overview of quality, health, safety and environmental

Trans Adriatic Pipeline AG Lindenstrasse 2, 6340 Baar, Switzerland

www.tap-ag.com

Copyright Reserved: This document may not be copied, shown to or placed at the disposal of third parties of 24

without prior consent of TAP AG.

Overview of Quality, Health,

Safety and Environmental

(QHSE) Management at TAP

AG

October 2020



Table of Contents

1. Introduction ................................................................................................................................................. 3

1.1 Purpose ................................................................................................................................................. 4

1.2 Abbreviations and Definitions ............................................................................................................... 4

2. Integrated QHSE Management System ...................................................................................................... 6

2.1 Introduction ........................................................................................................................................... 6

2.2 Scope .................................................................................................................................................... 7

2.3 Leadership and commitment ................................................................................................................. 8

2.4 Management System Processes and document structure ................................................................... 8

2.4.1 Process Map .................................................................................................................................. 8

2.4.2 Documentation Structure ............................................................................................................... 9

2.5 QHSE Policies ..................................................................................................................................... 12

2.6 Planning .............................................................................................................................................. 13

2.6.1 Risk Management and opportunities ........................................................................................... 13

2.6.2 QHSE Plans and Programs ......................................................................................................... 14

2.6.3 QHSE Communication and QHSE Culture .................................................................................. 14

2.7 Implementing ....................................................................................................................................... 16

2.7.1 QHSE Compliance and Legal requirements ................................................................................ 17

2.7.2 Competence and Training ............................................................................................................ 17

2.7.3 QHSE Management in contractors .............................................................................................. 17

2.7.4 Management of Change............................................................................................................... 18

2.7.5 Behaviour Based Safety (BBS) .................................................................................................... 18

2.7.6 HSE Incident reporting and investigation ..................................................................................... 19

2.7.7 Lessons Learned .......................................................................................................................... 19

2.7.8 Permit to Work System ................................................................................................................ 19

2.7.9 Environmental, Social and Cultural Heritage Management ......................................................... 20

2.8 Checking ............................................................................................................................................. 20

2.8.1 Monitoring, Measurement, Analysis, Evaluation and Reporting .................................................. 20

2.8.2 Internal QHSE Audits ................................................................................................................... 20

2.9 Improving ............................................................................................................................................ 21

2.9.1 Organisational Knowledge ........................................................................................................... 21

2.9.2 Management of Non Conformances ............................................................................................ 21

2.9.3 Management Review ................................................................................................................... 21

2.10 TAP AG 7 Principles of Quality ......................................................................................................... 22

2.11 Emergency Preparedness and Response ........................................................................................ 22

2.11.1 Alert Management ...................................................................................................................... 22

2.11.2 Notification ................................................................................................................................. 24

2.11.3 Training and Preparedness ........................................................................................................ 24



1. Introduction

The Trans Adriatic Pipeline (TAP AG) is designed to transport natural gas from the Shah Deniz II development in Azerbaijan to the European market.

The TAP AG pipeline has the following main economic and strategic benefits:

• Diversification of gas transportation routes

• Reducing the risk of over-reliance on a single energy source and improved security and diversity of energy supply.

• Access to gas produced in the Caspian Region

The TAP AG pipeline route is illustrated in Figure 1 and described below.

Figure 1 – TAP AG Pipeline Route

Starting at the border of Greece and Turkey, where it connects with the Trans Anatolian Pipeline (TANAP), TAP AG crosses Northern Greece, Albania and the Adriatic Sea to southern Italy, where connects to the Italian gas transportation grid. The TAP AG project represents the final stage in the development of the Southern Gas Corridor, traversing 6 countries and 3,500 km.

The initial capacity of TAP AG is 10 billion cubic metres (bcm) of gas per year with a potential overall capacity of 20 bcm following the installation of necessary additional equipment and infrastructure (e.g. additional compressor stations).

TAP AG has developed an integrated Quality, Health, Safety, Environmental Management System (hereafter

QHSE MS) and tools to ensure that the organisation complies with the relevant legislation and regulations

in the field of health and safety and the environment.



1.1 Purpose

The purpose of this document is to provide an overview of how QHSE is managed at Trans Adriatic Pipeline

(hereafter TAP AG).

This document covers operations and maintenance and provides an overview of the QHSE-related

management system.

