Group Health, Safety, Environment and Security Handbook

Group Health, Safety, Environment and Security Handbook
Group Health,
Safety, Environment
and Security Handbook
February 2012
MA-GL-HSE-005 Version 1
Table of contents
Introduction 2
Safety is a core value
Message from the Chief Executive Officer 4
HSEQ policy statement
4.1 HSEQ common principles 6
4.2 Health
4.3 Safety
4.4 Environmental 9
4.5 Security 10
4.6 Substance abuse policy
4.7 Jewellery policy
4.8 Knife policy
4.9 HSE awareness at onshore and offshore worksites
Your duties and responsibilities 14
Leadership duties and accountability 15
Short service worker programme
Training requirements
HSE induction – what you need to know 17
10. Cultural awareness 18
11. Malaria control plan 19
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
12. Smoking rules 19
13. Fatigue
14. Risk Management 20
15. Management of Change (MOC) 22
16. Permit to Work 23
17. HSE department roles
18. Safety representatives/delegates
19. Communication 24
20. Critical safety behaviours 26
21. HSEQ observation and intervention
22. Incident reporting and investigation 30
23. Personal Protective Equipment (PPE) 34
24. Emergency situations
25. Harmful substances 37
26. Lifting operations 38
27. Manual handling
28. Working at height
29. Slips, trips, falls and hand injuries 43
30. Dropped objects
31. What to do in the event of an accident
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
1. Introduction
We believe that all our people are entitled to the same level of protection
regardless of where in the world they work. To ensure a consistent approach
to safeguarding Health, Safety, Environment and Security we have developed
a global HSE Management System supported by our HSE processes,
procedures, instructions and guidelines, as well as a mature security system.
Subsea 7’s Business Management System is a controlled suite of
documentation of which this document forms a part.
The guidance given in this handbook:
• Identifies key features of HSE management process rules which you must
understand and comply with, if Subsea 7 is to achieve consistent HSE
• Tells you about the Group’s HSE goals, objectives and culture
• Provides an overview of how Subsea 7 expects you to work safely using the
processes which form the elements of our Management System
• Lists issues concerning your safety with which you need to become familiar
when you join a worksite
• Identifies Subsea 7’s collective responsibilities and the role of the HSE
departments with regards to HSE management
• Empowers you to address unsafe conditions in your work place or to stop
unsafe behaviour by work colleagues
• Promotes the reporting of all near miss incidents, damage, illnesses
and injuries so that Subsea 7 can learn from any mistakes and make
• Provides lists of topics to help you assess the risks associated with work
tasks and to assist you when involved in toolbox talks or similar
• Leads you in maintaining your security by listing the key security actions
you should take
People who are new to Subsea 7 may be unfamiliar with how Subsea 7
manages HSE in their working environment. Please do not hesitate to ask
your supervisor to explain anything you are unsure about or tell you more
about HSE.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
2. Safety is a core value
We are committed to an incident-free workplace, every day, everywhere.
We continue to minimise the impact of our activities on the environment.
We share and embrace the following core values:
• Safety
• Integrity
• Innovation
• Performance
• Collaboration
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
3. Message from the Chief Executive Officer
Safety is one of our core values, and we
believe that by working together with
integrity, we will create an incident-free
Subsea 7 workplace every day, everywhere.
We can make this a reality if we have
the right attitude to health, safety,
environmental and security management:
by following Group instructions and
procedures; by upholding our own high
standards and never cutting corners;
by helping others who may be new to a
particular worksite and by challenging those
who disregard our rules. We all have a part to play. Our project management
teams will help you succeed by setting safety priorities as part of the project
work execution.
I believe that safety, quality and good management are inextricably linked.
A safe worksite is a well run worksite. A well run worksite, onshore or offshore,
is a safe place to work.
This handbook will give you an overview of how we manage HSE issues
across our business. It also introduces the key management principles that
you must follow on our barges, ships and in our yards or offices – all worksites.
Day to day management of HSE is a line management responsibility supported
by our HSE professionals.
Please take the time to read this document carefully. Keep it with you as a
useful reference and act on the advice it offers. Make sure you do not become
complacent. Remember: it is vital to maintain your safety focus at all times.
If we all do so, we can create a business which is second to none in terms of
safe project delivery.
Jean Cahuzac
Chief Executive Officer
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
4. HSEQ policy statement
Subsea 7 is committed to an incident-free workplace, every day, everywhere.
Our performance depends on our ability to continually improve the quality of the
services we provide to our clients, while protecting people and minimising the
impact on the environment. Subsea 7 requires an active commitment to HSEQ
from all our people and our contractors in all work activities. Line managers are
responsible and accountable for ensuring compliance with all HSEQ policies
and procedures and this Corporate HSEQ Policy. We will always communicate
openly on HSEQ issues with our stakeholders and share with them our
experience and knowledge of successful HSEQ initiatives.
