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SUMMARY

1. 2. 3. 4. 5. 6. 7. 8. 8.1 8.2 8.3 8.4 9. 9.1 9.2 9.3 9.4 9.5 9.6 10 . 10.1 10.2 10.3 11 . 11.1

INTRODUCTION APPLICABILITY DEFINITIONS AND ABBREVIATIONS REFERENCES AND OTHER RELEVANT DOCUMENTS HSE IMS OVERVIEW IMS STRUCTURE HSEPOLICY PLANNING HSE RISK A SSESSMENT ENVIRONMENTAL ASPECTS IN NORMAL OPERATING CONDITIONS LEGAL AND OTHER REQUIREMENTS IMPROVEMENT PROGRAM IMPLEMENTING ORGANIZATION STRUCTURE AND RESOURCES ALLOCATION HSE TRAINING COMMUNICATION DOCUMENTATION M ANAGEMENT OPERATIONAL CONTROL EMERGENCY RESPONSE CHECKING HSE MONITORIN NON CONFORMITIES, CORRECTIVE AND PREVENTIVE ACTIONS AUDIT REVIEWING MANAGEMENT REVIEW

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1.

INTRODUCTION Consistently with the Group culture, policies and commitments, Edison ASID developed a Health, Safety and Environment (HSE) Integrated Management System (IMS) with the following main objectives: Harmonizing the HSE management practices already in place in all its subsidiaries and affiliated worldwide; Sharing with contractors a set of common requirements to allow a proper management of HSE issues during operational activities; Guaranteeing compliance with applicable legislation in all countries where it operates; Ensuring a proper HSE management also in the lack of specific legal provisions; Go beyond legal compliance where economically and technically feasible.

To facilitate the achievement of these objectives on a global scale, the HSE IMS has been elaborated as a set of guidelines aiming at: establishing the HSE minimum requirements, from both an organizational and a technical standpoint, that Edison ASID intends to apply to its activities globally; providing the road-map to allow subsidiary and affiliated companies to tailor locally the system, via the development of country/branch/site/project specific procedures and working instructions whenever applicable.

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2.

APPLICABILITY The HSE IMS applies to all Edison ASID E&P activities in Italy and abroad suc h as: Acquisition; Exploration; Appraisal ; Development; Production and maintenance; Decommissioning; Abandonment.

Specifically the HSE IMS covers the following ASID processes: Scouting; Explorative seismic survey; Seismic survey evaluation; Explorative well survey; Well survey evaluation; Well development.

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3.

DEFINITIONS AND ABBREVIATIONS The principal terms and abbreviations used in the present document are reported below: ALARP ASID BU CA COMPANY CONTRACTOR EERA ENVIRONMENTAL ASPECT ENVIRONMENTAL IMPACT As Low As Reasonably Practicable Asset Hydrocarbons Business Unit Corrective action. Action to eliminate the cause of a detected non conformity EDISON Any entity or person whom EDISON has awarded a part of the work Evacuation, Escape and Rescue Analysis Element of an organizations activities or products or services that can interact with the environment Any change to the environment whether adverse or beneficial, wholly or partially resulting from an organizations environmental aspect Environmental Impact Assessments Exploration and Production Emergency Shut Down Hazard Identification Hazard and Operability Study Health, Safety and Environment Integrated Management System Job Hazard Analysis Lost Time Injury Frequency Non conformit. Non-fulfillment of a HSE requirement Non Governative Organisation Preventive action. Action to eliminate the cause of a potential non conformity Plan, Do, Check, Act Process and Instrumentation Diagrams Quantitative Risk Assessment Any entity or person whom CONTRACTOR has subcontracted a part of the work Total Reportable Case Frequency

EIA E&P ESD HAZID HAZOP HSE IMS JHA LTIF NC NGO PA PDCA P&IDs QRA SUBCONTRACTOR TRCF

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4.

REFERENCES AND OTHER RELEVANT DOCUMENTS For the development of the HSE IMS, reference has been made to the available internationally acknowledged standards covering the HSE aspects, to the approaches adopted by other Oil&Gas Companies. Specifically the following Standards have been considered: No. 1 2 3 Title ISO 14001: 2004 Environmental Management System OHSAS 18001: 1999 Occupational Health and Safety Management System ISO17776: Petroleum and natural gas industries Production installations Guidelines and tools for hazard identification and risk assessment

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HSE IMS OVERVIEW The development of the HSE IMS has been carried out following the PDCA cycle (Figure 5.1-1) approach which concepts are here below briefly summarized: Plan: analyze activities to establish the processes (objectives, actions etc.) required to continually improve you performance; Do: implement the processes; Check: monitor and measure the processes to verify its effectiveness and report the results to decision makers; Act: decide changes needed to continually improve the processes;

Fig. 5-1 - PDCA

Taking the PDCA cycle as a reference led to the identification of the fundamentals on which HSE IMS has been defined. These fundamentals are: An HSE Policy where the Edison ASID reports its commitments towards HSE performance continual improvement; The HSE risk assessment and the environmental impact evaluation of all Edison ASID E&P activities, including activities managed by contractors and subcontractors; Identification and planning of specific strategic HSE objectives and targets both at BU and local level ;

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Identification, dissemination and periodical updating of the legal and non-legal requirements applicable to activities carried out; Definition of Edison ASID HSE roles and responsibilities both at BU and local level; Definition and implementation of the HSE requirements for the operational control of day-to-day activities; Definition and implementation of training cycles (identification of needs, planning and execution of training sessions, effectiveness verification) to ensure competence and awareness of concerned personnel ;

Identification, planning and implementation of all the surveillance, monitoring, maintenance and review activities required to verify that the HSE management is in line with the defined IMS principles and rules and is in compliance with the legal applicable requirements, and necessary to guarantee the efficiency and efficacy of the system itself.

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6.

IMS STRUCTURE The further elaboration of such fundamentals within the PDCA frame yield to an HSE IMS structure as reported in Figure 5.2-1. Fig. 6-1 HSE IMS Structure

Considering otherwise the vertical dimension of its structure, the HSE IMS is organized in several documentation levels as depicted in Figure 5.2-2 and described here below: First level documentation: Edison ASID Policy already previously cited; Second level documentation: System Guidelines regulating the management activities required to guarantee the IMS efficiency and effectiveness (e.g.: risk assessment, improvement program, training, surveillance) ; Third level documentation: Operational Guidelines setting the minimum health, safety and environmental requirements to comply with while carrying out the day-to-day operational activities; Fourth level documen tation: Project/Branch specific procedures and working instructions tailoring at local level the IMS according to country/branch/site/project specifities.

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Fig. 6-2 HSE IMS document levels

The present manual reports in the following sections the contents of the HSE IMS System Guidelines while the Operational Guidelines are reported in another dedicated document.

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7.

HSE POLICY Edison ASID manages its activities pursuing excellence in the field of health, safety and environment. In this light, Edison ASID is committed to: Ensure compliance with health, safety and environment legislation applicable to all its activities in Italy and abroad; Prevent health and safety risks and environmental pollution; Seek a continuous improvement of the HSE performance of its activities through the definition of clear and quantified objectives, both at BU and local level ; Identify key HSE indicators to monitor the progress of continuous improvement process; Sensitize, inform and train personnel to ensure its involvement in the continuous HSE improvement process; Seek and take into consideration the standpoint of stakeholders while defining HSE management strategies, objectives and requirements; Request the participation and support of contractors for the fulfillment of the commitments above listed.

All Edison ASID employees, and especially its executives and managers in their respective areas of authority, must remain vigilant and regularly check that these commitments are complied with.

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8. PLANNING

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SUMMARY

1. 2. 2.1 2.2 3. 4. 4.1 4.2

DEFINITIONS AND ABBREVATIONS.........................................................................................................................................4 INTRODUCTION...............................................................................................................................................................................5 PURPOSE ..........................................................................................................................................................................................5 OBJECTIVE ......................................................................................................................................................................................5 REFERENCES AND OTHER RELEVANT DOCUMENTS .........................................................................................................6 RISK MANAGEMENT APPROACH..............................................................................................................................................7 RISK TEAM COMPOSITION AND SKILLS....................................................................................................................................8 TOOLS FOR HAZARD IDENTIFICATION AND RISK A SSESSMENT ...........................................................................................9 4.2.1 Experience/Judgement ........................................................................................................................................................ 10 4.2.2 Checklists............................................................................................................................................................................... 10 HAZARD AND RISK TERM INOLOGY...................................................................................................................................... 13 HAZARDS.......................................................................................................................................................................................13 RISK................................................................................................................................................................................................13 ACCEPTANCE CRITERIA............................................................................................................................................................14 ALARP ..........................................................................................................................................................................................14 RISK MANAGEMENT PROCESS............................................................................................................................................... 16 HAZARD IDENTIFICATION .........................................................................................................................................................18 RISK EVALUATION ......................................................................................................................................................................19 RISK ACCEPTANCE .....................................................................................................................................................................21 RISK REDUCTION MEASURES ....................................................................................................................................................24 RISK DOCUMENTATION AND REPORTING......................................................................................................................... 26 RISK ASSESSMENT REPORT .......................................................................................................................................................26 RISK REGISTER.............................................................................................................................................................................27 RESPONSE ACTION SHEET ........................................................................................................................................................28 HAZARD IDENTIFICATION TECHNIQUES ............................................................................................................................. 29 HAZARD IDENTIFICATION (HAZID)........................................................................................................................................29 HAZARD AND OPERABILITY ANALYSIS (HAZOP)................................................................................................................30 QUANTITATIVE RISK A SSESSMENT (QRA).............................................................................................................................30 JOB HAZARD ANALYSIS (JHA)..................................................................................................................................................32 CONTINUOUS IMPROVEMENT................................................................................................................................................. 35 ROLES AND RESPONSIBILITIES ........................................................................................................................................ 36 ASID BU DIRECTOR ...................................................................................................................................................................36 ASID HSE AND RISK COORDINATOR.......................................................................................................................................36 ASID BRANCH HSE AND RISK M ANAGERS.............................................................................................................................36 LEGAL CONSUEL ..........................................................................................................................................................................37

5. 5.1 5.2 5.3 5.4 6. 6.1 6.2 6.3 6.4 7. 7.1 7.2 7.3 8. 8.1 8.2 8.3 8.4 9. 10. 10.1 10.2 10.3 10.4

APPENDICES:............................................................................................................................................................................................ 38 APPENDIX A CHECKLIST.................................................................................................................................................................. 39

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APPENDIX B HAZARD IDENTIFICATI MATRIX.................................................................................................................... 44 ON APPENDIX C CONSEQUENCE CATEGORY DEFINITION.......................................................................................................... 45 APPENDIX D LIKELIHOOD SCALE DE FINITION ........................................................................................................................ 46 APPENDIX E RISK ASSESSMENT WORKSHEET ........................................................................................................................ 47 APPENDIX F RISK REGISTER........................................................................................................................................................... 48 APPENDIX G RESPONSE ACTION SHEET.................................................................................................................................... 49 APPENDIX H HAZID WORKSHEET................................................................................................................................................. 50 APPENDIX I HAZOP WORKSHEET................................................................................................................................................. 51 APPENDIX J JHA WORKSHEET ...................................................................................................................................................... 52

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ALARP ASID BU COMPANY CONTRACTOR EERA EIA E&P FEED HAZID HAZOP HSE HSEMS JHA P&IDs QRA SUBCONTRACTOR As Low As Reasonably Practicable Asset Hydrocarbons Business Unit Edison Any entity or person whom Edison has awarded a part of the WORK Evacuation, Escape and Rescue Analysis Environmental Impact Assessments Exploration and Production Front End Engineering Design Hazard Identification Hazard and Operability Study Health, Safety and Environment Health, Safety and Environment Management System Job Hazard Analysis Process and Instrumentation Diagrams Quantitative Risk Assessment Any entity or person whom CONTRACTOR has subcontracted a part of the WORK

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2. 2.1

INTRODUCTION Purpose Edison is aware of the importance to identify and manage risks throughout all stages of the business lifecycle. All HSE risks associated with operations should be managed to a consistent and acceptable level. Edison ASID has developed this HSE Risk Assessment guideline to provide the overall framework for the management of HSE risks within the business and operations in order to identify, prevent, control and mitigate risks to personnel, property, the environment and public arising from processes, activities and materials used or encountered in them. The purpose of this guideline is to: Establish a common and consistent approach to HSE risk management; Ensure that all risks to people, environment, assets/production loss and public have been systematically identified and assessed; To provide a means to monitor and reduce risks to As Low As Reasonably Practicable (ALARP) throughout the activities execution; To outline the documents to be produced to report risk control activities.

2.2

Objective The objective of the HSE Risk Assessment guideline is to identify the methodology and criteria to manage risks at appropriate level of accuracy to be performed during Edison ASID E&P activities in Italy and abroad such as: Acquisition; Exploration; Appraisal; Development; Production and maintenance; Decommissioning; Abandonment.

