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OPERATIONAL EXCELLENCE QC-OEM-MNL-00-0001

Rev. 1

OE COMPLIANCE ASSURANCE MANUAL 11-Jul-2013

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QC-OEM-MNL-00-0001 Page 1 of 46

TABLE OF CONTENTS

1 INTRODUCTION ............................................................................................................ 2

2 SCOPE / PURPOSE ....................................................................................................... 2

3 DEFINITION ................................................................................................................... 2

4 OE ELEMENT REQUIREMENTS................................................................................... 2

5 RESPONSIBILITIES .................................................................................................... 45

6 REFERENCES ............................................................................................................. 46

7 ATTACHMENTS .......................................................................................................... 46

Rev Issue Date Amendment Description Prepared

By Reviewed

By Approved

By

1 11-Jul-13

Included the purpose, responsibilities and applicable work processes for OE elements in section I and Section II.

Included applicable regulations and reference standards for all OE elements in sections I, II and III.

Included applicable regulations, standards, guidelines in the attachments for reference.

Incorporated the information from the HSE Compliance Policy’ HSE-HGN-PCY-00-0002 into this document at respective sections and

HSE Compliance Policy’ HSE-HGN-PCY-00-0002 was made obsolete.

Ramdas

Carl Poldrack /Jeff Gates / Ahmad Homssi / / Jonathan Saucedo / Faiz Ahmed

Khalid Al-Jasim

0 11-Nov-12 First Release Ramdas OE element owners

Khalid Al-Jasim

Next Scheduled Periodic Review: July /2016


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1 INTRODUCTION

Company has adopted CPChem Operational Excellence (OE) System for System performance and compliance assurance. Operational Excellence System (OE) is intended to help Company standardize our efforts companywide and increase our collective rate of improvement.

The OE System elements for different work processes are outlined under 3 sections.

Management Process Work Processes and Involvement Focus Areas

2 SCOPE / PURPOSE

The scope and purpose of this document is to illustrate relevant documents and work process/practices developed by the Company to meet the OE element requirements and to identify the action owner for each element. The work processes and Reference Standards/requirements indicated in this document are not exhaustive.

This document is applicable to the manufacturing facilities in Mesaieed and Ras Laffan and the main administration facility in Doha.

3 DEFINITION

OE: Operational Excellence

PTW: Permit to Work

JSA: Job Safety Analysis

UCIT: Unsafe Condition Identification and Tracking

SMP: Standard Maintenance Procedure

SOP: Standard Operating Procedure

4 OE ELEMENT REQUIREMENTS

4.1 MANAGEMENT PROCESS

4.1.1 Element 1.1, Management Commitment and Leadership

To provide policy, management direction, resource support, and engaged leadership for the achievement of world class Operational Excellence. Responsibilities include:

i. `Effective implementation of the Operational Excellence Policy and OE System.


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Work Process

Associated Facility Policy/Procedure/Activity:

i. Q-Chem Management System (HSE-HGN-PCY-00-0001).

ii. Management Leadership, Communication, and Accountability (QC-OEM-PCY-00-0001).b

iii. Performance Management Policy (AD-HRD-PCY-00-0021).

iv. Strategic Planning and Deployment (QC-OEM-PCY-00-0004).

v. Management System Responsibility and Accountability Matrix (QC-OEM-MTX-00-0003)

vi. Tenets of Operation Training (presented by Plant Leadership), incorporating Tenets on LLR, meetings, etc.

vii. Town hall meetings, CPChem, QP, Qatofin reports.

http://qedms/NetFYI/cgi/NetFYIIsapi.DLL?Method=AddLogin+RetrieveDoc&L=L&DSN=FYI&UserID=RO&PASSWORD=RO&C=Plant%20Information--RO&F=281&D=314239








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4.1.2 Element 1.2 – Accountability and Responsibilities

To ensure that OE roles, responsibilities, and authorities are defined, documented, and communicated, and that all of the organization’s members are accountable for assigned roles, responsibilities, and results. Responsibilities include:

i. Define, document and communicate OE roles, responsibilities, and authorities for

their organization.

ii. Accountable for OE results including leadership of OE implementation and improvement of OE results.

iii. All employees are responsible for performing their defined OE roles and

responsibilities. At a minimum, all employees are expected to participate in the achievement of safe and incident-free business operations and are accountable for their behaviors and individual results.

4.1.2.1 Work Process


i. Management Leadership, Communication, and Accountability (QC-OEM-PCY-

00-0001).

ii. Management System Responsibility and Accountability Matrix (QC-OEM-MTX-00-0003)

iii. Delegation of Authority (AD-HRD-PCY-00-0024).

iv. Employee involvement in the programs and processes such as: QSAFE, UCIT

(Unsafe condition Identification and Tracking), RIT (Reliability Improvement Team), Tool box meetings, Incident Investigation, Job safety Analysis (JSA) procedures, Standard Maintenance Procedures (SMP), Standard Operating Procedures (SOP) reviews, Change Review Teams(CRT), Management Of Change(MOC), Pre-Startup Safety Review(PSSR) etc.

v. Step Change "1 on 1" discussion with Plant Leadership representative.







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4.1.3 Element 1.3 – Strategic Planning and Deployment

To develop and deploy Operational Excellence (OE) goals, metrics, and initiatives that maintain ongoing performance improvement and achieve targeted step change improvements when needed. To maintain alignment of OE strategies throughout QChem, with a traceable “line-of-sight” ownership within all organizations for key OE improvement objectives. Responsibilities include:

i. Setting and deploying organization-specific goals, metrics, and initiatives in

alignment with the OE Focus Areas, goals, and initiatives.



i. Performance Metrics Development (PM-GEN-PRO-00-0001).

ii. Strategic Planning and Deployment (QC-OEM-PCY-00-0004).

iii. Plant Performance Updates.

iv. Plant Performance Metrics Review

v. Town hall meetings, Department/Unit Meetings, Plant Performance Metrics Updates.




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4.1.4 Element 1.4 – Communication

To provide OE related communications with internal and external stakeholders, including opportunities for influencing emerging or proposed laws and regulations that may affect the company. Responsibilities include:

i. External and internal communications at their respective levels to include local

communities, employees, and other relevant local stakeholders.



i. Management Leadership, Communication and Accountability (QC-OEM-PCY-00-0001).

ii. Corporate Communication Policy (AD-PRD-PCY-00-0001).

iii. MSDS and Technical Date sheet of Q-Chem products are all available at Q-Chem Internet page. Town Hall Meetings, Joint Marketing Advisory Committee, Contractor Communication, Managers Safety Communication Meeting.





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4.1.5 Element 1.5 – System Performance Assessments

To ensure regular, internal and external assessment of OE management system performance for all reporting entities. Responsibilities include:

i. Conduct ongoing performance assessments of their operations and business

activities to assure compliance with applicable aspects of OE and to enhance existing OE processes and programs.



i. Compliance Assurance (QC-OEM-PRO-00-0001).

ii. Management Review (QC-OEM-PCY-00-0003).

iii. Management Leadership, Communication, and Accountability (QC-OEM-PCY-

00-0001).

4.1.5.2 References

i. Referenced Standards

29 CFR 1910.119(o)(1)






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4.1.6 Element 1.6 – Benchmarking, Global OE Procedures, and Best Practices

To identify and prioritize OE performance gaps among similar CPChem, affiliate, and competitor operations or functions, and to improve OE results through shared efforts including development and deployment of best practices and CPChem procedures. Responsibilities include:

i. Responsible for agreeing on inter-functional Product Stewardship Focus Group

deliverables and membership, as well as providing sponsorship for the group.

ii. The Plant Managers Team is responsible for approving Best Practices specific to their operations or functions.

iii. Deploying adopted Global OE Procedures and Best Practices.