Policy implementation
The Company has an HSEQ Committee which oversees all HSEQ matters. This
Committee is chaired by the Chief Executive Officer and establishes procedures
and guiding principles as it deems necessary to carry out the Company
HSEQ policy. The Company has established and maintains assessment, selfevaluation and audit programmes to monitor the Company’s compliance with
this Policy. A Compliance audit report is presented to the Subsea 7 S.A. Board
of Directors at least once a year.
Compliance with relevant legislation
The Company standards comply with all applicable laws and regulations in the
countries where we operate.
Risk Management
The Company strives to mitigate the impact of any foreseeable hazards, which
may endanger health, safety and the environment, or could affect the quality
of products and services it provides. This will be achieved through formal risk
assessments as required per Company Policies and Procedures.
The Company is committed to provide training and development needs as
appropriate for each individual’s duties and responsibilities – this will always
include HSEQ training. Line managers are responsible for ensuring that
appropriate training is given and individual competency evaluation is conducted
as per the Company’s standards.
This policy will be regularly reviewed to ensure on going suitability. This is
critical to the continuous success of our business as it allows us to optimise our
Company performance and adds value for all our stakeholders.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
4.1 HSEQ common principles
The following principles provide a common foundation across the Group
on which our HSEQ and Security policies are built:
• We work according to applicable laws, codes and regulations
• We comply with approved procedures, rules and instructions
• We provide our people with all necessary information, instruction and
• Our people are trained and competent for the tasks they are expected to
• We provide Safe Systems of Work (SSOW) facilitated by efficient planning,
robust risk assessment and effective management of change
• All incidents must be reported and investigated and remedial actions
assigned and completed
• Clear objectives are set and progress is regularly reviewed
• Documentation is reviewed in accordance with a scheduled programme or
after a significant change
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
4.2 Health
We manage business activities to keep health risks to a minimum.
We provide a healthy working environment with the appropriate level of
surveillance and support.
We provide expert medical support to our people to ensure that appropriate
health examinations and preventative medicines are provided.
We promote good occupational health by ensuring compliance with regulatory
requirements and by providing clear guidance and information through our
health principles.
Health principles
We will:
• Work according to applicable health laws, codes and regulations
• Promote and maintain a positive health culture
• Provide and maintain healthy working conditions
• Consult our people on matters affecting their health
• Assess and control the health risks arising from our work activities
• Strive to prevent work-related ill health
• Make appropriate medical care available at all work-sites
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
4.3 Safety
We operate a risk management approach to our activities whereby we identify
hazards, assess the associated risks and then work to eliminate the hazards
or reduce the risks to a tolerable level. All of our vessels operate under the
International Safety Management Code (ISM).
Everyone who observes an unsafe situation or who feels it is not safe
to continue with a task has a duty to intervene and stop the job. Such
intervention will always be supported by Subsea 7’s Management.
We are convinced that encouraging safe behaviour and highlighting the
importance of personal safety as a way of life will help to create a work
environment where our people are safe and secure.
Our safety culture and management are supported by the subsea safety
principles which includes all safety training.
Subsea safety principles
We will:
• Work according to applicable safety laws, codes and regulations
• Promote and maintain a positive safety culture
• Review every incident and implement actions to prevent future occurrence
• Assess and control any safety risks arising from our work activities
• Consult our people on matters affecting their safety
• Provide and maintain safe work equipment and places of work
• Control, use and store hazardous substances safely
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
4.4 Environmental
We always conduct our business in a way that considers the environment
and which aims to keep any negative impact to a minimum. This policy
is managed by close attention to achieving regulatory compliance and
continually improving our environmental performance through careful selection
of consumables and working practices designed to reduce waste, energy
consumption and emissions.
Awareness of the impact that our activities may have on the environment and
the management of measures to control such impacts is encouraged through
our environmental principles.
Environmental principles
We will:
• Work according to applicable environmental laws, conventions, protocols
and regulations
• Promote and maintain a positive environmental culture
• Manage our activities to eliminate or reduce any potential negative
environmental impact
• Consider sustainability an important element in the way we do business
• Use planning, design and risk assessment to avoid and reduce
environmental risk; environmental aspects and registered work are assessed
on worksites and projects
Clean Operations Initiative
The initiative saves fuel, reduces air emissions and
improves the efficiency of our operations.
Execution can take effect as long as the operation
is safe and within the contract terms.
Anything equal to or more than 0.5m3 fuel saved is
classified as a recordable Clean Operation!
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
4.5 Security
Subsea 7 is absolutely committed to providing our people with secure
arrangements for their work environment and for away from home activities
such as travel and business trips. We operate security networks on both a
regional and global basis to manage security issues, to develop and implement
security plans and to monitor local security intelligence. It is our policy to
engage with local communities and to be sensitive to any local community
Subsea 7 works in compliance with the International Ship and Port Facilities
Security Code (ISPS), and we maintain ship and worksite security plans which
are regularly tested.
