Military reference books and manuals (2009-2023, Volume 4) - page 20
AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
Page 3 of 7
24-hour phone lines:
- Azerbaijan + (994 12) 4979 888
- Georgia + (995 32) 593699
- Turkey + (800) 1300 90522
Email: opentalk@myalertline.com
3.0 Specific Requirements
ISO 14001:2004 - 4.5.3 Non-conformity, corrective action and preventive action.
OHSAS 18001:2007 - 4.5.3.2 Nonconformity, corrective action and preventive action
OMS Essentials (2.3.3; 4.1.5; 4.4.2; 6.4.4; 7.1.6; 8.2.7)
4.0 Key Responsibilities
AzSPU HSE & Engineering VP / Operating Area (OA) Managers:
Providing adequate resources and leadership support for the implementation of all
required measures to ensure the effective implementation of this procedure.
Reviewing audit findings, and major or repeated cases of non-compliance
/ non-
conformance, and identifying opportunities to improve performance.
AzSPU Functional Team Leaders / Managers:
Recording and managing non-compliances and non-conformances at AzSPU level.
Maintaining a team Action Tracking System (ATS) to manage non-compliances / non-
conformances and corrective actions that are not uploaded into Tr@ction (if ATS is
required in addition to Tr@ction).
Issuing corrective action requests to, and obtaining notification of completion from,
Responsible Parties, and subsequently updating the team ATS (if ATS is required in
addition to Tr@ction).
Analysis of AzSPU non-compliance / non-conformance data to identify root causes and
trends.
Periodically reporting non-compliances / non-conformances to AzSPU ALT.
Consultation with operating sites to finalise AzSPU wide audit findings and corrective
actions prior to upload into Tr@ction.
OA/Asset HSE/H&S/ E Team Leaders / Managers:
Recording and managing non-compliances / non-conformances at OA/Asset level.
Consultation with the Asset/Facility Operations Manager to finalise non-compliances /
non-conformances, corrective actions, responsibilities, and close out dates for
completion, prior to upload into Tr@ction or the local ATS.
Maintaining the OA/Asset level ATS to track implementation of all corrective and
preventative actions that are not uploaded into Tr@ction.
Issuing corrective action requests to, and obtaining notification of completion from,
Control Tier:
2-AzSPU
Revision Date: Nov 04, 2010
Document Number: AzSPU-HSSE-DOC-00040-2
Print Date: 2/1/201111/11/2010
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu
AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
Page 4 of 7
Responsible Parties, and subsequently updating the OA/Asset level ATS.
Analysis of OA / Asset non-compliance / non-conformance data to identify root causes
and trends.
Periodically reporting non-compliances / non-conformances to AzSPU ALT
Directing the development, maintenance and use of site inspection checklists or other
mechanisms as appropriate to ensure that non-compliances / non-conformances and
corrective and preventative actions are identified.
Encouraging all staff to report HSE non-compliances / non-conformances.
Asset/Facility Operations Manager:
Consultation with the OA/Asset HSE/H&S/ E Team Leaders / Managers to agree non-
compliance / non-conformance corrective actions, responsibilities, and close out dates for
completion, prior to upload into Tr@ction or the local ATS.
Accountable for employees under their supervision implementing the required corrective
and preventative actions in Tr@ction and the local ATS.
Employees:
Reporting HSSE non-compliances / non-conformances and incidents.
Responsible Parties for corrective and preventative actions in Tr@ction and local ATSs
are responsible for undertaking these actions and confirming completion of tasks.
5.0 Procedure
5.1 Identification of HSE Non-Compliances / Non-conformances
Non-compliances and non-conformances may be identified by any employee or contractor
working for, or on behalf of, AzSPU. Employees or contractors who become aware of a non-
compliance / non-conformance may notify any of the following:
Their supervisor
Site HSE Advisor
AzSPU Functional Team Leaders / Managers or OA/Asset HSE/H&S/ E Team Leaders /
Managers
Other HSE-Designated Person(s)
AzSPU Legal Advisor
OpenTalk (for anonymous reporting)
Non-compliances / non-conformances may also be identified directly by site supervisors, HSSE
Advisors, etc, during internal and external audits and inspections, and during monitoring of
operational conditions.
5.2 Recording and Managing HSE Non-compliances / Non-conformances
There are two systems available within the AzSPU for recording and managing non-compliances
/ non-conformances, namely:
Control Tier:
2-AzSPU
Revision Date: Nov 04, 2010
Document Number: AzSPU-HSSE-DOC-00040-2
Print Date: 2/1/201111/11/2010
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
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AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
Page 5 of 7
Tr@ction
Local Action Tracking Systems (ATSs)
These are discussed in more detail below.
Tr@ction:
The AzSPU Tr@ction Findings and Action Tracking Procedure details responsibilities and
processes for uploading findings and action items into the Tr@ction system (AzSPU-HSSE-
DOC-00119-2).
Guidelines for using Tr@ction and a complete list of data that requires upload into the Tr@ction
system is provided in the AzSPU Tr@ction User’s Guide (AzSPU-HSSE-DOC-00119-A1).
Local Action Tracking Systems (ATSs):
Non-compliance / non-conformance issues that are recorded in local Action Tracking Systems
(rather than the Tr@ction system) include those resulting from:
Asset / jobsite audits and inspections
Weekly permit to work inspections
Housekeeping observations
On-site monitoring - particularly routine operational discharges / emissions that are out
of compliance with defined specifications.
Following determination of the required corrective / preventative action the Responsible Party is
notified, a schedule for completion agreed, and the relevant ATS updated. ATSs held at AzSPU
level are managed by the relevant AzSPU Functional Leader / Manager (if ATS is required in
addition to Tr@ction). ATSs held at OA/Asset level are managed by the OA/Asset HSE/H&S/ E
Team Leaders / Managers.
Local ATSs include as a minimum:
Non-compliance / non-conformance category (as a minimum categorized as either:
Critical - non-compliance / non-conformance has a direct and immediate HSSE&S
impact that requires immediate corrective action. Non-critical - non-compliance / non-
conformance that does not present an immediate HSSE impact).
Required corrective or preventative action.
Responsibility.
Date for completion.
Status.
Local ATSs are retained on a shared drive to enable rapid access for all authorized personnel and
auditors.
5.3 HSSE Non-compliance / Non-conformance Follow up and Reporting
Responsible Parties for Action Items in Tr@ction, and the local ATSs, are responsible for
confirming completion of tasks, once actioned.
Control Tier:
2-AzSPU
Revision Date: Nov 04, 2010
Document Number: AzSPU-HSSE-DOC-00040-2
Print Date: 2/1/201111/11/2010
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AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
Page 6 of 7
In the case of Tr@ction, an internal messaging feature generates automated e-mails in line with
the follow-up and communication processes of the system. This includes notification to
Responsible Parties regarding Action Items that need to be closed, and notification to Supervisors
of overdue Action Items.
The AzSPU Functional Leaders / Managers and the OA/Asset HSE/H&S/ E Team Leaders /
Managers regularly check the status of corrective / preventative actions in their respective local
ATSs to verify that the scheduled Action Items are being undertaken.
Audits and inspections include a check on the status of corrective actions identified during the
previous audit or inspection. The auditor/inspector will also consider how effective the corrective
action has been in addressing the non-compliance
/ non-conformance. Where the required
corrective action has been ineffective, alternative actions will be recommended.
Compliance performance is periodically reported by the OA/Asset HSE/H&S/ E Team Leaders /
Managers to the applicable OA Management Team. In addition, the AzSPU Functional Leaders /
Managers provide a summary of performance to AzSPU ALT during management review
meetings.
5.4 External Notification
Reporting of routine operational discharges / emissions that are out of compliance with defined
specifications
(e.g. legislative permits or other standards) will be externally reported to the
regulators in accordance with OA / Asset specific agreements, permits and directives. Existing
reporting documentation and processes
(e.g. Annual Environmental Reports, Monthly
Environmental Reports, End of Well Reports, Non-Drilling Discharge Reports, etc) will be used
to submit this information.
It should be noted that releases of untreated effluents (e.g. sewage, produced water, hazardous
drainage, etc), resulting from treatment plant failure / maintenance, will be reported as a material
release in accordance with the Internal & External Material Release Reporting & Notification
Procedure (AzSPU-HSSE-DOC-00075-2).
6.0 Key Documents/Tools/References
Local Action Tracking Systems (ATSs)
Tr@ction
AzSPU Tr@ction Findings and Action Tracking Procedure (AzSPU-HSSE-DOC-00119-
2)
AzSPU-HSSE-DOC-00035-2 AzSPU External Audits and Self Assurance Programme
overview
AzSPU Tr@ction User’s Guide (AzSPU-HSSE-DOC-00119-A1)
AzSPU Internal and External Material Release
(Spill) Reporting & Notification
Procedure (AzSPU-HSSE-DOC-00075-2).
Revision Log
Control Tier:
2-AzSPU
Revision Date: Nov 04, 2010
Document Number: AzSPU-HSSE-DOC-00040-2
Print Date: 2/1/201111/11/2010
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
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AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
Page 7 of 7
Revision Date
Approver
Originator
Revision Details
January 9, 2006
Gunther Newcombe
Yuliy Zaytsev
Initial issue.
January 30, 2007
Gunther Newcombe
Yuliy Zaytsev
Recording of non-compliances in the
Tr@ction system incorporated into
procedure.
Clarification provided regarding
information to be uploaded in Tr@ction
and information to be uploaded in local
ATSs.
October 10, 2007
Yuliy Zaytsev
Rebecca Heath
Distinction between non-compliance and
non-conformance added to procedure.
Clarification provided regarding external
notification of out of specification
discharges / emissions.
February 18, 2009
AzSPU Safety &
AzSPU HSSE MS
Position titles updated throughout.
Compliance Manager
Senior Advisor
Open talk contact details corrected.
(Yuliy Zaytsev)
(Rebecca Heath)
Clarification provided regarding the
management of non-compliances and non-
conformances at AzSPU level:
- Responsibility reassigned to all AzSPU
Functional Team Leaders / Managers
(rather than just AzSPU HSE MS &
Compliance Manager).
- Local ATSs now optional at AzSPU level
if Tr@ction is considered sufficient for
tracking closure of non-compliances and
non-conformances.
March, 01, 2010
AzSPU Safety &
AzSPU HSSE MS
Annual update with minor changes
Compliance Manager
Team Leader
(Yuliy Zaytsev)
(Idrak Nazarov)
April 1, 2010
AzSPU Safety &
AzSPU HSSE MS
Doc reviewed and the validity extended to
Compliance Manager
Team Leader
30th of July. Doc will be reviewed again on
this date to incorporate any changes
(Yuliy Zaytsev)
(Idrak Nazarov)
resulting from reorganization.
November 4, 2010
AzSPU Regulatory
AzSPU HSE
Doc reviewed and the validity extended to
Compliance and
Compliance Team
4th November 2011.