Specifically the risk assessment should cover the following ASID processes: Scouting;

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Explorative seismic survey; Seismic survey evaluation; Explorative well survey; Well survey evaluation; Well development. Edison is committed to systematically identify and assess risks arising from its activities and operations, under normal, abnormal a emergency conditions. Besides, the risk assessment nd must include all the temporary phases that are foreseen in the life of the installation such as anomalous conditions dictated by maintenance activities. Comprehensive risk control measures will be identified to control and mitigate possible consequences of adverse hazardous scenarios through specific design features and application of appropriate standards and procedures.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.5.1 OHSAS 18001: 1999 Occupational Health and Safety Manageme nt System 4.5.1

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4.

RISK MANAGEMENT APPROACH Edison ASID approach to the Risk Management can be summarized as follows: Risk Analysis: Systematic identification of the Hazards which may affect or arise from Edison ASID activities and from the materials which are used or encountered in them; Risk Evaluation: Assessment of the associated risk arising from the identified hazards; Risk Reduction/control: Identification and implementation of risk-reduction measures in order to eliminate or at least reduce the risks where this is deemed to be necessary; Documentation of the Hazards and Risks together with the risk-reduction measures (Risk Assessment Report, Risk Register, Response Action Sheets). The following Figure outlines Edison ASID Risk Management approach. Fig.4-1 Risk Management Approach

Is Edison ASID interest to reduce risks to ALARP and in compliance with Edison ASID Risk acceptance criteria (refer to section 6.4 for more information) which reflect

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local conditions and circumstances, the balance of cost and benefits and the current state of scientific and technical knowledge. The above risk management approach must be applied to all the following Edison ASID processes: Scouting; Seismic Survey; Seismic Survey Evaluation; Well Survey; Well Survey Evaluation; Well development. Edison approach for hazard identification and risk assessment must: Be proactive in its scope and not applied only once incidents have occurred; Be consistent with operating experience and risk control measures employed; Be as early as possible in order that sufficient time can be given to the study before determining the most appropriate solution to manage; Provide input into the determination of facility requirements (training needs, administrative, engineering or operational controls etc.); Involving personnel at all organisational levels.

4.1

Risk Team Composition and Skills Hazards and risk identification is normally performed by a specific Risk Team. The Risk Team is composed by an adequate number of members and should have the following characteristics: Sufficient knowledge to recognise and identify all the HSE issues related with Edison ASID activities and operations subjected to the Risk Assessment; Skilled in the Risk techniques and objectives of the Risk Assessment; Knowledgeable about the design, operation and maintenance of the facilities and activities under consideration. The Risk Team is usually composed by a Team Leader who leads the Risk Team and the Risk Assessment session, a Secretary who records accurately the discussions to ensure that the minutes fully reflect the points identified during the Risk Assessment and the Partecipants who contribute and give inputs to the discussion.

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The Team Leader requires a high level of technical and managerial skills and sufficient years of experience in the Risk Management. The role of the Team Leader is critical to the success of the Risk Assessment since he is required to: Lead the team through the Risk Management Process; Prompt the brainstorming effort; Manage the discussion without compromising the creativity of the process; Identify the key issues as they are raised by the team. The Secretary and Participants should include experienced personnel (with experience in Edison ASID activities such as seismic survey, exploration activities, drilling campaign, abandonment etc.) available from the following disciplines: Project engineering; Process engineering; Production engineering; Operations; Specialists such as Reservoir Engineers and HSE Advisers. It is preferable but not essential that some of the Partecipants have been to a Risk Assessment meetings before. If a large number of the team are new to the Risk Management or have not attended a meeting for a long time, then a short pre-meeting should be held to describe and demonstrate the basic techniques and principles of the Risk Assessment.

4.2

Tools for Hazard Identification and Risk Assessment The level and extent of hazard identification and risk assessment activities vary depending on the scale of the installation and the stage in the installation life cycle when the identification and assessment process is undertaken. For example for complex installations (e.g. large production well) detail studies are required while for simpler installation or installation in the early design phases it may be possible to rely on application of recognized codes and standards. Hazard identification and risk assessment activities may need to be reviewed and updated if significant new issues are identified or if there is significant change to the installation. Hazards can be identified and assessed in a numbered of ways. Hazard identification and risk assessment tools are the following (Fig.4.2-1): Experience/judgement; Checklists;

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Codes and standards; Hazard identification techniques. Figure 4.2-1 Hazard Identification and Assessment Tools

HAZARD IDENTIFICATION TECHNIQUES CODES AND STANDARD

Increasing Level of Detail

CHECKLISTS

EXPERIENCE/ JUDGEMENT

4.2.1

Experience/Judgement The knowledge and expertise of staff, having appropriate experience, is used for hazard identification and assessment. This is particularly useful where the activity under consideration is similar to E&P business activities undertaken previously at the same or different locations. Practical staff experience gained in the field and feedback from incidents and near misses is invaluable. Refer to section 4.1 for more information on the Risk Team skills.

4.2.2

Checklists Checklists ensure that known hazards and threats have all been identified and assessed. The use of checklists, however, must not be allowed to limit the scope of review. They are normally drawn up from standards and operational experience and focus on areas where the potential for mistakes is high or where problems have occurred in the past. Checklists are easy to apply and can be used at any stage in the project life cycle.

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Main categories of a typical checklist can be: External and environmental hazards Natural and Environmental Hazards; Created (Man-made) Hazards; Effect of the Facility on the Surroundings; Infrastructure; Environmental Damage. Facility hazards Control Methods/Philosophy; Fire and Explosion Hazards; Process Hazards; Utility Systems; Maintenance Hazards; Construction/Existing Facilities. Health hazards Health Hazards. Project implementation issues Contracting Strategy; Hazards Recognition and Management; Contingency Planning; Competency. Refer to Appendix A for a checklist model reporting the above mentioned categories and guide work examples. 4.2.3 Codes and Standards Codes and Standards reflect collective knowledge and experience, accumulated on the basis of national or international operations. They generally focus on hazard assessment and control, since the hazard have already been identified and the standard methods for their control and mitigation defined. Codes and standards usually contain information on hazards applicable to a particular type of operation. For example for drilling and production equipment an ISO Standard can be use. In some cases compliance with prescriptive standards alone will reduce risk to 'as low as reasonably

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practicable'. Similarly, the acceptability of emissions or discharges to the environment or release of agents harmful to health can be assessed by reference to environmental quality standards and occupational health exposure limits. The following list gives an example of Codes and Standards useful in the Risk Analysis: 4.2.4 IEC 60300-3-9: Risk analysis of technological systems; EN1050: Safety of machinery Risk assessment; ISO17776: Petroleum and natural gas industries Production installations Guidelines and tools for hazard identification and risk assessment; NORSOK Z-013: Risk and emergency preparedness analysis; EN1441: Medical Devices - Risk Analysis. Hazard Identification Techniques Identification of the main hazards is important in the early stages of a design, in order to allow design decisions to be made which reduce risk. HAZID may be u seful to achieve this objective, while at later stages in a design QRA and HAZOP may be found useful. Evaluation of hazards and risks associated with construction tasks and operations, including inspection, testing and maintenance are undertaken using JHA and HAZOP techniques. All evaluation techniques provide results which are themselves subject to a range of uncertainty and consequently the results should be compared with the judgement of experienced personnel. Where there is felt to be potentially significant uncertainty in a key element of the evaluation, the use of alternative techniques should be investigated to validate results. Section 8 of this document describe some Hazard Identification Techniques in current use.

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5.

HAZARD AND RISK TERMINOLOGY This section provides an overview of the more common terminology and concepts used in the analysis of hazards and the determination of risk.

5.1

Hazards A hazard is defined as: The potential to cause harm, ill health or injury, damage to property, plant, products or the environment, production losses or increased liabilities. The concept that a hazard has the potential for something undesirable to happen rather than the actual event itself is important in understanding the approach to be adopted toward hazard identification and risk assessment. The terms acute and chronic are often used to differentiate between hazards with the potential to cause harm as a result of relatively short-term events such as oil spills, fires and explosions (acute hazards) and hazards which arise from long-term events such as continuous discharge and occupational exposure (chronic hazards). A hazardous event occurs when the hazards potential to cause harm is realized.

5.2

Risk Risk is define as: the product of the probability that a specified undesired event will occur and the severity of the consequences of the event. Risk = Probability x Severity of the consequences To determine the risk of a specific hazardous event taking place therefore requires information on the likelihood (possibility of something happening) of the event taking place and the severity of the adverse consequences that could be expected to follow from it. Risk is a term which combines the chance that a specified undesired event will occur and the severity of the consequences of the event.

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5.3

Acceptance Criter ia In order for Edison ASID to make decisions on the results of a risk assessment (determine whether the risk is fully acceptable, completely intolerable or somewhere in between) acceptance criteria are established. Edison ASID Acceptance Criteria express: the level of health, safety and/or environmental performance deemed acceptable for a given period or phase of activities. They may be defined both in quantitative and qualitative terms. Edison ASID acceptance criteria: Reflect best practice as contained in national or international standards reflect Edison ASID strategic and organisational objectives Take local condition under consideration in order to reflect differing approaches to risk management; factors which have an effect on the criteria are geographical location, environmental conditions, political and/or economic constrains and societal attitudes Are acceptable to Edison S.p.a., financial investors, regulators and society.

5.4

ALARP Edison ASID requires that residual risks associated with Facilities or activities have been reduced to ALARP . The definition of ALARP is: As low as reasonably practicable To reduce a risk to a level which is as low as reasonably practicable involves balancing reduction in risk against the time, trouble, difficulty and cost of achieving it. The ALARP level represents the point, objectively assessed, at which the time, trouble, difficulty and cost of further reduction measures become unreasonably disproportionate to the additional risk reduction obtained. ALARP principle is represented graphically in the Figure below:

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Figure 5.4-1 ALARP principle

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6.

RISK MANAGEMENT PROCESS To identify and assess risks, Edison ASID shall implement the following Risk Management Process, a continuous process, which typically implies four major steps: 1 - Identification and definition of hazards and their potential effects; 2 Evaluation (assessment) of risks and effects arising from the identified hazards either qualitatively or quantitatively in terms of the likelihood/probability of occurrence and severity of the consequences; 3 Assessment of tolerability of risk to personnel, environment, assets and public by comparing risk level with Edison ASID relevant acceptance criteria; 4 Identification of risk reduction measures needed to reduce the likelihood/probability (prevention) and/or the consequences of an accident (control and mitigation). This Process must be conducted regularly on all Edison ASID Projects and existing Facilitys operations and shall also be initiated when activities change. The above risk management process must be conducted during all Edison ASID processes and specific phases as shown in the following Table: Table 6-1 Edison ASID main processes and phases Process Scouting Siesmic Survey Phases Desk study and Field Trip Contractor selection Operative phase Decommissioning Pre-engineering Technical feasibility Study FEED Operative planning Contractor selection Operative phase Decommissioning

Seismic Survey Evaluation Well Survey

Well Survey Evaluation

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Well Development

Well development study Contractor selection Design Project Management Team Selection Operative phase Well production Decommissioning

The Risk Management Process is represented graphically in Figure 6 Guidance on each -1. step is provided in the following sections. Fig. 6-1 - Risk Assessment Process

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6.1

Hazard Identification Before the risks associated with a particular activity can be assessed, it is first necessary to systematically identified the hazards which may affect, or arise from, the particular operation under consideration. The identification of potential HSE hazards and effects covers all phases of Edison ASID processes and related activities at the appropriate level of accuracy, taking also into account all phases in the life of any installation including temporary conditions dictated by maintenance activities. For each activity, the most significant hazards should be identified in terms of: Potential sources of incidents; Human health hazards; Environmental hazards; Company Reputation hazards; Possibility of breaching applicable laws and rules; Possibility of violating Edison Policy, assigned objectives and targets; Possibility of violating identified expectancy of stakeholders; Potential sources of economic loss. Example of HSE aspects to be considered are: Fire and explosion; Exposure to chemical; Driving; Asphyxiation and electrocution; Human factors; Emissions; Wastes; Noise; Vibration; Water; Atmosphere; Ecosystems alteration. It is important to underline tha t the hazard indentification addresses specific project activities. For each project the main activities and subactivities should be defined in order to easily identify the specific related hazards. An example of matrix for the hazard identification is provided in Appendix B.

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This task is often an iterative process and discussions and decisions must be recorded. This stage can be the most cost-effective time to eliminate potential major hazards. The identification of the hazards and effects should be performed using adequate personal experiences (Refer to section 4.1 for more information on the Risk Team skills), checklists, codes and standards references and specialized hazard identification techniques. Refer to Section 8 of this document for more information on the different techniques for hazard identification.

6.2

Risk Evaluation Once the hazards have been identified, the risks they present to personnel, environment, assets and people are evaluated. Risk evaluation requires consideration of both the severity of consequences of the potential hazard and the likelihood of the realisation.