Subsea 7 maintains its effective security programmes through compliance with
international protocols, ships’ flag-state rules, industry best practice and our
own rules and procedures.
Security principles
We will:
• Promote and maintain a positive security culture
• Assess and manage threats so that we can protect our people and assets
• Take account of security issues in all aspects of our operations and planning
Key points
• Refer to Subsea 7 travel packs when travelling overseas
• Follow all travel instructions and local rules
• Keep your possessions close to you
• Do not attract attention to yourself
• Always have a contact list in country
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
4.6 Substance abuse policy
Everyone on a Subsea 7 worksite has the responsibility to be fit and ready to
carry out his or her work duties at all times, without risk of their performance
being impaired or their competence reduced by substance abuse.
Subsea 7 will not tolerate the use of alcohol or any other prohibited substance
on any worksite.
Arriving at a Subsea 7 worksite or business meeting under the influence
of alcohol in any amount is strictly prohibited.
To maintain a workplace that is free from substance abuse, Subsea 7 may
conduct searches, pre-employment screening, random tests or post-incident
tests for drugs and alcohol.
Abuse of alcohol or other prohibited substances will result in disciplinary
procedures. Subsea 7’s Human Resources Departments will ensure correct
local application of this policy, in accordance with legislation.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
4.7 Jewellery policy
The wearing of jewellery is not permitted at the workplace, defined as follows:
every ship, barge, workshop, construction yard, warehouse, stores area or the
like, and includes any office facility where the work activity involves any risk
from wearing jewellery.
Specifically, the wearing of finger rings, earrings and facial jewellery is
prohibited in the workplace. The wearing of bracelets and necklaces is also
prohibited in the workplace; the only exception is for medical bracelets which
should be of the ‘open copper’ type or close fitting and covered by clothing
and personal protective equipment, such as coveralls.
Where other jewellery is worn, such as that associated with body piercing, this
is only permitted where the jewellery is continuously and completely covered
by clothing such as coveralls or catering jackets.
Wrist watches must be removed when working with moving equipment and
This policy is to be maintained by everyone at Subsea 7 whilst working or
visiting a workplace of a client, subcontractor or third party facility.
4.8 Knife policy
The use of clasp or sheath knives is to be avoided, and wherever possible an
alternative cutting tool must be used. Where a knife is considered to be the
safest and most appropriate tool, it must be used with care and safety gloves
with the appropriate cut protection. Stop and assess the risk.
Knives are to have round-ended blades to minimise stabbing injuries. Divers’
knives (underwater use), galley knives (galley use) and cutlery (galley use) are
excluded from this hardware requirement.
People are not permitted to bring their own knives to work. Appropriate cutting
tools will be maintained and provided at the worksite. Cutting tools and
safety knives should be inspected prior to use, any damage reported and a
replacement sourced.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
4.9 HSE awareness at onshore and offshore worksites
We have set specific HOUSE RULES which must be complied with at all
worksites, whether offshore or onshore, in an office, fabrication yard, shipyard
or workshop. Your supervisor will be able to help you to access these and any
local HSE rules and documents.
You are required to remain alert to other operations going on around you.
Never take short cuts that could put your own or other people’s safety at risk
or cause harm to the environment.
Do not assume that a piece of equipment is safe to use because it has been
delivered to the worksite. Make sure it has been checked thoroughly before it
is used for the first time.
If you work offshore you must be particularly careful when the motion of the
ship or barge is being adversely affected by weather conditions. Site specific
issues will be detailed in HSE plans or Ships Marine Operations manuals.
Never use a chemical without familiarising yourself with the hazards (control
of substances hazardous to health). Familiarise yourself with requirements for
waste segregation on the site. Avoid any spillage of oil and chemicals by good
housekeeping and operating practices. Report any incidents.