1.2 Abbreviations and Definitions

BOD Board of Directors

CSR Corporate and Social Responsibility

BBS TAP AG Behaviour Based Safety Procedure

BS OSHAS 18001

/ISO 45001

Occupational Health and Safety Management Systems – Requirements

Coms Communication

CMT Crisis Management Team

CTA Common Terms Agreement

EMAS Eco-Management and Audit Scheme

ER Emergency Response

ESCH Environmental, Social and Cultural Heritage

ESMM Environmental and Social Management Manual

ETS Emissions Trading System

FEED Front End Engineering Design

FERA Fire and Explosion Risk Analysis

HAZID Hazard Identification

HAZOP Hazard and Operability Studies

HSE Health Safety Environment

HSELV Health and Safety Leadership Visits

Interested party Person or organisation that can affect, be affected by, or perceive itself to be affected by a decision or activity

IMT Incident Management Team

IOGP International Association of Oil & Gas Producers

ISO 9001:2015 Quality Management System - Requirements

ISO 14001:2015 Environmental Management Systems – Requirements with Guidance for Use

ITT Invitation to Tender

KPI Key Performance Indicator

LT Leadership Team

MOC Management of Change

MS Management System

NC Non Conformance



Ops Operations

Pims DC Electronic Document Management System Document Control Module

PO Planned Observation

PRT Pipeline Receiving Terminal

PTW Permit to Work

QHSE MS Quality, Health, Safety and Environmental Management System

QRA Quantitative Risk Analysis Onshore Pipeline

TAP AG Trans Adriatic Pipeline AG



2. Integrated QHSE Management System

2.1 Introduction

TAP AG has designed its integrated QHSE Management System (see 2.4.2 documentation structure)

following international QHSE standards. QHSE MS fulfils our shareholders’, stakeholders’ and lenders’

expectations regarding the quality of our services, the safety of all interested parties and environmental

protection.

TAP AG’s QHSE MS is certified against the international standards:

– ISO 9001:2015 for Quality Management System

– OHSAS 18001:2007 for Safety Management System

– ISO 14001:2015 for Environmental Management System

TAP AG will proceed with the upgrade of OHSAS 18001 to the new national ISO 45001:2018 standard,

while it also intends to register with EMAS for the Italian section.

The QHSE MS is based on the Plan-Do-Check-Act model of systematic management, as per the following

figure.



Figure 2_Plan Do Check Act Model at TAP AG

The key objectives of TAP AG’s integrated QHSE MS are to:

• minimise the likelihood of overlapping responsibilities

• avoid duplication of effort and create objectives and plans that do not compete against or contradict each other

• better allocate available resources

• apply harmonised methods and processes and reduce documentation

• meet applicable ISO standards’ and shareholders’ and stakeholders’ requirements.

2.2 Scope

TAP AG QHSE MS is applicable to the following owned and operated facilities in Greece, Albania and Italy:

– Pipeline right of way (550 km) from the border between Greece and Turkey in Kipoi up to the

border between Greece and Albania, including compressor station at Kipoi and 23 block valve

stations



– Pipeline right of way (215 km) from Qendër, Bilisht in Korçë to 17 km north-west of Fier,

approximately 400 m inland from the shoreline, the compressor station near Fier, the metering

station near Bilisht and 9 block valve stations

– Pipeline right of way (105 km) pipeline traversing the Adriatic Sea to the Italian coast, the micro-

tunnel site near the town of San Foca (Melendugno – Lecce), the pipeline right of way (8.2 km),

Pipeline Receiving Terminal (PRT) and back-up control centre in Brindisi

– TAP AG Headquarters in Switzerland and TAP AG pipeline host countries (offices and facilities)

The QHSE Management System is intended to apply to TAP AG and O&M contractors undertaking work

within TAP AG operational facilities listed above.

2.3 Leadership and commitment

TAP AG Leadership Team (LT) demonstrates QHSE leadership and commitment with respect to employees,

contractors, communities and customers by ensuring that:

– Applicable statutory and regulatory QHSE requirements are determined, understood and consistently

met;

– The risks and opportunities that can affect gas transportation and the ability to enhance customer

satisfaction are determined and addressed.

The TAP AG management through the QHSE Function, ensures that this management system is

established, maintained and continually improved including the processes required and their interactions.

To support the implementation of the QHSE policies and management system, QHSE function includes

among its roles:

– Encouraging strong QHSE leadership in TAP AG

– Promoting robust QHSE management throughout TAP AG by providing the Functions with

management tools in order to ensure they can properly exercise their “line management”

responsibility for QHSE

– Remaining true to the TAP AG value of Responsibility – acting safely and caring for the future

– Fulfilling an assurance function – monitoring QHSE performance and directing improvements in

order to achieve exemplary QHSE performance.

2.4 Management System Processes and document structure

2.4.1 Process Map

TAP AG has developed the QHSE Management Process Map accessible to all TAP AG employees via

intranet, as a tool to:

– show the sequence and interaction of our processes. TAP AG employee through this map can

understand the processes, meaning they understand what we are doing and how we are doing it

– while also providing access to the associated and last updated documents (policies, manuals,

procedures) that define controls over these processes.



Figure 3_TAP AG Process Map

Process owners ensure that their specific process is implemented, monitored and continuously improved.

2.4.2 Documentation Structure

A hierarchical documentation structure applies for documentation at TAP AG as follows:

Figure 4_Documentation Hierarchy

The documentation supports the delivery of our processes including:

are the processes that are related with decision making activities

are the processes that are related with the provision of our services

Supporting are the processes that indirectly contribute to the value added of our final services



– Policies & Strategies: TAP AG Policies provide a framework for deploying our objectives in the subject,

relevant to the policy.