Environment Manager
Leader
Control Tier:
2-AzSPU
Revision Date: Nov 04, 2010
Document Number: AzSPU-HSSE-DOC-00040-2
Print Date: 2/1/201111/11/2010
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AzSPU HSE Foundation Competencies
AzSPU HSE Foundation Competencies
Document number:
AzSPU-HSE-DOC-00044-2
Title of Document:
AzSPU Training Foundation Competency
CD #:
Guidelines
Authority:
HSE L&OD Advisor / Learning Ops Manager
Custodian:
Learning Coordinator
Scope:
AzSPU
Doc. Admin.:
HSEMS Coordinator
Issue Date:
01/01/04
Issuing Dept:
HSE & Engineering
Revision Date:
10/08/2010
Control Tier:
2 - AzSPU
Next Review:
10/08/2011
Chapter-Page:
Control Tier:
2-AzSPU
Revision Date: August 10, 2010
Document Number: << AzSPU-HSE-DOC-00044-2>>
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS
DOCUMENT CAN BE FOUND AT http://bp1houdm004/dkazspu
AzSPU HSE Foundation Competencies
1.0 Purpose/Scope
The purpose of this document is to describe the foundation competencies in Health, Safety & Environment at
the AzSPU level. This document defines business unit HSE competency requirements for non-HSE
professionals and recommending suitable training/development plans to meet these competencies. This
document applies to BP Exploration (Caspian Sea) Ltd. full time national permanent; expatriate in; Georgia
permanent, and agency staff in addition to contractors as defined within the AzSPU HSE Training, Awareness
and Competence Procedure (AzSPU-HSE-DOC-00030-2) which describes the process of identifying HSE
training requirements, delivering training commensurate with defined responsibilities, and maintaining training
records. It is at the discretion of a BP supervisor, team leader, and/or manager, to determine if the scope of this
document would apply to day rates and/or summer interns working less than 6 months.
2.0 Definitions
This section provides definitions for terms referenced in this procedure. Only definitions unique to this procedure are
included here. General HSE management system definitions are in the Definitions document AzSPU-HSE-DOC-00021-2.
3.0 General Requirements
ISO 14001 - Element 4.4.2 Competence, training and awareness
BP Global HSE Compliance Framework - Step 3, Items 3.2, 3.5, 3.7, 3.9
4.0
Roles, Responsibilities & Definitions
AzSPU HSE Learning and Development Advisor
1. Identifies the recommended training and development plans applicable to HSE foundation competencies
as defined within (1) BP’s Competency Online (CoL) Framework, (2) AzSPU HSE Training, Awareness and
Competence Procedure, (3) AzSPU HSE Training Requirements Matrix.
2. Tracks the status of HSE training against targets and provides a status update to the ALT and
Operations/Midstream VPs each quarter.
5.0
Procedure/Process
HSE and social foundation competencies are defined in accordance with this procedure to ensure that BP employees and
contractors are provided with foundation training in HSE and social issues based on their job role. This will enable
personnel to conduct their work tasks in a way that safeguards the environment; protects employee and community health,
safety, and security; meets social obligations; meets legal and other requirements; and meets the requirements of BP HSE
Policy.
Title of Document:
AzSPU Training Foundation Competency
CD #:
Guidelines
Authority:
HSE L&OD Advisor / Learning Ops Manager
Custodian:
Learning Coordinator
Scope:
AzSPU
Doc. Admin.:
HSEMS Coordinator
Issue Date:
01/01/04
Issuing Dept:
HSE & Engineering
Revision Date:
10/08/2010
Control Tier:
2 - AzSPU
Next Review:
10/08/2011
Chapter-Page:
Control Tier:
2-AzSPU
Revision Date: August 10, 2010
Document Number: << AzSPU-HSE-DOC-00044-2>>
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS
DOCUMENT CAN BE FOUND AT http://bp1houdm004/dkazspu
AzSPU HSE Foundation Competencies
This document defines foundation competency levels required for each job group/category. This document does not
define technical and professional competencies as these competencies will vary and may require a higher level of HSE
competencies.
Job Profile:
Group 1
Office Based Non -TL Personnel
Group 2
Field Based Non - TL Personnel
Group 3
Office Based TL Personnel
Group 4
Field Based TL Personnel
* Office Based personnel HSE training requirements are set on the basis of recommendation and should be
agreed with respective Vice President.
HSE Recommended Development Plan:
Job Profile 1
Job Profile 2
Job Profile 3
Job Profile 4
Behavioral Safety Observation
Behavioral Safety Observation
Behavioral Safety Observation
SOC
(BOSS) (recommended)
(BOSS)
(BOSS) OR SOC as per target set
by VP (recommended)
The aforementioned are MINIMUM (core) HSE training requirements (see Appendix A) based on the HSE
foundation competencies defined within the Competencies Online Framework. Additional HSE training such as
HAZWOPER, Major Emergency Management, Confine Space Entry, etc., for above job profiles are further
defined within performance unit site (non core) HSE training matrices. To determine your non-core HSE
training requirements, contact your performance unit Learning Coordinator and/or HSE Advisor.
6.0
Key Documents, Tools, References
AzSPU Health, Safety, Security, Environmental (HSE) Training, Awareness and Competence Procedure
(AzSPU-HSE-DOC-00030-2)
Virtual Training Assistant Learning Management System
Title of Document:
AzSPU Training Foundation Competency
CD #:
Guidelines
Authority:
HSE L&OD Advisor / Learning Ops Manager
Custodian:
Learning Coordinator
Scope:
AzSPU
Doc. Admin.:
HSEMS Coordinator
Issue Date:
01/01/04
Issuing Dept:
HSE & Engineering
Revision Date:
10/08/2010
Control Tier:
2 - AzSPU
Next Review:
10/08/2011
Chapter-Page:
Control Tier:
2-AzSPU
Revision Date: August 10, 2010
Document Number: << AzSPU-HSE-DOC-00044-2>>
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS
DOCUMENT CAN BE FOUND AT http://bp1houdm004/dkazspu
AzSPU HSE Foundation Competencies
Appendix A
Refresher/
Employee-
Employee-
AzSPU Minimum HSE Training Req.
Frequency
Ofc
TL-Ofc
Field
TL-Field
Behavioral Safety Observation (BOSS)
None
recommend
core
Safety Observation Conversations
None
recommend
core
Revision Log
Revision Date
Authority
Reviser
Revision Details
01 Feb 14
M.Holmes
M. Holmes
Reformatted document into HSEMS procedure template.
Removed competency skill definitions and replaced with link
to CoL.
14 March 06
M.Holmes
Y.Mirtagavi
Reflected HSE Training Manager as Authority of document
25 March 06
Y.Mirtagavi
Y.Mirtagavi
Reflected HSE L&D Specialist as custodian of the document
20 August 2007
Y.Mirtagavi
Y.Mirtagavi
Reflected change in moving towards BSA
17 December
Y.Mirtagavi
Y.Mirtagavi
Reflected change in moving from BSA to SOC
2007
17 January 2008
Y.Mirtagavi
Y.Mirtagavi
Reflected change in approved list of minimum HSE training
requirements
13 March 2008
Y.Mirtagavi
Y.Mirtagavi
Added Appendix with the list of Minimum Core HSE trainings
requirements and updated links to other documents in Section
6
21 April 2008
Y.Mirtagavi
Ilaha
Added Ilaha Akhmedova as document custodian
Akhmedova
21 May 2008
Y.Mirtagavi
Ilaha
Revised Core HSE training requirements with ALT
Akhmedova
09 June 2008
Y.Mirtagavi
Ilaha
Revised Core HSE training requirements with ALT to remove
Akhmedova
Basic Fire extinguishers for Ops personnel since they
undertake higher level program
12 August 2008
Y.Mirtagavi
Ilaha
Changed title of Basic Fire Extinguishers into BFF
Akhmedova
27 August 2008
Y.Mirtagavi
Ilaha
Changed requirement of Office based TLs from SOC to BST
Akhmedova
28 August 2008
Y.Mirtagavi
Ilaha
Revised core HSE training requirements for each job profile
Akhmedova
following ALT discussion
03 September
Y.Mirtagavi
Ilaha
Revised core HSE training requirements for each job profile
2008
Akhmedova
following discussion with Security Manager
05September
Y.Mirtagavi
Ilaha
Revised core HSE training requirements for each job profile
2008
Akhmedova
following discussion with Teymuraz Babayev on Driver
training
20 October 2008
Y.Mirtagavi
Ilaha
Included requirement to update ALT and PULT against
Akhmedova
training requirements
Title of Document:
AzSPU Training Foundation Competency
CD #:
Guidelines
Authority:
HSE L&OD Advisor / Learning Ops Manager
Custodian:
Learning Coordinator
Scope:
AzSPU
Doc. Admin.:
HSEMS Coordinator
Issue Date:
01/01/04
Issuing Dept:
HSE & Engineering
Revision Date:
10/08/2010
Control Tier:
2 - AzSPU
Next Review:
10/08/2011
Chapter-Page:
Control Tier:
2-AzSPU
Revision Date: August 10, 2010
Document Number: << AzSPU-HSE-DOC-00044-2>>
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED VERSION OF THIS
DOCUMENT CAN BE FOUND AT http://bp1houdm004/dkazspu
AzSPU HSE Foundation Competencies
26 November
Y.Mirtagavi
Ilaha
Updated FA training reqs for all site based employees
2008
Akhmedova
10 February 2009 Y.Mirtagavi
Ilaha
Removed FA, COSHH and Incident Investigation from core
Akhmedova
HSE training requirements and PUs determine their respective
needs.
Updated SOC as requirement for office based TLs in line with
2009 HSE targets
18 February 2009 Y.Mirtagavi
Ilaha
SOC training requirements for office based population set as
Akhmedova
per discretion of respective VP
05 May 2009
Y.Mirtagavi
Ilaha
Office based employees training requirements for Shared
Akhmedova
Services, i.e. Finance, C&EA, HR functions are
recommended, not mandatory.
29 September
Y.Mirtagavi
Ilaha
Removed driver/security personnel training reqs as being
2009
Akhmedova
outsourced service
29 January 2010 Y.Mirtagavi
Leyla
Removed reference to Social training requirements;
Balaglanova
Changed PUL to VP;
Removed reference to People Data Management System;
Removed HSE Foundation competencies example.
02 August 2010
Y.Mirtagavi
Y.Mirtagavi
Changed custodian and issuing department.