Placeholder (To be developed)


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4.1.7 Element 1.7 – Management Review

To ensure that organizations annually assess their overall OE outcome performance and OE effectiveness with the objective of identifying facility, organization, and management system strengths and weaknesses, and recommending changes to achieve improved overall outcome performance. Responsibilities include:

i. Reviewing OE results and sharing appropriate findings and recommendations

within their reporting structure.



i. Management Review (QC-OEM-PCY-00-0003)

ii. Management Agenda Review (QC-OEM-AGD-00-0001)

iii. Plant Metrics and performance gaps/trends (Management Review Agenda)

iv. Strategic Planning and Deployment (QC-OEM-PCY-00-0004)





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4.2 WORK PROCESSES AND INVOLVEMENT

4.2.1 Element 2.1 – Records and Information Management

To require organizations to maintain documents and records critical to OE activities that is current, accurate, controlled, properly retained, and accessible by affected employees and contractors. Responsibilities include:

i. Ensure that records are managed according to the Q-Chem Records and

Information Management Policy and Program requirements, and that employees understand their records management responsibilities.

ii. All employees are responsible for following the retention requirements as outlined in the Q-Chem Records Retention Schedule and applying them to the records under their control or custody.



i. Information Life Cycle Manual (QC-IMT-MNL-00-0001).

ii. Records & Document Management Policy (QC-IMT-PCY-00-0002).

iii. Records and Information Retention Policy (QC-IMT-PCY-00-0004).

iv. Records and Information Retention Schedule (QC-IMT-SHD-00-0001).






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4.2.2 Element 2.2 – Personnel Performance Management

To ensure that employees are competent in their work and that they conduct their activities in accordance with company OE expectations, policies, requirements, and applicable laws and regulations. Responsibilities include:

i. Human Resources are responsible for establishing personnel policies and

procedures consistent with maintaining OE expectations of the organization’s personnel.

ii. Facilities, Product Lines, and Staffs are responsible for implementing all relevant personnel policies and procedures consistent with maintaining OE expectations of the organization’s personnel.



i. Performance Management Process (AD-HRD-PCY-00-0021)

ii. Discipline Policy (AD-HRD-PCY-00-0015)

iii. Leave Policy (AD-HRD-PCY-00-0003)

iv. Recruitment and Manpower Planning (AD-HRD-PCY-00-0026)

v. Job Description (Original Version) - EDMS Files (http://qnetm/EDMSTree/)

EDMS Documents/Other documents/Administration/Job Description

vi. Job Description (New Version) - under construction in SharePoint - (http://qspwebm2/dep/HR/ManpowerPlanning/JD/Forms/Group Department View.aspx

vii. Employee profile (hard files) in Personnel Administration and Recruitment - containing employee qualifications, education and experience. This will be automated soon.

viii. Training records available in LSO - SAP R3 (records can be provided by appropriate training personnel upon request)

ix. All performance appraisals are available in SAP - Tcode PHAP_ADMIN_PA-PA: Administrator - Appraisal Document. Samples of appraisals can be made available by authorized OD personnel upon request.

x. Each performance appraisal is available to the respective owners/individuals through ESS/MSS - (http://qsapeppdm.qsap.qchem.com:50000/irj/portal)

xi. Internal Selection Policy (AD-HRD-PCY-00-0017)

xii. Performance Management Policy (AD-HRD-PCY-00-0021)





http://qspwebm2/dep/HR/ManpowerPlanning/JD/Forms/Group%20Department%20View.aspx

http://qspwebm2/dep/HR/ManpowerPlanning/JD/Forms/Group%20Department%20View.aspx

http://qsapeppdm.qsap.qchem.com:50000/irj/portal




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4.2.3 Element 2.3 – Training

To ensure that employees, contractors, and visitors are trained so that they have the knowledge and skills to perform their work or visit in a safe, secure, and environmentally sound manner, and in compliance with company policies, requirements, and all applicable laws and regulations. Responsibilities include:

i. Maintain effective employee training programs and for striving to ensure that

contractors maintain effective training programs for their employees.

ii. Employees are responsible for supporting company training requirements by providing guidance, materials, or training resources, as appropriate.



i. Training Guidelines (AD-TRN-GLN-00-0001)

ii. Global Training Matrix (AD-TRN-MTX-00-0001)

iii. Contractor Training And Visitor Orientation Program (AD-TRN-PRO-00-0024)

iv. Training - Operator Certification & Refresher Training (QC-PSM-PCY-00-0005)

v. Maintenance Technician Certification & Refresher Training (AD-TRN-PRO-

00-0010)

vi. PPE Program (HSE-SAF-PPT-00-0011)

vii. Incident Reporting & Investigation (HSE-SAF-PPT-00-0015 & HSE-SAF-PPT-00-0022)

viii. Emergency Preparedness and Response (HSE-SAF-PPT-00-0042)

ix. Heat Stress Awareness – (HSE-SAF-PPT-00-0010)

x. Confined Space – (HSE-SAF-PPT-00-0005)

xi. Permit To Work – (HSE-SAF-PPT-00-0025)

xii. Lock Tag and Try – (HSE-SAF-PPT-00-0007)

xiii. Respiratory Protection Program – (HSE-SAF-PPT-00-0002)

xiv. Job Safety analysis – (HSE-SAF-PPT-00-0026)

xv. Computer System Policy – (IT-GEN-PPT-00-0001)





















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xvi. Doha Security Orientation – (AD-TRN-PPT-00-0042)

xvii. Security Orientation - (HSE-SEC-PPT-00-0002)

xviii. Training Records Management Procedure – (AD-TRN-PRO-00-0001)

xix. SAP E-Learning Procedure – (AD-TRN-PRO-00-0008)

xx. Procedure for Creating, Approving and Maintaining Quality of Training Material

(AD-TRN-PRO-00-0012)

4.2.3.2 References


RCRA: 40 CFR 265.16(d)(3)

DOT: 49 CFR 172.704(d)(3)(5)

PSM: 29 CFR 1910.119(g)(1)(3)

PSM: 29 CFR 1910.119(j)(3)

RMP: 40 CFR 68.71(a)

CPCHEM EHS 510

29 CFR 1910.38(f)(1) (f)(3)

PSM: 29 CFR 1910.119(g)(1)(i)

40 CFR 717.12

PSM: 29 CFR 1910.119(g)(2) requires refresher operator training at least

every three years, more RMP: 40 CFR 68.71(a)(b)

Records and Document Retention QC-IMT-PCY-00-0004

Records and Document Management QC-IMT-PCY-00-0002 EPA

RCRA: 40 CFR 265.16(d)(4)

PSM: 29 CFR 1910.119(g)(3)

DOT: 49 CFR 172.704(d)(1) – (5)

OSHA Hazwoper: 29 CFR 1910.120(q)(8)(ii)

OSHA Hazwoper: 29 CFR 1910.120(q)(6)(ii), (iii), (iv) & (v) RMP: 40

CFR 68.71(b)(c)

NFPA 654 11.3 (Dust), as reference in OSHA’s Dust NEP (CPL 03-00-

008).

