedure and the Claims Management Procedure.
Controls 13
Crisis and Emergency Management
Crisis and Emergency Management Control 1
Risk Assessment
Intent
Identify potential incidents that threaten the safety of people, environment, property and reputation.
1.1 Identify credible emergency scenarios based on evaluation of material risks and most likely hazards associated with BHP Billiton Petroleum activity. Engage a cross-functional team inclusive of stakeholders to define: Mitigation activities designed to reduce the impact(s) arising from each identified emergency response scenario.
Preparedness activities associated with organizing and mobilizing essential emergency response resources. Response strategies and actions to be followed during the emergency. Recovery strategies and actions required postemergency for the re-establishment of normal state.
1.2
Emergency Response Structure

Intent
Ensure that an adequate organization is established, that roles and responsibilities are identified, then communicated and understood.
2.1 Put in place an emergency response organization in alignment with BHP Billiton Petroleum CEM procedure as follows: Establish a tiered response structure (FRT/IMT/EMT) to direct, control, coordinate and escalate response and recovery activities. Authorize competent personnel to respond to and manage emergencies as follows: - Confirm the nature and extent of an incident; - Trigger and activate an appropriate emergency response at each tier level, commensurate with severity of the emergency;
- Have plans, processes and procedures for the activation, operation, coordination and communication of the incident response; - Have resources available to support the plans, processes and procedures to manage an incident; and - Communicate with stakeholders. Put in place adequate redundancy of personnel such that successful emergency response is likely, even if key individuals are not able to perform their assigned roles.
Controls 17
Plans
Intent
Ensure that plans identify routine and contingency actions for managing risks and incidents.
3.1 Develop Emergency Response plans that are scaled according to the BHP Billiton Petroleum activities, associated hazards, material risks and applicable regulatory requirements. At a minimum plans must include: Critical information that is organized and prioritized for quick access. Procedures for incident detection, notification, incident severity thresholds at which each response level is mobilized. Procedures to communicate and coordinate with all persons involved in responding to or potentially affected by the emergency. Clear roles and responsibilities of all responders. 3.2
Identification of response organizations and descriptions of command and control structures. Identification, description and methods of notifying and mobilizing predetermined resources, required personnel, equipment, and services. A communications plan to engage stakeholders including coordination with Group Public Affairs, for incidents with a maximum foreseeable loss. Review Emergency Response plans annually, as well as under the following circumstances: Change in nature of activity and associated risks. Change in availability or provision of response resources, services or equipment. Inclusion of lessons identified through training exercises or real events. Change in regulatory or Company requirements.
Provision of Resources
Intent
Identify, allocate and maintain necessary resources.
4.1 Put in place resource management arrangements to enable timely and unimpeded access to identified resources which prevent, mitigate, prepare for, respond to, or recover from identified emergency scenarios; resource management must include the following tasks: Establishing processes for describing, inventorying, requesting, and tracking resources. Activating, dispatching and deactivating these processes prior to and during an emergency. Contingency planning for shortfalls of resources Establishing alarm and warning systems to inform all affected personnel an emergency condition exists and what actions to take. Ensuring access to qualified medical resources.
4.2
4.3
4.4
4.5
Conduct an assessment to identify resource capability shortfalls, constraints and the steps necessary to overcome any shortfalls and constraints. Establish formalized 3rd party contracts and agreements with defined performance standards/criteria for the provision of resources, services or equipment in support of emergency response activities. Define Mutual aid arrangements inclusive of each participants commitment, as well as other agreed responsibilities. Establish and implement Inspection, testing and maintenance procedures for emergency response equipment.
Training and Exercises

Intent
Individuals are skilled in their knowledge and application of plans and that processes and resources are acceptable.
5.1 Train individuals assigned emergency response duties in their roles and responsibilities prior to commencement of duties or actively participating in an actual response. Identify frequency and scope of training through training needs analysis and comply with relevant regulatory requirements. Maintain training records and certification.
5.4 5.5
5.2
5.6
5.3
Develop exercises using realistic scenarios. Events should be based on the relevant material risks. Design exercises to test and evaluate individual essential elements, interrelated elements, or the entire plan(s), procedures, and capabilities. Conduct post exercise and event reviews to assess the achievement of the aims and objectives and provide a written report that includes outcomes and required actions.
Business Continuity
Intent
A plan is established which defines the steps necessary to ensure the continuation of or re-establishment of business activities following an emergency event.
6.1 Develop business continuity plans aligned with the BHP Billiton Petroleum Business Continuity procedure, that are scaled according to the BHP Billiton Petroleum activities, associated hazards, material risks and applicable critical activities. Identify critical activities whose loss as the result of a disruption beyond the emergency response phase that would have the greatest impact in the shortest time and which need to be recovered most rapidly. Identify measures that: Reduce the likelihood of a disruption. Shorten the period of disruption. Limit the impact of a disruption on key products and services.
6.4
Develop business continuity strategies and plan(s) which set out prioritized objectives in terms of: Critical activities to be recovered. Timescales in which they are to be recovered. Resources including external needed for implementing the recovery. Recovery levels needed for each critical activity. The situation in which the plan can be utilized.
6.2
6.3
Controls 19
Review
Intent
Ensure plans are current, people are trained and resources are allocated in a consistent manner.
7.1 Review Emergency Response arrangements including response plans annually as part of the local HSEC assurance review and update plan(s) and procedures as deemed necessary.
Security
Security Control 1
Accountabilities
Intent
Personnel with security management responsibilities or duties are suitably experienced, or trained, to perform the function.
1.1 1.2 Appoint a Security Focal Point (SFP) and register the appointment in a security plan. Execute the SFP responsibilities as defined in the Site Security & Asset Protection Performance procedure.
1.3
Attain the required SFP training and competence as defined in the Site Security & Asset Protection Performance procedure.
Security Control 2
Risk Assessment
Intent
Security risks are identified and mitigations or controls for vulnerabilities are evaluated.
2.1 2.2 2.3 2.4 Conduct an initial Security risk assessment Utilize the Security Threat Management procedure to evaluate security-specific threats Document security risk assessments and associated mitigations. Record material risks in the appropriate risk register.
2.5
2.6 2.7
Update or review the initial Security risk assessment: annually, prior to commencement of any new activity or significant or material change to routine activities, or upon a change in threat or threat level. Brief the relevant Divisional President on all material risks. Assess risks from Explosive Remnants of War where appropriate and in accordance with the Threat Management Plan procedure.
Controls 23
Security Control 3
Plans
Intent
Detailed responsibilities, operating procedures and controls to reduce and mitigate identified vulnerabilities or risks are captured within an approved security plan.
3.1 3.2 Develop a Security Plan in accordance with Site Security & Asset Protection Performance procedure. Review Security Plans as part of the Security Risk Assessment process and update accordingly.
3.3
3.4
Label Security Plans and contingencies as CONFIDENTIAL and share on a need-to-know basis as approved in accordance with Appendix A. Make available for review Security Operating Procedures to all company personnel assigned to the activity.
Security Control 4
Use of Public and Private Security Resources

Intent
Resources engaged to protect Company personnel and properties are effective and operate within a framework that upholds respect for individual rights. Public or Private Security forces shall comply with Voluntary Principles of Security and Human Rights.
4.1 4.2 Review licensing and authority of Private and Public Security Resources to be engaged. Private security resources comply with all relevant Company policies and applicable laws including, without limitation: The US Foreign and Corrupt Practices Act (FCPA) and all other relevant anti-corruption laws. The Voluntary Principles on Security and Human Rights (VPSHR). Written agreement to the International Code of Conduct for Private Security providers.
4.3
Encourage Public Security resources to comply with all relevant Company policies and applicable laws including, without limitation: The US Foreign and Corrupt Practices Act (FCPA) and all other relevant anti-corruption laws. The Voluntary Principles on Security and Human Rights (VPSHR).
4.4
4.5
Receive approval from the Chief Executive BHP Billiton Petroleum prior to engaging any public or private security resource that may not adhere to the VPSHR. The appointed SFP is to ensure compliance to all VPSHR GLD requirements by following the Site Security & Asset Protection Performance procedure.
Security Control 5
Firearms and the Use of Force

Intent
The use of firearms, weapons and the use of force by any security force shall be considered only when all other mitigation options have been exhausted and there remains an intolerable risk of harm or loss of human life due to an adversarial threat.
5.1 Gain approval for the carriage, storage, or use of firearms on BHP Billiton Petroleum business by the Chief Executive BHP Billiton Petroleum. This includes use for both the protection of human life and stewardship requirements such as injured livestock management. This control does not apply to the use of flare guns for emergency purposes. Deploy armed security guards only when warranted by a security risk assessment and approved by the Chief Executive BHP Billiton Petroleum.
5.3
5.4
5.2
Comply with the International Association of Oil & Gas Producers Firearms and Use of Force principles as well as comply with, or meet the intent of, the Voluntary Principles on Security & Human Rights as it relates to the management of firearms, ammunition, and the rules of engagement for firearms use. Brief any responding armed law enforcement or emergency response officials, legally acting within their appropriate jurisdiction and official capacity, of associated hazards of discharging firearms relative to the BHP Billiton Petroleum activity.
Security Control 6
Security Training and Awareness

Intent
All personnel are appropriately aware of security risks and individual responsibilities are understood and individuals with security responsibilities are competent to perform specific security duties.
6.1 Include a description of security risks and procedures during HSEC inductions or orientations and specifically address: any unique or local security risks; an overview of security controls in place; individual responsibilities for preservation of security and incident reporting. Implement a process to support all personnel working at marine facilities or vessels to receive specific maritime security awareness training in alignment with ISPS Code.
6.3
Train personnel with security duties to perform their duties as documented in security plans, standard operating procedures and emergency response plans.
6.2
Controls 25
Appendix A
Security and Emergency Management Approvals Framework1

Recommend Country/PU/Project Security Mgr Country/PU/Project HSE Mgr Division President Head of Gp HSEC Asset Protection Endorse Inform Approve Country/PU/Project Mgr Divisional HSE Mgr CSG President 3
VP HSE
Selection and appointment of Security employees or contractors.
As required by BHP Billiton Petroleum HR Approvals Framework.
Selection and appointment of security consultants or service providers, including training.
Engagement of any security provider not compliant with the Voluntary Principles on Security and Human Rights.
Design or modification of physical and technical site security controls.
PU, Project or Country level security procedures and plans.
PU, Project or Country level journey management procedures.
Safe travel plans for travel in high, or extreme, risk areas without established Production Units or Project Controls.
Security risk assessments, when conducted by an external agency, consultants and non-Asset Protection personnel. Deployment of firearms in support of BHP Billiton Petroleum operations.
1 2 3
These approvals are intended in addition to normal approvals required by the BHP Billiton Petroleum Approvals Framework. Legal endorsement may be required for contracting of specific security services. CSG President approval required for travel to destinations rated as Extreme risk.
Legal 2
Health and Hygiene
Health and Hygiene Control 1
Occupational Exposure
Intent
To identify potential or actual health & hygiene exposures and implement measures to eliminate or minimize the risk of adverse health effects.
1.1 1.2 Complete a Baseline Assessment to establish an Occupational Health & Hygiene Exposure profile. Communicate Baseline Assessment findings to the Senior Manager; relevant Senior Manager direct reports; Central HSEC team. Develop Occupational Health & Hygiene monitoring strategies associated with the Baseline Assessment.
1.4 1.5 1.6 1.7 1.8
1.3
Develop and implement Exposure Control Plan(s) to manage issues highlighted in the Baseline Assessment. Communicate findings and proposed plans to affected personnel. Provide targeted training to affected personnel. Report on progress against the Exposure Control Plan(s). Train persons with responsibilities for managing Occupational Hygiene Exposures for role.
Fit for Work

Intent
To ensure all personnel are present fit-for-work upon employment and while performing duties assigned.
2.1 2.2 Comply with fit for work requirements in accordance with BHP Billiton Petroleum Health and Hygiene procedures. Undertake BHP Billiton Petroleum Medical assessments or equivalent in accordance with BHP Billiton Petroleum Health and Hygiene procedures. Implement a drug and alcohol testing program in accordance with the BHP Billiton Petroleum Drug and Alcohol Procedure. Implement a fatigue management program in accordance with BHP Billiton Petroleum Fatigue Management Procedure.
2.5
2.6 2.7 2.8
2.3
Manage injury and illness cases in accordance with the BHP Billiton Petroleum Injury & Illness Case Management Procedure. Identify resources to implement systems to manage all aspects of Fitness to Work. Require Site Medical Professionals to be approved by the BHP Billiton Petroleum Health & Hygiene Manager. Require third party medical support to be approved by the BHP Billiton Petroleum Health & Hygiene Manager.
2.4
Controls 29
Reporting and Management Review