10 August 2010
Y.Mirtagavi
Y.Mirtagavi
Changed HSSE to HSE
Title of Document:
AzSPU Training Foundation Competency
CD #:
Guidelines
Authority:
HSE L&OD Advisor / Learning Ops Manager
Custodian:
Learning Coordinator
Scope:
AzSPU
Doc. Admin.:
HSEMS Coordinator
Issue Date:
01/01/04
Issuing Dept:
HSE & Engineering
Revision Date:
10/08/2010
Control Tier:
2 - AzSPU
Next Review:
10/08/2011
Chapter-Page:
Control Tier:
2-AzSPU
Revision Date: August 10, 2010
Document Number: << AzSPU-HSE-DOC-00044-2>>
Print Date: 2/1/2011
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AzSPU HSE Legal & Regulatory Requirements Procedure
Page 1 of 21
HSE LEGAL AND REGULATORY
REQUIREMENTS PROCEDURE
This document incorporates requirements from the AzSPU HSE Compliance Framework
Procedure (AzSPU-HSSE-DOC-00141-2) and the AzSPU HSE Compliance Assurance
Process (AzSPU-HSSE-DOC-00039-2).
These documents are now obsolete.
AZSPU-HSSE-DOC-00038-2
Authority:
Faig Askerov (AzSPU
Custodian:
Anar Naghiyev (AzSPU HSE
Regulatory Compliance &
Compliance Team Leader)
Environment Manager)
Scope:
AzSPU Functions &
Document
HSE Document Coordinator
Operating Areas
Administrator:
Issue Date:
July, 2000
Issuing Dept:
AzSPU HSE & Engineering
Revision Date:
30 July, 2010
Control Tier:
2 AzSPU
Next Review Date:
30 July, 2011
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 2 of 21
1.0
Purpose/Scope
In accordance with OMS Sub-element 7.1, BP entities are required to comply with applicable
legal and regulatory requirements.
This procedure outlines the process AzSPU has in place for complying with applicable health,
safety, and environmental (HSE) legal and regulatory requirements, and is in alignment with
OMS and GRP 7.1-0001 „Legal & Regulatory HSSE Compliance‟.
Within the AzSPU, legal & regulatory HSE requirements are contained within:
Legal agreements such as Production Sharing Agreements (PSAs) and Host Government
Agreements (HGAs).
National laws and regulations.
International treaties and conventions.
Regional and lender agreements.
Commitments made in ESIAs.
Failure to meet these requirements can adversely impact business, significantly damage
reputation, and result in civil, administrative and criminal penalties.
This controlled procedure applies to AzSPU Functions and Operating Areas engaged in the
drilling, production, and/or transportation of oil and gas.
Revision of this procedure and the operational controls detailed therein will be in accordance with
the AzSPU HSSE MS Document Management Procedure (AzSPU-HSSE-DOC-00025-2).
2.0
Definitions
Refer to the AzSPU List of HSSE Definitions AzSPU-HSSE-DOC-00021-2. Definitions specific
to this procedure are included below.
Compliance Task Manager (CTM) - a software tool which serves as an electronic compliance
matrix enabling BP businesses to manage the relationship between applicable legal and regulatory
HSE requirements, compliance tasks, responsible parties, operational controls, and completion
evidence.
APS List - Activities, Products and Services List.
3.0
Specific Requirements
OMS Sub-element 7.1 - Regulatory Compliance (7.1.1, 7.1.1.1, 7.1.2, 7.1.3, 7.1.4,
7.1.5, 7.1.6, 7.1.8).
OMS Sub-element 4.2 - Management of Change (4.2.2)
OMS Sub-element 1.6 - Communication & Engagement (1.6.2)
OMS Sub-element 2.3 - Operating Discipline (2.3.3)
OMS Sub-element 7.5 - Product Stewardship (7.5.1)
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 3 of 21
GRP 7.1-0001 Legal & Regulatory HSSE Compliance
ISO 14001:2004 - 4.3.2 Legal & Other Requirements
4.0
Key Responsibilities
AzSPU HSE & Engineering Vice President
The AzSPU HSE & Engineering VP has high-level accountability for the AzSPU‟s legal and
regulatory compliance, and is responsible for appointing a Single Point Accountability (SPA) to
drive implementation and sustain the overall HSE legal and regulatory compliance process within
AzSPU.
AzSPU Regulatory Compliance & Environment Manager
The AzSPU Regulatory Compliance & Environment Manager is the Single Point Accountability
(SPA) for AzSPU‟s HSE regulatory compliance processes.
Accountable for:
Serving as AzSPU‟s champion for legal and regulatory HSE compliance and engaging
the leadership team to drive compliance processes.
Continuously promoting an organisational culture that embraces an uncompromising
commitment to HSE compliance.
Engaging all appropriate stakeholders on the HSE compliance process.
Coordinating AzSPU compliance processes with Group HSE Compliance Team in Safety
& Operations.
Proactively seeking and sharing information and learnings from other BP entities.
Ensuring that resources and funding needed to deliver the HSE compliance processes are
integrated into the annual plan.
Assurance of the accuracy and completeness of information contained within the HSE
Risk Matrices, HSE Legal Registers, and CTM, and for ensuring these systems are
updated as new or modified requirements are identified.
Monitoring CTM monthly dashboard progress reports.
Contracting the services of external providers / consultancies involved in supplying HSE
legislative information and legislative translation services
(in line with PSCM
requirements).
Managing the process of preparation of Compliance Requirement Position Papers, as
required.
AzSPU HSE Compliance Team
Responsible for:
Annual update of the AzSPU HSE Compliance Risk Matrices.
Maintainance of the CTM database.
Maintenance of the HSE Legal Registers (in consultation with Functional Authorities /
Specialists and Georgia Legal / Regulatory Affairs Team).
Facilitating the process of the development of Compliance Requirement Position Papers,
as required
(in consultation with Functional Authorities / Specialists, AzSPU Legal
Team, Georgia Legal / Regulatory Affairs Team).
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 4 of 21
Facilitating the applicability screening process.
Facilitating the interpretation of applicable HSE legisative documents, and the
development / verification of CTM compliance tasks.
Validation of verified compliance tasks and their upload and activation in CTM.
Tracking and identification of new or amended Azerbaijani national and international
legislative requirements (in consultation with the AzSPU Legal Team).
Maintaining a library of applicable Azerbaijani and International HSE laws and
regulations.
Managing the process of translation of applicable Azerbaijani HSE legislation into
English.
Co-ordinating the services of external providers / consultancies involved in supplying
HSE legislative information.
Acting as HSE Compliance Advisors in the AzSPU e-MoC system and completing the
relevant sections of the HSE Compliance Form.
Preparation of monthly progress dashboards to track the development / verification /
activation of compliance tasks, and closure of compliance tasks. Also responsible for
associated spot-checks to determine quality of task closure.
Communicating legally required training identified in CTM compliance tasks to the HSE
& Engineering Org Capability Team Leader.
Area / D&C H&S Team Leader / ST Compliance & Environment Team Leader / Georgia
Exports Compliance & Environment Team Leader / Azerbaijan Exports Compliance Lead
1
Responsible for:
Developing and maintaining facility Activities, Products and Services Lists (with input
from Operations / Maintenance / Wells Managers).
Completing the first section of the HSE Compliance Form (as part of the e-MoC process)
and updating relevant APS lists in response to on-site operational changes and submitting
these documents to the AzSPU HSE Compliance Team (through the HSE Compliance
Advisors). NB: In the e-MoC system this position is referred to as ‘H&S TL / Env &
Compliance TL’.
Functional Authorities / Specialists
Responsible for:
Applicability screening of national and international HSE legislation (consultation with
the APS List SMEs, Operations / Maintenance / Wells Managers, AzSPU Legal Team
and Georgia Legal / Regulatory Affairs Team carried out where further clarification
required).
Interpretation of applicable HSE legisative documents, and development of CTM
compliance tasks (in consultation with AzSPU Legal Team or Georgia Legal / Regulatory
Affairs Team, as required).
Leading the process of verification of town performed (functional) CTM compliance
1 These positions are not consistent as the Offshore Compliance & Environment Team Leader position is
currently vacant, and it is considered too much work for one person to be responsible for these tasks for
Azeri, Chirag / DWG, Shah Deniz, Logistics and Sub-sea Ops.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
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tasks (in collaboration with Task Owners / Supervisors).
Highlighting any defficiencies in operational controls during the compliance task
verification process and initiating improvement processes (town performed / functional
tasks).
Development of new HSE documentation where compliance task operational control is
not in existence and procedural control is determined to be required.
Consulting with the relevant Area Engineering Support Team Leader (AESTL) / D&C
Engineering Team Leader in order to assess the feasibility of compliance task
engineering requirements and any conflicts with existing Engineering Technical
Practices.
Providing input to Compliance Requirement Position Papers, as required.
Offshore / Sangachal / Exports Compliance Advisors
Responsible for:
Leading the process of verification of site performed CTM compliance tasks
(in
collaboration with Task Owners / Supervisors).
Highlighting any defficiencies in operational controls during the compliance task
verification process and initiating improvement processes (site performed tasks).
Monitoring the compliance task closure process for their facilities to ensure that deadlines
are not routinely missed.
Analysis of Tr@ction data for their facilities in order to identify recurring non-
compliance issues and their route causes so that they can be treated with a higher level of
priority and attention.
Monitoring the CTM User Training status for their facilities to ensure that all CTM Task
Owners and Supervisors have received appropriate system training.
Area Engineering Support Team Leader (AESTL) / D&C Engineering Team Leader
Responsible for provision of advice regarding engineering related compliance tasks
(particularly their feasibility and any conflicts with existing engineering documentation).
Operations Managers / Maintenance / Wells Managers
Responsible for:
Providing input to Activities, Products and Services (APS) Lists maintained by
the Area / D&C H&S Team Leader / ST Compliance & Environment Team Leader /
Georgia Exports Compliance & Environment Team Leader
/ Azerbaijan Exports
Compliance Lead.
Technical Authorities
Responsible for development of new technical documentation where compliance task
operational control is not in existence and procedural control is determined to be
required.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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version of this document can be found at http://docs.bpweb.bp.com/dkazspu
AzSPU HSSE Legal & Regulatory Requirements Procedure
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AzSPU Legal Team
Responsible for provision of advice to AzSPU HSE Compliance Team regarding new or
amended HSE legislative requirements, and applicability of HSE legislation and
interpretation of legislative text (where required).
Providing input to Compliance Requirement Position Papers, as required.
Georgia Legal / Regulatory Affairs Team
Responsible for:
Identification of new and amended Georgian national legislative requirements.
Identification of future legal requirements, review of draft documents and provision of
input to relevant bodies regarding conflicts with other legislation, etc.
Communication of any new / amended Acts to the AzSPU HSE Compliance Team so that
they can facilitate the process of applicability review.
Contracting the services of external providers involved in supplying Georgian HSE
legislative information.
Provision of advice to Functional Authorities / Specialists regarding applicability and
interpretation of Georgian legislative text.
Providing input to Compliance Requirement Position Papers, as required.
CTM Task Supervisors
Accountable for:
Verification of CTM compliance tasks, identification of task ownership and operational
controls (in collaboration with respective Functional Authority / Specialist or Offshore /
Sangachal / Exports Compliance Advisor).