PSM: 29 CFR 1910.119(g)(2)

RMP: 40 CFR 68.71(b)







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4.2.4 Element 2.4 – Employee Involvement

To ensure that all employees participate in the achievement of a safe; compliant and incident free business and work place; including development; implementation; and on-going operation of OE processes and programs. Responsibilities include:

i. Creating and supporting a work environment and work processes that enable

employees to proactively identify and respond to OE concerns as well as participate in developing, implementing, and reviewing OE goals, programs, and changes to the workplace.

ii. All employees are responsible for participating in activities that maintain and

improve the business and workplace in a safe, compliant, and incident-free manner.



i. QSAFE Process

ii. PSM Compliance Manual (QC-PSM-MNL-00-0001)

iii. Management Leadership, Communication, and Accountability (QC-OEM-PCY-

00-0001)

iv. Job Safety Analysis (JSA) Procedure (HSE-SAF-PRO-00-0009)

v. Step Change meeting, Tenets of Operation training.

vi. MOC/PSSR Policy, Design Control Procedure (TE-DES-PRO-00-0025), QSAFE process.

vii. PHA teams involves operators or specialist, MOC has a CRT composed of different craftsmen

viii. Safety/Env Procedures are being reviewed by a "review team" composed of end users or SMEs.

ix. PSSR is a multi-disciplined team including affected employees

x. Unsafe Condition identification and tracking

4.2.4.2 References


29 CFR 1910.119(c)(1-3)

40 CFR 68.83(b-c)







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4.2.5 Element 2.5 – Third-Party Services

To ensure that OE considerations are addressed in the qualification, selection, and performance verification of third-party suppliers and service providers, and to systematically manage contractor performance, requiring improvements in contractor practices, where appropriate, to make them consistent with OE goals and objectives. Responsibilities include:

i. Establishing contracts that include appropriate terms and conditions stipulating

compliance with applicable OE requirements.

ii. Ensuring contractor performance is appropriately monitored and that contractors receive applicable OE information.

iii. Ensuring that Commercial Associates’ performance is appropriately monitored and that Commercial Associates receive applicable OE information (Refer to OE S2.5).

iv. Staff groups are responsible for consulting with Facilities and Project Management Teams as necessary, to support contract development and execution activities.

v. Contractors are responsible for ensuring their employees understand their responsibilities under OE.



i. Contract Process (MA-CON-PRO-00-0001)

ii. Hazard Communication Program (HSE-SAF-PLN-00-0006)

iii. Chemical Approval Request Form (HSE-SAF-SFM-00-0030), DSR, STRAFF

iv. Process Safety Management Manual (Contractors) QC-PSM-PCY-00-0006

v. Contract Administration and Performance Evaluation (MA-CON-PRO-00-

0002)

4.2.5.2 References

i. Referenced Standards Q-Chem will implement a Process Safety Management system compliant with the guidelines set forth by the United States of America Code of Federal Regulations, Title 29: Subtitle B – Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, Part 1910 Occupational Safety and Health Standards.

This Process Safety Management System will comply with the specific requirements noted in Title 29 Code of Federal Regulations Part 1910 Subpart H Paragraph 119, Process Safety Management of Highly Hazardous Chemicals.




http://qedms/NetFYI/cgi/NetFYIIsapi.DLL?Method=RetrieveDoc&L=L&C=Plant%20Information--RO&F=281&D=270021




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29 CFR 1910.119(h)(2)(i-iii),

29 CFR 1910.119(h)(2)(v) ref. to (h)(3)(i) - (v)

29 CFR 1910.119(h)(2)(v)

EHS-5180

EHS-6200

EHS-6205

EHS-6206

ii. Exception :

a) 29CFR 1910.119 (h) Contractors: Local conditions including regulatory,

language, skill transfer, personnel availability, and accepted standards of practice render this section not applicable. U.S. Dept of Labour regulations addressing contractor safety are not broadly applied in Qatar. Thus, requirements therein cannot be required of third parties. Q-Chem will develop a procedure for managing the contractors.


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4.2.6 Element 2.6 – Facility Design, Construction, and Start-up

To ensure that the design, construction, and start-up of new or modified facilities addresses reliability and meets OE goals and objectives as part of the project management work process. Responsibilities include:

i. Manufacturing Engineering, Project Management Teams, and Facilities are

responsible for managing the design, construction, and start-up of new or modified Facilities.



i. Design Control (TE-DES-PRO-00-0025)

ii. Design Basis Scoping Paper (TE-DES-SFM-00-0038)

iii. Codes and Standards Reference List (TE-DCC-LST-00-0005)

iv. Variance Approval Form (TE-DES-SFM-00-0033)

v. Guideline to Develop Scope of Work for Service Contracts (MA-CON-GLN-00-

0001)

vi. CPDEP Phase 1 – Small Projects (TE-DES-PRO-00-0015)

vii. CPDEP Phase 2 – Small Projects (TE-DES-PRO-00-0016)

viii. CPDEP Phase 3 – Small Projects (TE-DES-PRO-00-0017)

ix. CPDEP Phase 4 – Small Projects (TE-DES-PRO-00-0018)

4.2.6.2 References


EHS-6150

29 CFR 1910.119(d)(3)(ii)

29 CFR 1910.119(i)(1),

29 CFR 1910.119(i)(2)(i),

29 CFR 1910.119(i)(2)(ii),

40 CFR 68.77(a),

40 CFR 68.77(b)(2)(3)(4)












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4.2.7 Element 2.7 – Management of Change

To appropriately manage risks associated with changes that may impact environmental, health, personnel safety, process safety, product safety, and security. Responsibilities include:

i. Manage changes to the Facility, respective products Commercial Associates.

ii. Product Lines are responsible for managing changes to respective Company products and changes to respective Commercial Associates.



i. MOC/PSSR Procedure (QC-PSM-PRO-00-0003)

ii. Operating Procedures Review, Revision, and Certification (PD-ADM-PRO-00-

0001)

iii. SMP Development, Review, and Approval (MC-ADM-PRO-00-0001)

iv. Laboratory Operating Procedures, Review, Revision, and Certification (TE-LAB-PRO-00-0002)

v. Safety Manual Development and Review Process (HSE-SAF-PRO-00-0020)

vi. Building Siting Procedure (HSE-SAF-PRO-00-0014)

vii. Chemical Approval Process (part of Hazcom HSE-SAF-PLN-00-0006)

viii. Personnel Management of Change (PMOC-QC-OEM-PRO-00-0002)

4.2.7.2 References


EHS-6185

1910.119

EHS-6110












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4.2.8 Element 2.8 – Incidents and Instances of Non-conformance

To require the reporting and investigation of incidents and instances of nonconformance with appropriate rigor in a timely manner to determine root causes(s) and to develop action plans to prevent reoccurrence. Responsibilities include:

i. Facilities and Product Lines are responsible for appropriately reporting, investigating, and following up on incidents and instances of non-conformance.



i. Environmental Monitoring & Reporting Plan (HSE-ENV-PLN-00-0003),

ii. Incident / Nearmiss Reporting and Investigation Procedure (HSE-SAF-PRO-00-0001),

iii. Distribution Emergency Response, Incident Reporting and Investigation (MK-

BSR-PRO-00-0015),

iv. Operational Interruption Event Reporting & Investigation (PD-GEN-PRO-00-0003)

4.2.8.2 References


MIC Environmental Guidelines and Protection Standard (Rev 1, 2007),

State of Qatar Environmental Law 30,

GLOBAL OE PROCEDURE

Incident Recording and Reporting Procedure (EHS -1200),

15 U.S.C. § 2607(e)

TSCA § 8(e)