Intent
To ensure compliance and quality assurance with Company requirements and regulatory agencies.
3.1 3.2 Make available the results of Occupational Exposure monitoring and surveillance to participating individuals. Conduct management reviews of all occupational health and hygiene programs, incidents and opportunities for improvement.
Health and Hygiene Controls
Applicability Supplement
Occupational Health and Hygiene Aspect

Baseline Assessment Exposure Profile Exposure Control Plan Health and Hygiene Exposure Reporting Health Surveillance Reporting Management Review
Office
Applicable1 Applicable
2
Short Term Projects

*Applicable N/A N/A N/A N/A
Long Term Projects

*Applicable *Applicable *Applicable
Production
*Applicable *Applicable *Applicable *Applicable *Applicable
*Applicable
*Applicable
*Applicable
*Applicable
Office
Fitness for Work *Applicable
Short Term Projects

*Applicable
Long Term Projects

*Applicable
Production
*Applicable
Notes
*In accordance with procedure Short Term Projects A project with duration of less than or equal to 6 months. (includes Development & Exploration Projects) Long Term Projects A project with duration of greater than 6 months. (includes Development & Exploration Projects) Production includes World Wide Drilling long term rigs
1 2
Qualitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure) Quantitative assessment (refer to BHP Billiton Petroleum Occupational Exposure Procedure)
Associated Documentation
Medical Assessment Procedure Occupational Exposure Management Procedure (Occupational Hygiene) Injury/Illness Case Management Drug and Alcohol Ergonomics Fatigue Management Hearing Conservation Respiratory Protection Drug and Alcohol Procedure for Workers Regulated by the DOT Travel Medical Kit Use and Contents First Aid and Medical Equipment Pre-requisites for Site Medical Professionals Medical Protocols for Site Medical Professionals Assessment for Determination of Occupational Health Support Bloodborne Pathogens Questionnaire Actions by Sites with a Site Medical Professional Actions by Sites without a Site Medical Professional Audiometric Testing Process with Work-Relatedness Determination Process Health & Hygiene Control Compliance Assessment Workbook
Controls 31
Aviation
Aviation Control 1
General Requirements
Intent
To manage aviation activities in order to identify, assess and eliminate or minimize aviation related risk.
Implement the following for BHP Billiton Petroleum activity: 1.1 Use aircraft operators approved by Head of Group HSEC and the BHP Billiton Petroleum Principal Aviation Specialist (no deviation allowed). 1.2 Conduct aircraft operations in accordance with the BHP Billiton Petroleum Aircraft Charter Requirements which includes compliance with the Flight Safety Foundation Basic Aviation Risk Standard (BARS). 1.3 Have in place a written agreement (contract) with the charter operator that includes the BHP Billiton Petroleum Aircraft Charter Requirements and the BARS.
1.4 1.5
1.6
1.7
Require aircraft with two turbine engines and operated by two qualified pilots for carrying of passengers. Manage BHP Billiton Petroleum aviation activities in accordance with the BHP Billiton Petroleum Aviation Management Procedure. Engage the BHP Billiton Petroleum Principal Aviation Specialist prior to the start of any new operation or if there are significant changes to existing operations. Conduct Aviation Self Assessments annually.
Controls 35
Marine Operations
Marine Control 1
Operations Management
Intent
Marine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks
Documentation
1.1 Implement documentation for the management of marine operations commensurate with activities and associated risk. The documentation must cover: Compliance with the requirements in this Control and local marine operations regulations (e.g., MOM for USCG, Safety Case for NOPSA). Conformance to the Marine Operations Framework Process. Conformance to the requirements of the BHP Billiton Petroleum Marine Operations Documentation Procedure. Vessel specific types and operational work scope. Roles, responsibilities and training requirements for key marine operations personnel. Site and/or field data required to support the execution of the BHP Billiton Petroleum marine operations. Process for conducting risk assessments requirements outlined in the Marine Operations Control document. Emergency response plans. Identified critical controls and established performance standards. Processes for testing critical controls associated with emergency response procedures prior to commencement of activities and periodically thereafter against a schedule of drills. Suitable procedures for storm avoidance and/or emergency down-manning. Berthing and Terminal Handbook for off take operations (see Marine Operations Control 6.4).
Marine Operations Risk Assessment

1.2 Evaluate marine operations HSEC risks in accordance with the BHP Billiton Petroleum Hazard and Risk Management Controls for: Use of a new build vessel or a vessel under construction prior to engagement. Use of a vessel undergoing modification, or requiring modification or conversion prior to commencement of the modification works. Offshore and onshore personnel transfers. Changes to a routine marine operation. Changes to regulatory or other requirements. Changes to environmental and/or operational conditions. Engage responsible managers and other relevant personnel to participate in Marine Operations risk assessments. Obtain Principal Marine Specialist endorsement where Marine Operations risk assessments identify material risks. Implement an emergency response plan for management of Marine Operations. The plan must take into account: The roles and responsibilities of emergency response personnel from BHP Billiton Petroleum and third party marine contractors such as vessels operators or off-take tanker operators. Documented lines of communications between BHP Billiton Petroleum and relevant marine third parties. Oil spill response plans based on nature of the product, likely dispersion and available response resources. Oil spill response plans must include coordination with BHP Billiton Petroleum Marketing for transport of petroleum products. Local emergency response capabilities. Methods for recovering people falling overboard and contingency plans for recovery of people at imminent significant risk during personnel offshore and onshore personnel transfer. Hazards associated with the surrounding environment.
1.3 1.4
Emergency Response Plans

1.5
Controls 39
Marine Control 1
Operations Management (continued)

Intent
Marine operations must be conducted in accordance with documented procedures implemented to manage marine operations risks.
1.6
Exercise the Emergency Response plan(s) annually and if practicable within 30 days of a new operations start. Tests and exercises should be designed to include: Worst case scenarios covering weather, hours of darkness and availability of response resources. Effectiveness of bridging documentation between the third party marine contractors, operators, other emergency response resources (e.g., oil spill resources) and BHP Billiton Petroleum.
1.9
Review Marine Operations documentation including outcomes of the risk assessment annually. The review must involve personnel from affected functions and the Principal Marine Specialist. The review must consider as a minimum the following: Changes in operational scope Procedural changes Changes in regulatory requirement
Communication
1.7 Communicate relevant Marine Operations documentation including the outcomes of the risk assessment to stakeholders, including affected employees and contractors. Update Marine Operations documentation including the outcomes of the risk assessment to reflect temporary changes to any critical controls or when there are events such as brownfield projects, seismic campaigns and dive support vessel activities.
Variances
1.10 Obtain an approved BHP Billiton Petroleum HSEC Variance Form in circumstances where the requirements of this Controls document cannot be met prior to commencing Marine Operations activity. Variances to this procedure must be approved by: Principal Marine Specialist Contract Line Manager Project Manager For Variance Requests where the Functional Specialist has assessed the consequence as an actual or potential significant event, additional approval is required from: Vice President HSEC
Review
1.8
Marine Control 2
Contracting of Vessels
Intent
Marine vessels and marine operations suppliers are audited and verified as qualified to meet the requirements of the Marine Operations Controls prior to use.
Selection, Approval and Engagement of Marine Operations Suppliers
2.1 Obtain the endorsement from the Principal Marine Specialist regarding the use of marine vessels and marine operations contractors to ensure the appropriate specification, terms and conditions and written agreements are applied as follows: Tender process Contract award 2.2 Changes to existing contracts Include a copy of the Marine Operations Controls and the BHP Billiton Petroleum Marine Audit Procedure in Tender documentation relating to marine operations contracts. Obtain approval from the Principal Marine Specialist for the use of all contracted marine vessels prior to engagement. Audit all marine vessels prior to contract award according to the requirements of the BHP Billiton Petroleum Marine Audit Procedure. Complete all high level and HSEC critical audit findings, as defined in the BHP Billiton Petroleum Marine Audit Procedure, prior to contract execution (e.g., commencement of field activities or construction activities). Variation from this requirement must be endorsed by the Principal Marine Specialist or delegate. Obtain endorsement from the Principal Marine Specialist for the closure of high level and HSEC critical marine audit findings. Obtain endorsement from the Principal Marine Specialist for the proposed modifications to marine vessels; modifications to critical equipment must be approved by the Divisional President. Exempt vessels that have been independently audited within the last 12 months from a BHP Billiton Petroleum audit subject to a review of the findings and status of the associated actions by the Principal Marine Specialist.
New Build Vessels and Vessel Modifications

2.9 Subject new build dynamically positioned vessels and existing vessels with modified1 DP systems to a Failure Mode and Effects Analysis (FMEA) together with appropriate proving trials; the scope of sea trials and the FMEA must be endorsed by the Principal Marine Specialist. 2.10 Subject new build vessels and vessels undergoing modifications to the propulsion, steering or hull dynamics to appropriate sea trials; the scope of sea trials and the FMEA must be endorsed by the Principal Marine Specialist.
Bridging Documentation
2.11 Prepare bridging documentation in accordance with Element 10 of the BHP Billiton Petroleum HSEC Management System Framework. 2.12 Address in the bridging documentation differences and interface processes between BHP Billiton Petroleum and the marine contractor, including: Communication protocols that cover: - Normal activities - SIMOPS - Incident reporting Roles and responsibilities. Coordination of emergency response plan. 2.13 Communicate the bridging documentation to all affected personnel.
2.3 2.4
2.5
2.6
Marine Operations
2.14 Comply with the Marine Operations Framework Process when contracting vessels.
2.7
2.8
A modification means any substantial changes that would require Classification Society approval.
Controls 41
Marine Control 3
Facility Safety Zones

Intent
Marine safety zones are established and managed at BHP Billiton Petroleum and contracted third party facilities (including MODUs).
Establishment of Safety Zones
3.1 Establish and maintain a Facility Safety Zone for Offshore facilities as follows: A minimum distance of 500m or as required by regulations. Define provisions for monitoring the safety zone. Define activities permitted within the safety zone. Define critical controls to manage activities in the safety zone including the Facility Safety Zone Check Sheet. Define controls for SIMOPs in the safety zone. Communicate information concerning the safety zone to relevant stakeholders, including affected employees, contractors and contractor vessels.
Marine Operations within Safety Zone

3.2 Complete Part A of the Facility Safety Zone Check Sheet and obtain approval from the Facility OIM prior to entering the safety zone. Complete Part B and Part C of the Facility Safety Zone Check Sheet and obtain approval from the Facility OIM prior to the following respective phases: Commencement of work within the safety zone (Part B). Departure from the Facility Safety zone (Part C). Keep the Facility Safety Zone clear except for vessel operations and activities approved by the Facility OIM. Require vessels to keep clear or to depart the Facility Safety Zone when unable to maintain position or are experiencing degradation of station keeping capability. Establish Facility Safety Zones for third party contracted operations such as drill rigs, heavy lift vessels or flotels in accordance with this control and document relevant aspects in the associated bridging documentation.
3.3
3.4 3.5
Third Party Facilities

3.6
Marine Control 4
Personnel Transfer
Intent
Personnel transfer risks are controlled to ensure the safe transfer of personnel.
Offshore Personnel Transfers
4.1 Conduct a risk assessment prior to initial commencement of offshore personnel transfer activities, to identify the most appropriate means of transfer and relevant controls. Personnel transfer methods include: By helicopter Basket transfers Boat to Boat Transfer Davit to Davit Transfer Swing Rope 4.2 Temporary bridges Consider helicopters as the preferred primary means of personnel transfer to vessels and facilities with a certified helideck. All helicopter operations must meet the requirements of the Aviation Operations Controls. Prohibit the use of collapsible personnel transfer baskets (e.g., Billy Pugh X-800 series nets or similar) must not be used. Use only rigid personnel transfer baskets (e.g., Billy Pugh X-904 and Reflex Marine FROG) or offshore personnel transfers. Conduct marine personnel transfers under a lift plan in accordance with the BHP Billiton Petroleum Lifting Equipment Control and Operations Procedure. Personnel basket transfers must also comply with the BHP Billiton Petroleum Personnel Transfer and Man-Riding Procedure. Prohibit personnel basket transfers during the hours of darkness with the exception of emergency situations. Assign a designated person to supervise the transfer operation at each of the landing zones. Subject all lifting equipment utilized in basket transfer operations to a visual inspection by a competent person such as a certified rigger prior to use.
Offshore Temporary Bridge