House rules
Always follow safety sign information
Keep work sites clean, tidy and obstruction free
Use the right tool in the right way for the job
Use the correct manual handling technique if manual handling cannot be
5. Hold the handrail on stairs, walk, do not run
6. Always plan every lifting operation
7. Never cross safety barriers or enter prohibited areas
8. When risk assessing task plans, always consider the environmental
conditions and their effects
9. Always wear vehicle seat belts and never use a hand held mobile phone
when driving
10. Wear and maintain the correct PPE
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
5. Your duties and responsibilities
To make sure that we all work to the same basic standards, you must:
• You have an obligation to stop any activity or operation which you consider
unsafe (including those of subcontractors)
• Always be aware of your own safety and the safety of others
• Prevent damage to equipment and the environment
• Comply with all policies, procedures and rules
• Read and understand Critical Safety Behaviours and avoid exhibiting ‘at
risk’ behaviours proven to cause almost all of Subsea 7’s injuries
• Work safely in accordance with Subsea 7’s processes, procedures and rules
• Think about the hazards and risks you and others may be exposed to before
you start, and during the execution of any task and take the necessary
precautions to mitigate these risks
• Not take short-cuts
• Be aware of safety issues at all times even after work is over – remember
injuries can also happen when you are off shift
• Bring your HSE concerns to the immediate attention of your supervisor
• Report promptly all unsafe conditions and practices (including those of sub
contractors) to your supervisor
• Report all injuries and illnesses, no matter how minor, to your supervisor or
the medic promptly
• Report equipment damage, near misses and every spill/release to your
• Always use the proper safety equipment/PPE
• When travelling/working in malarial regions, take the prescribed
chemoprophylaxis medication, use repellent and protective clothing
• Ensure you travel with valid certificates (survival, medical, vaccinations and
malaria compliance attestation when applicable)
• Ensure your physical examination/health screening is up to date
• Ensure you have understood your worksite induction and participate in
toolbox talks on each shift
• Follow all security instructions
• Use tools for their intended purpose only - no unauthorised modifications or
use of sub-standard equipment
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
6. Leadership duties and accountability
Managers and team leaders have overall responsibility for and are held
accountable for the health and safety of people working for them. This
includes the protection of people, the environment and equipment on their
Their responsibility includes activities such as:
• Conducting risk assessment and evaluation
• Providing safe operational procedures
• Providing safe equipment
• Ensuring a robust permit to work system is used where special activities or
non-routine work takes place
• Ensuring good worksite housekeeping
• Carrying out safety induction/familiarisation training
• Listening to workers’ concerns with regard to safety and acting on them
• Promoting the Critical Safety Behaviours campaign
• Intervening when at-risk behaviour is observed
• Setting a good example through personal leadership and the promotion of
health, safety and environmental policies and initiatives
• Demonstrating accountability through performance reviews, counselling and
disciplinary action
• Leading investigations into injuries,
accidents and high potential
incidents, contributing to the
reports and ensuring follow up of
actions and provision of feedback
• Ensuring people working under
supervision have received
adequate training to enable them
to perform their assigned tasks
• Conducting management site
visits and reporting findings
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
7. Short service worker programme
Subsea 7 has implemented a programme on specific worksites to indentify,
train and monitor workers who are new to that worksite, and/or the company.
These workers should be easily identified. In an offshore environment Subsea
7 people must pay attention to those new to the site, watch out for their safety
and ensure they understand the activities taking place in their surroundings.
8. Training requirements
Subsea 7 has multiple levels of awareness and training programmes
depending on each individual’s activities and worksite environment.
Everyone will undergo an HSEQ introduction to the company and a site
specific induction. If your role requires specialised qualifications and training,
whether it is internal or external, this will be addressed.
HSE training summary
Familiarisation Training
DVD or E-learning in groups
Foundational Training
Intermediate Training
Subsea 7 Values
Subsea 7 Policies
Subsea 7 Safety Culture
Safe Conditions
Critical Safety Behaviours
Risk Assessment
Management of Change
Permit to Work
Working at Height
Confined Space Entry
Safe Use of Work Equipment
Manual Handling
Chemical Management
Noise, Environment
Check it!
Manual Handling Foundation
Noise Foundation
Lift Planning Foundation
Scheme of Assurance for
Work Equipment
Critical Safety Behaviours
Risk Assessment Foundation
Hazardous Substances
Permit to Work
Management of Change
Risk Assessment
Safety Leadership
Working at Height
Taproot - Root Cause Analysis
Advanced Training
Direct Coaching
Miscellaneous Topics
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
9. HSE induction - what you need to know
When visiting a worksite for the first time you must attend a ‘safety
induction’ as soon as possible after your arrival. Your induction may
include the following issues:
• Organisation at the worksite – roles and responsibilities
• The Emergency Plan and its location, alarms, and responses
• Overview of work areas, “no-go” areas and general traffic areas
• Muster points and escape routes
• Survival craft and equipment
• Man overboard actions
• Fire fighting equipment
• First aid treatment and location of equipment
• Safety signs and their meaning – PPE areas, first aid, warnings etc
• Identification of safety representatives
• Review of safety notice board
• Smoking rules and smoking/no smoking areas
• Worksite waste disposal and segregation procedure
• Worksite security procedures
• HSE Risk Assessment system at the site
• Permit to work system and type of work which requires a permit
• Hazardous areas and precautionary measures
• Confined space working
• Handling of dangerous substances
• Protective clothing, equipment and what you must use in your job
• Reporting of incidents, damage and injuries
• Reporting of HSEQ observations
• Project/location specific information
When you have read this HSE handbook and attended your induction, you
will understand better how we can all successfully manage HSE together.