– Manuals: Provide high level controls associated with the subject regarding what has to be done, how it

is to be achieved and who is responsible for each element of the manual.

– Management System Procedures (at two levels): Provide the requirements/parameters/controls in

specific topics in support of the Management System, so deploying our Manual’s principles in detail.

– Work Instructions: Provide detailed instruction on how to carry out work associated with specific work

activities in support of delivering the objectives of process.

– Other assorted document types required by one or more of TAP AG’s processes.

All system and Process related documents are accessed via the intranet and the master documents

managed in Pims DC (TAP AG Enterprise Document Management System).

The following illustration shows how the Master Documentation of the QHSE MS is structured, in order the

above objective to be achieved. Furthermore, the QHSE documentation on TAP AG Process Map has been

designed following the below structure.



Commitments Register

Environmental and Social Management

Manual

ESIAs EU LegislationNational

LegislationPermits

International / Lender Standards

Source documents

QHSE Management System Manual

QHSE Auditing

Non-conformity Management

Procedure

Level 2 Manuals

Level 3.1 General Procedures

TAP Operations Environmental

Standards Manual

TAP Context Analysis – Risk, Opportunity and Actions Report

QHSE Integrated Operational Control

Procedures

Management Of Key Performance

Indicators Procedure

QHSE Management Review Procedure

TAP Lessons Learned Procedure

QHSE Environmental Operational Control

Procedures

QHSE - Communication

Procedure

QHSE Safety Operational Control

Procedures

QHSE Plans And Programs Procedure

Integrated QHSE Management System

Planning Implementing Checking Improving

Country HSE

Manuals

QHSE Policies

Level 1 Policies

Legend

Level 3.2 Procedures

Input Documents to

the QHSE Management

System

Project Documents

TAP Policies

Level 5 Method Statements,

Plans

QHSE Committee and Network

Meeting

Level 4 Work Instructions

• QHSE Policy

• Lone Worker

• Drug & Alcohol

• TAP Safe Driving

QHSE Policies

•

• Confined Spaces• Electrical Works• Journey Management• Lifting Operations• Permit to Work• Radiological Works• Safety and Consultation Zones• Self Supported Cranes• Use of Scaffolding• Working at Height• Interventions On Safety Valve• Works With Risk Of Fire And Explosion

•

• Grievance Management• Identification And Assessment of TAP

Environmental Aspects And Impacts• Noise Control• Offsets Management• Operational Control and follow up of

Environmental Aspects• Pollution prevention• Waste Control• Spills Control And Discharge Management

Procedure• Atmospheric Emissions Management

• QHSE Training Procedure

• QHSE Management In Procurement Process

• Corporate Management Of Change Procedure

• QHSE Incident Reporting And Investigation Procedure

• Alert Management

• HSE Hazard, Impact and Risk Assessment

• QHSE Moments

• Safety Data Sheet Control

• Special Operations Control

• TAP Behavior Based Safety

• TAP Traveler Procedure

• Technical Risk Matrix And Tolerance Criteria

•

• Personal Protective Equipment (PPE)• Use of Unmanned Vehicles (Drones)• Permit To Work Role Assessment • Norm monitoring

•

• Cultural Heritage Management (Greece)• Cultural Heritage Management (Albania)• Cultural Heritage Management (Italy)• Livelihood Restoration (Greece)• Livelihood Restoration (Albania)• Livelihood Restoration (Italy)• Office Waste Management (Baar)• Office Waste Management (Greece)• Office Waste Management (Albania)• Office Waste Management (Italy)• Reporting and Calculation of NOx SOx and

CO Emissions• Emissions Management Under European

Union Emissions Trading System (ETS) Procedure

• Greenhouse Gas Emissions Monitoring & Reporting Procedure

• Environmental and Social Impact Assessments

• Environmental Monitoring Documents

• Emergency Response Plans

• HSE Risk Assessments (Job Role and Facilities)

• Scenario Specific Response Guidelines

•

• HSE Legal Compliance• QHSE Minimum standards for Contractors• Management System Documentation

Integrated QHSE Health and Safety Environmental

Operational Control QHSE Documentation




Level 3.2 Specific QHSE Operational

Control Procedures

Level 3.2 Specific QHSE Operational

Control Procedures

• Air Quality Monitoring

• CEMS Systems Reading And Discharge From Stack

• Ground Water Sampling

• Light Monitoring

• Noise Monitoring

• Waste Water Sampling

Level 5 Method Statements

Project Documents

Level 5 Docs

Level 3.2 Integrated QHSE Operational

Control Procedures

Figure 5_ Presentation of QHSE Management System Documentation



2.5 QHSE Policies

The TAP AG has developed the following policies related to health,

safety and environment issues:

• QHSE Policy

• Drug and Alcohol Policy

• Driving Policy

• Lone Worker Policy

• CSR Policy

QHSE Policy sets out the key commitments of TAP AG Top

Management regarding QHSE matters and provides a framework for

the setting of QHSE objectives. The QHSE Policy is aligned with the

TAP AG’s purpose and our strategic direction. Our QHSE Policy has

been developed with consideration to our Environmental Aspects and

Impacts together with the risks associated with the provision of gas

transportation.