4.9 Inspect and certify fit for purpose all temporary bridges, landing platforms and securing arrangements. 4.10 Clearly mark and keep free of obstructions access and egress to temporary bridges.
Dockside
4.11 Require use of a gangway or accommodation ladder for all BHP Billiton Petroleum owned or contracted vessels alongside docks. 4.12 Install gangways and ladders in accordance with the manufacturers design and operating requirements. 4.13 Use an approved safety net as a supplement for gangways and accommodation ladders. 4.14 Provide safe means of access for personnel transfer between vessels rafted alongside each other. 4.15 Require the use of a designated person supervising transfer operations between vessels rafted alongside each other. 4.16 Conduct a risk assessment to determine the requirements for additional means of access/egress for vessels/facilities in shipyards. (e.g., two gangways).
4.3
4.4
Familiarization and Orientation

4.17 Brief personnel undertaking offshore marine transfers prior to commencing the initial transfer and then at ongoing intervals, the frequency of which is determined based on: The assessed risk and nature of the transfer method. Applicable regulatory requirements. Helicopter transfers require safety briefing prior to each flight, as per the BHP Billiton Petroleum Aviation Operations Controls. 4.18 Include the following in the user briefing: An overview of the transfer method type Hazards and risk management controls Emergency procedures Communication protocols (if required)
4.5
4.6 4.7 4.8
Controls 43
Marine Control 5
Transfer of Supplies
Intent
Safe and environmentally responsible transfer of supplies (excluding petroleum products such as crude) to and from BHP Billiton Petroleum facilities and/or to and from contracted third party vessels.
Cargo transferred by Crane
5.1 Manage crane cargo transfers in accordance with the BHP Billiton Petroleum Lifting Equipment Control and Operations Procedure. Comply with the Marine Containment Audit Check Sheet when vessels are engaged in bulk transfer activities. Manage bulk transfer activities under a permit-to-work. Implement a process to support using dedicated bulk transfer hoses for the transfer of a single substance type only (e.g., diesel, potable water, brine). Bulk transfer hoses must not be used for the transfer of other materials. Maintain direct line of sight during cargo transfer activities between the vessels master and the bulk hose(s). Use bulk transfer hoses which have the capacity to remain afloat at all times. Where the inherent buoyancy of the hose is insufficient to support a particular product additional flotation devices must be provided. Provide adequate illumination where bulk cargo transfers take place during hours of darkness. All hoses and the support vessel must be illuminated prior to, and throughout the transfer operation. Hoses should be fitted with retro-reflective material when illumination cannot be consistently maintained.
5.8
Liquid Bulk Transfer

5.2 5.3 5.4
Use dry break couplings on hoses used for bulk transfer of petroleum, petroleum based products, and brines (for example Avery Hardoll or TODO couplings). Additionally, there must be a weak link breakaway coupling (for example a KLAW coupling) within the hose string. 5.9 Provide vessel Masters with a completed Dangerous Goods Declaration and MSDS (material safety data sheet) prior to commencement of loading or back-loading dangerous goods. 5.10 Conduct a risk assessment prior to back-loading contaminated supplies onto a vessel for transport onshore. 5.11 Obtain approval from the vessel master and the shore base manager prior to back-loading contaminated supplies onto a vessel for transport onshore.
5.5 5.6
Project Execution Plans

5.12 Conduct a risk assessment as part of the Project Execution Plan for project related transfers, (e.g., pipe bundles, sub sea lifts and heavy lifts).
5.7
Marine Control 6
Off-Take Tanker Operations

Intent
Tanker operations for petroleum products (including crude, condensate, LPG and LNG) to and/or from BHP Billiton Petroleum facilities are conducted using safe and environmentally responsible methods.
Tanker Vetting & Inspection
6.1 6.2 Implement a formal Off-take tanker vetting arrangement using an approved marine tanker vetting company. Audit the approved marine tanker vetting company on an annual basis to ensure compliance with industry vetting standards. Use tankers for the off-take of petroleum products which have undergone a formal vetting and inspection process in accordance with OCIMF and meet the BHP Billiton Petroleum Vetting and Operating Standards. Develop and maintain a Berthing and Terminal Handbook in accordance with the Marine Operations Document Procedure for the management of tanker off-take activities. Include the following in the Berthing and Terminal Handbook: Terminal/location details Communications plan (including applicable VHF channels) A site specific lifting vessel questionnaire Relevant regulatory requirements Availability of bunkers, potable water and stores Any restrictions on crew transfers (except in case of emergency) Roles, responsibilities and training requirements for personnel associated with critical controls Operating limits/requirements at the facility/berth (e.g., max deadweight tonnage and displacement, vapor recovery, ballast) 6.8
Environmental limitations Engine and steering gear tests required prior to the commencement of approach Pilotage and pilot boarding controls Insurance requirements (Protection & Indemnity) Mooring procedures including inspection requirements prior to mooring Pollution prevention and preparedness controls including coordinated emergency response plans Hose connection and disconnection, including emergency disconnect procedures Cargo operations Where the off-take tanker requires assistance by a vessel on static tow during the off-take, a procedure is required for the static tow Communicate relevant aspects of the Berthing & Terminal Handbook to stakeholders including Joint Venture Partners, customers and vessel owner/operators. Test critical controls associated with emergency response procedures prior to commencement of off-take activities and periodically thereafter against a schedule of drills. Assess management of off-take arrangements and any other Terminal Controls against requirements of the BHP Billiton Petroleum Marine Operations Off-Take Tanker Controls. Engage BHP Billiton Petroleum Principal Marine Specialist where a material risk has been identified.
6.3
Facility/Tanker Operations
6.4
6.5
6.6
6.7
Joint Interest Unit Operations
6.9
Controls 45
Fatal Risk
Fatal Risk Control 1
Road Going and Light Vehicles

Intent
Select, equip, operate and maintain Road Going & Light Vehicles to protect personnel (including pedestrians) from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant For new acquisitions of Road Going and Light Vehicles
1.1 Acquire new BHP Billiton owned or leased light vehicles which have a 5 Star NCAP (USA- NHTSA or IIHS) safety rating. This includes the safety features referenced in Appendix B. See Appendix B for NCAP, NHTSA and IIHS details. Implement a process to support all BHP Billiton owned or leased light vehicles having a 5 Star NCAP or equivalent safety rating by 1st January 2016. In the intervening period, existing vehicles must have the safety features referenced in Appendix D. Fit company owned or leased vehicles being used at site or on direct company business with support equipment as defined by location specific risk assessment (this does not apply to personal vehicles used temporarily on business travel). See Appendix B for examples of support equipment.
Procedures Light vehicle management process.

1.5 Inspect and maintain vehicles as follows: Implement a formal inspection & preventative maintenance system in keeping with manufacturer guidance. Identify and manage high-risk road journeys. Implement emergency response arrangements to mitigate consequences of accidents or break down risk. Comply with BHP Billiton Petroleum Management of Change (MoC) Process with regard to vehicle modifications (company owned & leased vehicles only). Prohibit installation of aftermarket equipment to 5 Star NCAP vehicles (other than special purpose light vehicles such as ambulances) except where necessary to meet the requirements of visibility and communications equipment. 1.6 Comply with Traffic Management Plan requirement for a minimum safe distance to be maintained between light vehicles and mobile equipment when light vehicles are used within a facility. Notes: See Appendix B for supplementary information regarding Road Going and Light Vehicles.
Existing Road Going and Light Vehicle fleet

1.2
Support Equipment
1.3
People Competence Management

1.4 Use and manage competent drivers (employees and contractors) as follows: Operate vehicles with certified, licensed drivers. Comply with local regulatory certification requirements. Comply with company defined requirements inclusive of training on defensive driving. Implement a process for identifying and managing at-risk driving behaviours. Prohibit the use of mobile phones by drivers, including hands-free applications, unless the vehicle is stopped at a safe location.
Controls 49
Mobile Equipment
Intent
Select, equip, operate and maintain Mobile Equipment to protect the workforce and the public (including pedestrians) from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Safety Features
2.1 Select mobile equipment appropriate for the function and cargo to be carried or task to be performed. This includes the safety features referenced in Appendix B. Fit mobile equipment with support equipment as defined by risk assessment. See Appendix B for examples of support equipment. Provide safe access and egress, including: Emergency egress, from mobile equipment. Safe systems of work for operation and maintenance of components where there is a potential to fall two or more meters, or where a fall could result in a significant incident.
Procedures Mobile Equipment Management Process

2.6 Implement a defined process for management of mobile equipment which includes the following: A documented formal inspection & preventative maintenance system for mobile equipment and registered heavy vehicles; inclusive of checks required prior to operation and appropriate action to be taken if defects are identified. Define requirements for the isolation of mobile equipment in line with the BHP Billiton Petroleum Fatal Risk Control - Isolation and Permit to Work. Require compliance with BHP Billiton Petroleum Management of Change (MoC) Process with regard to vehicle modifications (company owned & leased vehicles only). Develop a process for management of traffic which includes: Use of an authorized traffic management plan (see Appendix C). A process to identify and manage high-risk road journeys. Emergency response arrangements to mitigate consequences of accidents or break down risk.
Support Equipment
2.2
Access and Egress

2.3
2.7
Equipment Management Risk Mitigation

2.4 Manage equipment operation and maintenance to: Prevent uncontrolled movement of vehicles and mobile equipment during operation and repairs. Mitigate risks from towing and recovering mobile equipment, loading and unloading of cargo to prevent dropped objects, spillage or un-planned movement of loads.

2.5 Use and manage competent people: Operate mobile equipment using certified, competent drivers. This includes local regulatory and company defined requirements. Identify and manage at-risk driving behaviours. Prohibit the use of mobile phones by drivers, including hands-free applications, unless the vehicle is stopped at a safe location.
Explosives
Intent
The transport, storage and usage of explosives and initiating components must only be performed by trained, competent and authorised employees and contractors in strictly managed and controlled environments for the security of explosive materials and protection of personnel.
Plant Explosives Register
3.1 Define and document in a register the approved types of explosives to be used for supporting BHP Billiton Petroleum activities.
Process for control access to areas of blasting activity, including clearance zones for potentially affected areas. Process for mitigating the risks of equipment operating in the vicinity of loaded holes or explosives remnants. Process for management of simultaneous operations use of explosives is involved. Emergency Response arrangements when explosives are involved. Process for managing the risk of misfires and the destruction of old explosives. Process for identifying and managing the risks of blasting in hot or reactive ground. See BHP Billiton Glossary of Terms. Supplementary Requirements Comply with all applicable local laws and regulations controlling use of explosives. Comply with manufacturers, regulatory and BHP Billiton Petroleum requirements as it relates to the packing of explosives, inclusive of secondary boxes. Comply with manufacturers, regulatory and BHP Billiton Petroleum requirements as it relates to support documentation for explosives. Notes: See Appendix B for supplementary information regarding Explosives.

3.2 Engage third party specialists in the management and use of explosives who are suitably qualified as per manufacturers, regulatory and BHP Billiton Petroleum requirements. Educate impacted personnel about access control to support effective management of blasting activity.
3.3
3.5
Procedures Explosives Management Process

3.4 Develop and implement an Explosives Management Procedure which includes the following: Defined processes for management of all stages of operations involving the use, transportation, storage, handling and disposal of explosives. Defined training and competency requirements for transport, storage, handling and usage of explosives and initiating components.
Controls 51
Hazardous Materials
Intent
Process, store, handle, produce, transport, recycle and dispose of hazardous materials to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Hazardous Material Risk Mitigation
4.1 Implement the following arrangements: Locate vessels, containers, bulk stores and process areas containing hazardous materials within areas of adequate design and size to safely contain spills and allow for effective response to spills. Identify vessels, containers or pipes containing hazardous materials by appropriate signage or labels and, where relevant, clearly indicate the direction of flow. Equipment associated with hazardous materials must fail to a safe condition in the event of interruption to electric, hydraulic or pneumatic power supply. Segregate hazardous materials from incompatible materials. Install detectors/monitoring appropriate to the hazard where there is the potential for exposure to harmful levels of flammable or toxic materials. Identify and make available Emergency Response equipment associated with Hazardous Materials operations. Maintain copies of all relevant design input and output records including those from risk assessments throughout the life of the plant. Access control appropriate to the identified risk for the process, storage and handling areas of hazardous materials.