Remember to ask your supervisor or manager for further help if you do not
understand any aspect of this handbook or the induction.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
10. Cultural awareness
Subsea 7 operates globally and you may be required to work in or travel
through parts of the world where the culture and environment is not familiar
to you. Please behave respectfully towards the citizens and customs of other
countries at all times.
In most instances, Subsea 7 will arrange the services of reputable agents to
assist in your transfer to your place of work and to provide help and assistance
in dealing with issues such as:
• Personal security
• Health
• Personal property and baggage
• Visas and travel documents
• Internal transportation, meals and accommodation in transit
Your Subsea 7 Management Team will also provide you with current
information and advice on ways to minimise exposure to particular health risks
in the countries in which you will work or through which you will travel.
Please take the time to study the information and advice provided.
Always follow the instructions of the reputable agents and / or local security
teams provided by Subsea 7.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
11. Malaria control plan
Subsea 7 has established a Malaria Control Plan to protect vulnerable people
by providing:
A. Awareness
B. Bite Prevention
C. Chemical Prophylactics
D. Diagnosis and Treatment
The ultimate aim of this policy is to have
no cases of malaria amongst people who
do not have a natural immunity, i.e. people
who are not indigenous to countries where
malaria is endemic.
The Malaria Control Programme applies to every person required to travel for
Subsea 7 to an area where there is a risk of contracting malaria, onshore as
well as offshore. Our people are required to participate in the programme and
to confirm their agreement to participate by signature on the Malaria Control
Plan Attestation Form.
12. Smoking rules
Each Subsea 7 office, barge, ship and worksite has defined areas where
smoking is permitted. Smoking is only permitted in designated areas. You
must comply with the ‘no smoking’ signs.
13. Fatigue
Fatigue due to long working hours, or lack of rest caused by circumstances
such as travel, may affect your ability to concentrate, presenting a safety
hazard to you or your work colleagues.
Please notify your supervisor if you feel that your concentration is likely to be
affected by fatigue. Your supervisor will try to arrange shift rotations so that
you are rested before commencing your work, or your shift duration is reduced
to avoid a related hazardous condition.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
14. Risk Management
Risk Management is a key component in our Business Management System
that identifies, evaluates and determines the means of reducing risks to
an acceptable level across a wide range of factors to protect people, the
environment, assets and to avoid loss.
Overall Risk
Design / Engineering
Tender risk
Technical integrity,
projects & O.R.
HSE risk
level 0
HSE risk
level 1
Review selected key risks
Smart lessons
criticality rating
Technical audit
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
Subsea 7 has procedures to systematically identify and evaluate the hazards
and effects that might arise from our activities and from the materials that are
used or encountered in them. The scope of the Risk Management process
ranges from design through to fabrication, installation and operation. Risk
Management in Subsea 7 is covered by the different methodologies shown
on the following chart, including Risk Assessment (RA) level 0, 1, 2 and 3.
Fabrication / Loading /
Project risk register
Installation /
Review and
approve MOC
IMR plan
HSE risk
level 2
Task risk
level 3
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
15. Management of Change (MOC)
Experience has shown that incidents such as injury or damage are often
caused by not following the planned course of action due to some form of
unexpected change. Control of change must be as rigorous as the initial
planning and risk assessment of our activities. This means that we need to
re-assess risks associated with the change. We do this through a defined
Management of Change process (see Management of Change process
document). Its key features are:
• Changes to the planned procedure are subjected to hazard identification risk
assessment and control analysis
• Changes are subject to approval by Management/Supervision in accordance
with the MOC process before the work is carried out
• People involved in the work must be told about the new procedure or
equipment and risks prior to the work
• Work cannot proceed until the change has been re-assessed, approved and
the revised procedures explained to those involved in the task
• Damaged rigging has required a change in configuration using available
rigging onboard. This change is subject to the full MOC process
• An offshore crew has devised an improved methodology for executing a
portion of the work addressed in the procedure. This change is subject to
the full MOC process
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
16. Permit to Work (PTW)
Subsea 7 operates a Permit to Work (PTW) system at worksites to control
non-routine or special work activities that could present a health or safety risk
to anyone or risk of environmental damage as identified in risk assessment (see
Permit to Work process document). Examples of where this process would apply:
• Non routine welding, burning or grinding where flammable materials are
present (complemented by Hot Work Checklist)
• Dealing with explosives
• High pressure water jetting or grit blasting
• Pressure testing
• Breaking into pipelines/hoses containing residual pressure or combustible
• Isolating electrical or mechanical machinery to allow maintenance or repair
(complemented by Electrical or Mechanical Checklist)
• Working at height i.e. any position where the potential exists for a person to
have a fall likely to cause a personal injury
• Removing protection systems (e.g. machinery guards)
• Any work that directly affects critical safety systems
• Entering into confined spaces or places where the atmosphere is suspect
(complemented by Confined Space Checklist)
• Spray painting or using chemicals in closed or confined spaces
• Activities involving radioactive sources such as non-destructive testing
Work may need to be carried out by specialists with specific training or
qualifications and require dedicated supervision at all times. Only people who
have completed PTW training and are designated as the Person in Charge are
allowed to raise a PTW.