6.2.1

Consequence Evaluation The consequences are those of credible scenarios (taking the prevailing circumstances into consideration) that can develop from the release of a hazard. The consequence estimates are based on envisaged scenarios of what might happen. Hazards can have consequences in all four consequence categories: Personnel: Harm to the health and safety of personnel involved in Edison ASID operations and activities; Property Damage and/or Loss of Revenue: Damage to Edison ASID physical asset and/or impacts on projects (failure to meet project objectives) and/or production losses; Environmental: Damage to the environment deriving from Edison ASID operational activities or from incidents; Public: Damage to the general public which may produce adverse public reaction with consequences on Edison S.p.a.reputation. It is important to remember that most activities which carry some degree of risk, entail risk to more than one of the above categories. All possible effects of a hazard must be considered together. Refer to Appendix C for Edison ASID detailed definitions of the consequence categories.

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6.2.2

Frequency/Likelihood Evaluation The frequency estimates are based on historical information that such a scenario has happened under similar conditions in the same business and/or within Edison ASID, knowing full well that circumstances will never be exactly the same. Examples of likelihood scale definitions are provided in Appendix D.

6.2.3

Risk Determination Having determined the probability of the different scenario and the consequences arising from that event, it is possible to represent the severity of the risk graphically using a Risk Matrix. To assess the risk the following sequence should be followed: first the potential consequences are estimated and only thereafter the likelihood of such consequences occurring are estimated. Edison ASID developed the following Risk Assessment Matrix (Table 6.2.3-1) where: The vertical axis represents the measure of likelihood of the occurrence of an undesired event. The scale of likelihood from 0.5 to 10 is used to indicate the increasing likelihood; The horizontal axis represents the consequence severity that could occur with that event. The scale of consequences from "1" to "100" is used to indicate increasing severity. The intersection of the chosen column with the chosen row is the risk level. The overall risk is classified according to which of the consequences has the highest rating. The numbers in each box of the matrix give an index of the severity of the determined risks and a priority order for their management. High numbers correspond to more severe risks which need to be managed firstly.

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Table 6.2.3-1 Risk Matrix

6.3

Risk Acceptance As soon as the level of risk is defined in the risk matrix, its necessary to assess its acceptability (tolerability) which means the comparison of the risk level with Edison ASID identified acceptability/tolerability thresholds in order to determine whether the risk is fully acceptable, completely intolerable or somewhere in between. The Risk Matrix and Risk Acceptability criteria have been defined and approved after a detailed analysis of Edison ASID Management of the historical databases and past experiences of Companies and industries operating in the same business. ASID BU present and past experiences, HSE Policy and strategic objectives have also been considered.

6.3.1

Risk Acceptability Criteria Edison ASID established three Risk acceptability thresholds which are clearly indicated on the Risk Assessment Matrix by the three different shaded-in areas (Fig. 6.3.1-1).

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Fig. 6.3.1-1 Risk Matrix with Risk Acceptability Criteria

Each of the three coloured regions in the Risk Matrix identify the limits of Edison ASID risk acceptability/tolerability (Table 6.3.1-1). The three different colours classify risks as Low, Medium or High. Table 6.3.1-1 Risk Acceptability Criteria
The level of risk is acceptable and generic control LOW RISK measures are required to avoid deterioration. (Continuous Improvement) The level of risks can be acceptable only once riskMEDIUM RISK reduction measures have been identified and (Risk reduction Measures/ALARP) implemented. Application of ALARP. The level of risk is not acceptable and risk control measures are required to mitigate the effects and to move the risk level to the yellow area. Complementary risk analysis required (QRA, HAZOP etc.) HIGH RISK (Intolerable Risk)

The numbers in each box of the risk matrix give an index of the severity of the determined risks and a priority order for their management. High numbers correspond to a major severity of risk. For example if two risks follow in the red area (high risk) one in the 160 box and the other one in the 500 box, the second risk is the most severe and need to be manage firstly.

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The results of the risk assessment should be recorded in the Risk Assessment Worksheet and Risk Register (refer to section 7 for more information) together with the data sources and assumption used. This record should be used by operations personnel developing procedures and issuing work instructions and by key people to communicate the hazards that have been identified and the measures that are in place to prevent and mitigate the risk of occurrence. The response required for each risk level is summarised in the table below: Table 6.3.1-2 Risk Ranking Response
Management Authority HSE Risk Ranking Project /Operations Manager Manager LOW RISK No further action or studies required but the risk must be kept monitored. Facility management should document all risk studies. MEDIUM RISK Document risk studies, potential hazards and risk reducing measures. Facility management should evaluate risk reducing measures and implement feasible measures. Facility management shall demonstrate that risk are ALARP and seek ASID HSE and Risk Manager concurrence if risks will not be reduced to lower ranking in a reasonable time frame. ASID BU Director ASID HSE and Risk HIGH RISK Document risk studies, potential hazards and risk reducing measures. Quantitative risk analysis studies are mandatory. Risk reducing measures are mandatory. Identity additional risk reducing measures and implement all feasible measures. ASID BU Director and ASID HSE and Risk Coordinator are required to authorize the deviation if risk will not be reduced to a lower category in a reasonable time frame. Opportunities to reduce risks shall be reviewed annually and continued operations re -authorised. Response

/Facility Management ASID Branch HSE and Risk Manager

Coordinator

Edison ASID Branches shall not engineer, build, operate or acquire Assets, Facilities or operations which have been evaluated as having high risk, without written authorization from Edison ASID BU Management. Such high-risk Facilities or operations must be subject to on-

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going r reduction and/or management efforts, which are reviewed and approved by ASID isk BU Management on yearly basis.

6.4

Risk Reduction Measures Risk reduction measures include preventative measures (reduction of the likelihood) and mitigation measures (reduction of severity of consequences). Risk reduction measures also include recovery preparedness measures which address emergency procedures as well as restoration and compensation procedures to recover. Risk reduction measures introduce controls in order to reduce and/or, where possible, to remove the risk. Figure 6.5-1 indicates the Risk Reduction criteria which should follow the alternatives in the shown sequence of preference Fig. 6.4-1 Risk Reduction Criteria

INTRODUCE CONTROLS

REDUCE RISK (Mitigation Measures)

REMOVE RISK

RISK REDUCTION CRITERIA


The remedial measures needed to control each of the intolerable risks should be based on good safe working practice to reduce the residual risk to a level which is practible. The following concept are used to reduce risk: Reduction: reduce the hazardous situations or the frequency or duration of exposure; Substitution: Substitute hazardous materials with less hazardous ones; Attenuation: using the hazardous materials or processes in a way that limits their hazard potential; Simplification: making the plant and process simpler to design, build and operate.

Factors that will influence the selection of measures to reduce the risk include: The technical feasibility of the risk reducing measures; The contribution of the risk reducing measures;

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The costs and risks associated with implementing the measure; The degree of uncertainty associated with the risk, or the risk-reduction technique, including human factors. Evaluation of risk-reducing measures should always be based on sound engineering principles and common sense. The following aspects should also be observed: local conditions and circumstances, the state of scientific and technical knowledge relating to the particular situation, and the estimated costs and benefits. For each risk identified risk which required the identification and implementation of mitigation measures a Response Action Sheet should be filled. Refer to section 7.3 for more information on the Response Action Sheet. Edison should also establish methods for monitoring the required risk reduction measures to ensure both the effectiveness and timeliness of their implementation. Effective risk reduction measures and follow-up require visible commitment of management and on-site supervision, as well as the understanding and ownership by operations personnel.

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7.

RISK DOCUMENTATION AND REPORTING Edison ASID should develop, maintain and update the following specific project risk documentation: Risk Assessment Report; Risk Register; Response Action Sheet.

7.1

Risk Assessment Report When a Risk Assessment is carried out a Risk Assessment Report should be produced. The Risk Assessment Report describes the overall Risk Assessment Process and the methodology and criteria utilized. A typical table of contents of a Risk Assessment Report is the following: Summary and conclusions; Objectives and scope; Limitations, assumptions and justification of hypotheses; Description of relevant parts of the system; Analysis methodology; Hazard identification results; Models used, including assumptions and validation; Data and their sources; Risk estimation results; Sensitivity and uncertainty analysis; Discussion of results (including discussion of analytic difficulties); References; Risk Assessment Worksheet (Attachment). All risks identified in the risk assessment are listed in the Risk Assessment Worksheet attached at the end of the Risk Assessment Report. The Risk Assessment Worksheet shows the results of the Risk Assessment process carrie d out during the formal meeting and it includes: Activity description; Subactivity description; Hazard identified; Hazard effect; Control measures already in place; Risk level;

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Action to be taken; Residual Risk level; Action by; Action date. Appendix E shows the Risk Assessment Worksheet.

7.2

Risk Register The Risk Register contains all the medium and high risks identified in the risk assessment process captured in the risk assessment report. The Risk Register is the log/database where all unacceptable risks which required reduction measures are logged, along with their current status and action required, and tracked through to cl sure. o The Risk Register is a live document and must be maintained and updated throughout all Edison ASID main processes and activities from seismic survey to well development and must reflect all significant changes in operations and in the business. The Risk Register is the main means for recording, tracking and controlling risks throughout a project execution. Specific objectives of the Risk Register are listed below: Assign responsible persons and due dates for the Actions in the Risk Register; Ensure all Actions are communicated to the responsible person/organisation; Allow tracking of all Actions status; Provide a means to ensure the Risk Register is up to date; Validate the completion of identified Actions. The Risk Register contains the following information: Activity/Hazard; Risk Rank; Action; Residual Risk; Justification for closure; Action Party; Action Date; Status.

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A Risk Register example is given is Appendix F. 7.3 Response Action Sheet For each risk identified in the Risk Register a Response Action Sheet should be filled in to demonstrate how Edison ASID implemented the mitigation measures in order to reduce the risk. The Action Response should be completed and returned to enable the updating of the Risk Register. The Action Response Sheet should be filled in by the Project Manager during the project The Action Response Sheet is specifically prepared for the responsible person to whom actions has been addressed. A due date is also assigned for the action to be completed. Periodical Action response verification is made by all the HSE and Risk Project Manager to check the status of the action. A ctions are only considered closed when the HSE and Risk Project Manager signs and agrees the action has been implemented. execution.

Refer to Appendix G for the template of the Response Action Sheet. The Action Response Sheet contains the following information: Risk Raised By (HAZID, QRA, etc.); Relevant Project Phase (Design, Installation, Commissioning, etc.); Consequence Area (Personnel, Property, Environmental, Public); Frequency/Likelihood; Risk rank; Hazard/cause; Controls in place; Actions to be conducted; Person responsible for the Action; Required Date for completion of the Action; Response to Actions; Current status of actions.

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8.

HAZARD IDENTIFICATION TECHNIQUES The techniques used in the risk management process will vary depending upon the project phase, operational mode, or the complexity of system or Facility being subject to the risk management process. Besides the selection of the appropriate techniques depends upon the information available and the phase of the project or maturity of the operation. The following Hazard identification techniques for Risk Assessment are presented hereinafter: Hazard Identification (HAZID); Hazard and Operability Analysis (HAZOP); Quantitative Risk Assessment (QRA); Job Hazard Analysis (JHA). For further information about additional techniques of Risk Assessment refer to International Standard ISO 17776: 2000.

8.1

Hazard Identification (HAZID) HAZID (Hazard Identification) is a structured brainstorming technique that is particularly useful in the early stages of a development. It is therefore likely to be the first formal HSE-related study for any new project. The study should be held as soon as enough general information is available. The objective of the HAZID study is to recognise and identify the issues rather than to discuss the consequences and propose solutions. Hence the duration of a study would normally be short, (a typic al study duration for a major development would be two to three days). This represents a very efficient use of time and is a significant advantage over alternative identification techniques. The HAZID technique is: A means of identifying and describing occupational HSE hazards and threats at the earliest practicable stage of a development or venture; A meeting employing a highly experienced multi-discipline team using a structured brainstorming technique, based on a checklist of potential HSE issues, to assess the applicability of potential hazards; A rapid identification and description process only, not a forum for trying to solve potential problems.

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During the study, all hazards which are identified by the team are minuted and described on a HAZID Worksheet (see Appendix H). Recommendations for remedial action are not normally part of the HAZID scope although the team may however use the 'controls' section of the worksheet to propose alternative solutions or methods of reducing risk.

8.2

Hazard and Operability Analysis (HAZOP) The HAZOP analysis is primarily used for identifying safety hazards and operability problems of continuous process systems (especially fluid and thermal systems). It is also used to review procedures and other sequential operations. In HAZOP Analysis an interdisciplinary team uses a systematic approach to identify hazards and operability problems occurring as a result of deviations from the standard process conditions. The team analyses the effects of any deviations and determine possible causes for the deviation (operator error, blockage in outflow etc.) the consequences of the deviations (spillage of liquid, pollution etc.) and the safeguards in place to prevent the deviation (level of control, pipe overflow etc.). If the causes and consequences are significant and the safeguards are inadequate, the details are recorded so that follow-up action can be taken. The HAZOP results are the teams findings which include the hazards and operating problems identified, recommendations for changes in design, procedures etc. to improve the system and recommendations to conduct studies in areas where no conclusion was possible due to lack of information. The objective of the HAZOP study is to identify possible problems areas and to make recommendations as to how the specific problems may be resolved. Before a HAZOP analysis can be carried out is necessary to assess the detailed information concerning the design and operation of a process. The HAZOP analysis requires considerable knowledge of the process, instrumentation and operations of the existing facilities. At the end of the HAZOP study the HAZOP Worksheet should be filled in (refer to Appendix I).