4.3 Training, Access and Monitoring Provide personnel with information and training on the nature of the hazards to which they may be exposed and the means of assessing and controlling their exposure. Educate personnel about the importance of adhering to access control requirements. Assess and monitor health of personnel involved in hazardous materials management activities.
Procedures Hazardous Materials Management

4.4 Conduct an initial risk assessment as follows: Conduct a basis of design process hazard analysis (PHA) for new, modified or temporary processes which transports, produces, stores, uses or disposes of hazardous materials. Update As-built design drawings based on findings from PHA. Manage Hazardous Materials as follows: Complete a PHA and define required controls before any new hazardous materials are first used. Maintain a site register of hazardous materials. Maintain Material Safety Data Sheets (MSDS) for hazardous materials and make them accessible for involved personnel. Implement an appropriate maintenance system to support the safe operation of equipment involved in processing hazardous materials. Make available, relevant procedures, associated documentation and records for the management of Hazardous Materials. Address identified risk from Hazardous Materials in the site Emergency Response Plan.
4.5
Management of Temporary Powered Equipment

4.2 Implement the following arrangements for the use of Temporary Powered Equipment: Site Temporary Powered Equipment in an appropriate zone that conforms with regulatory and BHP Billiton Petroleum requirements to minimize potential negative interaction with hazardous materials. Equip Temporary Powered Equipment with appropriate protective devices for use in those defined zones which include automatic shutdown devices, over-speed protection, spark arrestors, protected exhaust manifolds, non-flammable fuel lines, pneumatic starter motors.
Isolation and Permit to Work

Intent
Plan and manage phases of work, tasks, locations, machinery, vehicles and mobile equipment requiring a permit-to-work, or isolation of energy sources to safely perform work (including de-energisation of stored energy) to protect personnel from harm.
Plant Purchasing and Design
5.1 Purchase equipment which meet the requirements of this control (this includes hired and contracted temporary equipment) Identify any points of isolation. Provide personnel performing the work with unique, secure, control of the points of isolation prior to commencing work.
Safe management of breaking of containment. Permit to Work management. Defined controls which apply to personnel accessing machinery that may start and stop automatically or by instruction from a remote location. Control and approval of software overrides, hard-wire bridging or interlock bypassing. Control of isolations and permits-to-work which span one or more shift handovers. Definition of how a competent person will prove safe isolation is achieved before commencing work. Determination and description of actions required if there is any doubt safe isolation was achieved. Management of permits-to-work and isolations for interacting with simultaneous activities. Work authorization by a responsible person. Verification that all personnel undertaking work requiring a permit understand the hazards being controlled by the permit, the permit conditions to be met, isolation standards to be achieved and the control of simultaneous operations (SIMOPS) activities. Authorization of changes which may affect the scope of the permit-to-work and/or the isolation standard(s) required, including a re-assessment of the hazards, potential impact on other operations, changes to planned tasks and the action to be taken by the permit-holder in response to an emergency. Verification that isolated equipment/plant is returned to a safe operating condition before equipment/plant is brought back into service. Notes: See Appendix B for supplementary information regarding Isolation and Permit to Work.
5.2 5.3
People Use and Manage Competent People

5.4 Authorization, Training, Accountabilities Specify who can authorize the issue of a permit-to-work. Establish the training and competency requirements for permit issuers, permit holders and persons performing isolations inclusive of lock-out/tag-out. Define the responsibilities and accountabilities of the permit issuer, individual permit holders and persons performing isolations.
Procedures Isolations and Permit to Work (PTW) Management

5.5 Implement an Isolations and PTW procedure(s) which include the following processes: Identify and document all sources of stored energy which could impact the planned activity. Identify and document the hazards. Identify, document and implement appropriate prevention and mitigation controls to manage the hazards associated with the planned activity. Identify and document isolation points. Safe management of identified isolations.
Controls 53
Equipment Safeguarding
Intent
Manage the interaction between personnel and moving parts of plant and equipment to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Design, Modifications and Controls
6.1 Design plant and equipment as follows: Eliminate the need for guarding where practicable in new, temporary or modified plant and equipment. All energy sources must be considered. Safeguarding must be in place where other potential mitigation measures do not adequately protect personnel. Design and construct plant and equipment safeguards to comply with applicable law, standards, codes of practice and relevant recognized industry practices and considering maintainability and operability. Install fail-to-safe switches or devices on all manually operated rotating plant, rotating equipment and power hand tools (e.g., saws, lathes, drill presses, etc.). Retain and control all documentation related to the risk-based process for the selection of safeguarding requirements.
Procedure Equipment Safeguarding Management Process

6.3 Implement the following via procedure: Do not modify or alter guarding except through the application of the BHP Billiton Petroleum Management of Change (MoC) process. Retain and control all documentation related to the risk-based process for the modification of safeguarding requirements. Use the BHP Billiton Petroleum Management of Change (MoC) process to ensure the integrity of safeguarding is addressed when change occurs. Conduct a Process Hazard Analysis (PHA) to identify where safeguarding and interlocks are required on plant and equipment. Implement a formal inspection and maintenance system to ensure the integrity of plant and equipment safeguarding. Remove guards for maintenance and repair only after plant and equipment has been isolated, and verified as isolated (proved isolated) in line with the BHP Billiton Petroleum Fatal Risk Control - Isolation and Permit to Work. Where the temporary removal of safeguards is necessary on operating plant and equipment, for the purposes of fault finding, testing and commissioning, a PHA must be conducted. Guards must be re-instated prior to plant and equipment being put back into operation.
People Separate People from Moving Parts

6.2 Control and monitor access to plant and equipment where safeguarding and interlock systems are assessed as insufficient to protect people.
Working at Height
Intent
Manage Work at height activities where there is a potential to fall two meters or more, where a fall could result in a significant incident, or where there is the danger of dropped objects from the work being performed.
Plant Design and Controls
7.1 Design new plant and equipment and plan tasks to minimize the need to work at height where a fall could result in a significant incident, or where there is the danger of dropped objects from the work being performed. Provide a secure working area of suitable design and strength where work at height is unavoidable. This working area must include: Flooring securely fastened in place so it cannot be accidentally dislodged. Mesh, railings or solid barriers to prevent a person falling. Toe-boards or similar means to prevent tools and materials falling off the edge of the platform. Provide a fall arrest or fall restraint system if a fixed ladder is used and a work at height risk exists. Require fall arrest and fall restraint systems to: Have lanyards and snap-hooks with a secondary locking mechanism. Be used in a manner which ensures the user is able to achieve 100% tie-off 100% of the time. Incorporate a shock absorber when using a fall arrest system. Protect personnel from objects dropped or dislodged by personnel working at height by using barricades, warning signs and tool lanyards.
Procedure Work at Height Management Process.

7.9 7.10 7.11 Prohibit the use of portable ladders unless provision of a secure working area is not reasonably practicable. Prohibit the use of portable ladders for tasks at heights exceeding 9 meters. Require personnel to use a fall arrest or fall restraint system where provision of a secure working area is not reasonably practicable. The system must incorporate a full body harness attached to anchor points and or safety lines designed to withstand the maximum dynamic load from all persons attached to the anchor point and/or safety line. Require personnel working in Mobile Elevated Work Platforms (includes cherry pickers, scissor lifts and vehicle-mounted booms) or suspended work baskets to wear a fall restraint system attached to an anchor point in the basket, which is designed to withstand the maximum dynamic load from all persons attached. Inspect work at height equipment prior to use and clearly show compliance with periodic inspection with marks or tags. Prohibit personnel from working alone when using a fall arrest system. Develop a plan for immediate response to a person suspended in a harness within a time to prevent suspension trauma.
7.2
7.12
7.3 7.4
7.13
7.14 7.15
7.5

7.6 7.7 7.8 Engage third parties who are suitably qualified to execute specialist Working at Height activity. Educate people about their required role to support effective management of Work at Height activity. Personnel who work at height must have no Fit to Work at Height restriction.
Controls 55
Lifting Operations
Intent
Manage lifting operations to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Positioning, Illumination and Protection
8.1 Use lift equipment appropriate to the activity. Install and correctly position lifting equipment to eliminate the risk of the equipment or a load striking a person. Illuminate lifting operations appropriately. Provide cranes with electrical/mechanical overload protection and, except for automated cranes, calibrated load cells with a display clearly visible to the operator. Provide load moment indicators on cranes, other than electric overhead travelling cranes, portal cranes or automated stacker cranes.
Procedure Lifting Operations Management Process

8.3 Operate, maintain, inspect, test and certify cranes and lifting equipment using approved standards, systems and procedures. Define and manage the operational area to prevent the risk of injury from the equipment or the load. Mark all lifting equipment to show the safe working load. Undertake defined periodic examination and testing of cranes and lifting equipment using a competent person. Mark lifting equipment clearly to confirm compliance with the periodic examination requirements. Implement a process to clearly identify and quarantine damaged or out-of-certification lifting equipment. Implement a process to identify and manage the risk of sling roll-out from the hook. Develop clear criteria for what constitutes a complex lift and require such lifts to have a lift plan. Implement a process to verify the ground is suitable for safe operation of cranes and, where they are fitted, deploy outriggers. Provide operating manuals and load charts in a language understandable to the crane operator. Certify cranes and any associated equipment used for lifting personnel.
People Training and Competence

8.2 Plan and execute lifts safely. The level of planning will be appropriate to the complexity of the lift. Plan and execute lifts using trained, certified, competent and authorized personnel.
Dropped Objects
Intent
Manage potential dropped objects to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Secure Potential Dropped Objects
9.1 Identify and manage potential dropped objects Assess permanently installed equipment suspended more than 2 meters above ground to determine the requirement for primary and secondary securing mechanisms in order to prevent dropped objects. Implement an in-built secondary securing device (e.g., nuts with split pin or securing wire) on the primary securing mechanism; where an external secondary securing mechanism is deemed unnecessary or impractical. Comply with relevant approved design standards, manufacturers specifications and local regulations for the following: permanent structures temporary structures plant and equipment portable elevated work platforms movable elevated work platforms suspended work baskets scaffold structures

9.3 Engage third party specialists who are suitably qualified to identify potential dropped objects to conduct scheduled Dropped Object assessment inspections. Educate personnel about the risks of potential dropped objects and their role in supporting the process.
9.4
Procedure Dropped Objects Management Process

9.5 Implement a dropped object management system. The system must include the following provisions: A register of all structural objects that have the potential to drop. Control strategies for managing these objects. Assessment of the impact of weather on these potential dropped objects or work associated with these objects. Associated maintenance arrangements inclusive of inspections. A process which manages temporary tools and equipment being taken aloft, inclusive of a return to a safe location at the end of work activity. A process to ensure contractor-owned and contractoroperated equipment, third-party equipment, and equipment hired or contracted directly for BHP Billiton Petroleum activity complies with this Fatal Risk Control before usage. Notes: See Appendix B for supplementary information regarding Dropped Objects.
9.2
Controls 57
Working with Pressure

Intent
Manage pressurized equipment to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Design
10.1 Design, construct, test, inspect, place into service and maintain pressure equipment, regardless of pressure rating, in accordance with appropriate internationally recognized industry standards. 10.2 Design and install storage and racking systems with positive latching retaining bars that prevent pressurized bottles/containers from tilting out of the rack. 10.3 Mark with a unique identifier and verified maximum working pressure, all new and refurbished/repaired pressure vessels as defined by API codes. 10.4 Label pressure containing equipment to identify contents and pressure. This must include all buried pipelines/ flow-lines and associated rights-of-ways. 10.5 Provide a means of safe isolation for all instrument connections on pressure containing systems. 10.6 Use pipe-work in the following order of preference: 1. Fixed pipe-work (temporary or permanent) 2. Flexible type steel piping (temporary or permanent) 3. Temporary pipes connected with swivel joints 10.7 Provide permanent piping systems with properly engineered and installed piping clamps and restraints; design must factor in vibration and thermal effects on the piping and restraints.