The QHSE Policies are available to interested parties and other via:

− The company internet website (to external interested parties).

− The company intranet site (to internal interested parties).

− Any other suitable means (such as but not limited to Induction and TAP AG HSE app).

TAP AG requires all contractors to conform to the TAP AG policies, which are embedded in all major

contracts.

The leadership team may periodically review and update the existing QHSE policies to reflect the current

TAP AG vision and values; and to ensure compliance with all relevant project standards.



2.6 Planning

2.6.1 Risk Management and opportunities

TAP AG has established a number of risk management procedures providing the methodology to be used

for the various types of risk related to TAP AG. Risks shall be escalated, as appropriate, and considered at

each relevant division of the organisation as shown below.

Figure 6_Hierarchy of Responsibility for Risk Management

Records of risk assessments are maintained in different reports and at different level such as the QRAs,

HAZID, HAZOPS, Facility Risk Assessment, Job Position Risk Assessment, environmental aspects and

impacts, in Country Specific Risk Registers, Business Risk Matrix and the Risk Management Module of Pims.

Identification of the main hazards was important in the early stages of a design, in order to allow design

decisions to be made so as to reduce the risk. Hazards identification and risk assessment involves a series

of steps:

– Identification of Hazard;

– Assessment of the risk;

– Elimination or reduction of the risk (where it is deemed to be necessary).

The following risk analysis was carried out during the FEED (Front End Engineering Design) Phase and

confirm through detailed Design Phase:

– Hazard Identification (HAZID);

– Hazard and Operability Studies (HAZOP);

– Fire and Explosion Risk Analysis (FERA);

– Quantitative Risk Analysis (QRA);

– Semiquantitative risk analysis (SQRA).

– Layers of protection analysis (LOPA);

The results of the risk analysis, together with regulatory requirements, company’s governing documents and

operator safety objectives, form the basis for a safe facility design and layout development as well as the

development of the annual plans and programs, facility response plans and scenario response guidelines.



Priority has been given to the use of preventive measures and inherently safer design principles to reduce

occupational health and safety risks. During design of the infrastructure the barrier principle applies. The

intention with the barrier principle is that if one barrier fails there shall be other barrier(-s) (barriers and/or

systems) that will prevent the event to escalate into a hazard situation.

General business risk is evaluated at a strategic level in the Leadership Team meetings with a full description

included in regular reporting to the Board. These risks cover all disciplines (legal, operation, commercial,

financial, schedule, QHSE, etc) and are further analysed and managed within the departments and

disciplines.

Planning to address risks and opportunities related to the QHSE MS are carried out under the authority of

the QHSE Committee, based on the analysis of business environment (context) and the requirements of

interested parties.

2.6.2 QHSE Plans and Programs

A Corporate triennial QHSE Strategic plan is developed to ensure TAP AG’s QHSE commitments with long

term strategic objectives to enable the Company to respond to its QHSE challenges, risks and opportunities.

This plan provides direction to TAP AG Leadership whilst considering relevant stakeholders, shareholders,

and other external drivers.

Annual Corporate QHSE Plans and Programs set out how the QHSE Strategic Plan shall be delivered and

detail the Key Performance Indicators (KPI) with specific actions, roles and responsibilities and action plans

to meet the strategic QHSE objectives.

A QHSE Committee is established as a monitoring and decision-making body and to ensure industry good

practice and standards are adopted for QHSE. The committee is responsible for the approval of the QHSE

Activity Plan and Programs and is informed and consulted on the development of policies and procedures.

2.6.3 QHSE Communication and QHSE Culture

Annually TAP AG approves under QHSE Committee a Coms and wellbeing Program with different

campaigns covering topical QHSE subjects. This program may also include campaigns to communities/

municipalities to share with them TAP AG good practices and increase QHSE perception among them.

The management system objective is to implement a two-way mechanism for the communication of QHSE

issues, concerns, information, direction, guidance, queries, etc. throughout the TAP AG organisation via the

Line Management of the organisation:

• “Top-down" from the Leadership Team (LT) to Site Teams

• “Bottom-up" from the Site Teams to the Leadership Team (LT)

Coms. Function ensures that external and internal communication is managed including (but may not be

limited to):

– Public relations and external profiling

– Corporate communications strategies and plans that impact TAP AG’s national or international reputation

– Media Relations

– Branding of TAP AG internally and externally

– Communications coordination across the communications function

– Plans for participation in conferences and seminars

– Website, Intranet and social media



To facilitate communication and consultation within TAP AG and with contractors, TAP AG has established

a QHSE Executive forum of representatives from TAP AG (Leadership team, Ops. Director and TAP AG

QHSE), and main O&M contractors with the goal of sharing industry best practices, establishing consistent

wide QHSE guidelines and identifying where improvements in QHSE management can be made.