8.3

Quantitative Risk Assessment (QRA) QRA is the generic term used for techniques which allow the risk associated with particular activity to be estimated in absolute quantitative terms (numerically) rather than in relative terms

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such as high or low. It may be used to determine all risk dimensions, including risk to personnel, risk to the environment, risk to the installation and/or the assets and financial interests. In general the process involves the following steps: Identification of Hazards which is usually undertaken using some form of HAZID; Determination of a set of representative hazardous e vents; Estimation of the frequency of occurrence of the representative hazardous event. This is normally done by reference to appropriate historical data; Evaluation of the direct effects of the hazardous event. This step involves the use of mathematical m odels. The end result of this phase is a series of end events, together with their estimated frequency of occurrence; Evaluation of the consequences which involves assessing the consequence of the end events. The outcome of this phase is a series of cons equences arising from a particular hazardous event, togheter with their estimated frequency of occurrence; Risk summation: the overall frequency of each of the consequence is determined by summing up the relevant frequencies for all the possible end events. The QRA should only be used as a tool to assist in decision making and not as a mechanistic means of deciding a course of action. The application of QRA in not necessarily limited to large, complex and expensive studies. It is a technique which can be used quickly and cheaply to help structure a solutions to problems for which the solution is not intuitively obvious. Risk is often defined as a function of the chance that a specified undesired event will occur and the severity of the consequences of the event. For QRA purposes, chance can be expressed as frequency or probability of an occurrence. If no attempt is made to estimate the chance, we may be driven by the consequence into investing heavily on risk reduction measures which are ineffective. This is illustrated in Figure 8.3-1 The risk curve (shaded) indicates the area in which effective risk reduction measures can be taken.

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Fig. 8.3-1 Determination of Risk

On the left side of the curve the consequences are too small to cause concern, regardless of the probability. On the right side the consequences could be dramatic but the probability is so low that it would be more effective to invest in those risk reduction measures which concentrate on the events contributing to the peak of the risk curve.

8.4

Job Hazard Analysis (JHA) Job Hazard Analysis (JHA) is the application of the hazards and effects management process at the task level, identifying and assessing the hazards of each element of the task and defining appropriate controls and recovery measures. The methodology is derived from the work study technique known as Task Analysis, and is known variously as Job Safety Analysis (JSA), Work Safety and Health Analysis, Activity Risk Assessment (ARA). JHA is appropriate for any task where the hazards and control measures need to be formally assessed. The most common areas of application are: routine tasks that have the potential for serious incidents; routine tasks having a history of incidents, including near misses; new tasks or tasks introducing new work methods; routine tasks being carried out in unusual circumstances;

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non-routine or one-off tasks; as a verification of the hazard management elements of an established work procedure. The first step of a JHA is to break down the task into its basic steps, describing what is to be done, and in what sequence. If more than 15 steps are identified and it is not feasible to merge some steps without losing essential detail, it is recommended that the task itself is split and separate JHAs are conducted for each part.

Each step description should: provide a statement of what is to be done, without reference to how it is to be done or who is to do it; begin with an action verb (install, remove, assemble etc); end with the subject being discussed (pump, valve, hoist etc); omit reference to hazards. The key activity in a JHA is to determine the hazards and potential incidents associated with each particular step. Results of the JHA should be tabulated in the JHA Worksheet (refer to Appendix J). A copy of this summary should be available at the workplace for use as a site reference. The JHA process is represented graphically in the Figure below.

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Fig. 8.4-1 JHA Process

To ensure that the experience and information gained by doi g the job remains available to n others who may be required to perform the same or similar jobs, the JHA team should, at the completion of each job, review and update the original JHA.

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9.

CONTINUOUS IMPROVEMENT Periodically Edison ASID Risk Assessment Process should be reviewed and improved as part of the continuous improvement process. This review should in addition be performed, if one of the following conditions occurs: the activities being carried out by Edison ASID have, or are going to be changed; the risks associated with the activities changed, or are going to; new projects start in new areas; new or amended legislation is issued; an organisational restructuring takes place. Edison ASID should maintain procedures for planning and controlling changes, both permanent and temporary, in people, plant, processes and procedures, to avoid adverse consequences. The procedures should be suitable to address the HSE issues involved according to the nature of the changes and their potential consequences. Edison should establish separate plans for the HSE management of new operations (relating, for example, to acquisitions, developments, products, services and processes), or modified operations where the modification introduces significantly different HSE concerns.

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10.

ROLES AND RESPONSIBILITIES This section provides a description of Edison ASID specific roles and responsabilities for the HSE Risk Management.

10.1

ASID BU Director The BU Director has the responsibility to establish an effective and efficient risk management program within the Business Unit.

10.2

ASID HSE and Risk Coordinator The ASID HSE and Risk Coordinator shall be the focal point for all Edison ASID risk management activities in Italy and abroad. He/she shall ensure the awareness and implementation of this guideline to all ASID levels. HSE and Risk activities involvement include: HSE risk assessment guideline awareness to all Edison ASID Branches in Italy and abroad; Ensuring that adequate funds and human resources are available for the implementation of this risk assessment guideline; Risk technical and operational assistance to ASID Branch HSE and Risk Managers; Coordination with ASID Branch HSE and Risk Managers risk related issues.

10.3

ASID Branch HSE and Risk Managers The ASID Branch HSE and Risk Managers shall be responsible for conducting and implementing HSE risk assessment procedure at all Branch levels and in all Projects carried out under their area of responsibility. The ASID Branch HSE and Risk Managers shall ensure that all health and safety risks are identified and controlled during all specific branch projects. ASID Branch HSE and Risk Managers shall ensure: Awareness and compliance of the HSE risk assessment guideline by Contractors, Subcontractors and Suppliers; That all project risk assessments have been carried out prior starting; HSE and Risk Training; Project HSE and Risk Meetings; That formal Risk Assessments are carried out during projects;

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Interface and coordination with ASID HSE and Risk Coordinator; Monitoring and reporting of HSE and risk performance.

10.4

Legal Consuel Edison ASID BU may obtain advice from legal counsel regarding risk management. Legal counsel shall ensure the awareness of the consequences of risks posed by Edison ASID activities in order to determine whether to independently conduct an analysis of potential liability in anticipation of probable litigation (whether as plaintiff or defendant).

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APPENDICES: APPENDIX A CHECKLIST APPENDIX B HAZARD IDENTIFICATION MATRIX APPENDIX C CONSEQUENCE CATEGORY DEFINITION APPENDIX D LIKELIHOOD SCALE DEFINITION APPENDIX E RISK ASSESSMENT WORKSHEET APPENDIX F RISK REGISTER APPENDIX G RESPONSE ACTION SHEET APPENDIX H HAZID WORKSHEET APPENDIX I HAZOP WORKSHEET APPENDIX J JHA WORKSHEET

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APPENDIX A CHECKLIST

External and Environmental Hazards

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APPENDIX A (CONTINUOUS) CHECKLIST

Facility Hazards

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APPENDIX A (CONTINUOUS) CHECKLIST

Facility Hazards (continued)

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APPENDIX A (CONTINUOUS) CHECKLIST

Health Hazards

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APPENDIX A (CONTINUOUS) CHECKLIST

Project implementation issues

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APPENDIX B HAZARD IDENTIFICATION MATRIX

Activities Seismic Survey

Subactivities Operative phase

Hazards Identification Hazardous materials and gases under pressure Environmental effects Lifting and mechanical handling

Comments The hazards associated with seismic survey arise particularly from the handling of hazardous materials, including explosives and compressed air, and the many mechanical handling tasks. Loss or damage to the seismic streamer with spillage of kerosene is an environmental hazard. The identification of hazards need to be undertaken by both Edison ASID (the concession holder) and the rig owner/drilling contractor in close cooperation. Particular attention should be given to identifying hazards arising when normal techniques are extended outside their normal range of conditions (high pressure/high temperature wells, extreme environmental conditions, high H2S content, etc.)

Well development

Drilling

Mud System Drilling Program Hazardous materials (chemicals, explosives,toxics from the reservoir)

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APPENDIX C CONSEQUENCE CATEGORY DEFINITION

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APPENDIX D LIKELIHOOD SCALE DEFINITION

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APPENDIX E RISK ASSESSMENT WORKSHEET

Residual Risk Consequence Consequence Risk Factor Risk Factor Risk Cat.

Prob.

Prob.

Activity

Subactivity

Hazards Identified

Hazard Effect

Safeguards (Control Measures)

Mitigating Measures

Risk

Action By

Action Date

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APPENDIX F RISK REGISTER

Hazard / Activity

Risk Rank

Actions

Residual Risk

Justification for Closure

Action Party

Action Date

Status

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APPENDIX G RESPONSE ACTION SHEET

HAZID Report Reference: Title of Title HAZID: Action For: Action No. / e.g. 1.1.2 Page : Consequence: Hazard/Cause:

XXX-0000-XXX-XXXX

Rev:

XXX

Risk Rank: e.g. Accidental Damage: dropped objects from the drill rig

Response Due : Sub System: Freq:

Pre-mob/Date e.g. Well Security

Controls:

e.g. Lifting /handling procedures

Action:

e.g. Specific risk assessment for dropped objects to determine adequate protection

Response (Justification):

e.g. Assessment complete. reduced Risk Rank to C. Procedural limitations on drill rig lifting areas recommended to reduce risk to ALARP and Risk Rank to B. Risk Assessment After Implementation Freq: Risk Rank : Status: Name Name Name Signature Signature Signature Date: Date: Date:

Consequence:

OPEN/Clos ed/Ongoing

Sonsub Representative: Verified (Saipem Rep): Verified (DEL Rep):

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APPENDIX H HAZID WORKSHEET

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APPENDIX I HAZOP WORKSHEET

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APPENDIX J JHA WORKSHEET

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Environmental Aspects in Normal Operating Conditions

HSE IMS BU Hydrocarbons Asset Environmental Aspects in Normal Operating Conditions SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 5. 5.1. 5.2. 5.3.

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DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 ENVIRONMENTAL ASPECTS IN NORMAL OPERATING CONDITIONS ........................................................................ 5 IDENTIFICATION............................................................................................................................................................................5 CHARACTERIZ ATION ....................................................................................................................................................................5 EVALUATION..................................................................................................................................................................................5 PROCEDURES...................................................................................................................................................................................6 TRAINING........................................................................................................................................................................................6 UPDATING.......................................................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU E&P HSE IMS NGO CONTRACTOR SUBCONTRACTOR ENVIRONMENTAL ASPECT ENVIRONMENTAL IMPACT Asset Hydrocarbons Business Unit Exploration and Production Health, Safety and Environment Integrated Management System Non governmental organization Any entity or person whom Edison has awarded a part of the work Any entity or person whom CONTRACTOR has subcontracted a part of the work Element of an organizations activities or products or services that can interact with the environment Any change to the environment whether adverse or beneficial, wholly or partially resulting from an organizations environmental aspect

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for review of environmental aspects in normal operating conditions.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System OHSAS 18001: 1999 Occupational Health and Safety Management System

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4.

ENVIRONMENTAL ASPECTS IN NORMAL OPERATING CONDITIONS Beside the identification and evaluation of environmental aspects in emergency situations (see guideline HSE Risk Assessment), it shall be carried out an environmental review aimed at assessing the magnitude of environmental aspects associated to activities carried out by Edison ASID E&P also in normal operating conditions. The environmental review shall consist of, at a minimum, the phases here below summarized.

4.1.

Identification A methodology to identify environmental aspects associated to all activities carried out by Edison ASID E&P, including activities of contractors and subcontractors, shall be elaborated and implemented. Environmental aspects to be considered shall include, where applicable, but could not be limited to: Energy, Water and Material consumption; Production of waste; Wastewater discharges; Emissions to air; External noise; Impacts on local fauna and flora.

4.2.

Characterization Identified environmental aspects shall be then characterized in order to collect information useful later on to carry out an evaluation of its significance. Information to collect shall include but is not limited to: Quantities consumed/discharged/emitted/disposed of; Sensitivity of receptors (e.g.: quality of water bodies, anthropic degree of the area concerned by the impact); Type of contaminants associated to a certain impact (e.g.: organic chemicals, metals etc.).

4.3.

Evaluation Criteria to then evaluate the significance of identified environmental aspects shall be defined and implemented.

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The definition of the criteria shall consider: Impact of the environmental aspect; Associated legal and non-legal requirements; Sensitivity of interested parties (public, governmental authorities, media, NGOs).

4.4.

Procedures Potential needs to draw up dedicated procedures in order to ensure a proper management of significant environmental aspects shall be evaluated. Should this be the case: The preparation and management of the procedures shall comply with the minimum requirements set in the guideline Documentation management; All concerned personnel shall be trained with respect to what addressed by the procedures; training shall be planned and carried out in compliance with the minimum requirements set in guideline HSE Training; Access to the procedures shall be guaranteed for all concerned personnel.

4.5.

Training Needs in terms of training with respect to management of significant environmental aspects shall be defined. Training shall be planned and carried out in compliance with the minimum requirements set in guideline HSE Training;

4.6.