10.8 Use persons who are trained in: Job Risk Assessment, Isolations and Permit to Work; Emergency Response; Lock Out/Tag Out; Safe pressure testing practices. These personnel must wear appropriate PPE during pressure testing.
Procedure Working with Pressure Management

10.9 Implement a maintenance program which includes the following: Verification of ratings and currency of pressure testing equipment prior to usage. Inclusion of pressure containing equipment in the planned maintenance system. Verification of performance standards and certifications where pressure equipment classed as Critical. Clamp or restrain flexible hoses and temporary piping to prevent whipping in the event of a connection failure. 10.10 Implement procedure(s) to cover the following: Visual inspection for transit and other damage; thread and sealing surfaces integrity; flanges and bolts being fit for purpose. Use a documented handover procedure to transfer responsibility to the testing authority. This procedure must include verification of torque requirements/ methodology and system isolation points/methods. Incorporation of an exclusion zone for pressure testing; pressure testing with gases must be approved; pressure testing with volatile/flammable fluids is not permitted; pressure testing must be conducted in accordance with a written procedure and supporting Job Risk Assessment.
Presence of Hydrogen Sulphide (H2S)

Intent
Manage exposure to hydrogen sulphide (H2S) to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Design
11.1 Design, construct, and maintain equipment that is required for H2S service using materials suitable for H2S service (e.g., NACE Standard MR 0175-96, Standard Material Requirements: Sulphide Stress Cracking Resistant - Metallic Materials for Oilfield Equipment). 11.2 Label systems and piping that contain H2S. 11.3 Secure potential exposure points from public access through the use of fences, locked gates and warning signs. 11.4 Identify and make available Emergency Response equipment associated with H2S operations.
Procedure H2S Management

11.5 Train persons involved in BHP Billiton Petroleum activity with potential for exposure to H2S; visitors must receive adequate training to support safe operations for the duration of their stay. 11.6 Require persons involved in H2S Emergency response are clean shaven to minimize exposure to H2S while effecting their duties; additionally they must be subject to a face-fit testing for breathing air apparatus; Site Medical professionals supporting operations must receive training in the physiological effects of H2S toxicity and its treatment.
11.7 Assess the likelihood of encountering H2S each time a new hydrocarbon source is introduced; an existing source is being worked upon or reservoir analysis indicates the requirement for such a review. 11.8 Define and implement an appropriate H2S Management System inclusive of controls and mitigations. This includes the use of fixed, portable, personal detection systems; breathing air and associated equipment for normal work activity; emergency escape; emergency rescue; emergency drills; muster points; use of aids such as wind socks; associated maintenance systems. 11.9 Assess the potential impact of H2S exposure to the public and implement relevant controls as part of the Emergency Response Plan.
Controls 59
Confined Space Entry (CSE)

Intent
Manage entry into and work within confined spaces to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Confined Spaces
12.1 Identify confined spaces and maintain a confined space register. Use the register to inform all work planned on such confined spaces; the register must include permanent equipment and any permanent or temporary third-party service contractor equipment used in support of BHP Billiton Petroleum activity. 12.2 Label all known confined spaces to prevent inadvertent or unauthorized access to those spaces by personnel. 12.3 Assess equipment and spaces that undergo a modification (permanent or temporary) to determine whether the modification has created a confined space. 12.4 Identify and make available Emergency Response equipment associated with Confined Space Entry operations.
Procedure Confined Space Entry Management Process

12.8 Conduct confined space entry only after other alternatives have been evaluated and deemed unsuitable. 12.9 Identify and implement limits for exposure to dangerous gases or other occupational exposures. 12.10 Conduct a documented risk assessment prior to actual entry into a confined space. 12.11 Require a Permit to Work for Confined Space activity. 12.12 Isolate piping, equipment and spaces connected with or adjacent to the confined space in accordance with Fatal Risk Control 5 Isolation and Permit to Work. 12.13 Assess the atmosphere of any confined space prior to entry. Continue ongoing monitoring while work is being performed to ensure it remains safe. Minimum atmospheric monitoring includes: Oxygen content; Lower Explosive Limit; Toxicity of atmosphere. 12.14 Provide adequate ventilation to ensure a safe atmosphere at all times, from initial entry until the work is completed and the space is evacuated. 12.15 Do not introduce pure oxygen into an oxygen deficient space. 12.16 Do not use combustion engine driven or nitrogen driven mobile tools and equipment in confined spaces. 12.17 Locate gas cylinders used for the purposes of cutting or welding outside the confined space. 12.18 Isolate sources of gases when cutting or welding work is paused or stopped. Effective communication is required between those conducting the work and those controlling the gas shut-off outside the space. Notes: See Appendix B for supplementary information regarding Confined Space Entry.
People Roles and Responsibilities

12.5 Define and document the roles and responsibilities for all personnel working in and supervising work in confined spaces. 12.6 Use people who are trained, deemed competent and assessed as fit to work in confined spaces. 12.7 Require personnel who work in confined spaces to be appropriately trained in Permit to Work and Job Risk Assessment processes.
Diving
Intent
Manage diving activity to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities.
Plant Diving Equipment and Support Vessels
13.1 Use marine equipment and vessels to support diving operations, including support vessels which comply with the specifications in the BHP Billiton Petroleum Marine Operations Controls. 13.2 Identify and make available Emergency Response equipment associated with Diving Operations. 13.3 Do not use band-masks or recreational SCUBA equipment; re-breather apparatus other than where used in rescue or emergency operations.
Procedure Diving Management Process

13.6 Conduct diving operations only where the use of remotely operated vessels (ROV) is not practicable. 13.7 Implement BHP Billiton Petroleum Diving Operations Procedure for all diving activities. 13.8 Conduct Diving Operations in accordance with a written Dive Plan; plan must include specific emergency action plans aligned with the diving risk assessment. 13.9 Prohibit the following diving and subsea activities: Diving operations of any type at working depth in excess of 1,000 feet sea water (or 304 meters sea water). Diving in environments assessed by risk assessment as heavily contaminated. Notes: See Appendix B for supplementary information regarding Diving.

13.4 Use trained, certified, experienced and competent personnel for diving operations including personnel inspecting and maintaining diving equipment. 13.5 Do not use uncertified or recreationally certified diving personnel.
Controls 61
Ground Disturbance and Ground Control

Intent
Manage work involving a man-made cut, cavity, trench or depression in the earths surface formed by earth removal to protect personnel from harm and prevent the risk of fatalities, injuries and incidents related to BHP Billiton Petroleum activities. This includes falls of ground at stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations.
Plant Design and Use Appropriate Equipment
14.1 Source and use equipment appropriate for Ground Disturbance and Ground Control activity. 14.2 Source or define standards for the design and quality of ground support materials. 14.3 Identify and make available Emergency Response equipment associated with Ground Disturbance or Ground Control rescue and recovery as deemed necessary.
Methods to assess hazardous atmospheres based on risk. Methods for controlled disturbance of ground, inclusive of standards for the measuring, monitoring and analysis of ground condition data, classifying soil and aligning equipment selection, work methodology and emergency response protocols. Methods of securing disturbed ground inclusive of shoring, shielding, sloping and benching and assessment of excavation stability and the effectiveness of ground support (20 feet and deeper require engineered protective systems). Methods for management of stockpiles of disturbed ground. Methods for management of naturally occurring water in disturbed ground. A process for management of planned and unplanned changes to ground conditions inclusive of the impact of weather. Process for effective communications to affected personnel. Means for assuring the integrity of the installation of ground support materials, including frequency of examination and methods for repair. Identification and use of appropriate PPE. Emergency Response arrangements inclusive of rescue from cave-in. 14.6 Undertake an annual review of the Ground Disturbance and Ground Control procedure. Notes: See Appendix B for supplementary information regarding Ground Disturbance and Ground Control.

14.4 Use personnel who are suitably experienced and have been trained and certified to conduct Ground disturbance and Ground Control activity including personnel responsible for inspections and maintenance.
Procedure Ground Disturbance and Ground Control Management Process

14.5 Develop and maintain an approved Ground Disturbance and Ground Control procedure prepared by a competent person. The procedure must address the following requirements as applicable: Mark excavations with a unique name or identification number at sufficient intervals to accurately identify the location. Process for contacting relevant stakeholders prior to disturbing the ground. Process for identification and management of overground and under-ground hazards inclusive of buried pipelines, electrical cables, water lines. Methods for management of traffic. Methods to separate and protect personnel from unsecured ground inclusive of barriers, barricades, other access restrictions especially when powered equipment is in use or when Confined Space Entry permits are required.
Appendix B
Notes, Application and inter-relationship of Fatal Risk Controls