17. HSE department roles
Subsea 7’s businesses and operations have HSE departments with responsibility
for guiding the implementation of HSE policies. They also measure safety
performance against specific HSE improvement action plans. They provide
independent audits of worksites to measure the effectiveness of the systems
so that they can provide advice and assistance to improve safety performance.
When incidents occur, Subsea 7’s HSE departments co-ordinate the analysis of
all incidents, damage and injury events and provide investigative services for the
more serious events including near miss incidents with a high potential outcome.
Investigation findings are used to provide a basis for continuous improvement to
our procedures and processes.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
18. Safety representatives/delegates
Subsea 7 encourages the participation of all our people in promoting safe
working practices throughout our operations. Forums are held regularly for
you and your colleagues to discuss issues of concern and make proposals to
improve HSE performance.
Worksites nominate worker safety representatives/delegates to act on
behalf of peer groups at HSE meetings. These representatives/delegates are
identified clearly in the work areas. We encourage you to be a safety champion
and volunteer.
19. Communication
Subsea 7 encourages you to bring HSE issues to the attention of any of
the following:
• Your immediate supervisor
• Your worksite manager
• A member of the worksite safety committee
• An elected safety delegate
• A member of a team involved in hazard identification and risk assessment
• Your team when participating in a toolbox talk
• The person carrying out the task
Subsea 7’s Senior Managers regularly visit worksites to enquire about HSE
concerns. These visits provide an opportunity for you to speak to them as
they are interested in hearing your ideas on how safety performance can be
improved. Safety communication is a two-way process; so if you speak to a
manager about safety concerns, Subsea 7 will respond – to let you know what
action is being taken or to explain why action will not be taken. Managers have
a duty to respond to you in a timely manner with their findings and actions.
If you find it difficult to raise your safety issue with any of the people listed
above, or feel your concern has not been fairly addressed, you may contact
the supporting HSE Manager or the VP HSEQ.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
Toolbox Talks
Toolbox talks provide the forum for the Supervisor or the ‘Person In Charge’ of
Work Team to ensure that everyone involved in the activity fully understands
the tasks, hazards involved, hazard control measures to be employed and;
procedures to be followed.
All work groups will hold a daily toolbox meeting at the beginning of each shift
to discuss the planned scope of work for that day. Additional toolbox meetings
should be held as required throughout the shift i.e. if there are significant
changes to the task, people involved or environment conditions. The attendees
at a toolbox meeting and any other relevant information shall be formally
recorded on Toolbox Talk Form (FO-GL-HSE-016).
Worksite management representatives and engineers will periodically attend
the toolbox meetings to monitor their effectiveness and obtain feedback on
work related HSE issues.
Time Out for Safety
‘Time Out for Safety’ empowers individual workers, supervisors and managers
who perceive that there is a potential hazard associated with a task to stop the
work and take time out for safety without the fear of negative consequences.
Time Out for Safety may also be used by supervisors and team leaders to hold
a short discussion with their work teams to focus on a HSEQ related topic of
interest i.e. a recent incident or near miss, a received safety alert or information
bulletin, a lesson learned, etc.
Some examples of when a Time Out for Safety might be called are:
• A change of plan, or to pass on urgent information critical to the job in
Management of Change
• An unscheduled event, or the emergence of a previously unidentified risk or
• Incomplete understanding of instructions, procedures or ongoing activities
• To discuss relevant incidents’ or near miss, safety alert
• A need to ask for help or direction
• As a means to focus on a particularly hazardous task or condition
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
20. Critical safety behaviours
Over 90% of injuries
are caused by ‘at risk’
The following safety
behaviours when
inadequate or lacking
(‘at risk’) have been
identified as the key
causes of Subsea 7
Eyes on path
‘3’ point contact
Assistance needed/used
Hot work preparation
x ü
Manual handling
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
Line of fire
Use of tools and equipment
Pinch points
Correct PPE worn
Use of barriers and warnings
Walking/working surfaces
Pre-job planning
Immediate report of injury
Eyes on task
A behaviour
is an
Lock out tag out system
Conformance to safety rules,
procedures or policies
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
21. HSEQ observation and intervention
Everyone has a part to play in managing safety. You are responsible for looking
after your own safety and the safety of those around you. By keeping alert
you can help to eliminate at-risk behaviours, correct unsafe conditions and
contribute to safety at your worksite.