Completion / fulfillment of required CTM tasks / requirements.
Ensuring proper communication of CTM compliance tasks to Task Owners, that required
technical and legally required training has been carried out, and that task owners are
competent to complete tasks.
Taking corrective action if Task Owner does not complete compliance task by set
deadline.
Communicating information on transfer of Task Supervisor ownership
(during
organisational / personnel change) to AzSPU HSE Compliance Team.
Notifying the AzSPU HSE Compliance Team of any changes to operational controls
associated with activated compliance tasks.
CTM Task Owners
Responsible for:
Verification of CTM compliance tasks, confirmation of task ownership, and identification
of operational controls (in collaboration with respective Functional Authority / Specialist
or Offshore / Sangachal / Exports Compliance Advisor).
Completion / fulfillment of required CTM tasks / requirements.
Entering non-compliant compliance task monitoring results into Tr@ction for action
tracking and closure.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
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Communicating information on transfer of Task Owner (during organisational / personnel
change) to AzSPU HSE Compliance Team.
Notifying the AzSPU HSE Compliance Team of any changes to operational controls
associated with activated compliance tasks.
5.0
Procedure
5.1
HSE Compliance Risk
AzSPU identifies and evaluates legal and regulatory HSE compliance risk and uses this
information to prioritise its compliance management processes.
AzSPU‟s HSE Compliance Risk Matrices for Azerbaijan and Georgia (AzSPU-HSSE-DOC-
00281-2) were initially developed using the BP Group Compliance Framework Risk Prioritisation
Tool.
Subsequent updates to the HSE Compliance Risk Matrices are carried out purely through
consultation with personnel with a sound knowledge of the practices and compliance history of
the whole AzSPU (e.g. representatives from AzSPU HSE & Engineering, AzSPU Legal Team,
etc). Updates take into account the HSE compliance environment in which AzSPU operates, and
the current state of HSE compliance management processes.
The resulting HSE Compliance Risk Matrices (Boston Squares) identify the highest priority areas
for compliance planning. This determines priority of CTM compliance task development /
verification / activation (see Section 5.4), and Compliance Requirement Position Paper (CRPP)
development (see Section 5.3). The information is also used as the basis for the AzSPU risk based
HSE compliance auditing programme (see Section 5.7).
The AzSPU HSE Compliance Team manages the update of the HSE Compliance Risk Matrices
on an annual basis.
5.2
Compliance Matrix
Compliance Task Manager (CTM) is a software tool which serves as an electronic compliance
matrix enabling AzSPU to manage the relationship between applicable legal and regulatory HSE
requirements, compliance tasks, responsible parties, operational controls, and completion
evidence. The purpose of the tool is to demonstrate that AzSPU can maintain justifiable
confidence in consistently meeting HSE compliance obligations.
CTM is accessible to AzSPU users via the BP intranet and includes:
Details of the applicable compliance requirement (High-Level/Detailed Requirement).
Tasks required to maintain compliance with requirement (Task Title/Task Description).
Task frequency (Recurrence Criteria).
Operational Controls in place to assist in accomplishing the task or meeting the
requirement.
The title of the person responsible for completion of required tasks (Owner).
The title of the person accountable for the completion of required tasks (Supervisor).
Record keeping requirements.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
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Reporting requirements.
Tasks associated with applicable legal and regulatory binding requirements are in the process of
being uploaded to CTM, based on the HSE Legal Registers (see Section 5.3). Priority is given to
the highest risk compliance subject areas, as identified in the AzSPU HSE Compliance Risk
Matrices (AzSPU-HSSE-DOC-00281-2).
The AzSPU HSE Compliance Team is responsible for the effective management of CTM,
including ensuring that it can be accessed by staff in accordance with the controls administered
by the Global Administrator. CTM will be regularly updated to reflect changes in regulatory
requirements, operational activities, etc (see Section 5.6).
Communication of information on HSE compliance expectations and provision of training on the
use of CTM is carried out in accordance with the AzSPU HSE Compliance Training &
Communication Strategy 2008-2009+ (AzSPU-HSSE-DOC-00145-2).
In terms of „other‟ requirements (e.g. corporate requirements such as OMS, GDPs / GRPs),
AzSPU has separate processes established to manage conformance (e.g. procedural requirements,
gap assessments, audits / inspections) that are in place and well progressed.
5.3
Applicability Review
The first step in the applicability review process involves the identification of activities, products,
and services (APSs) of the business. This is carried out by the relevant Area / D&C H&S Team
Leader / ST Compliance & Environment Team Leader / Georgia Exports Compliance &
Environment Team Leader / Azerbaijan Exports Compliance Lead, with input from the respective
Operations and Maintenance Managers. APS Lists prepared to date are available in dK (AzSPU-
HSSE-DOC-00263-2).
Periodic review and update of the APS lists by the relevant Area / D&C H&S Team Leader / ST
Compliance & Environment Team Leader / Georgia Exports Compliance & Environment Team
Leader / Azerbaijan Exports Compliance Lead is carried out as part of the formal e-MoC process
and communicated to the AzSPU HSE Compliance Team (see Section 5.6.2).
Applicability screening of national and international legislation is then carried out by the relevant
Functional Authority / Specialist, based on information in the APS lists. Consultation with APS
List SMEs, Operational Managers / Maintenance / Wells Managers, the AzSPU Legal Team and
the Georgia Legal / Regulatory Affairs Team is carried out where further clarification is required.
The AzSPU HSE Compliance Team is responsible for overseeing / facilitating the applicability
screening process.
The output of this process is a number of HSE Legal Registers, managed by the AzSPU HSE
Compliance Team, which list all known HSE legislative documents and the applicability of each
to AzSPU operations (by Facility). Where it is determined that a HSE legislative document is not
applicable to AzSPU operations, the rational for this is provided in the relevant HSE Legal
Register.
At present the following AzSPU HSE Legal Registers are in place:
Register of HSE Drivers AzSPU-HSSE-DOC-00038-A1 (includes all project-specific
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
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approved documents, e.g. PSAs, ESIAs, ESAPs, etc).
Register of Azerbaijani HSE National Legislation AzSPU-HSSE-DOC-00038-A2.
Register of Georgian HSE National Legislation AzSPU-HSSE-DOC-00038-A6.
Register of International HSE Guidelines and Regulations for Azerbaijan AzSPU-HSSE-
DOC-00038-A4.
Register of International HSE Guidelines and Regulations for Georgia AzSPU-HSSE-
DOC-00038-A8.
AzSPU Azerbaijan ESIA Permit Register AzSPU-HSSE-DOC-00038-A5.
AzSPU Azerbaijan Other HSE Permit Register AzSPU-HSSE-DOC-00038-A7.
Applicability review is an ongoing process, with the HSE Legal Registers updated as new or
amended legislative requirements are identified, or as changes in operational activities dictate
(see Section 5.6).
Compliance Requirement Position Papers (CRPPs)
In addition to the above, the development of CRPPs is carried out to manage certain high-risk
compliance subject areas (where required). This process is facilitated by the AzSPU HSE
Compliance Team in consultation with Functional Authorities / Specialists, AzSPU Legal Team,
Georgia Legal
/ Regulatory Affairs Team, etc. CRPPs summarise current national and
international legal compliance requirements and standards, identify potential conflicts, and
propose ways of resolving them.
5.4
Compliance Task Development / Verification / Activation
Legal and regulatory HSE requirements are extracted from applicable HSE legislative documents
and incorporated into the CTM database. The AzSPU HSE Compliance Team is responsible for
overseeing / facilitating the whole process.
Functional Authorities
/ Specialists are responsible for interpretation of HSE legislative
documents and the development of compliance tasks, in consultation with the AzSPU Legal
Team / Georgia Legal Team (as required). More detail is provided in the AzSPU CTM
Compliance Task Development Procedure (AzSPU-HSSE-DOC-00114-2). If in-house expertise
is not sufficient, the Functional Authorities / Specialists can use external consultancy support for
the compliance task development process.
For site performed tasks, the Offshore / Sangachal / Exports Compliance Advisors are responsible
for leading the process of compliance task verification, including identification of task ownership
and operational controls (this process involves close collaboration with the selected Task Owner /
Task Supervisor). For town performed (functional) tasks, the Functional Authorities / Specialists
are responsible for leading the process of compliance task verification. Guidance is provided in
the AzSPU CTM Compliance Task Verification Procedure (AzSPU-HSSE-DOC-00094-2).
Operational controls can be procedural, physical (e.g. valves, signage), or employee expertise
(e.g. training, certification, demonstrable expertise). If operational controls are not considered
effective / adequate it is the relevant Functional Authority / Specialist or Offshore / Sangachal /
Exports Compliance Advisor‟s responsibility to highlight this as an issue and initiate
improvement processes.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 10 of 21
Update of existing procedures is the responsibility of the Document Custodian (see AzSPU HSSE
Document Management Procedure AzSPU-HSSE-DOC-00025-2). If the development of new
procedures is required this is the responsibility of the relevant Functional Authority / Specialist or
Technical Authority.
If compliance tasks are engineering related, the relevant Functional Authority / Specialist or
Offshore / Sangachal / Exports Compliance Advisor also consults with the relevant AESTL/D&C
Engineering TL in order to assess the feasibility of the engineering requirements and any conflicts
with existing Engineering Technical Practices, or other engineering documentation.
Once the process of task verification has been completed, the compliance tasks are then returned
to the AzSPU HSE Compliance Team for final validation prior to compliance task upload and
activation in CTM. The HSE Compliance Team is responsible for communicating legally
required training identified in the CTM compliance tasks to the HSE & Engineering Org
Capability Team Leader for incorporation into facility training matrices.
It should be noted that it is the responsibility of the Task Supervisor to ensure proper
communication of CTM compliance tasks to Task Owners, that required technical and legally
required training has been carried out, and that Task Owners are competent to complete their
tasks. Offshore / Sangachal / Exports Compliance Advisor will monitor the CTM User Training
status of their facilities to ensure that all CTM Task Owners and Supervisors have received
appropriate system training.
5.5
Closing Compliance Tasks
Individuals with responsibilities and accountabilities associated with CTM tracked tasks (Task
Owners and Task Supervisors) receive automatic e-mail notification of deadlines for task
completion.
On completion of the tasks assigned to them, individuals register their tasks as complete directly
within the CTM system and identify the documents / records that demonstrate compliance.
If a CTM compliance task is not completed by the Task Owner, by the set deadline, the CTM
system automatically notifies the Task Supervisor who is responsible for launching the process of
corrective action. It is the responsibility of the Offshore / Sangachal / Exports Compliance
Advisor to monitor this process and ensure that task deadlines are not routinely missed.