68 FR 33129 (amending 43 FR 11111, Part II)

29 CFR 1904.8(a)

29 CFR 1904.29(b)(3)

29 CFR 1904.29(a)

(OSHA Form 300-A and 301, or equivalent)

29 CFR 1904.32(b)(6)

29 CFR 1904.33(a)

29 CFR 1904.39(a)(b)(2) 29 CFR 1910.119(m)(7)

40 CFR 68.81(g)

EHS-1200,

29 CFR 1910.119(m)(2)

40 CFR 68.81(b)(c)









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29 CFR 1910.119(m)(3)

29 CFR 1910.119(m)(4)(iv)(v);

40 CFR 68.81(d)(4)(5)

29 CFR 1910.119(m)(4)

29 CFR 1910.119(m)(6);

40 CFR 68.81(f)


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4.2.9 Element 2.9 – Preventive and Corrective Actions

To evaluate, implement, and track to completion, preventive and corrective actions. Responsibilities include:

i. Facilities and Product Lines shall appropriately manage preventive and corrective actions recommended by or developed during investigation or assessment activities.



i. Incident/Nearmiss Reporting and Investigation Procedure (HSE-SAF-PRO-00-

0001)

ii. PHA and HAZOP/LOPA Procedure (QC-PSM-PRO-00-0001), PSM Compliance Manual (QC-PSM-MNL-00-0001)

iii. QCHEM: Emergency Action and Accountability Plan (HSE-ERT-PLN-00-0003) and Emergency Management Plan (HSE-ERT-PRO-00-0001).

iv. RLOC: Emergency Action and Accountability Plan (HSE-ERT-PLN-30-0002)

and Emergency Management Plan (HSE-ERT-PLN-30-0001)

v. Compliance Assurance Procedure (QC-OEM-PRO-00-0001)

vi. MOC/PSSR Procedure (QC-PSM-PRO-00-0003)

vii. Security Vulnerability Assessment

viii. Customer Complaint Administration

ix. Operational Interruption Reporting and Investigation

x. Action Item Management Guidelines (HSE-HGN-GLN-00-0004)

xi. Action Tracker

xii. Monthly management review of metrics

xiii. Equipment Integrity Program (QC-PSM-MNL-00-0002)

4.2.9.2 References


EHS-1200

EHS-5200

EHS-6200

EHS-6205














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EHS-6185

EHS-6350

EHS-7205


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4.2.10 Element 2.10 – Risk Management

To require organizations to identify, evaluate, and manage existing and/or potential hazards associated with products, operations, and supply chains. Responsibilities include:

i. Product Lines are responsible for managing risks associated with products, product regulatory requirements, and operations associated with toll manufacturers, suppliers, and distributors, that could impact employee and contractor health and safety, product safety, the environment, security, and the community.

ii. Facilities, Product Lines, and Global Procurement are responsible for managing risks associated with the distribution of raw materials they purchase.

iii. Facilities are responsible for managing risks associated with unit operations and other activities that could impact employee or contractor health and safety, process safety, the environment, Facility security, and local community relations.



i. PHA and HAZOP/LOPA Procedures (QC-PSM-PRO-00-0001)

ii. MOC/PSSR Procedure (QC-PSM-PRO-00-0003)

iii. Job Safety Analysis (JSA) Procedure (HSE-SAF-PRO-00-0009)

iv. Permit to Work (PTW) Procedure (HSE-SAF-PRO-00-0006)

v. IH Risk Assessments

vi. Security Vulnerability Assessments

vii. Facility Siting Studies

viii. QSAFE Program (HSE-HGN-PCY-00-0007)

ix. UCIT (Unsafe Condition Identification and Tracking) Process (HSE-SAF-PRO-00-0025)

x. Environmental Aspects/Impacts

xi. Chemical Approval Process (HSE-SAF-PLN-00-0006)

xii. Material Purchasing, Verification, Storage and Handling Guideline (TE-ERG-

GLN-00-0010)












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4.2.11 Element 2.11 – Compliance Assurance

To require that all OE-related laws, regulations, and Company policies and procedures are identified, are monitored for change, are understood, and are appropriately complied with, without regard to the degree of enforcement. Responsibilities include:

i. All organizations (Facilities, Product Lines, Staffs, and Research & Technology) are responsible for understanding and complying with all laws, regulations, and Company policy and procedures applicable to their location or business activities (Refer to OE S2.11).

ii. Senior Leadership Team, Facility, and Product Line Management are responsible

for ensuring that a process for anonymously reporting compliance-related concerns is made available to all personnel in their organization



i. Compliance Assurance Procedure (QC-OEM-PRO-00-0001)

ii. HSE Compliance Policy (HSE-HGN-PCY-00-0002)

iii. OE Compliance Assurance Manual (QC-OEM-MNL-00-0001)





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4.3 FOCUS AREAS

The following are the Operational Excellence Focus Areas derived directly from the CPChem Operational Excellence System and pinpoint specific areas the Company intends to target for continual improvement:

4.3.1 Element 3.1 - Employee Health and Safety The associated documents and the work processes are in place to implement the OE System Element 3.1 to have the protective measures for employees and to monitor effectiveness of employee protective programs.


i. QSAFE, Toolbox talk, JSA, PTW, Morning Meeting, UCIT, Safety audit

ii. QSAFE Policy: HSE-HGN-PCY-00-0007

iii. Ergonomics Program: HSE-SAF-PLN-00-0023

iv. Weekly Leadership Walkthrough Inspection (HSE-SAF-GLN-30-0001), Shift team safety audits

v. UCIT System (HSE-SAF-PRO-00-0025)

vi. Tenets of Operation training (NEO/GOT), Incident investigation, Tenets of

Operation poster/pocket card, Step-Change process, Lesson's Learned

vii. MSDS (on PTW), PTW, JSA, PHA, Hazcom, IH Exposure assessments, Safety Alert, SOP/SMP, Safety Manual, lesson's learned communication, MSCM, Safety campaigns, toolbox talk, DSR communication, signs and labels.

viii. QSAFE data and PSAP, PSM metrics, weekly safety statistics, IH exposure

assessments, PTW audit, compliance training completion record, Leadership Team KPI.

ix. Fitness For Duty Procedure (AD-MED-PRO-00-0010)

x. Business Travel Medical Procedure (AD-MED-PRO-00-0012)

xi. Procedures are all saved at EDMS and Safety webpage. All employees

including base load contractors have access to EDMS and non-base load through their DSR, procedures are being reviewed as per safety manual review procedure, best practices are being incorporated (HSE-SAF-PRO-00-0020),

xii. Medical Surveillance Program (AD-MED-PLN-00-0001),

xiii. Audiometric Testing, Benzene Medical, 1-3 Butadiene Medical, Formaldehyde

Medical, Hexavalent Chromium, Bloodborne Pathogen.











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xiv. IH monitoring plan, assessment, survey reports, medical surveillance program,

sampling plan

xv. (a) NEO/GOT, Global training matrix, STRAF, Hazcom training for contractors. (b) SOP/SMP/Lab procedures, Safety Manual, (C) JSA, QSAFE.

xvi. HSE-SAF-PLN-00-0002 (PPE).

4.3.1.2 References


Q-Chem will implement a baseline employee health and safety management system compliant with the guidelines set forth by the United States of America Code of Federal Regulations, Title 29: Subtitle B - Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, (OSHA) Part 1910 Occupational Safety and Health Standards.