Regarding communities, from the beginning of the pipeline construction, TAP AG has engaged with local

communities to provide them with safety best practices such as safe driving, use of PPEs, children on sites,

etc, with the objective to change the mentality on safety and championed a safety culture to all host

countries.

Another example is “Call before you dig”. Non-authorised works performed in Trans Adriatic Pipeline’s

restricted ownership zone or near pipeline facilities may compromise the safety of pipeline operations.

To ensure safety for all at restricted ownership zone, TAP AG has launched the “Call before you dig”

campaign at host countries to request for land and local residents a prompt report before they dig or begin

activities in TAP’s restricted ownership zone, which is defined as a 4-metre area on either side of the pipeline

(4 + 4, 8m in total).

The telephone line is called "General Enquiries and Grievance line". Call staff shall provide all necessary

information and instructions/guidelines to anyone wishing to embark on activities in the proximity of the

pipeline. Call Centre staff shall provide general information available in TAP public domain. All specific

requests shall be recorded and forwarded to relevant departments.

Please visit our website for more information.



Golden rules for safety

To promote effective and proactive HSE culture, in addition to site risk assessments, TAP AG focuses the

attention on the following activities and risks that commonly lead to serious injuries and fatalities, by assigning

each one a standard known as a Golden Rule for Safety.

These rules summarise the minimum standard expected when completing these activities and managing

these risks:

– Permit to Work

– Ground Disturbance

– Confined Space Entry

– Working at Heights

– Energy Isolation

– Lifting Operations

– Driving Safely

– Hot Work

The TAP AG Golden Rules of Safety are applicable to all TAP AG managed (and managed on behalf of TAP

AG) locations and activities.

2.7 Implementing

In the implementation phase, TAP AG has developed a set of QHSE procedures to facilitate the

implementation of different plans and programs for the safe execution of activities and respect of

environment. These procedures are divided into three main categories;

• Integrated: those procedures applicable to Quality, Environment and Health and Safety issues such

as incident reporting and investigation, HSE legal requirements, contractors’ control, change

management, training and Behaviour Based Safety observations.

• H&S operational control: specific procedures related to health and safety that will require their

implementation according to the activity being executed. To remark Permit to Work (PTW), PPE

control, working at height, electrical works, confined space, lifting operations, works with risk of fire

and explosion.

• Environment and social operational control: in this case refers to specific procedures to protect

environment and communities. These include among others, emissions management under ETS,

noise control, waste management, pollution prevention, spills and discharge control, fugitive

emissions, carbon management, grievance, cultural heritage, etc.

In the next sections a detailed description is provided for some of these more relevant procedures.



2.7.1 QHSE Compliance and Legal requirements

TAP AG QHSE Function have identified the HSE legal requirements applicable to TAP AG’s activities and

facilities that includes:

- At European level: directives, decisions and regulations published in the Official Journal of the

European Community, to the extent applicable

- At the national level: applicable laws, decrees, regulations etc.

Regulatory HSE compliance is managed in accordance with TAP AG HSE Legal Compliance Procedure

through the use of electronic compliance database. The electronic database is updated periodically (varying

depending on the country) to ensure it remains reliable and current.

2.7.2 Competence and Training

TAP AG provides general awareness training to all employees and consultants regarding key QHSE issues

as part of the induction training for new starts. A QHSE induction for all staff and certain contractors also

includes QHSE information and this is supplemented with worksite specific QHSE training.

TAP AG has established a portfolio of web-based QHSE training courses, both adapted from existing

materials in the oil and gas industry and as custom-made courses specific to TAP AG’s QHSE standards

and procedures. A number of these courses are mandatory for all employees and completion is linked to the

personnel assessment process. Mandatory training is described on the Annual Training Program.

For the Operations staff, TAP AG developed the Training And Competency Assurance Strategy, as well as

the training plan (matrix) based on the on job role, location, risk exposure and tasks that the staff will have

to perform during the operational phase.

To make sure that the staff is trained and competent to perform the relevant tasks, TAP AG has drafted the

“Operations Training And Competence Assurance Procedure”.

Example of some QHSE training provided to the Operations staff in the different locations is:

• QHSE Procedure training: Operational Controls training, Environmental training, TAP AG Golden

Rules and Management System, Permit to Work, etc.

• HSE skills training: defensive and off-road driving, first aid, fire fighting, gas testing, working at height,

etc.

• Emergency Response: IMT (Incident Management Team), Emergency Response Plan training and

exercises in the different countries, etc.

• Other specific technical training related to safety elements of the asset.

2.7.3 QHSE Management in contractors

QHSE performance in contractors is key for safety execution and environmental control of our activities. For

this reason, QHSE is present from procurement phase including, where required, specific QHSE

requirements in pre-qualification and tender documents for suppling of goods and services.