It should be noted that CTM compliance tasks can be completed but still in non-compliance, for
example the required monitoring could be conducted, but the results found to be non-compliant
with legislation and regulations. In instances such as these, the non-compliant monitoring results
will be entered into Tr@ction for action tracking and closure by the Task Owner - see AzSPU
HSSE Non-compliances / Non-conformances Corrective and Preventative Action Procedure
(AzSPU-HSSE-DOC-00040-2).
Analysis of Tr@ction data will be carried out by the Offshore / Sangachal / Exports Compliance
Advisors in order to identify recurring non-compliance issues and their route causes (which are
treated with a higher level of priority and attention).
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 11 of 21
5.6
Change Management
5.6.1 New or amended legislative requirements
Update of HSE Legal Registers
Azerbaijani National HSE Legislation
Due to the dynamic nature of the legislative environment in Azerbaijan, there is no single reliable
source for obtaining information. To manage this AzSPU utilises a number of information
sources to ensure that the Register of Azerbaijani HSE National Legislation is as complete as
possible.
New or amended national legislative requirements are identified by the AzSPU HSE Compliance
Team, in consultation with the AzSPU Legal Team. The following sources for tracking and
monitoring national legislation are utilized:
Review of existing legislative registers in various departments of the AzSPU, including
the AzSPU Legal Team.
Interaction with regulatory agencies including the Ministry of Ecology and Natural
Resources (MENR), the Ministry of Emergency Situations (MES), the Ministry of Health
(MoH) and the State Statistical Committee to source regulatory information (GOSTs,
SNIPs, Rules, etc).
Monitoring of internet information sources, including web-sites of the President of the
Azerbaijan Republic and Milli Majlis (Parliament of Azerbaijan).
„Vnesh Expert Service (VES)‟ legislative database, which is provided and maintained by
an external provider. The AzSPU HSE Compliance Team reviews the database on a
weekly basis and also receive weekly information update e-mails from VES.
In all cases where new or amended requirements are identified, the applicability to AzSPU
operations in Azerbaijan is determined by the relevant Functional Authority / Specialist based on
information provided in the APS lists (AzSPU-HSSE-DOC-00263-2). Consultation with APS
List SMEs, Operations / Maintenance / Wells Managers, and the AzSPU Legal Team is carried
out where further clarification is required. The AzSPU Register of Azerbaijani HSE National
Legislation is then updated by the AzSPU HSE Compliance Team and uploaded to dK.
Hard copies of national HSE legislative documents, in the Azerbaijani language, are stored in the
AzSPU HSE Compliance Team Library. If a legislative document is determined as applicable to
AzSPU operations it is translated into English by the AzSPU Translation Team. The AzSPU HSE
Compliance Team then review the translated document, upload the English electronic version to
dK and provide a link to the document through the AzSPU Register of Azerbaijani HSE National
Legislation (AzSPU-HSSE-DOC-00038-A2).
Georgian National HSE Legislation
Within Georgia, new or amended national legislative requirements are identified by the Georgia
Legal Team and the Georgia Regulatory Affairs Team through a weekly bulletin entitled “Legal
Messenger‟, which publishes a list of all the normative and legislative Acts (laws, orders and
decrees) and any updates to them.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 12 of 21
In addition to the above, future legislative requirements are identified by the Georgia Legal Team
through the following sources:
The „International Association of Business and Parliament‟ - informs the Legal Team of
any laws at draft stage in Parliament.
The Ministry of Justice - informs the Legal Team of any decrees / orders at draft stage
(body is responsible for approval of all legal sub-normative acts submitted by other
ministries for approval).
The Georgia Legal Team is permitted to review the documents (laws, decrees and orders) while
they are at draft stage and provide input to the relevant body regarding conflicts with other
legislation, etc. Once approved, the Acts are announced in the „Legal Messenger‟.
The Georgia Legal Team communicates any new / amended Acts to the AzSPU HSE Compliance
Team so that they can facilitate the process of applicability review.
In all cases where new or amended requirements are identified, the applicability to AzSPU
operations in Azerbaijan is determined by the relevant Functional Authority / Specialist based on
information provided in the APS lists (AzSPU-HSSE-DOC-00263-2). Consultation with APS
List SMEs, Operations
/ Maintenance
/ Wells Managers, and the Georgia Legal Team /
Regulatory Affairs Team is carried out where further clarification is required. The AzSPU
Register of Georgian HSE National Legislation is then updated by the AzSPU HSE Compliance
Team and uploaded to dK.
Copies of Georgian legislative documents (in the Georgian language) are stored in a centralized
system entitled
„Codex‟, which is updated on a weekly basis. The process for translating
applicable Georgian legislative documents (or extracted tasks) into English is currently under
review, this section will be updated as soon as this process is finalised.
International / EU Countries HSE Legislation
Certain project-specific agreements state that operations will meet referenced international
requirements, or requirements from a certain country or region, outside the country of operation.
New or amended international legislative requirements are identified by the AzSPU HSE
Compliance Team, in consultation with the AzSPU Legal Team and the Georgia Legal Team.
The following sources for tracking and monitoring international legislation are utilized:
Internet searches of relevant websites, e.g. International Maritime Organisation (IMO),
etc.
International consultants called upon to review international legislation for specific
subject areas (as required).
In all cases where new or amended requirements are identified, the applicability to AzSPU
operations is determined by the relevant Functional Authority / Specialist based on information
provided in the APS lists. Consultation with APS List SMEs, Operations / Maintenance / Wells
Managers, and the AzSPU Legal Team is carried out where further clarification is required.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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version of this document can be found at http://docs.bpweb.bp.com/dkazspu
AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 13 of 21
The AzSPU Register of International Guidelines and Regulations for Azerbaijan (AzSPU-HSSE-
DOC-00038-A4) and the AzSPU Register of International HSE Guidelines and Regulations for
Georgia (AzSPU-HSSE-DOC-00038-A8) are then updated accordingly by the AzSPU HSE
Compliance Team and uploaded to dK.
Electronic copies of international legislation are generally available in English. If an international
legislative document is determined applicable to AzSPU operations it is uploaded to dK and a
link provided to the document through the relevant register.
Update of CTM
Where new or amended national or international legislative requirements are determined as
applicable to AzSPU operations, compliance task development / verification / activation takes
place (as outlined in Section 5.4). It should be noted that in addition to the development of new
compliance tasks, removal or editing of existing compliance tasks may be required.
The process associated with the identification of new or amended legislative requirements and the
subsequent management of change is summarized in Figure 1.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 14 of 21
Figure 1: Tracking New / Amended Legislative Requirements
Azerbaijan: New or amended
Georgia: New or amended
legal requirements identified by
legislation identified by
AzSPU HSE Compliance
Georgia Legal Team and
Team, in consultation with
Regulatory Affairs Team
AzSPU Legal Team
Relevant Functional Authority / Specialist determines
applicability of new or amended legal requirements, based on
relevant APS Lists. Consultation with APS List SMEs, Ops /
Maintenance / Wells Managers, AzSPU Legal Team, Georgia
Legal / Regulatory Affairs Team, where required.
Update discontinued, rationale
Are new or
No
recorded in relevant HSSE Legal
amended
Register by AzSPU HSE
reqs
Compliance Team
applicable?
Yes
Recorded as applicable in relevant
HSSE Legal Register by
AzSPU HSE Compliance Team
Relevant Functional Authority / Specialist interprets new or amended legal
documents, extracts specific requirements and develops CTM compliance tasks,
in consultation with AzSPU Legal Team / Georgia Legal Team, as required.
Compliance task removal, or editing of existing tasks, may be required.
<Process for extracting compliance requirements from Georgian legislative
documents is currently under review>.
Offshore / Sangachal / Exports Compliance Advisor (site
performed tasks), or relevant Functional Authority /
Specialist (town performed tasks), leads compliance task
collaboration with Task
verification (involves close
Owner / Task Supervisor).
(May require improvement of operational controls or
development / update of procedures & technical
practices).
AzSPU HSE Compliance Team validate
new / amended compliance tasks, upload
to CTM and activate.
Requirements
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 15 of 21
5.6.2 Changes to operational activities
Update of HSE Legal Registers
Changes to on-site operational activities are managed through the AzSPU Technical, Chemical,
and Drilling & Completion (D&C) e-MoC processes (see AzSPU Management of Change
Procedure AzSPU-GEN-PRC-001-C7).
If on-site operational changes activate one of these e-MoC process, the MoC Coordinator is
responsible for notifying the relevant Area / D&C H&S Team Leader / ST Compliance &
Environment Team Leader / Georgia Exports Compliance & Environment Team Leader /
Azerbaijan Exports Compliance Lead.
The relevant Area / D&C H&S Team Leader / ST Compliance & Environment Team Leader /
Georgia Exports Compliance & Environment Team Leader / Azerbaijan Exports Compliance
Lead 2 (or delegate) is responsible for completing the first section of the HSE Compliance Form
(which is an attachment in the e-MoC system (MOC-FRM-025)) providing a short summary of
the operational change, and amending and submitting the revised Operating Area / Facility APS
List (if relevant) to the AzSPU HSE Compliance Team.
In the majority of cases, on-site changes to operational activities will be small-scale and will not
affect the Operating Area / Facility APS List information. Where this is the case the Area / D&C
H&S Team Leader / ST Compliance & Environment Team Leader / Georgia Exports Compliance
& Environment Team Leader / Azerbaijan Exports Compliance Lead submits only the HSE
Compliance Form (with the first section completed) to the AzSPU HSE Compliance Team who
review, complete the second section of the form, upload to the e-MoC system and close out.
In instances where on-site changes to operational activities do affect the Operating Area / Facility
APS List, the AzSPU HSE Compliance Team review the updated document and arrange for it to
be uploaded to dK. Applicability screening of national and international legislation in the relevant
HSE Legal Registers is then carried out by the relevant Functional Authority / Specialist, based
on information in the updated APS Lists. The AzSPU HSE Compliance Team facilitates the
process and amends the HSE Legal Register, where appropriate.
Update of CTM Database
Where additional national or international legislative requirements are now applicable (due to
changes in operational activities), the relevant Functional Authority / Specialist interprets the text
to extract applicable compliance requirements and compliance task development / verification /
activation takes place, as outlined in Section 5.4.
The second, third and fourth sections of the HSE Compliance Form are completed and it is
uploaded to the e-MoC system by the AzSPU HSE Compliance Team.
The process associated with changes to operational activities and the subsequent management of
change is summarized in Figure 2.
2 NB: In the e-MoC system this position is referred to as „H&S TL / Env & Compliance TL‟.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 16 of 21
Figure 2: Identifying Legal Requirements Associated with Operational Change
AzSPU e-MoC system - technical,
chemical and D&C MoCs
Relevant Area / D&C H&S Team Leader / ST Compliance & Env Team
Leader / Ge Exports Compliance & Environment Team Leader / Az
completes first section of HSSE Compliance
Exports Compliance Lead
Form providing a short summary of the operational change and submits to
AzSPU HSE Compliance Team
AzSPU HSE Compliance
Changes
No
Team completes second
required to
section of HSSE Compliance
relevant APS
Form reflecting this, uploads to
List?
e-MoC system and closes out.