Updating The environmental review shall be updated on a periodical basis and anyhow whenever a change in the activities carried out occurs. An update of the environmental review shall entail another evaluation in terms of procedures and training as reported in sections 4.4 and 4.5.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to carry out an environmental review as reported in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Undertake the responsibilities assigned to the Branch HSE Manager for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible for the execution of an environmental review in compliance with the minimum requirements set in the present guideline with respect to all activities that fall within the branchs competence, including activities carried out by contractors and subcontractors.

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Legal and other requirements

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 MANAGEMENT OF HSE RE QUIREMENTS................................................................................................................................ 5 IDENTIFICATION............................................................................................................................................................................5 ACCESS.............................................................................................................................................................................................5 PROCEDURES...................................................................................................................................................................................6 TRAINING........................................................................................................................................................................................6 UPDATING.......................................................................................................................................................................................6 COMPLIANCE..................................................................................................................................................................................7 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7 OPERATIONAL MANAGER............................................................................................................................................................8

ANNEX A LEGISLATIVE LOGBOOK................................................................................................................................................. 9

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of HSE applicable legal and non-legal requirements.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.3.2, 4.5.2 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.3.2

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4.

MANAGEMENT OF HSE REQUIREMENTS The management of HSE legal and non-legal requirements shal address, at a minimum, the topics l here below summarized.

4.1.

Identification HSE legal and non-legal requirements applicable to all Edison ASID E&P activities in Italy and abroad shall be identified prior to the start-up of the operations. For activities abroad, identification shall be carried with the support of qualified experts of local legislation. Legal requirements of concern shall include but could be not limited to: European directives, rules and standards where applicable; National and local (i.e.: Regions, Provinces, Municipalities) HSE legislation; HSE provisions reported in permits, licenses or authorisations required to operate.

Non-legal requirements of concern shall include but could be not limited to: Covenants/agreements subscribed with e.g. partners, competent authorities, local population; Sector standards and best practices where mandatory.

Applicability of HSE requirements shall be defined taking into consideration: The results of environmental review and risk assessment (see guidelines Environmental Aspects in Normal Operating Conditions and HSE Risk Assessment); The activities carried out by all personnel working for Edison ASID E&P, including activities managed by contractors and subcontractors. 4.2. Access Identified applicable HSE requirements shall be collected in a logbook that shall include, at a minimum, the followings: Requirement reference (code, issuing date etc.); A summary of the content of the requirement; Deadlines to comply with when applicable; Responsibilities in terms of activity to carry out to comply with.

Refer to Annex A for an example of the logbook.

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All personnel involved in activities subject to HSE legal or non-legal requirements shall be then identified and tools to guarantee that they can have access to the logbook shall be defined and implemented. Such tools may include as instance: Direct distribution of copies of the logbook (e.g.: files or hard-copies); Web-based access to the logbook.

The management of the logbook as document of the HSE IMS shall comply with the minimum requirements set in the guideline Documentation management.

4.3.

Procedures Potential needs to draw up dedicated procedures in order to ensure a proper management of particular HSE requirements shall be evaluated. Should this be the case: The preparation and management of the procedures shall comply with the minimum requirements set in the guideline Documentation management; All concerned personnel shall be trained with respect to what addressed by the procedures; training shall be planned and carried out in compliance with the minimum requirements set in guideline Training; Access to the procedures shall be guaranteed for all concerned personnel.

4.4.

Training Potential needs in terms of training with respect to HSE requirements contents and application shall be evaluated. Should this be the case training shall be planned and carried out in compliance with the minimum requirements set in guideline Training;

4.5.

Updating A system to periodically update the logbook shall be defined and implemented. The system shall entail, when necessary, the withdrawal of all existing obsolete versions of the logbook.

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Needs in terms of procedures and training shall be then re-evaluated as reported in sections 4.3 and 4.4.

4.6.

Compliance The compliance against identified HSE requirements for all Edison ASID E&P, where applicable , shall be guaranteed via: Planning and execution on at fixed intervals of formal audits in compliance with the minimum requirements set in the guideline HSE audits; Day-by-day surveillance of operations.

Non conformities that could arise from such inspections shall be managed in compliance with the minimum requirements set in the guideline Non conformities, corrective and preventive actions. 5. 5.1. ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to manage the HSE requirements as reported in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Undertake the responsibilities assigned to the Branch HSE Manager for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible for the implementation of all the minimum requirements set in the present guideline with respect to all activities that falls within the branchs competence, including activities carried out by contractors and subcontractors. In particular, he/she is directly responsible to:

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Identify HSE legal and non legal requirements applicable to Edison ASID E&P activities with the support of qualified experts of local legislation; Draw to up, update and made available to all concerned personnel the logbook collecting all applicable HSE requirements, supported by operational managers; Supported by operational managers, evaluate potential needs to draw up dedicated procedures to ensure a proper management of particular HSE requirements; Assign responsibilities for document preparation when applicable (layout, procedures); Supported by operational managers, evaluate potential needs to implement training regarding HSE requirements contents; Plan and execute compliance audits regarding HSE requirements.

5.4.

Operational manager Operational manager shall: Carry out day-by-day surveillance of operations regarding HSE requirements; Verify availability at point of use of the legislative logbook for all concerned personnel; Support Branch HSE Manager for the evaluation of the needs in terms of documentation to be developed (layouts, procedures) and training to be performed.

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ANNEX A LEGISLATIVE LOGBOOK

HSE ASPECTS (e.g. Air Emissions)


National/International Regulations ART. Normative Decree 1 Requirements Limits/Expirations/Deadlines Responsibilities

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Improvement Program

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SUMMARY
SUMMARY.................................................................................................................................................................................................... 2 1. 2. 3. 4. 4.1. 4.2. 4.3. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCU MENTS......................................................................................................... 4 IMPROVEMENT PROGRAM......................................................................................................................................................... 5 OBJECTIVES AND TARGETS..........................................................................................................................................................5 PERFORMANCE INDICATOR S........................................................................................................................................................6 IMPROVEMENT PROGRAM............................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 ASID BRANCH HSE MANAGERS..................................................................................................................................................7 OPERATIONAL MANAGER ...........................................................................................................................................................7

ANNEX A IMPROVEMENT PROGRAM............................................................................................................................................. 8

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P ESD HSE LTIF SUBCONTRACTOR TRCF Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Emergency Shut Down Health, Safety and Environment Lost Time Injury Frequency Any entity or person whom CONTRACTOR has subcontracted a part of the work Total Reportable Case Frequency

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the preparation and implementation of an HSE improvement program.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.3.3 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.3.3, 4.3.4

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4.

IMPROVEMENT PROGRAM The preparation and implementation of an HSE improvement program shall address, at a minimum, the topics here below summarized.

4.1.

Objectives and Targets HSE objectives and targets shall be defined taking into account at a minimum the following topics/documents: HSE Policy; Stakeholders expectations and requests; Significant environmental impacts and health and safety risks associated to the E&P activities carried out (see guidelines Environmental Aspects in Normal Operating Conditions and HSE Risk Assessment); HSE legal and non-legal requirements (see guideline Legal and other requirements); Results of the Management Review. Objectives and targets shall be defined, as far as it is achievable depending on technical, economic and organizational constraints, in order to ensure at a minimum: Minimisation of environmental impacts (harmful discharges, emissions, wastes, etc.) from operational activities; Minimisation of accidental losses (e.g. injuries, equipment damages, product losses, etc.) Efficient use of energy and natural resources; Improvement of the relationship with stakeholders.

The objectives and targets shall be: Relevant to all levels and functions of Edison ASID E&P; Relevant to activities carried out by contractors and subcontractors; Quantified, wherever practicable; Associated to a defined timescale; Realistic and achievable with respect to technical, economic, organizational and time constraints; Divulgated and promoted at all Edison ASID levels, including contractors and subcontractors.

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4.2.

Performance indicators Performance indicators shall be defined and periodically monitored in order to continually assess the degree to which objectives and targets are achieved. Such indicators shall be: Simple to identify, collect, measure, understand and use; Objective, verifiable and reproducible.

Typical world-wide accepted performance indicators for HSE matters are: 4.3. Lost Time Injury Frequency (LTIF); Total Reportable Case Frequency (TRCF); Injury Severity; Total Reported Sickness Absence; Total New Cases of Occupational Health; Incident Total and Potential; Emergency Shut Down (ESD) Trips and Alarms; Environmental inputs (e.g.: energy consumption) and outputs (e.g.: waste) during normal operating activities; Environmental accidents occurrence (e.g.: spills).

Improvement Program Identified HSE objectives and targets shall be documented via an Improvement Program (refer to Annex A for an example of Improvement Program) that shall contain at a minimum the following information: Clear description of the objectives and targets; The defined Performance indicators to monitor the achievement of the objectives; Time scales for the implementation; Roles and responsibilities for the implementation of the activities required to achieve the objectives; Economic resources when required.

The Improvement Program shall be review periodically, at least yearly, during the Management Review (see guideline Management Review) in order to monitor the implementation and achievement level of the defined objectives and targets.

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5.

ROLES AND RESPONSIBILITIES

5.1.

ASID BU Director The BU Director shall: Approve the improvement program at BU and Branch level; Ensure the availability of the economic, human and technical resources for the achievement of the objective and targets defined in the programs.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Define an improvement program at BU level and for activities carried out at locations where there are no branches being effective; Monitor the work in progress of such programs on a periodical basis; Support the Branch HSE Managers for the identification of the objectives and associated performance indicators at branch level.

5.3.

ASID Branch HSE Managers ASID Branch HSE Managers shall: Define an improvement program at the Branch level; Monitor the work in progress of such program on a periodical basis.

5.4.

Operational Manager Operational Manager shall: Support the HSE Branch Manager/ASID HSE coordinator for the definition of the improvement program; Ensure the implementation and monitoring the progress of the improvement program regarding his/her competence area;

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ANNEX A IMPROVEMENT PROGRAM

Objective

Target1

Activity2

Phases of the activity

Phases Implementation Deadlines

Responsibilities (job position and name)

Resources3

1 2

Quantification and deadline of the general objective identified. Activity required to achieve the target 3 Human and/or economic resources

HSE IMS BU Hydrocarbons Asset HSE IMS System Guidelines Manual

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9. IMPLEMENTING

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Organization structure and resources allocation

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 5. 5.1. 5.2. 5.3. 5.4. 5.5. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 ORGANIZATION AND RESOURCES DEFINITION................................................................................................................. 5 RESOURCES IDENTIFICATION ......................................................................................................................................................5 ORGANIZATION DEFINITION .......................................................................................................................................................5 JOB DESCRIPTIONS.........................................................................................................................................................................5 TRAINING........................................................................................................................................................................................6 REVIEW............................................................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 CORPORATE PASQ........................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH MANAGER.......................................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................8

ANNEX A EDISON ASID ORGANIZATION CHART....................................................................................................................... 9

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS Asset Hydrocarbons Business Unit Any entity or person whom EDISON has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System

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2.

PURPOSE The purpose of this guideline is to give an overview of the essential topics to be addressed when defining HSE IMS responsibilities and HSE IMS allocate resources allocation.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.5.1 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.5.1

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4.

ORGANIZATION AND RESOURCES DEFINITION The definition of Edisons organization structure and the allocation of resources throughout EDISON ASID shall address, at a minimum, the topics here below summarized.

4.1.

Resources identification Appropriate resources shall be made available to establish, implement and maintain the HSE integrated management system. Identification of resources shal take into account the following items: l Human resources and training; Infrastructure and technologies; Information systems; Financial and other resources specific to operations.

Resources allocation shall consider both the current and future needs when predictable.

4.2.

Organization definition Appropriate assignment of HSE responsibilities and authorities within EDISON ASID at all BU levels is essential to ensure successful establishment, implementation and maintenance of the HSE management system. In the light of what above mentioned, an Edison ASID HSE Organization Chart has been defined as reported in ANNEX A Contractors and subcontractors key HSE staff shall be identified in order to ensure an effective coordination and co-operation with EDISON HSE personnel.

4.3.

Job descriptions Potential needs to draw up dedicated job descriptions in order to properly describe skills and competences of HSE key figures shall be evaluated.

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The preparation and management of the job descriptions shall comply with the minimum requirements set in the guideline Documentation management;

4.4.

Training Needs in terms of training with respect to responsibilities/roles definition and assignment shall be evaluated. Training shall then be planned and carried out in compliance with the minimum requirements set in guideline HSE Training.

4.5.

Review Responsibilities and resources allocation shall be reviewed periodically (see the guideline management review) and anyhow whenever a change in the activities carried out or in the EDISON ASID organizational structure occurs.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall: Guarantee the overall availability for all EDISON ASID of economic, human and technical resources needed to establish, implement and maintain the HSE IMS ; Appoint the ASID HSE Coordinator.

5.2.

Corporate PASQ Corporate PASQ shall support the BU Director for: ASID HSE Coordinator appointing; The definition of the other HSE human resources required to manage EDISON ASID HSE IMS, in collaboration with the ASID HSE Coordinator and the Branch HSE managers where concerned.

5.3.