Control
1 Road Going and Light Vehicles
Application
This Control applies to BHP Billiton Petroleum owned, contracted (lease or hire) or operated road going and light vehicles used for work related activity. It also applies to all BHP Billiton Petroleum personnel using road going and light vehicles used for work related activities. Road Going Vehicles includes all surface light vehicles, trucks and buses that are designed for public road use. Examples include pick-ups trucks, four wheel and all-wheel drive vehicles, rigid and articulated trucks (including associated trailers) and buses of all sizes. Light Vehicles are a class of Road Going Vehicle which: Have four or more wheels, seat a maximum of 12 adults (including the driver), Are vehicles that, where registered, could be legally driven on a public roadway by a driver issued with an approved drivers license Do not exceed 4.5 tonnes gross vehicle mass (GVM), which is the maximum loaded mass of the motor vehicle as specified by: - the vehicles manufacturer; or - an approved and accredited automotive engineer, if the vehicle has been modified to the extent that the manufacturers specification is no longer appropriate. Light Vehicles may include the following categories of vehicles being used for work related activities: - BHP Billiton owned or leased vehicles; - Hired rental vehicles - Contractor or supplier vehicles operating on company property; - Private vehicles used for work related activity. The requirements of this Control do not apply in the following situations: Vehicles being driven on site to the employee or visitor car park area, or for delivery drop off in non-hazardous areas (e.g., warehouse deliveries). Private vehicles being used on an occasional basis to undertake a low risk work related trip, such as visits to Contractor offices etc, where approved by the Line Manager or equivalent. Employees traveling between their fixed or temporary residence and their fixed or temporary work place in either Company provided transport, public transport or personal transport. Situations where the employee departs from a reasonably direct route of work related travel for personal reasons, e.g., a side trip to visit a place of interest. Support equipment includes: Fire extinguisher High-visibility vest Signage appropriate for the location First aid kit Emergency roadside triangles or beacons Survival or emergency equipment suitable for the operating environment Signage appropriate for the location. Two-way radio. Method to move portable equipment while maintaining three points of contact. Road Going & Light Vehicle Safety Equipment includes: Air-bags for all occupants. Anti-lock braking system (ABS). 3-point inertia reel seat belt for all occupants. Systems for control of cargo and segregation of cargo from occupants. Roll-over protection based on 5 Star NCAP or equivalent rating and/or have installed an electronic stability control (ESC) system. Off-road Road which has no engineering design. Natural tracks, river beds, gullies, naturally occurring land. New Car Assessment Programmes (NCAP) New Car Assessment Programmes are active in the following countries or regions: Australia (ANCAP); Japan (JNCAP); S.E. Asia (ASEAN NCAP); Korea (KNCAP); Latin America (Latin NCAP); Europe (EuroNCAP); USA (NHTSA and IIHS). Until the NHTSA 5 star rating programme matures, and the available range of compliant vehicles increases, purchasers of USA-supplied vehicles can use IIHS Good ratings as evidence of NCAP equivalency (for instance, Good ratings in both frontal and side impact tests).
2 Mobile Equipment
This Control applies to the use of all mobile equipment over and above those vehicles covered under Fatal Risk Control 1 Road Going and Light Vehicles. Includes, but is not limited to, mobile elevating work platforms, self-propelled surface, tracked and rubber tyred equipment such as trucks, graders, tractors, excavators, drills, draglines and similar plant. It excludes relocatable plant such as crushers and stacking conveyors.
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Appendix B
Notes, Application and Inter-Relationship of Fatal Risk Controls continued
Control
2 Mobile Equipment (continued)
Application
Mobile Equipment safety features Seat belt. Fall-on and roll-over protection. Adequate lighting for safe execution of tasks. Reversing alarms, horn, effective windscreen wipers, guarding on moving parts. Support equipment includes: Fire extinguisher High -visibility vest Signage appropriate for the location First aid kit Emergency roadside triangles or beacons Survival or emergency equipment suitable for the operating environment Signage appropriate for the location. Two-way radio. Method to move portable equipment while maintaining three points of contact.
3 Explosives
For WWD activity only - this Control must be used in conjunction with the World-Wide Drilling (WWD) Explosives Management Guidelines contained within the Drilling Safety Guidelines Document No WWD015. DOT, OSHA, ATF or Local authorities requirements for shipping, handling and storing explosives must be complied with.
4 Hazardous Materials
This Control applies to activities related to hazardous materials management. It includes management of hydrocarbon processing facilities and operations and includes hazards associated with the extraction, production, processing and transport of hydrocarbons and associated products. These controls must be used in conjunction with the process hazard analysis (PHA) as defined in the Hazard and Risk Management Controls. This Control does not cover handling of explosives (covered in Fatal Risk Control 3 Explosives). This Control applies to the isolation of all sources of energy (electrical, mechanical, hydraulic, chemical, gravitational, pneumatic, kinetic, stored energy etc.). The requirements detailed in this Control must be used in conjunction with the BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure. This Control applies to safeguarding of people from moving parts of plant, mobile machines, equipment and power tools, including moving equipment, high pressure equipment and applications, electrical, and other energy sources with the potential to move, and objects falling or projected from moving parts. This includes the integrity of such equipment. This Control applies wherever there is potential for any person to fall 2 meters or more, or to gain access to within 2 meters of an open edge from where there is the potential to fall 2 meters or more, including working from various forms of portable and moveable elevated work platforms, workbaskets, ladders, scaffolding, or where a risk assessment has identified high potential fall hazards when working at heights of less than 2 meters. It also applies where a significant injury could result from a fall. (Note: if local applicable law requires more stringent controls, then those controls must be implemented.) This Control does not apply to rope rescue situations and abseiling that are regarded as specialist functions.
5 Isolation and Permit to Work
6 Equipment Safeguarding
7 Working At Height
8 Lifting Operations
This Control applies wherever lifting operations are undertaken. These controls must be used in conjunction with the BHP Billiton Petroleum Lifting Operations Procedure. This Control applies to all work conducted on BHP Billiton Petroleum sites and to facility equipment, third party equipment, and all equipment hired or contracted direct by BHP Billiton Petroleum. It includes: Objects falling or dropped from plant/equipment or a rig/derrick. Objects falling or dropped from crane booms, flare booms and other permanently or temporarily installed structures and buildings. Objects falling or dropped from elevated decks, platforms, scaffolding and any other workspace where equipment is mounted or secured overhead. Tools, equipment, and other objects falling or dropped while working from portable and moveable elevated work platforms and while persons are working at heights using a work harness or working in cages.
9 Dropped Objects
64 Health, Safety, Environment and Community Management System Framework
Appendix B
Notes, Application and Inter-Relationship of Fatal Risk Controls continued
Control
9 Dropped Objects (continued)
Application
This Control should be used in conjunction with the requirements of Fatal Risk Control 7 Working at Height and Fatal Risk Control 8 Lifting Operations. This Control excludes: Loads falling from cranes during lifting procedures these occurrences are covered under Lifting Operations Controls. Tubulars (drill strings, BHAs, test strings, casing and tubing, etc.) suspended from or in the rotary table that drop down the well these occurrences are covered by Drilling procedures.
10 Working with Pressure
This Control applies to all activities and operations where pressure-containing equipment is used. These controls must be used in conjunction with Fatal Risk Control 5 Isolation, BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure. This Control applies to all BHP Billiton Petroleum activities where H2S may be encountered. This Control applies to all BHP Billiton Petroleum activities involving confined space entry. These controls must be used in conjunction with Fatal Risk Control 5 Isolation and the BHP Billiton Petroleum Permit to Work Procedure and the BHP Billiton Petroleum Lock Out Tag Out Procedure. The definition of a confined space must reflect local applicable law. The Australian Standard AS2865 defines confines space as, any space which: Is at atmospheric pressure during occupancy; Is not intended or designed primarily as a place of work; May have restricted means for entry and exit; and may: - Have an atmosphere which contains potentially harmful levels of contaminants; - Not have a safe oxygen level; or - Cause engulfment.
11 Hydrogen Sulphide 12 Confined Space Entry
13 Diving
This Control applies to all diving activities including: Surface-supplied air diving. Surface supplied mixed gas diving. Saturation diving. Remotely Operated Vessels (ROV) interventions during diving operations. This Control does not apply to the use of non-diving related ROVs or manned submersibles.
14. Ground Distrubance and Ground Control
This control applies to all BHP Billiton Petroleum activities involving ground disturbance. It requires the identification of situations which could create dangers to personnel due to movement of ground at stockpiles, ponds, dam walls, waste rock dumps, trenches and similar locations. See OSHA 29 CFR 1926.650, .651, .652 OSHA defines an excavation as any man-made cut, cavity, trench, or depression in the earths surface as formed by earth removal. A trench refers to a narrow excavation made below the surface of the ground in which the depth is greater than the width-and the width does not exceed 15 feet. Trenching is common in utility work, where underground piping or cables are being installed or repaired. If an excavation is more than 4 feet in depth or if there is a potential for engulfment, there must be a protective system in place while workers are present in the excavation. Excavations more than 4 feet in depth must have a way to get in and out, usually a ladder, for every 25 feet of horizontal travel. Shoring , whether the traditional timber shores or the modern hydraulic shores, brace against and hold up the walls of an excavation, preventing cave-ins. (never work outside of the shored area) Shielding devices, commonly called trench boxes, shields, or coffins, are not designed to prevent a trench wall from collapsing, but rather serves as a shield to the workers within the structure should a cave-in occur. With both shoring and shielding, the workers are only protected as long as they stay within the protective confines of the systems. (never work outside of the shored area) Sloping refers to the cutting back of the trench walls at such an angle that there is little chance for collapse. Spoil piles shall be no closer than 2 ft from the edge of the excavation to the nearest point of the spoils.
Controls 65
Appendix C
Traffic Management Plan Requirements

Develop and implement a Traffic Management Plan which establishes site road engineering and vehicle operating standards for surface and underground Operations. The Traffic Management Plan must establish criteria for: Minimizing the risk for all site road users with site road network, traffic flow, intersection design and vehicle selection. Keeping the number of light vehicles on site as low as practicable. Minimizing interactions between pedestrians and vehicles, and heavy and light vehicles, with physical separation provided wherever practicable, including safe parking area design and parking protocols. Coloring, marking and equipping vehicles and mobile equipment for adequate visibility and easy identification at a safe distance by other vehicles, mobile equipment and pedestrians. Building roads with adequate delineation and protection from roadside and overhead hazards. Managing road maintenance, including hazards arising from dust and over-watering. Selecting road traffic signs and road markings consistent with the standards set by the national or state authorities in the country of operation. Where such standards do not exist, or are not suitable, the site must select an appropriate standard from the European Union, North America, Australia, South Africa or Chile. Mitigating risks to personnel from the hazards of remotecontrolled mobile equipment. Providing adequate visibility along company roads and at intersections. Implementing traffic safety procedures that at least include: - right of way rules at site intersections. - site overtaking and vehicle interaction protocols. - site speed limits and how they will be enforced. - the minimum safe distance to be maintained between site vehicles and mobile equipment. - control of access to, and egress from, restricted areas, including a process for ensuring the number of light vehicles in a restricted area is kept to the absolute minimum needed for effective Operations. - communication equipment requirements and communication protocols. - work-related use of company-provided vehicles off site, including the identification and management of high-risk road journeys. Providing training and competency requirements for: - road safety awareness including defensive driving techniques. - permits to operate/drive including site drivers licences based on specific site rules, vehicle type, operating standards and risks. - employees and contractors performing design and engineering of road networks, traffic flow and traffic engineering.
Appendix D
Transitional Requirements for Existing Light Vehicles

Driver side air-bag. 3-point inertia reel seat belts (2-point inertia reel seat belts where 3-point seat belts are not available). Systems for control of cargo and segregation of cargo from occupants. Vehicle design to mitigate risks to occupants from toppling or rollover.
66 Health, Safety, Environment and Community Management System Framework
Environment
Enviroment Control 1
Land and Marine Management

Land and Marine Disturbances
Intent
Land and marine disturbances must be managed to minimize environmental impact.
Control Framework
Where land activities or marine use may impact the environment: Assess the baseline biodiversity, land use, contaminated sites and environmental liability for areas potentially impacted. Identify and map the owned, leased or managed land, freshwater and marine areas, designated protected areas and areas of high conservation value. Assess actual and potential impacts to biodiversity, land use, contaminated sites and environmental liability. Quantify the acceptable level of impact taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to biodiversity and land use. Implement a monitoring and review program to evaluate the effectiveness of control measures.
Mandatory Controls
1.1 Obtain approval (i.e., internal and/or regulatory approval) to disturb land, freshwater, and marine areas that addresses regulatory requirements. This may be covered by the site closure plan, Environmental Management Plan, or regulatory submittal. Design vessels, vehicles, plant or equipment that may cause ground or seabed disturbance to ensure minimal disturbance while meeting operational requirements and allowing safe operation. Do not explore, drill, develop or extract within the boundaries of World Heritage listed properties. Identify any local International Union for Conservation of Nature (IUCN) Red List Threatened Species and do not operate where the direct impact will result in their extinction in the wild. Onshore, rehabilitate disturbed land as soon as practicable and consistent with the pre-disturbance land use or alternate land uses developed in consultation and/or agreement with stakeholders, regulators and land owners. Offshore, conduct hydrodynamic modelling to predict the extent of impacts to offshore habitat for any physical disturbance that may impact shoreline, near shore areas or areas protected for the purposes of conservation. Conduct baseline benthic monitoring to predict the extent of impacts to habitat.
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 1.7 Implement compensatory actions where actual or potential residual impacts, after preventative and mitigating controls have been implemented, exceed the quantified acceptable level of impact to biodiversity, land use, watersheds and/or water resources. 1.8 Do not conduct exploration, drilling and/or development in the following instances: Adjacent to World Heritage listed properties unless the proposed activity is compatible with the outstanding universal values. Within the boundaries of the IUCN Protected Areas Categories I-IV, unless a Biodiversity Action Plan is implemented that delivers measurable benefits to biodiversity commensurate with the level of expected biodiversity impact and meets regulatory requirements and authorizations. Onshore, obtain authorizations before the implementation of any material land conservation project.
1.2
1.3 1.4
1.5
1.9
1.6
Controls 69
Environment Control 2
Land and Marine Management