Suppliers/Contractors wishing to be considered for TAP AG contracts are subject to suitable levels of QHSE

evaluation in order to ensure that they have adequate QHSE management arrangements and performance

to meet TAP AG’s expectations, depending on the work that they are potentially undertaking on behalf of

TAP AG.

This shall be in regard to:

– Pre-qualification for work that may or may not be required at the point when the new

supplier/contractor is engaged.



– Invitation to Tender (ITT) when there is a required and known scope of work that is to be

undertaken.

Once contract is awarded, TAP AG request its contractors to comply with relevant TAP AG’s QHSE

Standards and Guidelines in addition to any applicable Laws and regulations in country.

TAP AG may require contractors to develop an HSE plan/Bridging document that shall address the HSE

risks associated with the work or services to be developed in our TAP AG facilities and define the actions to

be taken to control those risks to an acceptable level. Contractor’s HSE plan shall also contain the list all

Personnel engaged in the performance of the work including training records, competency and Fit to Work

certificates. HSE plan also refers to environmental management from contractors.

The Contractor shall also be requested to ensure that each subcontractor shall provide all QHSE obligations

specified in this point.

Commencement of the work shall be subject to the QHSE’s receipt and approval of all required HSE

documentation. Once approved, contractor shall have a “green light” that shall allow to work in TAP AG

premises.

2.7.4 Management of Change

Management of Change (MOC) is one of TAP AG’s key business processes; integral to the safe and efficient

operation of the company across all countries, facilities and sites. Furthermore, the controlled and rigorous

management of changes, has been proven to be ‘good for business’ and ultimately Company reputation.

Management of Change procedure defines a rigorous, controlled, step-by-step process to identify, assess,

communicate and manage change within TAP AG.

2.7.5 Behaviour Based Safety (BBS)

Research1 evidence suggests that organisations should concentrate 80% or more of their HSE culture

improvement efforts on behavioural factors (i.e. managerial HSE related behaviours) to prevent process

safety and serious incidents.

TAP AG uses BBS forms like HSE Visit, HSE Leadership Visit, Planned Observation, Unsafe act / condition

in order to intervene against unsafe conditions and demonstrate positive HSE behaviours.

• HSE Visits: HSE visits are performed regularly by site management or personnel with specific QHSE

roles (e.g. fire wardens, first aiders) and the guidelines of the TAP AG Behaviour Based Safety (BBS)

Procedure are applied.

• Leadership Visits (LV): Leadership visits are undertaken by management as management’s

behaviour and attitude are critical to the success of the HSELV. HSELV will help improve HSE

standards and the HSE culture of the organisation. HSE leaders don’t influence others through

power, status or authority; they demonstrate positive HSE behaviours that inspire others to do the

same.

• Planned Observation (PO): Planned observation involves observing HSE behaviour at the site /

other location; intervening with an individual(s) when unsafe behaviour is perceived; then having a

conversation with the individual(s) to understand the observation; and when required, having an

1 Dr D Cooper CFIOSH C.Psychol, ‘Navigating the Safety Culture Construct: A Review of the Evidence’

(2016)



agreement with the individual(s) performing the unsafe act, to make a commitment to change their

behaviour.

This shall be a scheduled action conducted in all cases by personnel that are familiarised and trained

on this tool. It is recommended also that people performing the PO shall also have the knowledge

and competence of the task being performed.

This intervention may also be used to congratulate individual(s) on their positive HSE performance.

Integrating PO into daily tasks contributes to creating effective HSE leadership at all levels and

empowers individuals to ‘stop the job’ if they feel its unsafe through Observation and Intervention.

When delivered by non-HSE personnel a PO is much more powerful coming from them and

increasing conversations about HSE creates a positive culture.

• Unsafe Act / Condition Observation: TAP AG personnel shall intervene when they see an unsafe

condition (or unsafe act). This is how TAP AG demonstrates its’ HSE approach that if something

unsafe is observed (i.e. unsafe condition or unsafe act) the observer has an obligation to do

something to make the situation safe i.e. if you see it, you own it – don’t walk by and where this is

not possible, identifying the person responsible and arranging with them to make safe.

2.7.6 HSE Incident reporting and investigation

TAP AG requires that all HSE incidents (including near misses, accidents, spill or releases of material to the

environment, or social incidents such as damage to cultural heritage or third-party property or infrastructure)

are reported and investigated so necessary actions are taken timely and measures are put in place to avoid

future occurrences.

TAP AG follows the International Association of Oil & Gas Producers (IOGP) rules and definitions for HSE

incidents.

Regarding the Lenders, under Common Terms Agreement (CTA) TAP AG is required to notify lenders of

QHSE incidents that fall within lender reporting criteria. TAP AG is also required to develop and implement

a remedial action plan where a QHSE incident results in a non-compliance with environmental and social

requirements outlined within the CTA.