ASID HSE Coordinator ASID HSE Coordinator shall: Support the BU Director for the definition of the other HSE human resources required to manage EDISON ASID HSE IMS, in collaboration with Corporate PASQ and Branch HSE Managers where concerned; Support the Branch Managers for the appointing of the Branch HSE Managers; Periodically review at BU level and for activities carried out at locations where there are no branches being effective, the adequacy of allocated human, technical and economic resources and report to BU Director possible gaps.

5.4.

Branch Manager The branch manager is responsible for the appointing of the HSE Branch manager and, on a branch scale, to ensure availability of economic, human and technical resources needed to establish, implement and maintain the HSE IMS.

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5.5.

Branch HSE Manager Branch HSE Manager shall periodically review at branch level the adequacy of allocated human, technical and economic resources and report to top management possible gaps.

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ANNEX A EDISON ASID ORGANIZATION CHART

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HSE Training

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 HSE TRAINING................................................................................................................................................................................. 5 IDENTIFICATION OF HSE TRAINING NEEDS..............................................................................................................................5 PLAN ................................................................................................................................................................................................5 RECORDS..........................................................................................................................................................................................6 EFFECTIVENESS ..............................................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7 OPERATIONAL MANAGER ...........................................................................................................................................................7

ANNEX A HSE TRAINING NEEDS IDENTIFICATION MATRIX................................................................................................... 8 ANNEX B TRAINING PLAN.................................................................................................................................................................. 9 ANNEX C TRAINING RECORD..........................................................................................................................................................10

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person w hom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of HSE training activities.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.4.2 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.4.2

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4.

HSE TRAINING The HSE training activities shall be carried out in compliance with the minimum requirements here below summarized.

4.1.

Identification of HSE training needs A system to identify HSE training needs shall be defined and implemented with respect to Edison ASID E&P activities in Italy and abroad. The identification shall be carried out taking into consideration at a minimum the followings: Activities carried out by all personnel working for Edison ASID E&P, including Contractors and Subcontractors; All the topics addressed by the HSE IMS with specific focus on management of HSE aspects and risks associated to these activities (see guidelines Environmental Aspects in Normal Operating Conditions and HSE Risk Assessment); Legal and non-legal HSE requirements (see guideline Legal and other requirements); New recruitments; Task reassignments; Non conformities, corrective and preventive actions resulting from the HSE periodical audit; Depending on the topic to be addressed, the need in terms of practical drills in addition to the theoretical training sessions. To help in the identification of personnel HSE training needs a matrix can be used. Refer to Annex A for an example of HSE training needs identification matrix.

4.2.

Plan A training plan shall be prepared and maintained updated at least yearly. The training plan shall include, at a minimum, the followings: Description of the training topic; List of trainees (name and function); Deadline for the execution; When applicable, refreshment frequency and date of the last training activity carried out; Trainers reference; Budget allocated where applicable.

Refer to Annex B for an example of a training plan.

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4.3.

Records A standardized method to record training activities shall be defined and implemented. Records shall specify at a minimum: Personnel trained (name, function, signature); Trainer reference (name, function, signature); Date of the training session; Description of the topics addressed.

Refer to Annex C for an example of Training Record. Training records shall be managed according to minimum requirements set in guideline Records management.

4.4.

Effectiveness Criteria and tools to verify the effectiveness of the training activities shall be defined and implemented. Records of the verifications carried out shall be retained. Records shall be managed according to minimum requirements set in guideline Records management.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to carry out training activities in compliance with the minimum requirements set in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Define the criteria and develop systems/tools to manage HSE training as reported in the present guideline; Manage training activities in compliance with the minimum requirements set in the present guideline at BU level and for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible for the implementation of all the minimum requirements set in the present guideline for all activities that fall within the branchs competence, including activities carried out by contractors and subcontractors. In particular, he/she is directly responsible to: Supported by operational managers, identify HSE training needs; Supported by operational managers, draw to up and update the training plan; Define and organize verifications of trainings effectiveness.

5.4.

Operational Manager Operational manager shall: Support Branch HSE Manager for the evalua tion of the HSE training needs; Validate, for activities within its responsibilities, the feasibility of training plan via the verification of the staff work loads versus the time requested for the training.

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ANNEX A HSE TRAINING NEEDS IDENTIFICATION MATRIX

Job position

Topics/documents IMS HSE

HSE Legislative requirements

Emergency Management

Comments

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ANNEX B TRAINING PLAN

Topics

Trainer

List of trainees (name and job position)

Deadline for the execution

Training session effectuated (YES/NO Date)

Date of the next training session (Follow-Up)

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ANNEX C TRAINING RECORD

TRAINING SESSION: DATE: TRAINER: TRAINER SIGNATURE: TOPICS ADDRESSED:

Surname - Name

Signature

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Communication

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 COMMUNICATION.......................................................................................................................................................................... 5 INTERNAL COMMUNICATION ......................................................................................................................................................5 EXTERNAL COMMUNICATION .....................................................................................................................................................5 SUSTAINABILITY REPORT ...........................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7 OPERATIONAL MANAGER ...........................................................................................................................................................7

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of internal and external communication.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.4.3 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.4.3

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4.

COMMUNICATION Communication about HSE aspects shall address, at a minimum, the topics here below summarized.

4.1.

Internal communication

4.1.1. Top-down Tools shall be defined and implemented in order to ensure a proper communication of HSE aspects to all Edison ASID E&P personnel. Communication topics shall include but could not be limited to: HSE policy; HSE objectives and targets at BU and Branch level; Significant environmental impacts and H&S risks (see guidelines Environmental Impacts in Normal Operating Conditions and HSE Risk Assessment) associated to the activities carried out; Trend of HSE performance indicators.

Tools can include: Briefings/Meetings (one-to-one, staff/team); Emails or Intranet; Newsletters (Branch or BU level); HSE performance reports; Placards, booklets and awareness programs/campaigns.

4.1.2. Bottom-up Tools shall be defined and implemented aimed at allowing an effective communication of personnels suggestions, comments and concerns on HSE matters to top management. To be noted that the communication of incidents, accidents and near misses is addressed in the guideline Non conformities, accidents, corrective and preventive actions

4.2.

External communication A system shall be designed and implemented for receiving and responding to communication or requests coming from stakeholders (e.g: public, media, government, control authorities etc.). The system shall at a minimum ensure:

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Traceability of incoming/outgoing communication; Management of documents carried out according to minimum requirements set in guideline Documentation management; Adequacy of the response with respect of the topic to be addressed.

Roles, responsibilities and chain of approval at BU and at Branch Level shall be defined in case of communications dealing with the following topics: Incidents, accidents and emergency situations in general (see also the guideline Emergency response); Legal issues.

Communication with Contractors and Subcontractors is addressed in a specific guideline focused on contractors management (see the guideline HSE Management of Contractors).

4.3.

Sustainability report The Edison group reports its HSE performance on a yearly basis via a dedicated sustainability report. Co-operation with Edison Group personnel in charge of the Sustainability Report preparation for the collection and elaboration of BU ASID data required for the sustainability report shall be ensured.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to manage internal and external communication in compliance with the minimum requirements set in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Define the criteria and develop systems/tools to manage communication as reported in the present guideline; Manage communication in compliance with the minimum requirements set in the present guideline at BU level and for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible to guarantee observance of the minimum requirements set in the present guideline for communications that concern documents/activities that fall within the branchs competence, including activities carried out by contractors and subcontractors.

5.4.

Operational Manager Operational manager shall participate into the implementation of the communication system, regarding the top-down and bottom-up communication with his personnel and contractors.

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Documentation management

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 MANAGEMENT OF IMS HSE DOCUMENTATION................................................................................................................... 5 PREPARATION ................................................................................................................................................................................5 DISTRIBUTION ................................................................................................................................................................................5 FILING..............................................................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7 OPERATIONAL MANAGER ...........................................................................................................................................................7

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of HSE IMS documentation.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.4.4, 4.4.5, 4.5.4 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.4.4, 4.4.5, 4.5.4

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4.

MANAGEMENT OF IMS HSE DOCUMENTATION The management of IMS HSE documentation shall address, at a minimum, the topics here below summarized.

4.1.

Preparation HSE IMS documentation shall be prepared in compliance with the following minimum requirements: Adequacy of the contents shall be guaranteed with respect to the topic addressed. In particular, documents addressing operational HSE issues (e.g.: waste management) shall be drawn up and/or revised by personnel having the proper technical skills to identify potential constraints when addressing management HSE aspects during the day-by-day operational activities; Revision status shall be readily identifiable to prevent use of obsolete documents; Revisions shall be traceable in order to allow to go back, when required, to the nature and date of all the changes operated; A standardized format of the documents with respect to its scope/type shall be defined and applied in order to guarantee a proper and homogeneous content for all IMS HSE documents of the same type; All documents shall be approved prior to issue. For each document, the chain of approval shall be defined taking into consideration the topics addressed. A list of existing IMS HSE documents shall be prepared and maintained updated at Branch and BU level.

4.2.

Distribution Criteria for the distribution of the IMS HSE documents shall be identified and implemented in the light of ensuring at a minimum: Controlled distribution of sensitive documentation; Traceability of the distribution is carried out and maintained updated; Availability at points of use of updated versions for all concerned personnel, including contractors and subcontractors; Withdrawal of all existing obsolete versions of the documents when an updated version is distributed.

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4.3.

Filing A system to file IMS HSE documents shall be developed. The system shall guarantee, at a minimum, the followings: Protection of the documents against damage, deterioration and loss; Easy retrieval of the documents when necessary; Archive responsibility, file location and filing duration clearly defined for each document.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to manage the HSE IMS documentation as reported in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Define the criteria and develop the systems to manage HSE IMS documentation as reported in the present guideline; Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Undertake the responsibilities assigned to the Branch HSE Manager for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible for the management of the HSE IMS documents in compliance with the minimum requirements set in the present guideline for the documentation developed at branch level.

5.4.

Operational Manager Operational Manager shall: Co-operate to draw up the documentation regulating the operational activities that fall within his/her responsibilities; Verify the availability for all the personnel upon his/her responsibility of HSE documentation of concern; File the HSE records of which he/she is directly responsible.

HSE IMS

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Emergency Response

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Emergency Response

HSE IMS

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Emergency Response

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 4.7. 5. 5.1. 5.2. 5.3. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 EMERGENCY RESPONSE.............................................................................................................................................................. 5 EMERGENCY RESPONSE MEASURES............................................................................................................................................5 EMERGENCY RESPONSE PLAN .....................................................................................................................................................5 ASSESSMENT OF THE EMERGENCY RESPONSE PLAN ...............................................................................................................6 REVIEW OF THE EMERGENCY RESPONSE PLAN .......................................................................................................................6 ACCESS.............................................................................................................................................................................................7 COMMUNICATION .........................................................................................................................................................................7 TRAINING........................................................................................................................................................................................7 ROLES AND RESPONSIBI LITIES ............................................................................................................................................... 8 ASID BU DIRECTOR ......................................................................................................................................................................8 ASID HSE COORDINATOR ...........................................................................................................................................................8 ASID BRANCH HSE MANAGERS..................................................................................................................................................8

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

HSE IMS

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Emergency Response

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of emergency response.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System OHSAS 18001: 1999 Occupational Health and Safety Management System

HSE IMS

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4.

EMERGENCY RESPONSE The emergency response shall be managed in compliance with the minimum requirements here below summarized.

4.1.

Emergency Response Measures On the basis of the emergency scenarios identified and assessed according to what reported in the guideline HSE Risk Assessment, emergencies response specific measures shall be identified and implemented. Emergency response measures where applicable shall include: Emergency shut-down systems; Fire-fighting devices; Emergency evacuation and escape procedures; Rescue craft; First-aid equipment and personnel; Specialist medical treatment; Oil-spill clean-up systems.

4.2.

Emergency Response Plan The outcomes of the risk assessment shall also be the basis for the drawing up of a detailed emergency plan. The Emergency Response Plan shall be specifically developed for each project, location and department and it shall: Be in compliance with national/local regulations; Aim to protect people, limit losses, public exposure and legal liabilities.

The Emergency Response Plan shall address, where applicable, at a minimum the following topics: Description of the possible emergency scenarios; Emergency response measures to be adopted with respect to each scenario identified; Emergency response organization/responsibilities; Emergency response team/s; Emergency response equipment; References of the external emergency services/bodies (telephone numbers and address) such as hospitals, doctors, fire brigades, ambulances etc.; Data on hazardous materials present (e.g.: quantities, location of storage areas, type of storage);

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Evacuation procedure to predetermined safe areas; Search and rescue plan; Traffic control plan; Removal and/or protection of vital equipment and materials; Emergency training to personnel Information to visitors; Emergency communication and notification; Internal and external/public reporting requirements.

The plan should be regularly updated, make available whenever needed and displayed at key/communications locations e.g. first aid points, switchboard etc, and in general shall be managed according to the minimum requirements set in guideline Documentation management.

4.3.

Assessment of the Emergency Response Plan Effectiveness of the emergency response plan shall be assessed via performing periodic drills that shall cover the whole emergency system (e.g.: extended also to test coordination between the internal emergency teams and the key external emergency services/bodies where applicable).