If you see something that looks unsafe, or an at-risk behaviour, approach
co-workers and discuss it using questions. Then either stop it, correct it or
bring it to the attention of somebody who can stop it and correct it. You should
also recognise and comment on safe behaviour.
Fill out an OBSERVATION card to share the information, prevent
re-occurrence and help improve Subsea 7 worksites. Likewise you should
report and recognise notably safe behaviour. The system is used to highlight
behaviours, quality, environmental events and worksite conditions. Fill out an
INTERVENTION card if you have had a conversation that questioned an
‘at-risk’ behaviour or supported an example of safe behaviour.
The reporting of these observations and interventions will reveal if there are
common trends that we can address through training or other corrective
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
22. Incident reporting and investigation
Incidents are actual events which do or could cause harm. They include injury,
illness, damage and near miss incidents. They are events that Subsea 7 wants
to prevent.
If an incident does occur, it is essential that it is properly reported so
that managers can investigate and take the necessary actions to prevent
All incidents are recorded in the Synergi ‘case’ database. You may have to
contribute to a report if you are injured or involved in an accident; please
remember, the report should only contain facts (do not include your opinions
or make unsubstantiated claims). The events will be investigated either by the
worksite manager or a special investigative team, depending on the severity of
the event.
Please remember to report all undesired events and injuries promptly.
Incident reporting in Synergi:
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
Near miss incident
This is an event which could have resulted in damage or injury. An incident
actually happened but no damage or injury was sustained. Near miss reporting
is required in order to communicate the lessons learned and prevent future
incidents and accidents.
Damage to materials, property or equipment, or where harm is caused to the
environment are included in this class. Damage specifically caused by fire or
explosion is also identified.
Describes events in which people have sustained an injury. Most sites will have
trained First Aiders available. In the case of the larger ships, barges or yards, a
Medic or Doctor will be available on site to treat the injured person. The medic
or doctor will categorise the ‘injury’.
This category is used for reporting illnesses.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
Examples: Safety observation
Unsafe condition of crane wire. Loose strands on wire.
(Near miss) incident
Load was swinging but did not hit anyone and was not damaged.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
Material - Load released when wire broke and the load was damaged.
Lost Time Injury (LTI) injury caused when load swung and struck a
person resulting in them being unfit for work for the next shift or longer.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
23. Personal Protective Equipment (PPE)
The planning and assessment of work activities will take account of any
hazards and where practicable, the risk from these hazards will be eliminated
or reduced. A residual risk may remain, but we can often reduce this further by
wearing appropriate PPE. It is Subsea 7’s policy to ensure that suitable PPE is
available to everybody and always used in work activities.
Your full compliance with safe, well proven working procedures should prevent
accidents and consequential injuries. PPE is the last personal line of defence,
but may not protect you if you fail to behave safely.
Every person on a worksite must wear
(unless in a designated safe zone):
• Hard-hat
• Coveralls with high visibility reflective
stripes or a high visibility tabard
• Safety boots/shoes
• Safety glasses
• Gloves (unless deemed unfit for task)
Additional PPE must be used when
required and may include:
• Hearing protection
• Fall protection harnesses
• Respiratory protection equipment
• Lifejackets (offshore applications
including in harbour use)
• Burning goggles or clear goggles
• Gloves with specific hand protection
• Welding hood
• Full face shield
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
24. Emergency situations
During your worksite induction you will be informed about the alarms used at
your workplace and the specific procedures that you must follow in case of
fire or other emergency situations. When an alarm is raised, stop work, make
your work place safe and go immediately to your designated muster station/
assembly point.
If you discover a fire, raise the alarm immediately. Attempt to extinguish the fire
only if you are familiar with the fire fighting equipment and are sure you will not
endanger your own life.
Ensure that during your induction you learn where to go for medical
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
25. Harmful substances
Every worksite, which uses any chemicals, must:
• Review the chemicals, which you use on a regular basis and ensure that
you are familiar with the associated hazards and personal protection
measures. Be familiar with the Material Safety Data Sheets (MSDS) and the
assessments for the safe use of chemicals.
• Follow all instructions related to safe use and storage of chemicals
• Understand spill cleanup procedures and know where spill response
equipment is stored.