Yes
Relevant Area / D&C H&S Team Leader / ST Compliance & Env Team Leader / Ge Pipelines
updates and
Compliance & Environment Team Leader / Az Pipelines Environment Team Leader
submits APS List to AzSPU HSE Compliance Team (document issued in dK)
Relevant Functional Authority / Specialist reviews HSSE Legal
Register to determine whether there are any compliance
implications (process facilitated by AzSPU HSE Compliance
Team)
AzSPU HSE Compliance
Are there
No
Team completes second
compliance
section of HSSE Compliance
implications?
Form reflecting this, uploads
Yes
to e-MoC system and closes
out.
Yes
Relevant HSSE Legal Registers
updated by AzSPU HSE Compliance Team
Relevant Functional Authority / Specialist interprets newly applicable
documents, extracts specific requirements and develops CTM compliance
tasks (compliance task removal, or editing of existing tasks, may be
required). Consultation with AzSPU Legal Team, Georgia Legal Team, as
required. <Process for extracting compliance requirements from Georgian
legislative documents is currently under review>. AzSPU HSE Compliance
Team completes second section of HSSE Compliance Form reflecting this.
Offshore / Sangachal / Exports Compliance Advisor (site
performed tasks), or relevant Functional Authority / Specialist
(town performed tasks), leads compliance task verification
collaboration with Task Owner / Task
(involves close
Supervisor). AzSPU HSSE Team completes third section of
HSSE Compliance Form reflecting this.
AzSPU HSE Compliance Team validate
completed compliance tasks, upload to CTM and
activate. AzSPU HSE Compliance Team
completes last section of HSSE Compliance Form
uploads to e-MoC system and closes out.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 17 of 21
5.6.3 Personnel & organisational change
In order to keep the Task Owner and Task Supervisor information up-to-date in the CTM system
it is a requirement of the AzSPU Organisational e-MoC process (AzSPU Management of Change
Procedure AzSPU-GEN-PRC-001-C7) to communicate information on transfer of compliance
task ownership to the AzSPU HSE Compliance Team and to confirm that the replacement
personnel have received appropriate compliance and technical training.
These requirements are included within the Organisational e-MoC - Personnel Changes Checklist
(MOC_FRM_019) and the Organisational e-MoC
- Organisational Changes Checklist
(MOC_FRM_020).
5.6.4 Changes to operational controls
It is the responsibility of Task Owners / Supervisors to notify the AzSPU HSE Compliance Team
of any changes to operational controls associated with activated compliance tasks (e.g. deletion of
an operational control, development of new operational controls relevant to the task).
The AzSPU HSE Compliance Team will then update the relevant CTM tasks accordingly in the
system.
5.7 Performance Management / Compliance Assurance
Monthly Progress Dashboards
The CTM database serves as the foundation for monitoring HSE compliance performance across
the AzSPU.
AzSPU has developed a monitoring process to track the development / verification / activation of
CTM compliance tasks, and the closure of CTM compliance tasks, through the preparation of
progress dashboards. These are maintained by the AzSPU HSE Compliance Team and are issued
to key personnel on a monthly basis. They are also uploaded to dK AzSPU-HSSE-REC-01204-2
and AzSPU-HSSE-REC-01206-2.
The AzSPU HSE Compliance Team also conducts spot-checks to determine the quality of task
closure and provision of evidence records.
Periodic review of the dashboards is carried out by the AzSPU Regulatory Compliance &
Environment Manager to determine progress and drive the process where needed.
Audit
In addition to the above (and until CTM is fully populated), compliance with AzSPU applicable
legal and regulatory HSE requirements is verified on a regular basis through a risk-based
compliance auditing programme in accordance with the AzSPU External Audit and Self
Assurance Program Overview (AzSPU-HSSE-DOC-00035-2) and the AzSPU Integrated Internal
Assurance Plan (AzSPU-HSSE-DOC-00071-2).
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 18 of 21
Monitoring
The AzSPU HSE Monitoring and Measurement Procedure
(AzSPU-HSSE-DOC-00029-2)
outlines the process for conducting monitoring on a regular basis to check that key parameters of
its operations are compliant with applicable legal and regulatory HSE requirements.
Non-compliances
Non-compliances against legal and regulatory HSE requirements are recorded in Tr@ction and
tracked to closure, as specified in the AzSPU HSSE Non-compliances / Non-conformances
Corrective and Preventative Action Procedure (AzSPU-HSSE-DOC-00040-2).
As stated in this procedure, non-compliance issues may be identified and reported by any
employee or contractor working for, or on behalf of, AzSPU. OpenTalk is available for
confidential anonymous reporting of compliance concerns.
Management Review
The AzSPU HSSE Management Review Procedure (AzSPU-HSSE-DOC-00070-2) provides a list
of compliance items / issues that are included within the scope of the AzSPU-wide Annual
Management Review Meeting, with the aim of promoting continual improvement in this area.
Certification
Compliance and Ethics Certification provides a key indicator of the extent to which AzSPU is
complying with applicable laws and regulations and BP‟s Code of Conduct. As part of this
process Line Managers obtain feedback from employees on any HSSE compliance concerns,
which are then reported upwards throughout the performance unit. Certification is conducted on
an annual basis throughout the AzSPU.
6.0 Key Documents/Tools/References
AzSPU HSSE Policy (AzSPU-HSSE-DOC-00001-2)
AzSPU‟s HSE Compliance Risk Matrices (AzSPU-HSSE-DOC-00281-2).
AzSPU HSE Compliance Training & Communication Strategy 2008-2009+ (AzSPU-
HSSE-DOC-00145-2).
AzSPU Activities, Products and Services Lists (AzSPU-HSSE-DOC-00263-2).
AzSPU APS List Template (AzSPU-HSSE-DOC-00038-A9).
Register of HSE Drivers AzSPU-HSSE-DOC-00038-A1.
Register of Azerbaijani HSE National Legislation AzSPU-HSSE-DOC-00038-A2.
Register of Georgian HSE National Legislation AzSPU-HSSE-DOC-00038-A6.
Register of International HSE Guidelines and Regulations for Azerbaijan AzSPU-HSSE-
DOC-00038-A4.
Register of International HSE Guidelines and Regulations for Georgia AzSPU-HSSE-
DOC-00038-A8.
AzSPU Azerbaijan ESIA Permit Register AzSPU-HSSE-DOC-00038-A5.
AzSPU Azerbaijan Other HSE Permit Register AzSPU-HSSE-DOC-00038-A7.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 19 of 21
AzSPU CTM Compliance Task Development Procedure (AzSPU-HSSE-DOC-00114-2).
AzSPU CTM Compliance Task Verification Procedure (AzSPU-HSSE-DOC-00094-2).
AzSPU HSSE Non-compliances / Non-conformances Corrective and Preventative Action
Procedure (AzSPU-HSSE-DOC-00040-2).
AzSPU CTM Compliance Task Development / Verification / Activation Dashboards
(AzSPU-HSSE-REC-01204-2).
AzSPU CTM Compliance Task Completion Dashboards (AzSPU-HSSE-DOC-01206-2).
AzSPU External Audit and Self Assurance Program Overview (AzSPU-HSSE-DOC-
00035-2).
AzSPU Integrated Internal Assurance Plan (AzSPU-HSSE-DOC-00071-2).
AzSPU HSE Monitoring and Measurement Procedure (AzSPU-HSSE-DOC-00029-2).
AzSPU HSSE Management Review Procedure (AzSPU-HSSE-DOC-00070-2).
Compliance Task Manager (CTM)
OpenTalk
e-MoC System
AzSPU Management of Change Procedure (AzSPU-GEN-PRC-001-C7).
Organisational e-MoC - Personnel Changes Checklist (MOC_FRM_019).
Organisational e-MoC - Organisational Changes Checklist (MOC_FRM_020).
e-MoC HSE Compliance Form (MOC-FRM-025).
Review / Revision Log
Revision Date
Authority
Custodian
Revision Details
07/2000
G. Vidrine
M. Tavartikiladze
New procedure
F. Askerov
08/2000
G. Vidrine
G. Stacey
Consistency with BP EMS Guidelines
R. Gallagher
04/2004
L. Emmons
S. Sultanova
Consistency with EMS requirements
December 25, 2005
Gunther Newcombe
Yuliy Zaytsev
Updated to incorporate BP GC&E HSSE
Compliance Management Framework,
AzSPU Env & Social Compliance matrix
requirements.
December 4, 2006
Gunther Newcombe
Yuliy Zaytsev
Roles and responsibilities of the AzSPU
HSSE MS & Compliance Manager, HSSE
MS and Compliance Team, and Technical
Authorities redefined.
Information on CTM database added.
Information on Register of Azerbaijani
National Legislation, Register of
International Drivers and Register of
Georgian National Legislation added
throughout document.
December 14,
AzSPU HSSE MS
AzSPU HSSE
Full review of document carried out.
2007
& Compliance
MS Senior
Purpose / scope revised to include more
Manager (Yuliy
Advisor
information on HSSE requirements
Zaytsev)
(Rebecca Heath)
applicable to AzSPU operations.
Responsibilities updated to reflect AzSPU
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 20 of 21
organizational changes and position titles
amended throughout.
Reference to the AzSPU (Azerbaijan)
ESIA Permit Register added.
Figures 1 and 2 updated to reflect
organizational changes and streamline
process.
August 06, 2008
AzSPU HSSE MS
AzSPU HSSE
Procedure expanded to include process
& Compliance
MS Senior
whereby current Azerbaijani and
Manager (Yuliy
Advisor
International HSSE legal requirements are
Zaytsev)
(Rebecca Heath)
located and accessed.
Procedure amended to include a MoC
process that describes how new or
amended legislative requirements, and
operational changes, are incorporated into
the HSSE Legal Registers and the CTM
database.
These changes have been made in response
to requirements in the BP Global HSSE
Compliance Framework, and in response
to an August 2007 S&OI audit finding.
Detailed description of Compliance Task
Manager (CTM) database, and its use in
the AzSPU, transferred to the AzSPU
HSSE Compliance Framework
Implementation Procedure (AzSPU-
HSSE-DOC-00141-2).
August 14, 2008
AzSPU HSSE MS
AzSPU HSSE
Procedure revised to take into account:
& Compliance
MS Senior
Update of “town performed” CTM
Manager (Yuliy
Advisor
compliance tasks.
Zaytsev)
(Rebecca Heath)
The development / update of procedures
if operational controls are considered
inadequate.
Consultation with engineering
representatives for all engineering
related compliance tasks.