4.4.

Review of the Emergency Response Plan The response plan shall be reviewed on a periodical basis and in any case: whenever a change in the E&P activities carried out occurs; after the occurrence of incidents or emergency situations which shall be adequately investigated and analyzed in order to prevent recurrence.

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4.5.

Access Tools to guarantee access to the emergency response plan to all interested parties shall be defined and implemented. Interested parties shall include, where applicable depending on the scenarios identified, but could not be limited to: All Edison BU ASID personnel; Contractors and subcontractors; Partners; External Emergency services/bodies; Governmental authorities.

4.6.

Communication Roles and responsibilities shall be clearly defined to manage internal and external communication in case of emergency. Depending on the magnitude of the scenarios identified, potential needs to create dedicated crisis management teams shall be evaluated. The crisis management team should be in charge mainly of manage communication with external bodies (governmental authorities, media, public) during emergency situations in tight co-operation with internal emergency teams and brigades.

4.7.

Training All personnel working for Edison ASID E&P, including contractors and subcontractors, shall be adequately trained to respond to emergency situations. All training activities shall be planned and executed in compliance with the minimum requirements reported in guideline HSE Training.

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5.

ROLES AND RESPONSIBILITIES

5.1.

ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to define and implement emergency response measures and plans as reported in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Undertake the responsibilities assigned to the Branch HSE Manager for activities carried out at locations where there are no branches being effective.

5.3.

ASID Branch HSE Managers Branch HSE Manager is responsible for the definition and implementation of emergency response measures and plans in compliance with the minimum requirements set in the present guideline with respect to all activities that falls within the branchs competence, including activities carried out by contractors and subcontractors.

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10. CHECKING

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HSE monitoring

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 HSE MONITORING.......................................................................................................................................................................... 5 MONITORING OF HSE ASPECTS ...................................................................................................................................................5 MAINTENANCE OF HSE SENSITIVE MACHINERY / PLANTS/ EQUIPMENT..............................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................7 OPERATIONAL MANAGER ...........................................................................................................................................................7

ANNEX A HSE MONITORING PLAN.................................................................................................................................................. 8 ANNEX B HSE MAINTENANCE PLAN............................................................................................................................................... 9

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU COMPANY CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Edison Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for monitoring of HSE aspects and maintenance of HSE sensitive machinery/plants/equipment.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.5.1 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.5.1

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4.

HSE MONITORING Monitoring of HSE aspects associated to activities carried put by Edison ASID E&P shall address, at a minimum, the topics here below summarized.

4.1.

Monitoring of HSE aspects A plan to monitor HSE aspects associated to activities carried out by Edison ASID E&P activities, including Contractors and Subcontractors activities, shall be defined and implemented. Monitoring activities to be reported in the plan shall be identified taking into consideration at a minimum: The results of environmental review and risk assessment (see guidelines Environmental Impacts in Normal Operating Conditions and HSE Risk Assessment); Legal and non-legal requirements; HSE provisions reported in permits, licenses or authorisations required to operate; Requirements reported in the HSE IMS operational guidelines.

The plan shall specify at a minimum the followings: Monitoring activity; Responsibilities; Periodicity; Deadlines.

Refer to Annex A for an example of the HSE monitoring Plan. The plan shall be periodically updated at a minimum on an annual basis. Monitoring of the HSE performance indicators, HSE objectives and targets is addressed in guideline Improvement program. All roles, responsibilities and planning of inspections and monitoring activities to be carried out according to requirements set in HSE IMS operational guidelines shall be reported in the HSE monitoring plan.

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4.2.

Maintenance of HSE sensitive machinery/plants/equipment HSE sensitivity (potential risk of generating an HSE impact in case of malfunctioning) of machinery/plants/equipment associated to activities carried out shall be determined. A plan to maintain HSE sensitive machinery/plants/equipment shall then be prepared. The plan shall specify at a minimum: Description of the machinery/plant/equipment; Maintenance activity; Responsibilities; Periodicity; Deadlines.

Refer to Annex B for an example of the HSE maintenance Plan. Where existing, instead of reporting the above listed information, the plan can refer to other maintenance logbook, plans etc. already in place. The plan shall include, wherever applicable, calibration and maintenance of HSE monitoring equipment. All roles, responsibilities and planning of maintenance activities to be carried out according to requirements set in HSE IMS operational guidelines shall be reported in the HSE maintenance plan.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to carry out monitoring of HSE aspects and maintenance of HSE sensitive machinery/plants/equipment in compliance with the minimum requirements set in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Manage monitoring of HSE aspects and maintenance of HSE sensitive machinery/plants/equipment in compliance with the minimum requirements set in the present guideline for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible to guarantee observance of the minimum requirements set in the present guideline for monitoring of HSE aspects and maintenance of HSE sensitive machinery/plants/equipment related to activities that fall within the branchs competence, including activities carried out by contractors and subcontractors.

5.4.

Operational Manager Operational Manager shall ensure, in his competence area, the implementation of the monitoring and maintenance activities as defined in the respective plans. He/she is also responsible for reporting the results or notifying any problem to the ASID Branch HSE manager/ASID HSE Coordinator.

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ANNEX A HSE MONITORING PLAN

HSE Aspects

Activity

Frequency

Supervisor 1

Responsible2

Registration and Storing (Document number and Storing place)

Carried out (Yes/No - Date)

1 2

Responsible for ensuring that monitoring activity is duly carried out (e.g.: Edison ASID Personnel). Responsible for carrying out directly the monitoring activity (e.g.: qualified contractor).

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ANNEX B HSE MAINTENANCE PLAN

Equipment/Plant/Machinery

Activity

Frequency

Supervisor 1

Responsible2

Registration and Storing (Document number and Storing place)

Carried out (Yes/No - Date)

1 2

Responsible for ensuring that maintenance activity is duly carried out (e.g.: Edison ASID Personnel). Responsible for carrying out directly the maintenance activity (e.g.: qualified contractor).

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Non conformities, accidents, corrective and preventive actions

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 5. 5.1. 5.2. 5.3. 5.4. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 NON CONFORMITIES, ACCIDENTS, CORRECTIVE AND PREVENTIVE ACTIONS..................................................... 5 NOTIFICATION AND RECO RDING ................................................................................................................................................5 CLASSIFICATION ............................................................................................................................................................................5 INVESTIGATION..............................................................................................................................................................................6 REGISTER.........................................................................................................................................................................................6 MONITORING AND A SSESSMENT ................................................................................................................................................7 ROLES AND RESPONSIBI LITIES ............................................................................................................................................... 8 ASID BU DIRECTOR ......................................................................................................................................................................8 ASID HSE COORDINATOR ...........................................................................................................................................................8 BRANCH HSE MANAGER..............................................................................................................................................................8 OPERATIONAL MANAGER ...........................................................................................................................................................8

ANNEX A NC/ACCIDENT/NEAR-MISS NOTIFICATION FORM...............................................................................................10 ANNEX B NC/ACCIDENT/NEAR-MISS REGISTER ......................................................................................................................11

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ACCIDENT ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR NEAR-MISS NON CONFORMITY (NC) CORRECTIVE ACTION (CA) PREVENTIVE ACTION (PA) Unexpected event which causes damage or harm to human beings or to the environment Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work Unexpected event that did not caused an accident either by chance or due to timely intervention. Non-fulfillment of a HSE requirement Action to eliminate the cause of a detected non conformity Action to eliminate the cause of a potential non conformity

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the management of non conformities, accidents, corrective and preventive actions.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS No. 1 2 Title ISO 14001: 2004 Environmental Management System 4.5.3 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.5.2

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4.

NON CONFORMITIES, ACCIDENTS, CORRECTIVE AND PREVENTIVE ACTIONS Management of NC, Accidents, CA and PA shall address, at a minimum, the topics here below summarized.

4.1.

Notification and recording Whoever detect a situation of potential NC, is witness to or involved in an Accident shall notify the Operational Managers. Operational Managers shall then: Depending on the nature and magnitude of the NC/Accident/Near-miss, evaluate if an immediate response to restore normal conditions is necessary and, should this be the case, implement the required actions; Depending on the nature and magnitude of the NC/Accident/Near-miss, evaluate the applicability of the Branch/Site emergency plan (see guideline Emergency response) and, should this be the case, act in compliance with the requirements therein reported; In case of an event causing injuries on personnel, ensure that medical assistance is provided according to the requirements set in the guidelines Medical Evacuation and First Aid; Record the NC/accident via a standardized form and send it to ASID HSE Coordinator and/or HSE Branch Manager depending on its nature and level of application (see section 5, Roles and Responsibilities). The NC/Accident/Near-miss notification standardized form (refer to Annex A for an example of NC format) shall include, at a minimum, the following specifications: Notifier (name, function, signature); Date; Form Progressive number (to be compiled by the ASID HSE Coordinator and/or HSE Branch Manager); Operational Manager (name, function, signature); NC/Accident/Near-miss location; Activity/ies and department/companies concerned/involved by the NC/Accident/Near-miss; Description of the evidence of the NC or of the Accident circumstances and consequences. Description of the immediate response implemented if any.

4.2.

Classification After having received the Notification form, ASID HSE Coordinator and/or HSE Branch Manager shall proceed to classify the NC/Accident/Near-miss according to the following criteria:

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Accident shall be classified according to the consequences categories listed in Appendix C of guideline HSE Risk Assessment; High potential Near-miss = Near-miss whose potential consequences, in terms of magnitude and severity, would have been critical; Minor Near-miss = Near-miss whose potential consequences, in terms of magnitude and severity, would not have been critical. Major NC = non conformity with respect to applicable legislation or with respect to the HSE IMS requirements affecting negatively the HSE IMS efficiency and effectiveness. Minor NC = non conformity with respect to the HSE IMS requirements not affecting the HSE IMS efficiency and effectiveness.

4.3.

Investigation Root causes of the NC/Accident/Near-miss shall be investigated in order to identify the proper CA/PA. Investigation and CA/PA definition shall include the following actions: Creation of an investigation team that shall incorporate the technical and management skills adequate to the nature of the NC/Accident/Near-miss; Review of the NC/Accident/Near-miss circumstances; Control of equipment and procedures or other data; Interviews with witnesses and concerned personnel.

Depending on the severity of the NC/Accident/Near-miss, potential needs to take pictures to record to support CA/PA identification shall be evaluated. 4.4. Register After notification, NC/Accident/Near-miss shall be recorded in a dedicated register that shall specify at a minimum (Refer to annex B for an example of the register): NC/Accident/Near-miss notification form number; Type (NC/Accident/Near-miss); NC/Accident/Near-miss classification; Description of the NC/Accident/Near-miss root cause Description of the defined CA/PA; CA/PA implementation Plan that shall specify: o Personnel/Function responsible to implement the CA/PA; o Resources (human or economic);

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o Deadline for the implementation; o CA/PA Effectiveness. The register shall be subject to evaluation during the Management Review (see the HSE IMS related guideline). 4.5. Monitoring and Assessment The progress of CA/PA implementation shall be periodically monitored and its effectiveness assessed and recorded. A failure of the CA/PA (CA/PA ineffectiveness or completion deadline missing) shall be considered as a new NC.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to manage NC/Accident/Near-miss, CA and PA in compliance with the minimum requirements set in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Manage NCs, Accidents, CAs and PAs in compliance with the minimum requirements set in the present guideline at BU level and for activities carried out at locations where there are no branches being effective.

5.3.

Branch HSE Manager Branch HSE Manager is responsible to guarantee observance of the minimum requirements set in the present guideline for NCs, Accidents, CAs and PAs that concern activities that fall within the branchs competence, including activities carried out by contractors and subcontractors. In particular, he/she is directly responsible to: Classify the NC/Accident/Near-miss; Supported by operational managers, investigate the root causes of the NC/Accident/Near-miss to identify the appropriate CA/PA; Decide about the effectiveness of a CA/PA; Keep records of all NC/Accident/Near-miss that has occurred via the dedicated register.

5.4.

Operational Manager Operational manager is responsible to: Put in place immediate response to restore normal conditions when necessary; Act in compliance with the requirements reported in the emergency plans where applicable; Ensure that medical assistance is provided according to the requirements set in the guidelines Medical Evacuation and First Aid; Record the NC/accid ent via a standardized form and send it to ASID HSE Coordinator and/or HSE Branch Manager depending on its nature and level of application;

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Support ASID HSE Coordinator and/or HSE Branch Manager for the identification of the root causes; Implement and monitor progress of any CA/PA that falls within his/her competence.