29 CFR 1910.22(a)(1) & (2) NFPA 654 Chapter 8.2 As referenced in

OSHA’s Combustible Dust National Emphasis Program (CPL 03-00-008).

29 CFR 1910.1200

29 CFR1910.132

29 CFR 1910.119

29 CFR 1910.1020

EHS Global Procedures,

29 CFR 1904.4

Qatar Law Sec 6, Article 26

29 CFR 1910.1000,

NFPA 654

29 CFR 1910.146

29 CFR 1910.147

29 CFR 1910.1030

29CFR 1910.134 Respiratory Protection: Q-Chem respiratory protection

policy will address the requirements for using respiratory protection

29 CFR 1910.95

29 CFR 1910.120

29 CFR 1910.1028

29 CFR 1910.1051

29 CFR 1910.1001

49 CFR 391.41 for CDL Drivers EHS-5190: 5.1.2. (Rev. 0)

49 CFR 391.41

45 CFR 164.502

29 CFR 1910.132

29 CFR 1910.151(C)

TG-20:08: Scaffolding Guidance from National Access and Scaffolding Confederation, UK



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BS EN 12811-1:2003 - Temporary works equipment. Scaffolds – Performance requirements and general design (Supersedes BS 5973)

BS EN 39:2001- Loose steel tubes for tube and coupler scaffolds. ( Supersedes BS 1139: Part: 1:Section 1.1 )

BS EN 74-1:2005 - Metal scaffolding. Couplers. Specification for steel couplers, loose spigots and base-plates for use in working scaffolds and false work made of steel tubes (BS 1139: Part: 2: Section2.1)

BS 2482 :2009 - Specification for timber scaffold boards

BS EN 1004:2004 - Mobile access and working towers made of prefabricated elements. Materials, dimensions, design loads, safety and performance requirements

ii. Exception:

a) 29CFR 1910.101 to 106 Compressed Gases, flammable and combustible

liquids: Compressed gas cylinders that are available in Qatar are manufactured to BS standards. Thus requirements for OSHA referenced standards could not be complied. Q-Chem will implement guidelines specified in United Kingdom Health and Safety Executive Requirements for compressed gas cylinders.

b) 29CFR 1910 Subpart D Sections 21-30, Walking and Working Surfaces: Local

conditions including regulatory, skill transfer, personnel availability, and accepted standards of practice render parts of this section are not applicable. Q-Chem will implement guidelines as outlined in the following United Kingdom Health and Safety Executive requirements B.S. 1139 Specifications for Tubing Couplers and Fittings For Use In Tubular Scaffolding. B.S 5973 Access and Working Scaffolds and Special Scaffolding Structures in Steel.

c) 29CFR 1904 Recording and Reporting Occupational Injuries and Illnesses:

Local conditions including regulatory, language, skill transfer, personnel availability, and accepted standards of practice render this section not applicable in all aspects. . Q-Chem will implement guidelines as outlined by the State of Qatar and establish baseline guidelines in this area that meets the intent of OSHA.

http://products.ihserc.com/shoppingcart/controller?callbackurl=Javascript%3Ans4%3Ddocument.layers%3Bif(ns4)%7bparent.window.close()%3B%7delse%7bopener.focus()%3B%7d&callapp=SPECS4&event=MediaSelect&sess=825889237&prod=SPECS4&GID=BDRMMCAAAAAAAAAA


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4.3.2 Element 3.2 - Product Stewardship The associated documents and the work processes in place to implement the OE System Element 3.2 to address product safety impacts of all new and existing products and process chemicals throughout their lifecycle including regulatory status and potential environmental (including resource conservation), health, safety, and security impacts.


i. Current work process are managed through various activities (for example)

At Q-Chem

HAZMAT labels for 1-Hexene & NAO products.

Safety briefing with ship crew prior to loading.

MSDS available for customers download or available upon request.

Q-Chem bags are properly labeled with safety markings.

The Contract of Analysis (COA) is provided as required by customer.

At RLOC

MSDS available for customers download or available upon request. For

example MSDS for Pygas (C5/C8) can be obtained from PD-UTL-PRO-31-

0010

The Contract of Analysis (COA) is provided as required by customer.

ii. Work process managed through CPChem

Third Party Logistics (TPL) are provided with COA for stock transfers

Shipping lines provide the route so that shipments are not routed to inappropriate locations.

iii. Customer complaint system (MK-PSC-PRO-00-0002)

iv. JMAC meetings for Stakeholders

4.3.2.2 References


29 CFR 1910.1200(f)(1),

29 CFR 1910.1201(a),

49 CFR 172.200(a),

49 CFR 172.300(a)

49 CFR 172.400(a)

29 CFR 1910.1200(g)(8),

29 CFR 1910.1200(g)(9),

29 CFR 1910.1200(g)(6)(iii)/(i)

29 CFR 1910.1200(g)(5)

40 CFR 717.12,



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40 CFR 721.5(a)

40 CFR 717.12


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4.3.3 Element 3.3 - Process Safety Information and Process Hazard Analysis

The associated documents and the work processes are in place to implement the O.E System Element 3.3 to manage the process safety risks of operations through appropriate hazard reviews and maintain the information pertinent to process safety.


i. Process Safety Information (PSI) QC-PSM-PCY-00-0002.

ii. PHA and HAZOP/LOPA Procedure (Global OE procedure EHS- 6200).

iii. Risk Ranking Matrix (Global OE procedures EHS-6100 & EHS-6101).

4.3.3.2 References

iii. Referenced Standards

Q-Chem will implement a Process Safety Management system compliant with the guidelines set forth by the United States of America Code of Federal Regulations, Title 29: Subtitle B – Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, Part 1910 Occupational Safety and Health Standards.

This Process Safety Management System will comply with the specific requirements noted in Title 29 Code of Federal Regulations Part 1910 Subpart H Paragraph 119, Process Safety Management of Highly Hazardous Chemicals.

1910.119

EHS-6200

EHS-6205

EHS-6206

iv. Exception :

b) 29CFR 1910.119 (h) Contractors: Local conditions including regulatory,

language, skill transfer, personnel availability, and accepted standards of practice render this section not applicable. U.S. Dept of Labour regulations addressing contractor safety are not broadly applied in Qatar. Thus, requirements therein cannot be required of third parties. Q-Chem will develop a procedure for managing the contractors.