Noise Disturbances
Intent
Noise must be managed to minimize impact to fauna and communities.
Control Framework
Where noise may impact fauna or the community: Assess actual and potential impacts to fauna and communities. Quantify the acceptable level of noise impact taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to fauna and the community. Implement a monitoring and review program to evaluate the effectiveness of control measures.
Mandatory Controls
2.1 Offshore, build sound power intensity of seismic shots gradually (soft-start) following Joint Nature Conservation Committee (JNCC) guidelines (4) to allow marine mammals time to leave the area. In areas where cetaceans are not expected and in the absence of passive acoustic monitoring (PAM) systems, judgement must be used to ensure the area is free from cetaceans prior to the soft start. Offshore, continually watch for marine mammals during the pre-shooting search and soft-start, and while airguns are firing, in regions with known (regulated, designated or otherwise indicated) marine mammal migratory pathways. Seismic source vessels must carry at least one competent Marine Mammal Observer (MMO) in accordance with JNCC guidelines (5). Offshore, for seismic operations, where stricter guidelines do not apply: Delay the soft-start if marine mammals are seen within 500 meters of the center of the array during the pre-shooting search. However, if marine mammals are detected within 500 meters of the center of the airgun array while the airguns are firing, either during the soft-start or while at full power, there is no requirement to stop firing the airguns (5). Conduct the pre-shooting search and soft start procedure after shut down of the seismic source, or if all airguns have stopped and not restarted for at least 10 minutes. Begin seismic activities at least 500 meters from the platform where marine mammals are congregating around a drilling or production platform, or other structures.
2.2
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 2.4 Onshore, conduct a baseline noise survey to determine representative background noise and perform noise modelling to ensure acceptable environmental noise targets are met off-site. 2.5 Onshore, incorporate efforts to manage noise using good industry practices. 2.6 Offshore, consider the use of PAM for all offshore source vessels involved in seismic acquisition; particularly for use in areas where marine mammals are likely to inhabit the proposed survey location.
2.3
Hydrocarbon Management
Hydrocarbon
Intent
Liquid hydrocarbon storage, pipelines and flowlines, must be managed to minimize the risk of land and water contamination.
Control Framework
Where hydrocarbon storage and pipelines may impact the environment: Assess actual and potential impacts to biodiversity, water, air or community. Quantify the acceptable level of impact taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to biodiversity, water, air or community. Implement a monitoring and review program to evaluate the effectiveness of control measures.
Mandatory Controls
3.1 3.2 Identify, map and manage liquid hydrocarbon storage and pipelines. Conduct and maintain a risk assessment for all existing below-ground or subaqueous liquid hydrocarbon storage tanks (including vessels) and associated pipelines to determine the likelihood of containment failure and implement any required control measures.
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 3.3 Implement a risk-based integrity management program for BHP Billiton Petroleum facilities and pipelines. 3.4 Construct new storage facilities and pipelines to comply with local regulatory requirements and accepted petroleum industry standards.
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Water Management
Water Sourcing, Use and Discharge
Intent
Water sourcing, use and discharge, including disposal, must be managed to minimize impact to water resources, biodiversity and communities.
Control Framework
Where water sourcing, use or discharge may impact the environment: Assess the baseline quantity and quality of water potentially impacted. Assess potential impacts on water quality and quantity. Quantify the acceptable level of impact to water taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to water (including quantity and quality criteria limits for water supply sources and discharges). Implement a monitoring and review program to verify the effectiveness of control measures.
Mandatory Controls
4.1 4.2 Maintain records of water sources, water use and wastewater generation. Where high quality water use exceeds or is anticipated to exceed 3,000 megaliters per annum for an Operation or project, or where water management is anticipated to be a material risk issue, the Operation or project must: Maintain a quantitative water balance model. Maintain a 5-year forecast for high quality water use. Establish targets and implement and maintain projects to reduce impacts to water resources in the regions where the Operation or project is located. These targets and projects must be included in the Asset 5-year plan. Maintain a high quality water use reduction cost curve that identifies potential projects to reduce all high quality water usage. Identify and assess water requirements, supply options and supply risks for the life of the Operation. Implement, monitor and review controls designed to deliver water supply requirements for the life of the Operation. Evaluate chemicals used for water treatment to minimize potential environmental impacts. Design, drill, complete, produce and abandon wells (oil, gas, water abstraction and water disposal), to meet local regulatory requirements and accepted industry standards for the protection of groundwater and surface water. Offshore, do not exceed a 24-hour average oil and grease concentration of 30 mg/l for discharges of produced formation water (PFW) (6).
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 4.6 Conduct an accounting of water use. 4.7 Evaluate water recycling and reuse. 4.8 Onshore, ensure surface casing strings are cemented back to surface to provide adequate isolation of all freshwater zones penetrated. If cement is unable to be circulated back to surface, run diagnostic logs to evaluate top of cement and perform remedial cementing operations if necessary, to provide adequate isolation. 4.9 Onshore, conduct groundwater monitoring to detect potential impacts from losses of containment at permanent facilities. 4.10 Onshore, preferably store waste water in tanks rather than pits/ponds. 4.11 Onshore, design and construct pits/ponds in a manner to prevent leaching and unauthorized access. 4.12 Onshore, install leak detection systems on permanent wastewater storage pits or ponds. 4.13 Offshore, use inline oil-in-water analysers with shut-downs/ auto-bypasses or manual sampling and testing for all PFW overboard discharges. 4.14 Offshore, manage ballast water in compliance with MARPOL 73/78 Annex I(7), International Maritime Organization (IMO) Ballast Water Management Convention(8) and BHP Billiton Petroleum Marine Operations Controls (9).
4.3 4.4
4.5
Air Management
Air Emissions
Intent
Air emissions (excluding greenhouse gases) must be managed to minimize impact to the atmosphere and subsequent impacts on water, land, biodiversity and communities.
Control Framework
Where air emissions may impact sensitive receptors: Assess the baseline air quality at sensitive receptors and maintain an inventory of air emissions. Assess potential air quality impacts on sensitive receptors. Quantify the acceptable level of impact to sensitive receptors air quality, taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact to sensitive receptors air quality (including air emissions criteria limits). Implement a monitoring and review program to verify the effectiveness of control measures.
Mandatory Controls
5.1 5.2 5.3 Use natural gas as the preferred fuel at production facilities where it is available. Use low-sulphur diesel (containing sulphur equal to or less than 500 ppm) as the fuel source where it is available. Assess suitability of SO2 controls, where low sulphur diesel is unavailable, for continuously operated major emissions sources. Utilize high-efficiency flare equipment on new facilities. Measure (preferably) or estimate (using accepted industry estimation methodology), record and report internally air emissions. Avoid cold venting of natural gas where practicable. Offshore, comply with emission guidelines for PM, SO2 and NOx as indicated by International Finance Corporation, World Bank Group guidelines for air emissions and ambient air quality (10) for engines and turbines (permanent and temporary) owned or operated by BHP Billiton Petroleum. Offshore, comply with the requirements of MARPOL 73/78 Annex VI (11) for emissions from combustion sources on controlled marine vessels.
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 5.9 Evaluate the use of the following designs for new facilities or at opportunistic retrofit: Clean/lean burn technology for use on BHP Billitonowned equipment for control of NOx, CO and volatile organic compounds. Smokeless flare or high efficiency flare equipment. Vapour-recovery equipment for all planned or steady state venting sources. Low or no-bleed pneumatic devices to regulate pressure and control valves to minimize releases to a flare system. Electronic igniters as a means of lighting flares in lieu of permanent pilots. Flare gas recovery systems. Flash gas and vent gas for fuel or sale. Compressed air instead of natural gas for powering instruments and controllers. Bypass or closed-loop systems to eliminate excessive flaring associated with commissioning and start-up activities.
5.4 5.5
5.6 5.7
5.8
Controls 73
Energy and Greenhouse Gas Management