• Prior to using hazardous chemical substances, instructions for their use
and precautions to be taken must be fully understood and when applicable,
identified on the Permit to Work. Detailed information is available to site
management through SYPOL on hazardous substance management.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
26. Lifting operations
Much of Subsea 7’s work involves lifting operations using cranes or other
lifting equipment. Subsea 7 has developed very specific rules covering the
use and maintenance of such equipment. Many lifting operations are subject
to detailed planning risk assessment and the implementation of approved lift
Some of the key issues in these rules are:
• Never work under a suspended load
• You must be adequately trained and authorised before you can operate
cranes, winches, fork lifts, jacks and any other lifting equipment
• Anyone using lifting equipment and/or rigging must be sure prior to use
that it is fit for purpose, has up to date certification showing that it has
successfully passed a test of its lifting capability. They must also ensure
that they understand and confirm with their supervisor the colour code
system for in-date lifting and rigging equipment
• The route for a lift must be clear of people and obstructions
• Equipment used for lifting people must be designed and certified and
marked for this purpose
• Check that equipment required for lifting people is marked ‘man-riding’
• Never use a people transfer basket to carry more than the stated number
of people
• Ensure that you understand and follow the lift plan
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
27. Manual handling
The first consideration: can manual handling be avoided?
All manual handling tasks must be assessed. Stop and think.
• Is the task repetitive?
• Will it take more than an easy effort to lift it or is it above the limits on the
next page?
• Do I have to push or pull?
• Does this involve more than one person?
If the answer is yes to any of these, a manual handling assessment should be
carried out to mitigate the risk of injury.
The most effective control to reduce injury or incidents from manual handling is
not to perform the manual handling in the first instance.
Is it too heavy? Get help or use a mechanical device.
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
Manual handling guide
Lift with your legs - not your back
Keep the load close to the waist
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
x x ü
Avoid twisting the back and
Put down then adjust
Keep the head up when handling.
Move smoothly. Don’t lift or handle
more than can be easily managed.
Lifting in teams
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
28. Working at height
Working at height should be considered as a last option when deciding how a
work task should be carried out and may require a permit to work. Working at
height should only be undertaken if the task is essential and alternative means
of completing the task have been fully considered. Refer to the Working at
Height Procedure when assessing the work.
Working at height can be defined as ‘Any position where the potential exists
for a person to have a fall likely to cause a personal injury’.
There is no minimum height where the risks should not be considered and
assessed. We should remember that 60% of serious injuries sustained due to
industrial falls are from a height of less than 2 metres.
The only occasion where a fall protection system may not be used is when a
greater hazard exists after implementing fall protection measures. The residual
risk must then still be assessed as acceptable to carry out the work.
You must receive working at height training before doing tasks that require it.
All scaffolding must be certified and inspected daily by a qualified person.
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
29. Slips, trips, falls and hand injuries
Take care to avoid slips, trips and falls and be aware that the main factors
contributing to slip, trip or fall accidents are:
• Failure to maintain three point contact behaviour
• Eyes not on path behaviour
• Unsuitable footwear
• Environmental factors – wind, rain, spray
• Unsuitable or poor quality flooring
• People - congestion
• Contamination – oil, paint, grease
• Obstacles and obstructions
• Poor housekeeping and maintenance
Trip hazard
The most common type of injury at worksites is to people’s hands and fingers.
In order to reduce these injuries we must:
• Avoid pinch points behaviour
• Keep eyes on task
• Use the correct PPE for our hands
• Be more aware of potential hazards to our hands
• Look out for our colleagues and warn of unseen danger
• Work using good practice and with the right tools
• Be familiar with the Risk Assessment hazards and controls and relevant
Hand critical safety behaviours
on task
Use of tools
and equipment
PPE worn
Conformance to safety
rules, procedures or
a visitor or a subcontractor, is required to comply with our HSE standards.
Health, Safety, Environment and Security
30. Dropped objects
Dropped objects have proved to be the third highest cause of fatalities and
serious injuries in the oil and gas industry.
DROPS Calculator
LTI = Lost Time Incident / DAFWC = Days Away From Work Case
Dropped height (metres)
First aid
Mass (kg)
In addition to the working at height guidance,
remember these simple tips:
• Use lanyards on tools
• Secure loose objects that can fall
• Maintain good housekeeping
Everyone at a Subsea 7 managed worksite, whether working for Subsea 7,
Health, Safety, Environment and Security
31. What to do in the event of an accident
In the event of an accident act in this order:
1.Secure the site - make sure it is safe
2.Raise the alarm
3.Bring First Aider to the injured person if safe to do so
For a list of resources and contacts please visit:
Should you have any questions relating to the content of this handbook or HSE in general please ask your
Supervisor. A soft copy of this handbook is available on the Management System.
This document is the property of Subsea 7, its affiliates and subsidiaries and copying and/or disclosure
of the information it contains is prohibited without the permission of Subsea 7. It has been reviewed
and approved in accordance with Business Management System requirements and where applicable an
audit trail is available within the relevant document management system. The most recently approved
version is regarded as the controlled copy with all other copies being for information only. It is the holder’s
responsibility to ensure that they hold the latest approved version. (c) Subsea 7, 2012.
a visitor or a subcontractor, is required to comply with our HSE standards.
February 2012
MA-GL-HSE-005 Version 1
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