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4.3.4 Element 3.4 - Pollution Prevention

The associated documents and the work processes are in place to implement the OE

System Element 3.4 to operate in a manner that continually improves environmental

performance and reduces impacts from facility operations and business activities.


i. Annually set goals and targets are reviewed every 3-months by management

team and updated for employees to view via charts, posts, and intranet.

ii. Annually updated company Bonus Metrics are circulated to employees by Management every year and updated for employees to view via charts, posts, and intranet.

iii. Key Performance Indicators, Goals and Metrics are reviewed by management

teams periodically. Quantification of emission, discharge and targets is required.

iv. Environmental have implemented many programs to ensure resource

conservation and productivity, including, but not limited to: (1) Awareness Training, (2) Flaring Reduction, (3) Chromium Catalyst Waste Minimization, (4) Monthly Waste Minimization Efforts, (5) Groundwater and Marine Environment Protection, (6) Spill Prevention Actions and Response Kits, (7) Chemicals Approval Procedure, (8) Management of Change / Environmental Checklist, (9) Trending and Monitoring of Resources Usage, and (10) Air Emissions Reduction (NOx, SO2, etc).

v. Waste Management Plan,

vi. Waste Management Minimization meeting,

vii. The pollution prevention is managed through many plans, programs, policies

and guidelines, such as:

Waste Management Plan

Environmental Monitoring and Reporting Plan

Pollution Prevention, Waste Minimization, and Resource Conservation Plan

Environmental Register of Aspects and Impacts

viii. Q-Chem Environmental Monitoring & Reporting Plan (HSE-ENV-PLN-00-0003) for reporting any violation on the CTO

Notification of Flaring/Stack Emission Non Conformity & Notification Logic (HSE-ENV-SFM-00-0014)

Notification of Liquid Discharge/Spills Non Conformity & Notification Logic (HSE-ENV-SFM-00-0015)

ix. Environmental SharePoint page for displaying Environmental register and

event






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x. Environmental Group had developed the Environmental Management System (HSE-ENV-PLN-00-0005). It lists the primary pollution prevention-related laws/regulations which apply to the Q-Chem facilities, such as:

HSE Compliance Policy

Land Lease Agreement

Environmental Clearance

Consent to Operate

Other Legal Requirements, such as: Legal Statute Related to the Environment and Due Diligence/Hold Harmless Clauses.

xi. GHG emission calculator established at RLOC. Q-Chem and Q-Chem II to

follow the same as RLOC.

xii. Environmental Group had developed the Pollution Prevention, Waste Minimization and Resources Conservation Plan (HSE-ENV-PLN-00-0004), that is tailored to the specific conditions in Q-Chem facilities and with the primary goal of controlling pollutants that may be generated from the plant site.

xiii. The following strategies are used:

Prevention: Stop pollution at the source; Unnecessary costs from power consumption, spending resources or raw material; Loss of product; Spills and accidental releases of hazardous materials; Use of Chlorofluorocarbon (CFC), ,Hydro chlorofluorocarbon (HCFC), and Halon;

Reduction/Optimization: Use of energy by exploring energy conservation principles; Quantity of hazardous waste generated; Amount of solid municipal waste generated; Air emissions; Water consumption;

Reuse: Waste that cannot be reduced;

Recycle: Waste that cannot be reduced or reused;

Treatment: Waste that cannot be reduced, reuse, or recycled;

Proper Management: Promote a pollution prevention ethic through improving employee awareness, comprehensive education and training; Handling of chemicals and replace or reduce toxic substances with less hazardous materials; Buy more environmentally friendly and recyclable products; and Establish guidelines and practices to manage, periodically assess, and improve the organization’s productive use and conservation of resources.

xiv. Environmental have implemented many programs to ensure resource

conservation and productivity, including, but not limited to:

Awareness Training,

Flaring Reduction,

Chromium Catalyst Waste Minimization,




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Monthly Waste Minimization Efforts,

Groundwater and Marine Environment Protection,

Spill Prevention Actions and Response Kits,

Chemicals Approval Procedure,

Management of Change / Environmental Checklist,

Trending and Monitoring of Resources Usage,

Air Emissions Reduction (NOx, SO2, etc).

4.3.4.2 References

i. Reporting Requirements

Air Emission Inventory Report to MOE in every quarter.


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4.3.5 Element 3.5 - Distribution

The associated documents and the work processes are in place to implement the OE System Element 3.5 to establish processes, procedures, and practices that promote safe, secure distribution of chemicals and products and that ensure product integrity is maintained.


i. Distribution Emergency Response, Incident Reporting and Investigation (MK-

BSR-PRO-00-0015)

ii. Distribution Incident Management Team Response Guide (MK-BSR-PRO-0016)

iii. Drills are being conducted by CPChem at NAO storage facilities.

iv. Work process for assessment of distribution risk is through information from

ASO, TPL.

v. Marine Carrier Selection and Evaluation Procedure (MK-BSR-PRO-00-0014)

vi. Contract of Affreightment (COA)

vii. As per SAP records,

Material classification - product code

Carrier equipment - shipping lines

Transportation modes - sea, land

viii. Third party logistics agreements

4.3.5.2 References


49 CFR 171.2(e)

IATA 1.2.1.

IMDG 1.1.1.1

49 CFR 171.2(f)

49 CFR 172.800(b)

49 CFR 172.702(a)

29 CFR 1910.119

49 CFR 171.2(f),

49 CFR 173.3(a)

IATA 5.0.1.2,

49 CFR 172.200(a)

IATA 8.0.2

IMDG 5.4.1.1

49 CFR 172.205(a)







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49 CFR 172.600(c)(1)

IATA 2.9.2, USG-12(c)

IMDG 5.4.3.2.1 NOTE: Includes hazardous products, hazardous wastes,

and hazardous samples.

49 CFR 172.702(a)

49 CFR 172.702(d)

IATA 1.5.0.4

49 CFR 172.704(a)(1)

IATA 1.5.5.2(a)

49 CFR 172.704(a)(2)(i)

IATA 1.5.5.2(b)

49 CFR 172.704(a)(3)

IATA 1.5.5.2(c)

49 CFR 172.704(a)(4)

49 CFR 172.704(a)(5)

49 CFR 172.704(a)(5)

49 CFR 172.704(c)(2)

IATA 1.5.0.3

(DOT: 3 years; IATA: 2 years)

49 CFR 172.704(d)

IATA 1.5.4 Such records must be retained for as long as the employee is

a hazmat employee and for 90 days thereafter.


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4.3.6 Element 3.6 - Community Awareness and Outreach


System Element 3.6 to build effective relationships with those communities that may be

affected by local company operations through proactive involvement, addressing

community concerns, and to ensure that strategic facility plans and potential

community impacts form facility activities are appropriately communicated.


i. Community Outreach Policy (AD-HRD-PCY-00-0004)

ii. Community Outreach Feedback Questionnaire (HSE-ENV-SFM-00-0039) posted in the Q-Chem website.

iii. Emergency Management Plan (HSE-ERT-PRO-00-0001)

iv. RLOC Emergency Management Plan (HSE-ERT-PLN-30-0001)

v. Employees are involved in Job Fairs, Exhibits, Environmental cleanup projects

4.3.6.2 References


Land Lease Agreement

This is a contract between Q-Chem Facilities and Qatar Petroleum (QP) that stipulates environmental guidelines and criteria, which the facilities shall adopt in operating our process at Mesaieed Industrial City & at Ras Laffan Industrial City from and after the commissioning of the facilities. Ref: (Q-Chem Land Lease Agreement / Environmental Guidelines & Environmental Protection Standards, Rev.1, November 2007) & Ref: (RLOC Land Lease Agreement/ Environmental Regulations for Ras Laffan Industrial City, Rev.1, 2005.)

Environmental Clearance

This is also known as the "Permit to Construct" and was issued by the Environment Department in 1999, upon the review and approval of Q-Chem & RLOC Facilities Environmental Impact Assessment Study (EIA) and lists the minimum design conditions and principles that need to be considered while building the plant. The Environmental Clearance was checked by the MOE for compliance before the first Consent to Operate was issued in 2002. Ref: (Q-Chem Environmental Clearance, Issued by Environment Department, Ministry of Municipal Affairs and Agriculture, Ref. 890/2/273/99, June 1999) & Ref: (RLOC Environmental Clearance, Issued by Environment Department, Ministry of Municipal Affairs and Agriculture, Ref. 890/2/273/99, June 1999 Q-Chem II and RLOC has been issued an EIA clearance for project vide ref. no. SCE 0015/92/04 dated October 21, 2004 from the former SCENR. In accordance with Law No. 30 of 2002 and its by-Law no. 4 of 2005.




http://qnet/EDMS/REDIRECT.ASP?F=299&D=270830







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Consent to Operate

Consent to Operate (CTO) permissions are issued by Ministry of Environment and renewed annually.