Energy Use and Greenhouse Gas Emissions
Intent
Energy use and greenhouse gas (GHG) emissions must be managed to reduce GHG emissions where emissions exceed or are anticipated to exceed 50,000 tonnes CO2-e (equivalent) per annum for an Operation or project.
Control Framework
Where emissions exceed 50,000 tonnes CO2-e per annum for an Operation or project: Identify, evaluate and implement energy and GHG reduction projects based on current and forecasted energy use and GHG emissions. Develop a management plan and implement a monitoring and review program to verify the effectiveness of energy reduction and GHG reduction projects.
Mandatory Controls
6.1 6.2 Maintain a GHG emission 5 year forecast. Where emissions exceed or are anticipated to exceed 1,000,000 tonnes CO2-e per annum for an Operation or project: Maintain an energy mass balance; Maintain a GHG reduction cost-curve that identifies potential projects to reduce all GHG emissions; Establish targets and implement and maintain projects to reduce greenhouse gas emissions consistent with the reduction quantums committed to from the GHG reduction cost curve. These targets and projects must be included in the 5-year plan. Measure (preferably) or estimate (using accepted industry estimation methodology), record and report internally GHG emissions. 6.4 Utilize waste heat recovery for new facilities or opportunistic retrofit if emissions are greater than 50,000 tonnes per year of CO2 equivalent (CO2-e). Apply the BHP Billiton Carbon Pricing Protocol during project selection for applicable capital decisions (12). Establish energy efficiency improvement goals and action plans to reduce emission levels. Goals should be on a normalized year-by-year basis and included in the management plan. Assess energy efficiency during the selection of new or replacement equipment for fixed or permanent installations. Energy efficiency evaluations are case-specific for the selection of the required parameters to conduct a lifecycle analysis. Avoid cold venting of natural gas where practicable.
6.5 6.6
6.7
6.3
6.8
Waste Management
Waste
Intent
Wastes, excluding drilling muds and drilled cuttings, must be managed to minimize the environmental impacts resulting from the production, storage, handling, transport, recycling and disposal.
Control Framework
Where hazardous, non-hazardous and general wastes are generated: Assess potential environmental impacts of wastes and determine if any wastes can be eliminated, reduced, recycled or reused in lieu of disposal. Quantify the acceptable level of impact taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact (including the tracking of waste from source to disposal). Implement a monitoring and review program to verify the effectiveness of control measures.
Mandatory Controls
7.1 7.2 Maintain records of waste type, source and quantities of wastes, and the storage and disposal locations. Manage, store, transport, and dispose or treat hazardous materials and hazardous wastes in accordance with regulatory requirements or industry best practice. Where hazardous wastes are generated and there are no regulatory requirements, utilize the United Nations Environment Programme Basel Convention on the Control of Transboundary Movements on Hazardous Wastes and Their Disposal (13) as a guide. Conduct audits or assessments at least every two years on waste management contractors to ensure their operating practices are appropriate and in compliance with regulations. Evaluate chemicals, materials and products for environmental impacts to achieve waste minimization. Onshore, dispose of hydrostatic test water according to regulations. Where regulations are not available, utilize best practices such as requirements of the International Finance Corporation (World Bank Group) (14). Offshore, manage sewage and grey water in compliance with MARPOL 73/78 Annex IV (15), and MARPOL 73/78 Annex V (16), respectively, or other applicable permits prior to discharge. Utilize a marine sanitation unit where installed.
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 7.7 Conduct risk-based HSEC evaluation on waste management contractors prior to final contractual arrangements.
7.3
7.4 7.5
7.6
Controls 75
Waste Management
Drilling Muds and Drilled Cuttings
Intent
The use, storage and discharge of drilling muds and cuttings must be managed to minimize adverse environmental impacts.
Control Framework
Where drilling muds and drilled cuttings are generated: Assess drilling muds and drill cuttings for recycling or reuse. Quantify the acceptable level of impact from discharges taking into account regulatory requirements and stakeholder expectations. Develop a management plan with preventative and mitigating controls that are implemented to achieve the acceptable level of impact. Implement a monitoring and review program to verify the effectiveness of control measures.
Mandatory Controls
8.1 Assess the environmental impacts when selecting drilling muds and completion fluids, including chemicals and additives. Onshore, construct pits used for drilling and completion operations to prevent unauthorized access and to prevent leaching, leakage or unauthorized discharge of pit contents into the surrounding environment. Construct pits to ensure that overflow associated with rainfall will not occur. Onshore, avoid use of oil or saltwater-based muds when drilling through groundwater and freshwater strata. Offshore, do not discharge oil based mud (OBM) or OBM-contaminated cuttings into the environment (10). Offshore, where a synthetic based mud (SBM) or OBM system is used, utilize separation equipment that is capable of ensuring the volume of SBM or OBM retained on drilled cuttings is no more than 10 percent by dry weight. Offshore, conduct ecotoxicity testing (acute, sub-lethal and/or chronic) on fluids to be discharged. This may be a prior test conducted on a generic mud composition for the well, or it may be a test on the actual mud in use or discharged during the drilling operation.
Risk-Based Controls
Based on the level of impact identified in a risk assessment process, the following must be implemented: 8.7 Evaluate use of low toxicity water based muds (WBM) for all drilling activities except for hole sections where SBM or OBM is justified for technical reasons. Onshore, consider closed-loop drilling systems.
8.2
8.8
8.3 8.4 8.5
8.6
Environment Controls
References
1. 2. 3. 4. 5. BHP Billiton. BHP Billiton Petroleum HSEC Management System Framework. BHP Billiton. BHP Billiton Petroleum Health, Safety, Environment and Community (HSEC) Policy BHP Billiton. Management Plan Preparation Document. BHP Billiton. BHP Billiton Petroleum Investment Process Manual. (PM-PR-IM-01) Joint Nature Conservation Committee (JNCC). 2010. ANNEX A- JNCC guidelines for minimising the risk of disturbance and injury to marine mammals from seismic surveys. August 2010 http://jncc.defra.gov.uk/pdf/JNCC_Guidelines_Seismic%20Guidelines_Aug%202010.pdf Oslo and Paris Commission (OSPAR). 2006. OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic. OSPAR Recommendation 2001/1 adopted by OSPAR 2001 (OSPAR 01/18/1, Annex 5), Amended by OSPAR Recommendation 2006/4 (OSPAR 06/23/1, Annex). OSPAR Recommendation 2001/1 for the Management of Produced Water from Offshore Installations. http://www.ospar.org/v_measures/browse.asp?me nu=00520417000000_000000_000000 International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex I: Regulations for the Prevention of Pollution by Oil. London: IMO, consolidation edition, 2006. International Maritime Organization Ballast Water Management Convention. 2009 BHP Billiton. BHP Billiton Petroleum Marine Operational Controls. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Offshore Oil and Gas Development. World Bank Group, April 30, 2007. http://www1.ifc.org/wps/wcm/connect/bfc6f4004886590bb80afa6a6515bb18/offshoreoil.pdf?MOD=AJPERES&CACHEI D=bfc6f4004886590bb80afa6a6515bb18 International Maritime Organization (IMO). 2009. International Convention for the Prevention of Pollution from Ships (MARPOL). Revised MARPOL Annex VI and NOx Technical Code 2008: Regulations for the Prevention of Air Pollution from Ships. London: IMO, 2009 Edition. BHP Billiton. Carbon Price Protocol. Updated quarterly. Information pertaining to the protocol can be obtained from relevant BHP Billiton Petroleum Planning or Economics analysts. United Nations Environment Programme. 1992. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. http://www.basel.int/Portals/4/Basel%20Convention/docs/text/con-e-rev.pdf. International Finance Corporation. 2007. Environmental, Health, and Safety Guidelines for Onshore Oil and Gas Development. World Bank Group, April 30, 2007. http://www1.ifc.org/wps/wcm/connect/4504dd0048855253ab44fb6a 6515bb18/Final%2B-%2BOnshore%2BOil%2Band%2BGas%2BDevelopment.pdf?MOD=AJPERES&id=1323153172270 International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex IV: Regulations for the Prevention of Pollution by Sewage from Ships. London: IMO, consolidation edition, 2006. International Maritime Organization (IMO). 2006. International Convention for the Prevention of Pollution from Ships (MARPOL). MARPOL Annex V: Regulations for the Prevention of Pollution by Garbage from Ships. London: IMO, consolidation edition, 2006
6.
7.
8. 9. 10.
11.
12. 13. 14.
15.
16.
Controls 77
Data Reporting
Data Reporting Control 1
General Requirements
Intent
BHP Billiton Petroleum Exploration, Development and Production groups must define applicable reporting obligations and submit data to Group HSEC to allow monitoring of HSEC performance in accordance with Table 1 (Scope) and Table 2 (Authorities).
Table 1 Scope
Entity
CSG1 (BHP Billiton Petroleum Level including Marketing) Asset (Production Units, Joint Interest Units) Operation (Minerva, LBA, BlackHawk, Atlantis) Closed Operation (Development/Production) Project in Study Phase2 (Development) Project in Execution Phase (Devlopment/Production) Exploration Other Function or Group Function3
2
Notes
Hyg N N Y N N N N N Env Y Y Y Y4 Y Y Y Y Comm Y Y Y Y Y Y Y Y Fines Y Y Y Y Y Y Y Y
4 2
Reporting Requirements H&S Y Y Y Y Y Y Y Y
H&S - Health & Safety data Hyg - Hygiene data Env - Environmental data Comm - Community data Fines - Regulatory data
1
Activities undertaken by a Customer Sector Group that are not covered by an Operation. Major capital project in any phase of the group investment process. Data for Group Functions (GFs) must be reported through Facilities and Services, not individual GF. Through Asset or direct.
Includes WWD, Supply, IM, HSEC at CSG or Asset level as relevant
Table 2 Authorities
Endorse
Data parameters to meet internal and external reporting obligations Head of HSEC (Asset) Senior Manager (Operation) HSEC data reported to Group HSEC
Approve
Inform
Senior Manager (Operation) or Project Director (if Project) or President CSG
Implement the following for Exploration, Development and Production controlled activity in accordance with the BHP Billiton Petroleum HSEC Data Reporting procedure: 1.1 Determine data reporting entities (e.g., Douglas, CR Luigs, Macedon, GGO Project X). 1.2 Define and document reporting boundaries including classification of activities as controlled or monitored. 1.3 Determine HSEC data reporting obligations in the areas of Safety, Occupational Health & Hygiene, Environment and Community. 1.4 Collect, review, verify, authorize and submit applicable HSEC data listed in Control 2 (Reporting Requirements). 1.5 Submit HSEC data to Group HSEC by 7th calendar day of the month; submit data adjustments by the 15th working day.
1.6
Comply with the following for each applicable data stream: Document measurement methods for each data point including calculations or estimations. Define how reconciliation or adjustment of data is managed. Identify data sources (e.g., invoice, meter). Define relevant calibration and maintenance processes and records (e.g., 1SAP records). Define how review, authorization and verification of data will occur. Define process for changing, correcting and authorizing changes to previously reported or recorded data. Define process for documenting data variations from one reporting period to another (+/- 20%). Maintain a documented audit trail to support submitted data. Follow data collection framework defined in Table 3.
Controls 81
Reporting Requirements
Intent
BHP Billiton Petroleum groups collect, track and manage applicable HSEC data as defined in the HSEC Data Reporting procedure to meet internal and external reporting obligations. Data must be reported as per Table 3 (HSEC Data collection framework) using HSEC data interpretations found in the BHP Billiton Petroleum HSEC Glossary.
2.1 Health (hygiene) Audiometric assessments Exposures to defined agents >OEL 2.2 Exposures to noise greater than 85dB(A) Health (illnesses) New cases of cancers, tumors or neoplasms Poisoning and toxic effects Noise induced hearing loss Dermatitis or eczema Infectious and parasitic diseases Musculoskeletal occupational illness Silicosis Chronic Obstructive Pulmonary Disease, Asthma, Pneumoconiosis, other respiratory system and other diseases and disorders Safety Fatalities Lost time cases Restricted work cases Medical treatment cases Restricted work days per injury/illness Lost days per injury/illness Exposure hours 2.4 Number and value of safety related fines Environment Number and value of environment related fines. Emissions Greenhouse Gas (GHG), Ozone depleting substances, fluoride, Nitrogen Dioxide (NOx), Sulphur Oxide (SOx), and mercury. 2.6
Energy use Water input and output Waste Land use Unplanned and planned liquid releases 2.5 Biodiversity data Community Community perception survey(s) Cultural Awareness training Human Rights training Number of security personnel Community complaints dust, noise, odor and other related Value of in-kind and direct contributions Value of community programs. Information applicable to indigenous peoples Significant disputes associated with land use and customary rights Information applicable to artisanal mining on or near owned land inclusive of risks and plans Information applicable to resettlement activities Details of stakeholder consultation Sustainability Report metrics by 7th calendar day of July Other BHP Billiton Petroleum HSEC Data Requirements Comply with other BHP Billiton Petroleum data reporting requirements as defined in the BHP Billiton Petroleum HSEC Controls (e.g., Process Safety, MOC).
2.3
Table 3 - HSEC Data Collection Framework Discipline

Safety and Health Framework Title 29 Code of Federal Regulations Part 1904 Occupational Safety and Health Administration (OSHA) Global Reporting Initiative Reporting Framework (GRI) and GRI Mining and Metals Sector Supplement. Energy content, greenhouse emission factors and calculation methods (in order of preference): 1. Local regulatory frameworks, if applicable 2. 2006 IPCC Guidelines for National Greenhouse Gas Inventories Emission factors for calculating greenhouse gas emissions (electricity): - Minerals Council of Australia Water Accounting Framework: See BHP Billiton Petroleum HSEC Glossary for data interpretations Minerals Council of Australia Water Accounting Framework. See BHP Billiton Petroleum HSEC Glossary for data interpretations Community Global Reporting Initiative Reporting Framework (GRI) and GRI Mining and Metals Sector Supplement Water inputs, outputs and quality HSEC Data Examples Injury and illness
Environment
Air pollutants (NOx, SOx) Ozone depleting substances Waste Land
Energy Greenhouse gas emissions
Community complaints Stakeholder consultation Human rights issues and breaches
Controls 83
Significant Events
Intent
BHP Billiton Petroleum Exploration, Development and Production groups actual and potential significant events must be reported, investigated and action taken to prevent recurrence in accordance with the BHP Billiton Petroleum Event Management procedure
3.1 Implement the following for all BHP Billiton Petroleum actual significant events associated with controlled activity: Notify authorities in accordance with Table 4. Seek legal advice and apply legal professional privilege. Record the event within 48 hours of occurrence. Complete an event investigation appropriate to the severity within 28 calendar days of occurrence. Distribute a copy of the completed investigation report in accordance with Table 4. 3.2 Implement the following for all BHP Billiton Petroleum potential significant events associated with controlled activity: Record the event within 48 hours of occurrence. Complete an event Investigation appropriate to the severity within 28 calendar days of occurrence. 3.3 Implement the following for all BHP Billiton Petroleum actual significant events and aviation-related potential significant events associated with monitored activities: Notify authorities in accordance with Table 4 within 24 hours of the event being reported to BHP Billiton Petroleum.
Table 4 Significant Event Notifications

Occurrence of an actual significant event (controlled activities)
Individual informing
President CSG or Head of Group Function or Division President
Individual informed
Head of Group HSEC Vice President Media Relations Head of Group Investor Relations Vice President Corporate Communications
Completed Investigation Report for actual significant events (controlled activities)
Individual informed
Head of Group HSEC
Occurrence of actual significant events and aviation-related potential significant events (monitored activities)
Individual informed
Group Management Committee (GMC) Owner Head of Group HSEC
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Health, Safety, Environment and Community

BHP Billiton Petroleum HSEC Controls Accountabilities Table

Marine Operations Controls

Hazard and Risk Management Controls

Fatal Risk Controls

Crisis and Emergency Management Controls

Health and Hygiene Controls

Data Reporting Controls

D Health, Safety, Environment and Community Management System Framework

BHP Billiton Petroleum HSEC Portal

Hazard and Risk Mangement

BHP Billiton Petroleum Controls

Hazard and Risk Control 1

1.9 1.10 1.11

Hazard and Risk Control 2

6 Health, Safety, Environment and Community

Hazard and Risk Control 3

Governance and Compliance

BHP Billiton Petroleum Controls

Figure 1 Community Requirements by BHP Billiton Petroleum Project Lifecycle

Exploration and Identification Phase

Stakeholder Engagement and Documentation

Identify Business Opportunity

Social Baseline Study

Social Impact and Opportunities Assessment

Design Community Development Management Plan

Implement Community Development Programs

HSEC Screening includes sociopolitical and human rights

Stakeholder Engagement Management Plan (if critical)

Commence Field Work

Design Local Procurement Plan

Implement Local Procurement Plan

Complaints and Grievances Mechanism

Obtain Broad-based Community Support

Decision to Proceed to Develop

Implement Initial Community Projects

Implement Stakeholder Engagement Management Plan

Initial Community Perception Survey

Annual Review Stakeholder Engagement Management Plan

Community Perception Survey 3-yr.

Human Rights Impact Assessment Maplecroft <6.25

Human Rights Impact Assessment

Complaints and Grievances Mechanism

Complaints and Grievances Mechanism

Three-year HRIA Review

Evaluate Material Risk

Evaluate Material Risk

Human Rights Management Plan

Human Rights Training

Human Rights Management Plan

Human Rights Training

Annual HRMP Review

10 Health, Safety, Environment and Community

12 Health, Safety, Environment and Community

BHP Billiton Petroleum Controls

Crisis and Emergency Management

Crisis and Emergency Management Control 1

Crisis and Emergency Management Control 2

Emergency Response Structure

Crisis and Emergency Management Control 3

Crisis and Emergency Management Control 4

Crisis and Emergency Management Control 5

Training and Exercises