December 1, 2008
AzSPU Safety &
AzSPU HSSE
Procedure expanded to include process
Compliance
MS Senior
whereby current Georgian HSSE legal
Systems Manager
Advisor
requirements are located and accessed.
(Yuliy Zaytsev)
(Rebecca Heath)
In addition, MoC process amended to
describe how new legislative requirements,
and operational changes, are incorporated
into the Georgian HSSE Legal Register.
September 3, 2009
AzSPU Safety &
AzSPU HSSE
Procedure updated to include linkage to
Compliance
MS Senior
AzSPU e-MoC system for changes to on-
Systems Manager
Advisor
site operational activities affecting
(Yuliy Zaytsev)
(Rebecca Heath)
compliance requirements.
09 December 2009
AzSPU Safety &
AzSPU HSSE
The Next Revision date has been changed
Compliance
MS Senior
to 20 June 2010 in accordance with the
Systems Manager
Advisor
Custodian request
(Yuliy Zaytsev)
(Rebecca Heath)
30 July, 2010
Faig Askerov
AzSPU HSSE
Document scope extended to include
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Legal & Regulatory Requirements Procedure
Page 21 of 21
(AzSPU Regulatory
MS Senior
requirements contained within the AzSPU
Compliance &
Advisor
HSE Compliance Framework Procedure
Environment
(Rebecca Heath)
(AzSPU-HSSE-DOC-00141-2) and the
Manager)
AzSPU HSE Compliance Assurance
Process (AzSPU-HSSE-DOC-00039-2).
These documents are now obsolete.
Procedure revised throughout to align with
the requirements of GRP 7.1-0001 Legal &
Regulatory HSSE Compliance.
Control tier: 2-AzSPU
Revision Date: 30 July, 2010
Document Number: AzSPU-HSSE-DOC-00038-2
Print Date: 2/1/2011
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AzSPU HSSE Calibration Procedure
Page 1 of 3
CALIBRATION PROCEDURE
AZSPU-HSSE-DOC-00031-2
Authority:
AzSPU Safety
&
Custodian:
AzSPU HSSE MS Team
Compliance
Systems
Leader Idrak Nazarov
Manager Yuliy Zaytsev
Scope:
AzSPU Operational PUs
Document
AzBU HSSE MS Document
Administrator:
Coordinator
Issue Date:
December 27, 2005
Issuing Dept:
HSSE
Revision Date:
May 1, 2010
Control Tier:
2- AzSPU
Next Review Date:
May 1, 2011
Control Tier:
2-AzSPU
Revision Date: May 1, 2010
Document Number: AzSPU-HSSE-DOC-00031-2
Print Date: 2/1/2011
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AzSPU HSSE Calibration Procedure
Page 2 of 3
1.0 Purpose/Scope
The purpose of this document is to outline procedures for the calibration of test and field
equipment in order to maintain an appropriate level of precision and accuracy.
This controlled procedure encompasses all activities, products or services of AzSPU Operational
PUs engaged in the drilling, production and/or transportation of oil and gas that; a) have the
potential to influence the Operations environmental aspects and potential impact on the
environment, b) have the potential to affect operations environmental objectives and targets or c)
may affect environmental regulatory compliance and performance. This also applies to AzSPU
OPS PUs main contractors engaged in the drilling, production and transportation of Oil and Gas.
This is a high level document that provides guidance to operational personnel in the
implementation of their site specific procedures in order to ensure consistency, where applicable,
across AzSPU operations.
Revision of this procedure and the operational controls detailed therein will be in accordance with
the AzSPU HSSE Document Management Procedure (AzSPU-HSSE-DOC-00025-2).
2.0 Definitions
Calibration: As used in this procedure, the term "calibration" refers to the process of
verification and/or adjustment of a measurement station by comparing the performance of its
components with that of certified test equipment.
Test Equipment - Critical equipment used to calibrate field equipment. Equipment used as the
standard to which field equipment is measured or calibrated against.
Field Equipment - Equipment used in the field or at facilities to monitor and/or measure the key
characteristics of operations and activities that have a significant impact on the environment.
Definitions common to the management system are outlined in the Definitions document AzSPU-
HSSE-DOC-00021-2.
3.0 Specific Requirements
OMS Sub-element 8.1 - Metrics & Reporting
ISO 14001:2004 - 4.5.1 Monitoring and Measurement
4.0 Key Responsibilities
Field Equipment Owner/Manager - Responsible for confirming that field equipment is
calibrated at required intervals and documented in a maintenance-tracking system (and/or with
calibration stickers.
Control Tier:
2-AzSPU
Revision Date: May 1, 2010
Document Number: AzSPU-HSSE-DOC-00031-2
Print Date: 2/1/2011
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AzSPU HSSE Calibration Procedure
Page 3 of 3
5.0 Procedure
Test equipment is calibrated to ensure that calibrations are traceable to appropriate standards. The
calibration results are appropriately documented.
Field equipment is calibrated against test equipment standards at a frequency no less than as
recommended by the equipment manufacturer, or as determined by the process and/or equipment
history
(any departure from the manufacturer’s recommendations should be justified). Field
equipment calibration is documented by inclusion in the maintenance-tracking system, and/or
through the use of calibration stickers. When calibration stickers are used, outdated calibration
stickers are removed from the equipment, covered with an updated calibration marking, or
otherwise rendered indistinguishable. It is the responsibility of the Field Equipment Owner /
Manager to confirm that field equipment is calibrated at required intervals and that this is
documented in the maintenance-tracking system and / or recorded using calibration stickers.
Equipment that is found to be out of calibration, out of calibration date, or not able to meet
calibration standards, is tagged “out of service” and is not used until repairs or calibration is
affected. Personnel shall not use equipment that yields data of questionable accuracy.
6.0 Key Documents/Tools/References
AzSPU HSSE Document Management Procedure (AzSPU-HSSE-DOC-00025-2)
AzSPU Record Control Procedure (AzSPU-HSSE-DOC-00041-2)
Revision Log
Revision Date
Approver
Originator
Revision Details
December 19, 2006
Gunther Newcombe
Yuliy Zaytsev
Revised issue
January 17, 2008
Yuliy Zaytsev
Farid Jafarov
Language edit and update in line with
revision log
March 16, 2009
Yuliy Zaytsev
Idrak Nazarov
Position Titles were amended and
updated in line with revision log
May 1, 2010
Yuliy Zaytsev
Idrak Nazarov
Annual review.
Control Tier:
2-AzSPU
Revision Date: May 1, 2010
Document Number: AzSPU-HSSE-DOC-00031-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 1 of 6
Operational Control Procedure
AZSPU-HSSE-DOC-00028-2
Authority:
AzSPU Safety
&
Custodian:
AzSPU HSE MS Team
Compliance
Systems
Leader (Idrak Nazarov)
Manager
(Yuliy
Zaytsev)
Scope:
AzSPU Operational PUs
Document
AzSPU
HSSE
MS
Administrator:
Document Co-coordinator
(Nargiz Abiyeva)
Issue Date:
December 27, 2005
Issuing Dept:
AzSPU HSSE
Revision Date:
May 19, 2009
Control Tier:
2- AzSPU
Next Review Date:
May 19, 2010
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 2 of 6
1.0 Purpose/Scope
The purpose of this document is to define the procedure for establishing and implementing
operational controls within AzSPU operations. Operational controls are developed and
implemented to comply with legal and other requirements
(5.1) and to control significant
environmental and social aspects as well as H&S Risks of operations (5.2) in accordance with
HSSE policy, objectives and targets.
This controlled procedure applies to AzSPU Operations PUs engaged in the drilling, production,
and/or transportation of oil and gas. This is a high level document that provides guidance to
operational personnel in the implementation of their site specific procedures in order to ensure
consistency, where applicable, across AzSPU operations.
Revision of this procedure and the operational controls detailed therein will be in accordance with
the Document Management Procedure AzSPU-HSSE-DOC-00025-2.
2.0 Definitions
Operational Control
- An implementing procedure, physical control, checklist, training,
employee expertise, or other means of controlling operations to manage significant environmental
aspects, H&S Risks and/or HSE requirements. Examples of physical controls can include valves,
automatic shutoff devices, engineered solutions, signage, etc. Operational controls, in the form of
procedures, stipulate operating criteria. Documented procedures are maintained as controlled
documents.
Refer to Document AzSPU-HSSE-DOC-00021-2 HSSE Definitions for definitions common to
this HSSE&S Management System.
3.0 Specific Requirements
Only requirements specific to this procedure are listed here. For requirements applicable to all
procedures refer to the AzSPU HSSE&S General requirements procedure AZSPU-HSSE-DOC-
00037-2.
ISO 14001 - 4.4.6 Operational Control
OSHAS 18001- 4.4.6 Operational Control
GHSER- Element 4: Working with contractor and other
Element 6: Operations and Maintenance
Element 7: Management of Change
BP Global HSSE Compliance Framework- Step 3, Items 3.4, 3.9, 3.10
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 3 of 6
4.0 Key Responsibilities
AzSPU Vice Presidents/Performance Unit Leaders
Provide resources and leadership for the development, implementation, maintenance, and
improvement of operational controls.
Periodically conduct formal Management Reviews as outlined in the Management
Review procedure AZSPU-HSSE-DOC-00070-2, to confirm suitability, adequacy, and
effectiveness of operational controls and to make recommendations for their
improvement.
AzSPU Safety and Compliance Systems Manager
Ensuring that relevant personnel are aware of relevant legal and other compliance
requirements.
Overseeing the development and management of the integrated AzSPU wide compliance
database (Compliance Task Manager) to incorporate operational controls where this is a
compliance requirement.
PU/Asset Operations Managers and Maintenance Managers
Working with the PU/Asset MS Team or HSE Advisor to assign responsible/accountable
positions for the implementation of operational controls.
Provide day-to-day support to help ensure that operational controls comply with
requirements.
Ensure that corrective and preventive actions are implemented.
PU/Asset MS Team and/or H&S / Environmental Advisor
Identify, approve and oversee the implementation of operational controls in compliance
with this procedure and PU/Asset level procedures.
Advise on the maintenance of effective operational controls for all relevant facilities.
Communicate responsibilities and expectations to operations personnel in order to
maintain effective operational controls.
Monitor the implementation of site specific operational controls, including required
preventative and corrective actions, and provide this information for incorporation into
the HSSE Compliance Task (CTM) Manager.
Site Personnel
To be aware of relevant procedures and competent to perform activities in accordance
with the operational controls defined in this procedure and the related PU/Asset level
procedures.
To have an understanding of the potential consequences of departure from operational
controls, including liability for non-compliance with HSSE & S requirements.
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 4 of 6
5.0 Procedure
5.1 Compliance with Legal and Other Requirements
The PU/Asset MS Team and/or H&S/Environmental Advisor, with assistance from operations
personnel, oversees the development, documentation, and maintenance of applicable operational
controls at PU/Asset level in accordance with the AzSPU HSSE Compliance Assurance Process
AZSPU-HSSE-DOC-00039-2 and the specific requirements detailed in the AzSPU HSSE
Compliance Task Manager (CTM).