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ANNEX A NC/ACCIDENT/NEAR-MISS NOTIFICATION FORM


NOTIFIER: name/function and signature OPERATIONAL MANAGER: Name/Function and signature DATE: FORM N:

Location:

Activity/ies and department/companies concerned/involved:

NC/Accident/Near-miss description:

Description of the immediate response implemented if any:

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ANNEX B NC/ACCIDENT/NEAR -MISS REGISTER


N1 Type2 CA/PA Implementation Plan Class Root Cause CA/PA Responsibility Resources 3 Deadline Effectiveness

1 2

Notificatin form number NC; Accident, Near-Miss 3 Human or economic

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HSE audits

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 4.7. 5. 5.1. 5.2. 5.3. 5.4. 5.5. 5.6. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 MANAGEMENT OF HSE AU DITS................................................................................................................................................. 5 PROGRAM ........................................................................................................................................................................................5 PREPARATION ................................................................................................................................................................................5 EXECUTION .....................................................................................................................................................................................6 FINDING CLASSIFICATION ............................................................................................................................................................6 REPORTING .....................................................................................................................................................................................6 AUDITORS QUALIFICATIO NS .......................................................................................................................................................7 ASSESSMENT OF THE AUDIT PROCESS .......................................................................................................................................7 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 8 ASID BU DIRECTOR ......................................................................................................................................................................8 ASID HSE COORDINATOR ...........................................................................................................................................................8 BRANCH HSE MANAGER..............................................................................................................................................................8 LEAD AUDITOR ..............................................................................................................................................................................8 OPERATIONAL MANAGER ...........................................................................................................................................................9 CORPORATE PASQ HSE OFFICERS.............................................................................................................................................9

ANNEX A AUDIT PROGRAM FORMA T..........................................................................................................................................10 ANNEX B AUDIT PLAN........................................................................................................................................................................11 ANNEX B AUDIT REPORT ..................................................................................................................................................................12

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CA CONTRACTOR E&P HSE IMS NC PA SUBCONTRACTOR Asset Hydrocarbons Business Unit Corrective action Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Non conformity Preventive action Any entity or person whom CONTRACTOR has subcontracted a part of the work

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the planning and execution of HSE audits.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.5.5 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.5.4

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4.

MANAGEMENT OF HSE AUDITS The management of HSE audits shall address, at a minimum, the topics here below summarized.

4.1.

Program An audit program shall be defined at a minimum on a yearly basis. The program shall cover all Edison ASID E&P activities in Italy and abroad, including activities of contractors and subcontractors and shall address: Application of all the topics addressed by the HSE IMS with specific focus on management of HSE aspects and risks associated to the activities carried out by personnel working for Edison ASID E&P, including contractors and subcontractors; Compliance with applicable HSE legal and non-legal requirements (see also guideline Legal and other requirements). Refer to Annex A for an example of Audit Program.

4.2.

Preparation An audit team shall be defined taking into consideration the followings: The independency and impartiality of the team with respect to the area being audited; The competence of the team members with respect to HSE and technical specificities of the activities subject to audit (see also section 4.5 Auditors qualification).

4.2.1. Audit Team

4.2.2. Audit Plan An Audit Plan shall be prepared and sent to the audited personnel in order to: Inform about audit objectives and scope; Detail areas/personnel involved; Specify location, date and schedule. Refer to Annex B for an example of Audit Plan.

4.2.3. Audit Protocols Potential needs to draw up dedicated Audit Protocols to be used as road-maps to guide auditor during the inspection shall be evaluated. These needs should be verified for instance taking into consideration also the complexity of the areas to be audited with respect to the auditors competence.

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4.3.

Execution A preliminary meeting shall be organised in order to: Introduce audit team and the audit plan; Review objectives and scope of the audit; Confirm audit schedule.

4.3.1. Kick off meeting

4.3.2. Execution The audit execution shall entail, at a minimum, the following activities: Interviews to personnel; Review of documents of interest; Inspection of site internal and external areas; Collection of documented evidences of any of the possible NC identified.

4.3.3. Close out meeting A closing meeting shall be organised in order to: Present audit findings to auditees; Ensure understanding of NC; Seek NC endorsement; Discuss about potential CA/PA,

4.4.

Finding classification Audit findings shall be classified according to the following criteria: Major NC = non conformity with respect to applicable legislation or with respect to the HSE IMS requirements affecting negatively the HSE IMS efficiency and effectiveness; Minor NC = non conformity with respect to the HSE IMS requirements not affecting the HSE IMS efficiency and effectiveness; Recommendation (R) = finding highlighting a high NC risk due to the short margin with which the conformity is ensured. Suggestion (S) = remark aimed at highlighting an improvement opportunity.

4.5.

Reporting Criteria to standardize the audit reporting shall be identified and implemented. An audit report shall be structured to contain, at a minimum, the following information:

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Date of the audit; Name and responsibilities of the audit team; Name and responsibilities of the auditees; Documents reviewed; Findings classification; Any modifications with respect to the original audit objectives, scope and planned\ schedule.

Refer to Annex C for an example of Audit Report Index. Criteria for the distribution of the report shall also be clearly defined and applied.

4.6.

Auditors qualifications Audits shall be carried out only by auditors qualified according to standard criteria. These criteria shall consider, at a minimum, the followings: HSE skills and competences; Technical and organisational knowledge of the activities/areas to be audited.

Criteria shall be differentiated in order to identify lead auditors whose responsibility will be mainly to define and then coordinate the audit teams (section 4.2 Audit team) during the inspections.

4.7.

Assessment of the audit process Efficiency and efficacy of the audits carried out shall be object of the HSE IMS Management Review (see guideline Management Review). The assessment shall concern all the audit process: Program, Preparation, Execution, Reporting and Auditors qualifications.

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5. 5.1.

ROLES AND RESPONSIBILITIES ASID BU Director The BU Director shall guarantee the availability of economic, human and technical resources needed to manage the HSE Audits as reported in the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Guarantee a consistent implementation of the present guideline for all Edison ASID E&P activities; Undertake the responsibilities assigned to the Branch HSE Manager for activities carried out at locations where there are no branches being effective; To guarantee independency and impartiality of audit activity, carry out audits that concern the activities of the Branch HSE Managers.

5.3.

Branch HSE Manager Branch HSE Manager is responsible for the implementation of all the minimum requirements set in the present guideline with respect to all activities that fall within the branchs competence, including activities carried out by contractors and subcontractors. In particular, he/she is directly responsible to: Prepare the audit program; Define the audit team; Draw up and update criteria regarding audit reporting; Define auditors qualification criteria; Assess audits efficiency and efficacy.

5.4.

Lead auditor Lead auditor is responsible for: Preparing audit plans and audit protocols, if required; Supervising and co-ordinating the audit execution; Organising audits kick-off meeting and close out meeting;

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5.5.

Operational Manager Operational Manager shall be considered as one of the best candidates to be a lead auditor. Moreover, he/she shall validate, for activities within its responsibilities, the feasibility of audit plans and programs via the verification of the staff work loads versus the time requested by the audit execution.

5.6.

Corporate PASQ HSE Officers In order to ensure independency and impartiality of audit activity, Corporate PASQ HSE officers are responsible to carry out audits focused on the ASID HSE Coordinator activities.

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ANNEX A AUDIT PROGRAM FORMAT


HSE IMS AUDIT PROGRAM Year: Prepared on: date Approved by (Lead Auditor): name and signature

N1

DEPARTMENT/CONTRACTOR

TOPIC/REQUIREMENT

PLANNED (MONTH)

AUDIT EXECUTION (YES/NO DATE)

(1) 1 Progressive number to be reported in the audit plan

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ANNEX B AUDIT PLAN


HSE IMS AUDIT PLAN Audit n 1: Plan prepared on: date Approved by (Lead Auditor): name and signature Audit Date:

Branch/Project Department/Contractor REFERENCE PERSONNEL2 1. Name/Function 2. Name/function


Schedule Topic/Requirement Ref.

AUDIT TEAM Auditor 1 (Lead auditor): Name/Function Auditor 2: Name/Function


Auditor

Reference document/s

From

To

see audit program of Area/Activity/Department/Contractor to be audited

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ANNEX C AUDIT REPORT INDEX Audit report shall completely and accurately report audits information and consider at a minimum the followings: Chapter 1: Objectives and scope Chapter 3: Audit plan Chapter 4: Limitations 1 Chapter 5: Findings Annex 1: Photo log Annex 2: Reports distribution list

Any modification occurred to the objectives, scope and plan of the audit and the reasons of such changes .

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11. REVIEWING

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Management Review

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SUMMARY
1. 2. 3. 4. 4.1. 4.2. 4.3. 5. 5.1. 5.2. 5.3. 5.4. 5.5. DEFINITIONS AND ABBREVATIONS ........................................................................................................................................ 3 PURPOSE........................................................................................................................................................................................... 4 REFERENCES AND OTHER RELEVANT DOCUMENTS ......................................................................................................... 4 MANAGEMENT REVIEW................................................................................................................................................................ 5 REVIEW PLANNING........................................................................................................................................................................5 REVIEW INPUT ...............................................................................................................................................................................5 REVIEW OUTPUT ...........................................................................................................................................................................6 ROLES AND RESPONSIBILITIES ............................................................................................................................................... 7 ASID BU DIRECTOR ......................................................................................................................................................................7 ASID HSE COORDINATOR ...........................................................................................................................................................7 BRANCH MANAGER.......................................................................................................................................................................7 BRANCH HSE MANAGER..............................................................................................................................................................8 OPERATIONAL MANAGER............................................................................................................................................................8

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1.

DEFINITIONS AND ABBREVATIONS The principal terms and abbreviations used in the present document are reported below: ASID BU CONTRACTOR E&P HSE IMS SUBCONTRACTOR Asset Hydrocarbons Business Unit Any entity or person whom Edison has awarded a part of the work Exploration and Production Health, Safety and Environment Integrated Management System Any entity or person whom CONTRACTOR has subcontracted a part of the work

HSE IMS

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2.

PURPOSE The purpose of this guideline is to establish a common and consistent approach throughout all Edison ASID for the planning and execution of the Management Review.

3.

REFERENCES AND OTHER RELEVANT DOCUMENTS

No. 1 2

Title ISO 14001: 2004 Environmental Management System 4.6 OHSAS 18001: 1999 Occupational Health and Safety Management System 4.6

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4.

MANAGEMENT REVIEW HSE IMS shall be periodically assessed by the Top Management in order to: Guarantee its adequacy according to the activities carried out; Evaluate the adequacy of the human, technical and economic resources allocated for the HSE IMS implementation and maintenance.

Two types of management review shall be considered and implemented: one at BU level and one at branch level where applicable. Both management reviews shall be carried out according to the minimum requirements set here below.

4.1.

Review Planning The planning of the management review shall include at a minimum: Definition and collection of all the required HSE IMS documentation and data (see section 4.2 Review Input); Definition of the schedule and agenda; Notification to all interested parties of the date established for the meeting with a proper anticipation.

4.2.

Review Input During the management review, the following information and data shall be reviewed: HSE Policy; HSE objectives and targets; Audit results; Audit process effectiveness; Non-conformity/observations records; Report of previous management review meetings; Status of corrective and preventive actio ns; Changes in the E&P activities; Training needs; Performance indicators effectiveness and trend; Incident, accident and near misses statistics;

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Legislative and authorisation updates and potential regulatory developments; Stakeholders expectations and concerns; Personnel suggestions, comments, and concerns; Emerging/growing concerns in specific areas; External information and communication.

4.3.

Review Output Outputs from the management review shall include decisions and actions relevant to: Improvement of the effectiveness of the IMS; Definition of new objectives and targets; Identification of corrective and preventive actions; Modifications concerning the performance indicators; Allocation, if required, of additional budgets and resources.

At the end of the Management review records of the results/outputs shall be retained.

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5.

ROLES AND RESPONSIBILITIES The management review at BU level shall be attended at a minimum by: ASID BU Director; ASID HSE Coordinator; Branch Managers or HSE Branch Managers.

The management review at branch level shall be attended at a minimum by the Branch Manager and the Branch HSE Manager. Individual responsibilities are summarized here below.

5.1.

ASID BU Director The BU Director shall: Define, supported by the ASID HSE Coordinator and the Branch HSE Managers, the actions at BU level to be implemented, if any, to guarantee the effectiveness of the HSE IMS and its continual improvement; Ensure at BU level the availability of the economic, human and technical resources for the implementation of these actions and for the implementation of the present guideline.

5.2.

ASID HSE Coordinator ASID HSE Coordinator shall: Plan and organize the management review at BU level in compliance with the minimum requirements set in the present guideline; Support the BU Director for the identification of the actions at BU Level to be implemented, if any, to guarantee the effectiveness of the HSE IMS.

5.3.

Branch Manager The Branch Manager shall: Define, supported by the Branch HSE Manager, the actions at branch level to be implemented, if any, to guarantee the effectiveness of the HSE IMS and its continual improvement;

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Ensure at branch level the availability of the economic, human and technical resources for the implementation of these actions and for the implementation of the present guideline.

5.4.

Branch HSE Manager ASID Branch HSE Managers shall: Provide to the HSE coordinator all the documents and data of interest for the management review at BU level regarding all activities that falls within the branchs competence, including activities carried out by contractors and subcontractors for management review; Support the BU Director for the identification of the actions at BU level to be implemented, if any, to guarantee the effectiveness of the HSE IMS; Plan and organize the management review at branch level in compliance with the minimum requirements set in the present guideline; Support the Branch Manager for the identification of the actions at branch level to be implemented, if any, to guarantee the effectiveness of the HSE IMS.

5.5.

Operational manager Operational manager shall support the Branch HSE Manager for the collection of all required HSE IMS documentation and data.