Other Legal Requirements

Legal Statute Related to the Environment

The only statute in the State of Qatar that is related to environmental issues is to Law no. 30 of 2002 and its By-Laws (mainly By-law no. 4 of 2005).

Due Diligence/Hold Harmless Clauses

Due diligence and hold harmless clauses are listed as specific provisions within all contracts managed by Materials Groups/Contracts Engineering Section, including those related to the environment. It is specifically referenced on Part I/Attachment A: General Conditions of Contract & Attachment D: Mutual Indemnity and Waiver of Recourse Agreement of all contracts.

OE Policy

This policy lists the proper environmental compliance controls and means to achieve the desired outputs as part of continuous improvement Ref. Operational Excellence Policy The Environmental Engineering section will ensure the full compliance with the OE Policy's requirements by applying all the processes related to it and use the findings as a planning and loss-control tool.

ii. Reporting Requirements:

As per the Environmental Monitoring and Reporting Plan (HSE-ENV-PLN-00-0005). This includes reporting to local authorities from Ministry of Environment, Industrial Cities Managements, Qatar Petroleum and Chevron Philips Chemicals Corporate and any other authority and differs in terms of reporting frequency, reported parameters and reporting forms.

iii. Permit License Requirements

As per the latest copies of the Land Lease Agreement issued by the industrial cities and the Consent to Operate permissions issued by Ministry of Environment. These documents are saved in the EDMS, hyperlinked in SharePoint, and hyperlinked in key environmental policies and procedures. Formal training to all involved personnel and departments is conducted within 30-days of any renewal.

http://qnetm/EDMS/REDIRECT.ASP?F=2936&D=270927

http://qnetm/EDMS/REDIRECT.ASP?F=2936&D=270927


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4.3.7 Element 3.7 - Security of Personnel and Assets

The associated documents and the work processes are in place to implement the OE System Element 3.7 to provide a secure environment for employees, assets, and business operations


i. HSE-SEC-PRO-00-0001 - Q-Chem Security Standard Operating Procedures

*restricted

ii. QC-MGT-PCY-00-0001 - Security Policy

iii. QPR-DIS-010 Procedure for Organized Visits

iv. QPR-DIS-009 Security Requirements for Anti-Intruder Fences *restricted

v. QPR-DIS-011 Procedure for Photographic Permits

vi. IP-IR-004 Request for Official Photography

vii. QPR-DIS-017 Procedure for Security Access Control *restricted

viii. SPR-DIS-001 Procedure for Threat Alert System and Physical Response *restricted

4.3.7.2 References


Law No. 11 of 2004 (Penal Code).

Law No. 23 of 2004 (Code of Criminal Procedure).

Law No. 19 of 2007 (Traffic Law).

Law No. 14 of 2004 (Labor Law).

Decision No. 9 of 2006 of the Minister of Civil Service and Housing Affairs

(Determination of Outdoor Summer Working Hours).

Law No. 19 of 2009 Regulating the Practice of Private Security Services

ii. Reporting Requirements

Under Law No. 19 QC Security is required to report security related incidents and/or concerns to the Appropriate Regulating Authority. In all cases it is advisable to do so through the QP Regional Industrial Security who will in turn notify the QP Industrial Security Directorate (QP-ISD)


http://qedms/NetFYI/cgi/NetFYIIsapi.DLL?Method=AddLogin+RetrieveDoc&L=L&DSN=FYI&UserID=RO&PASSWORD=RO&C=Plant%20Information--RO&F=281&D=286539http://qnet/EDMS/REDIRECT.ASP?F=281&D=286539


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iii. Permit License Requirements

Depending on decisions from the Ministry of Interiors Public Security Department with regard to the status of Q-Chem Security it may be necessary to license the Q-Chem Security Department. If required the license will need to be renewed every three years. As of October 18th 2012 this is still an evolving issue and the final outcome is not known.

Although not listed as a License there is a requirement to conduct a Security Risk Assessment in Q-Chem operated facilities (QC/QCII/RLOC/ST) every 5 years.


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4.3.8 Element 3.8 - Incident Prevention, Quality, and Reliability


System Element 3.8 to achieve and sustain incident free performance of business

operations and assure products meet or exceed quality requirements through the

implementation of programs and procedures.


Note: The work processes indicated below are not covering all departments and is also not exhaustive within each department indicated.

i. Safety

Lock Tag & Try (HSE-SAF-PRO-00-0004)

Confined Space Entry (HSE-SAF-PRO-00-0007)

Purging, Venting & Draining (HSE-SAF-PRO-00-0019),

Blinding (HSE-SAF-PRO-00-0005)

Safety & Emergency System Bypass (HSE-SAF-PRO-00-0012)

Permit to Work (HSE-SAF-PRO-00-0006)

Unit Entry (HSE-SAF-PRO-00-0003)

All in EDMS. For non-base load, access to procedures is from DSR.

Safety Manual Development & Review Process (HSE-SAF-PRO-00-0020)

Health and Safety procedures are part of the Global Training Matrix for Q-

Chem employees and Base Load contractors.

SAP e-Learning CBT's.

ii. Environment

Environmental Procedures are all saved at EDMS. Waste Management

Contractors access procedures from DSR.

Procedures are being reviewed every 2 years.

Training is being provided to the Waste Management Team by the Environmental Engineering team on the critical procedures.

Procedures are being used on training Waste Management Contractors.

iii. Maintenance

All SMP's and Checklists are loaded in EDMS

http://qspwebm2/dep/Training/Maintenance/Pages/SMPTrackingSheet.aspx

SMP Development & Approval (Procedures are developed based on the SMP Development procedure posted in the link above) MC-ADM-PRO-00-0001.






http://qedms/NetFYI/cgi/NetFYIIsapi.DLL?Method=RetrieveDoc&L=L&C=Plant%20Information--RO&F=150&D=268360








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The SMP's and Checklist's are developed by the persons using them and being reviewed by all users before approval. Any changes are also done by the users. The names of SMP developee and reveiwers are in the SMP Development & Change form.

Training of new employees, refresher training and Technician certification process is in place. Maintenance Technician Certification Procedure And Refresher Training (AD-TRN-PRO-00-0010)

OEM Manuals , Best practices, Procedures, standards / specifications are followed while ordering any equipments/ spares and for altering any equipment by SME's & TECHNICAL

We follow the PM program which is setup in SAP to carry out PM's as per the frequencies defined for each equipment to ensure the reliability of the equipment.

All the analyzers, measuring and test equipments are calibrated periodically as per their program and the test certificates are available with the concerned to ensure the reliability and quality of the systems.

Reliability Management. RIT teams have been formed to identify the Worst actors and to eliminate the recurrence of the failures

Employees are involved in the procedure review. Document review approval forms and JSA

In Maintenance we have the policy of cross functional movements of technicians to ensure their understanding and involvement of equipments plant wide.

iv. Production

Critical SOP's are sign off procedures. RLOC C2 pipeline operation is under QP operating agreement and Pygas operation is under Berth Services Agreement).

All SOP's are saved at EDMS as per Records and Information Management Policy. Contractors can get access to SOP's through their DSR.