TAP AG has implemented a procedure establishing responsibilities for incident reporting, management and

resolution and the process to be used across TAP AG to investigate incidents.

2.7.7 Lessons Learned

After incident investigation and depending on the category of the indecent a

lesson learned form will be completed and distributed containing the key

learnings from the incident and recommendations to prevent recurrence of

like-in-kind events.

2.7.8 Permit to Work System

The Permit to Work system is key for controlling the work to ensure that it is conducted safely. It is a formal process used to control the work in TAP AG’s facilities and the means of communication and co-ordination between the different parties involved in an activity.

TAP AG Permit to Work procedure is applied to regulate the operations and control of activities carried out at TAP AG’s assets providing direction for personnel involved in the process of preparing, issuing, monitoring and controlling as well as the responsibilities associated.



Correct use of the Permit to Work Procedure during planning, risk assessment, isolation of energy sources and work execution will ensure that the risks to personnel, the environment and assets are reduced to as low as reasonably practicable.

2.7.9 Environmental, Social and Cultural Heritage Management

To ensure management and monitoring of environmental, social and cultural heritage issues, TAP AG has

developed an Environmental and Social Management Manual (ESMM) that provides an overview of the

Environmental, Social and Cultural Heritage (ESCH) standards applicable to TAP AG’s operations, detailing

how operational ESCH risks are managed to conform with applicable TAP AG performance standards, key

roles and responsibilities associated with ESCH management and defines TAP AG internal and external

ESCH reporting requirements.

The ESMM also details the ESCH compliance oversight and assurance framework designed as a

mechanism to verify that the work planned and performed is conducted according to TAP AG’s ESCH

performance standards on issues such as carbon management, waste control, pollution prevention and air

emission monitoring. The framework is based on a range of tools and processes adopted by TAP AG to

manage, monitor, measure and report ESCH performance and avoid and mitigate impacts.

2.8 Checking

2.8.1 Monitoring, Measurement, Analysis, Evaluation and Reporting

The main thrust of monitoring and measuring shall be to determine the level of achievement of TAP AG’s

objectives (KPIs), plans, programs and the effectiveness of the QHSE MS. Information and data associated

with the performance of processes and effectiveness of the QHSE MS are annually analysed and evaluated.

Annual action plan(s) are developed and followed up by process owners as a focus for the setting of KPIs

(based on the above). These KPIs are collated into functional scorecards that are associated with functions

that support the delivery of gas.

Results and actions from the analysis and evaluation will be retained as records as will management review

records.

2.8.2 Internal QHSE Audits

TAP AG’s QHSE Function shall ensure that internal audits of the QHSE MS are carried out at planned

intervals and in compliance with the approved internal QHSE Audit Program. The purpose of these audits is

to provide information regarding whether practices at TAP AG comply with the requirements defined in the

company’s QHSE MS and the requirements of ISO 9001:2015, ISO 14001:2015 and ISO 45000:2018 and

that the system is effectively implemented across the company.

The criteria for audits and scope of audits is defined for each audit. Auditors are selected, and audits

conducted with consideration to objectivity and impartiality.

– Results of audits are reported to both the auditee and managers.

– Where required correction and corrective action shall be taken.

– Records of audits (audit reports and associated actions) shall be retained.



2.9 Improving

2.9.1 Organisational Knowledge

TAP AG shall provide the basis for managing the knowledge necessary for the operation of our processes

and conformity of our service (transportation of gas); management of knowledge may consider (but not be

limited to):

– Lessons learned from Quality, Health, Safety and Environmental events, as per TAP AG Lessons

Learned Procedure.

– Sharing of stored documented knowledge (explicit knowledge) such as management system and

process documents, reports, training material etc.

2.9.2 Management of Non Conformances

TAP AG manages non-conformances when they occur including those that arise from complaints:

– Acting to control and correct the non-conformity.

– Dealing with and containing consequences (such as any other issues of a similar nature, or any potential

for similar events).

Non-conformances are reviewed and evaluated and where required, corrective actions implemented to

eliminate the cause of a nonconformity and to prevent recurrence.

2.9.3 Management Review

The Leadership Team has established the QHSE Committee to periodically review the overall effectiveness

of the QHSE MS across all organisation of TAP AG (Headquarters and Host Countries).

The purpose of the Management Review is three-fold:

– To provide management with a summary of QHSE performance over the year particularly in regard

to:

– Suitability.

– Adequacy.

– Effectiveness.

– Alignment with TAP AG’s strategic direction.

– Identify where improvements can be made, and

– Summarise the significant QHSE risks and their proposed mitigation, in the following period.

The last two points are used to develop the QHSE Activity Plan and the QHSE Departmental targets for the

following year.



2.10 TAP AG 7 Principles of Quality

TAP QHSE management system has been developed in accordance with ISO 9001:2015 requirements. This

standard is based upon the Seven Quality Principles, which TAP has adopted and promotes through

induction:

Figure 7_ 7 Principles of Quality at TAP AG

These principles are in line with the definitions provided in the following ISO quality standards:

• ISO 9000:2015 “Quality management systems Fundamentals and vocabulary”;

• ISO 9004:2018 “Quality management – Quality of an organization – Guidance to achieve sustained

success”.

2.11 Emergency Preparedness and Response

2.11.1 Alert Management

TAP has developed an Alert Management Procedure that describes the Alert Management Process in TAP

providing direction for personnel involved as part of an integrated Operation and Maintenance system, and

includes the following:

– Instructions to be followed to perform Alert Management activities. – Assignment of responsibilities for Alert Management activities.

Under the concept of Alert TAP considers (a) “Events” as an abnormal situation of the transmission system

but is not classified as an emergency, thus does not require the activation of the site Emergency Response

Plan and (b) “Emergencies” which consist of a sudden, unexpected, or impending situation that causes, or

has the immediate potential to cause, injury, loss of life, damage to assets or the environment, damage to

reputation or interference with the normal business.

According to the level of Emergency (Tier 1, (Site level), Tier 2 (Country level) or Tier 3 (Crisis)) shall require

the activation of the appropriate Crisis and Emergency Response Plan which describes in detail the

notification and reporting lines, roles and responsibilities and specific resources put in place to manage an

emergency.



The following figure illustrates how TAP AG has organised their emergency teams (tiers) along with the main

tasks of each Tier.

Team Purpose Lead Location Main tasks

Crisis Management

Team

Tier 3

Strategic LT member Baar

Provide business level response focusing

onstrategic and business continuity issues

Liaison with Shareholders, other

stakeholders, media, next-of-kin (NOK)

Liaison with Contractor

headquarters/strategic emergency response

centres

Provide internal expertise as part of CMT

(e.g. legal, insurance, procurement)

Incident

Management Team

Tier 2

Tactical Asset

Manager

Country

where

incident

happens

Provide overall coordination of the response

in-country

Liaison with government agencies / local

communities

Liaison with contractor emergency/incident

team in-country

Communications link with Level 3 CMT and

Level 1 ERT

Emergency

Response Team

Tier 1

Operational

TAP

Response

Team

Leader

At

incident

location

/ field

Primary response at the emergency scene

Make scene safe and prepare for

investigation.

Call-out and liaise with emergency services

Communication link with the Level 2 IMT

Figure 8_TAP Crisis and Emergency Response Organisation

To succeed throughout all levels of the TAP AG Crisis and Emergency Response organisation, this strategy

is implemented by having;

• defined roles and responsibilities for all Crisis and Emergency Response teams;

• defined interfaces and communications between all teams at TAP AG Headquarters (HQ), Country

Offices (CO), Ops. sites and contractor organisations; and

• regularly trained duty managers and team members.



TAP AG Crisis and Emergency Response Principles

TAP AG’s four Crisis and Emergency Response principles are:

1. Principle of responsibility; what lies within the organisation’s responsibility in normal day-to-day

business is also its responsibility in a crisis. This means that all levels of the organisation shall plan for

pursuance and problem solving in an emergency.

2. Principle of parity; the emergency preparedness organisation should resemble the normal business

organisation as much as possible.

3. Principle of subsidiary; all crises shall be handled at the lowest possible level to achieve a satisfactory

response.

4. Principle of cooperation; the company has a responsibility to ensure the best possible cooperation with

relevant stakeholders.

TAP AG Crisis and Emergency Response Policy

During any crisis or emergency involving TAP AG assets or personnel, our over-riding priorities are to

PROTECT the following (in this order of priority):

1. People 2. Environment 3. Asset 4. Reputation

The ER Strategy is supported by different ER Plans which define detailed requirements, notification and

reporting lines, roles and responsibilities of the various members of the Teams and specific resources put in

place at TAP AG HQ and in the host countries and sites. These plans are routinely tested during exercises

and training initiatives in TAP AG HQ and in the host countries. The aforementioned plans are support with

an Alert Management Procedure.

2.11.2 Notification

TAP AG has local TAP AG Emergency Numbers active in Greece, Italy and Albania and these are publicized throughout the organization and across the right of way in the marker posts and in our facilities. These numbers are supported by a 24/7 Dispatching center to ensure this call is always answered.

TAP AG has also a Response Team 24/7 on each country trained to activate the response organisation through mobilisation of the response team and if needed the country IMTs or the Baar HQ CMT and in all cases prudent overreaction is requested i.e. if in doubt - inform.

2.11.3 Training and Preparedness

To ensure the preparedness of the TAP AG Crisis and Emergency Response organisation annual training is

scheduled and is intended to be delivered by external Crisis Management training organisations and/or

internally by the QHSE function.

For the exercise, an identified incident risk shall be used to develop a scenario. Two levels of the Crisis and

Emergency Response organization shall participate in the exercise, and the Teams will respond to scripted

injects on a timed basis. The exercise may include external agencies and organisations to add realism to

the exercise.