Operating Procedures Review, Revision And Certification (PD-ADM-PRO-00-0001)

Training – New Facility Operator Certification (AD-TRN-PRO-00-0019) - SOP's are included on the training package






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4.3.8.2 References


NFPA 654 (2006) Chapter 11.2.1 (Hazards associated with combustible

dust should be included in maintenance procedures)

29 CFR 1910.147(c)(4)

29 CFR 1910.146(d)(3)

29 CFR 1910.119(f)(4)

29 CFR 1910.119(l) or (f)

29 CFR 1910.119(k),

29 CFR 252(a)

29 CFR 1910.119(f)(4)

29 CFR1910.119(h)(2)(iv)

29 CFR 1910.119,

MOE Law 30

29 CFR 1910.119(f)(2)

29 CFR 1910.119(f)(3)

29 CFR 1910.119(g)(3)

29 CFR 1910.119

29 CFR 1910.119

29 CFR 1910.119(g)(1)(i)

29 CFR 1910.119(g)(2)

29 CFR 1910.119.(j)(6)(ii)/(iii)

29 CFR 1910.119(j)(2)

29 CFR 1910.119(j)(2) ref. to (j)(1),

29 CFR 1910.119.(j)(4)(i-iv),

29 CFR 1910.119(j)(3)/(5),

29 CFR 1910.119(d)(3)(iii),

29 CFR 1910.119(i)(1),

29 CFR 1910.119(j)(4)(iv)

29CFR1910.119

29CFR 1904 Recording and Reporting Occupational Injuries and Illnesses: Local conditions including regulatory, language, skill transfer, personnel availability, and accepted standards of practice render this section not applicable in all aspects. . Q-Chem will implement guidelines as outlined by the State of Qatar and establish baseline guidelines in this area that meets the intent of OSHA.


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4.3.9 Element 3.9 - Resource Conservation and Productivity

The associated documents and the work processes are in place to implement the O.E

System Element 3.9 to manage, periodically assess, and improve the organization’s

productive use of and conservation of resources.


i. Resource Conservation and Productivity (QC-OEM-PCY-00-0006), Pollution

Prevention, Waste Minimization and Resource Conservation Plan (HSE-ENV-

PLN-00-0004)

ii. Utility Dept Metrics, Townsend and Solomon Study.

iii. Plant Metrics for Maintenance (PM Status, Backlog work orders and Priority 1

Notifications)

iv. Materials Review Board (procedure/guideline is under review), SAP Logistics -

Materials Management

v. SAP Logistics- Production

vi. SAP Logistics - Plant Maintenance





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4.3.10 Element 3.10 - Emergency Preparedness and Response

The associated documents and the work processes are in place to implement the OE System Element 3.10 to require implementation of processes and programs to promote effective planning for an immediate response to emergencies.


i. QC-MGT-PLN-00-0001 Crisis Management Plan

ii. HSE-ERT-PRO-00-0001 Emergency Management Plan (Mesaieed)

iii. HSE-ERT-PLN-30-0001 Emergency Management Plan (RLOC)

iv. HSE-ERT-PRO-00-0014 Salam Tower Emergency Action Plan EAP

v. HSE-ERT-PLN-30-0002 Emergency Action and Accountability Plan RLOC

vi. HSE-ERT-PLN-00-0003 Emergency Action and Accountability Plan

(Mesaieed)

4.3.10.2 References


Q-Chem and Ras Laffan Olefins Company (RLOC), shall implement a site fire and emergency response system based on the applicable regulatory and consensus standards contained in the Occupational Safety and Health Administration (OSHA) and the applicable National Fire Protection (NFPA) standards.

OSHA 1910.120(q) Emergency Response Plans

HAZWOPER OSHA 1910.119(n) Emergency Planning and Response PSM

OSHA 1910.38 Emergency Action Plans

United States of America Code of Federal Regulations, Title 29: Subtitle B – Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, (OSHA) Part 1910 Occupational Safety and Health Standards, Subpart E Exit Routes, Emergency Action Plans, & Fire Prevention Plans

United States of America Code of Federal Regulations, Title 29: Subtitle B – Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, (OSHA) Part 1910 Occupational Safety and Health Standards, Subpart L Fire Protection.

United States of America Code of Federal Regulations, Title 29: Subtitle B – Regulations Relating to Labour, Chapter XVII Occupational Safety and Health Administration, (OSHA) Part 1910 Occupational Safety and Health Standards, Section 120 paragraph (q) Emergency Response to Hazardous Substance Releases.







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The applicable consensus standards of the National Fire Protection Association (NFPA).

State of Qatar Public Civil Defence Regulations.

Mesaieed and Ras Laffan Industrial City guidelines

5 RESPONSIBILITIES

Element owner and responsibility to implement the element requirements in the Company are in accordance with Management System Responsibility and Accountability Matrix (QC-OEM-MTX-00-0003)

5.1 Senior Management

i. Plan and provide necessary resources.

ii. Review company’s effectiveness in HSE&S areas and update company’s goals and targets to ensure sustainable development in these areas

5.2 HSE & S Managers

i. Ensure laws, regulations, guidelines and standards applicable to company in HSE&S areas are up-to-date and incorporated in related policies, procedures and practices

ii. Measure company’s compliance with applicable laws, regulations, guidelines and standards and develop necessary tools and programs to ensure sustainable improvement

iii. Report company’s compliance to senior management, stakeholders and customers, as needed and use the same in developing goals and targets for Company’s sustainable development

5.3 Managers and Superintendents

i. Ensure employees, contractors, and visitors under their supervision are in full compliance with the applicable HSE&S regulations and at all times

ii. Report to HSE&S managers the challenges and practicality of implementing the tools and programs established to ensure HSE&S compliance to enhance them

iii. Document evidences and records necessary to verify HSE&S compliance in their areas

5.4 Employees and Contractors

i. Follow strictly the company’s Tenets of Operation, Environmental, Safety, Security, Emergency Response and Health Management Systems at all times

ii. Actively participate in the company’s environmental, safety, security and emergency response compliance programs

iii. Stop all unsafe acts or those that pose hazard to company personnel, assets or activities and report those immediately through proper channels




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6 REFERENCES

i. CPChem OE System Manual – EHS-1100

ii. Management System Responsibility and Accountability Matrix (QC-OEM-MTX-00-0003)

7 ATTACHMENTS

i. Q-Chem Management System ii. Operational Excellence Policy Statement

iii. Q-Chem Consent to Operate (HSE-ENV-STD-00-0003) Q-Chem Consent To Operate (2012)

iv. RLOC Consent to Operate (to provide link)

v. State Environmental Protection Standards (HSE-ENV-STD-00-0004)

a. 1998 - State Environmental Standards

(Q-Chem follows these standards till April 2007)

b. 2002 - State Environmental Standards / Executive Regulations & By-Laws Of Law 30 / Year 2002

(Q-Chem will have to comply with these standards in April 2007)

c. State of Qatar Environmental Law - Law 30 Of Year 2002

vi. MIC Environmental Guidelines and Protection Standards 2011

vii. HSE regulations Legal Framework in Oil and Gas sector.pdf

viii. Qatari Law Compilation.doc

http://qspwebm2/oe/References/OE%20System%20Manual%20Edition%203.pdf











http://qspwebm2/oe/References/HSE%20Regulations%20Legal%20Framework%20in%20Oil%20and%20Gas%20sector.pdf

http://qspwebm2/oe/References/Qatari%20Law%20Compilation.doc