It is anticipated that over time all HSSE&S Legal and Other Requirements, will be incorporated
into CTM and CTM will be used to track the implementation of operational controls against
HSSE&S requirements at all levels within AzSPU.
CTM is described in more detail in the AzSPU HSSE Compliance Framework Implementation
Procedure AZSPU-HSSE-DOC-000141-2.
5.2 Control of Significant Environmental & Social Aspects and Health & Safety
Risks
Operational aspects/activities associated with significant environmental and social impacts are
identified in accordance with the AzSPU Aspect Identification and Significance Screening
Procedure AzSPU-HSSE-DOC-00027-2. Operational activities associated with health and safety
risks to employees are identified and addressed in with the AzSPU Permit to Work Procedure
AzSPU-HSSE-DOC-00060-2, the Procedure for Task Risk Assessment AzSPU-HSSE-DOC-
00063-2 and the Occupational Health Hazard Assessment and Control Program AzSPU-HSSE-
DOC-00124-2. Operational controls are developed and implemented for significant
environmental and social aspects and potential H&S risks where their absence would otherwise
lead to deviations from the HSSE Policy, objectives and targets. Operational controls have been
developed at the AzSPU level, eg. Safe System of Work
(SSoW), Health Management
Programmes, MoC processes. In addition site specific operational controls are described in the
relevant PU/Asset level procedures.
The procedures are written in sufficient detail that they should be able to be applied consistently
at all sites. However, there may still be the requirement for certain local rules covering site-
specific logistical / administrative arrangements and local variations in responsibilities to reflect
differences in organisational arrangements. Any form of deviation from an SSoW procedure,
including but not limited to local rules, shall be requested and authorised in accordance with the
SSoW Procedure for Deviations AzSPU-HSSE-DOC-00011-2.
AzSPU SSoW procedures covering the operational controls are described in AsSPU HSSE&S
Integrated Management System and Compliance Manual AzSU-HSSE-DOC-00091-2.
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 5 of 6
5.3 Management of Change (MOC)
MOC processes are implemented at all levels within AzSPU to evaluate and fully communicate
the HSE and social risks associated with significant changes to facilities and operational
activities, and to ensure that appropriate control measures are instituted. The management of
organizational, technical and process related changes is addressed in the AzSPU Management of
Change procedure (Document AZSPU-HSSE-DOC-00073-U).
Avoidance and/or mitigation of the HSE and social risks associated with changes in operational
activities is achieved using standardised processes, as appropriate to the scale and nature of the
planned changed, and may include; MoC checklists, task hazard assessment, work permitting
procedures and the project notice to proceed. Resulting modifications to operational controls are
communicated to relevant personnel in accordance with the Communications Procedure AZSPU-
HSSE-DOC-00018-2.
5.4 Training
The HSE Training Process, which is described in the AZSPU-HSSE-DOC-00030-2 HSSE&S
Training, Awareness and Competence Procedure, helps develop competency of relevant
personnel on performing activities in conformance with the HSSE operational controls. This
process addresses potential consequences for departure from operating procedures, including
liability for non-compliance with HSSE requirements.
6.0 Key Documents/Tools/References
Legal and Other Requirements Procedure Document AZSPU-HSSE-DOC-00038-2
Management Review Procedure Document AZSPU-HSSE-DOC-00070-2
Communications Procédure Document AZSPU-HSSE-DOC-00018-2
Aspect Identification and Significance Screening Procedure Document AzSPU-HSSE-
DOC-00027-2
AzSPU Permit to Work Procedure AzSPU-HSSE-DOC-00060-2
Procedure for Task Risk Assessment AzSPU-HSSE-DOC-00063-2
Occupational Health Hazard Assessment and Control Program AzSPU-HSSE-DOC-
00124-2
AzSPU Management of Change procedure AZSPU-HSSE-DOC-00073-U
HSSE&S Training, Awareness and Competence Procedure AZSPU-HSSE-DOC-00030-2
AzSPU HSSE Compliance Framework Implementation Procedure AZSPU-HSSE-DOC-
000141-2
AzSPU HSSE&S General Requirements Procedure AzSPU-HSSE-DOC-00037-2
Procedure for Deviations AzSPU-HSSE-DOC-00011-2
AsSPU HSSE&S Integrated Management System and Compliance Manual AzSU-HSSE-
DOC-00091-2
Asset-Specific Aspect and Impact Registers
Compliance Task Manager (CTM)
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Operational Control Procedure
Page 6 of 6
Revision Log
Revision Date
Authority
Custodian
Revision Details
December 27, 2005
Gunther Newcombe
Yuliy Zaytsev
Initial version
January 17, 2007
Yuliy Zaytsev
Rebecca Heath
Language edits and updates to address
operations. Information on
Operational Control definition added,
Reference to SSoW procedures
added. Information about Training
added.
May 12, 2008
Yuliy Zaytsev
Farid Jafarov
H&S aspects and reference to control
of H&S risks are incorporated.
Section 4.0 Key Responsibilities;
Position titles updated.
Information on CTM updated and
reference to AzSPU HSSE
Compliance Framework
Implementation Procedure added.
Reference to AzSPU Permit to Work
Procedure, Procedure for Task Risk
Assessment, Occupational Health
Hazard Assessment and Control
Program and AzSPU management of
Organizational changes procedure
added.
May, 19, 2009
Yuliy Zaytsev
Idrak Nazarov
Annual Review. (para: 4) Key Roles
(Safety & Compliance
(HSE MS Team
& Responsibilities were updated.
Systems Manager)
Leader)
(para: 5.2 & 6) The reference number
of Occupational Health Hazard
Assessment and Control Program
AzSPU-HSSE-DOC-00124-2 was
amended.
(para 5.3 & 6)The reference to
Organizational Management of
Change (AZSPU-HSSE-DOC-00029-
U) procedure was deleted, reference
was given to new AzSPU
Management of Change procedure
(AZSPU-HSSE-DOC-00073-U).
(para: 5.4 & 6) Reference to HSSE&S
Training, Awareness and Competence
Procedure was added.
Control Tier:
2-AzSPU
Revision Date: May 19, 2009
Document Number: AzSPU-HSSE-DOC-00028-2
Print Date: 2/1/2011
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AzSPU HSSE Policy
Page 1 of 2
AzSPU Health, Safety, Security and
Environmental (HSSE) Policy
AZSPU-HSSE-DOC-00001-2
Authority:
AzSPU Leader
Custodian:
AzSPU Safety & Compliance Systems Manager
Scope:
AzSPU
Document
AzSPU HSSE MS Document Coordinator
Administrator:
Issue Date:
Issuing Dept:
AzSPU HSSE
Revision Date:
6 January 2010
Control Tier:
2- AzSPU
Next Review
6 January 2011
Date:
Control Tier: 2-AzSPU
Revision Date: Jan 06, 2010
Document Number: AzSPU-HSSE-DOC-00001-2
Print Date: 2/1/2011
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AzSPU HSSE Policy
Page 2 of 2
AzSPU HSSE Policy - English
AzSPU HSSE Policy - Russian
AzSPU HSSE Policy - Azerbaijani
AzSPU HSSE Policy - Turkish
AzSPU HSSE Policy - Georgia
Revision/Review Log
Revision Date
Authority
Custodian
Revision Details
6 January 2010
AzSPU Leader -
AzSPU Safety &
Small amendments to the text, in order to
Rashid Javanshir
Compliance
align the Policy with the requirements of
Systems Manager
OMS.
- Yuliy Zaytsev
Control Tier: 2-AzSPU
Revision Date: Jan 06, 2010
Document Number: AzSPU-HSSE-DOC-00001-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 1 of 6
AzSPU HSSE&S Management System
Management Review Procedure
AzSPU-HSSE-DOC-00070-2
Authority:
AzSPU Safety &
Custodian:
AzSPU HSSE MS Senior
Compliance Systems
Advisor (Rebecca Heath)
Manager (Yuliy
Zaytsev)
Scope:
AzSPU Operational PUs
Document
AzSPU
HSSE
MS
Administrator:
Document Co-ordinator
Issue Date:
January 6, 2006
Issuing Dept:
AzSPU HSSE
Revision Date:
April 30, 2010
Control Tier:
2- AzSPU
Next Review Date:
December 31, 2010
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 2 of 6
1.0 Purpose
The purpose of this document is to describe the management review process established by BP to
ensure that AzSPU Operational Performance Units (PUs):
Review their Health, Safety, Security Environmental and Social Management System
(HSSE&S MS) on a regular basis to assess the continuing suitability, adequacy and
effectiveness of the system.
Address possible need for changes in policy, objectives and targets, and other elements of the
HSSE&S MS in order to achieve continual improvement.
This controlled procedure applies to AzSPU Operational PUs engaged in the drilling, production,
and/or transportation of oil and gas.
Revision of this procedure and the operational controls detailed therein will be in accordance with
the AzSPU HSSE&S MS Document Management Procedure (AzSPU-HSSE-DOC-00025-2).
2.0 Definitions
Refer to AzSPU HSSE&S MS Definitions
(AzSPU-HSSE-DOC-00021-2) for definitions
common to the HSSE&S MS.
3.0 Specific Requirements
Only requirements specific to this procedure are listed here. For requirements applicable to all
procedures refer to the AzSPU HSSE&S MS General Requirements Procedure (AzSPU-HSSE-
DOC-00037-2).
OMS Sub-element 8.3 - Performance Review.
ISO 14001 - 4.6 Management Review.
OHSAS 18001 - 4.6 Management Review.
4.0 Key Responsibilities
AzSPU HSE&TD Vice President - Accountable for closing out HSSE&S actions arising from
the AzSPU-wide Management Review Meeting.
Management Representatives (Vice Presidents / Performance Unit Leaders) - Responsible for
attending the AzSPU-wide Management Review Meeting and reporting to Top Management on
the performance of the HSSE&S MS, along with any recommendations for improvement.
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 3 of 6
AzSPU Safety and Compliance Systems Manager
Responsible for:
Formally recording all decisions made in the AzSPU-wide Management Review
Meeting, for inputting actions arising into the Tr@ction database, and for updating the
Action Checklist in line with Tr@ction closure information.
Reviewing and updating the HSSE&S MS, where appropriate, based on decisions made
as a result of the management review process.
Organising HSE Work Team Meetings and Face-to-Face Safety & Compliance Meetings
with PU / Asset representatives.
Performance Unit Leaders - responsible for organising PU / Asset Performance Review
Meetings.
5.0 Procedure
An AzSPU-wide Management Review Meeting is held on an annual basis and attended by
representatives from the PUs / Assets listed in the AzSPU Integrated HSSE&S Management
System Scope
(AzSPU-HSSE-DOC-00023-2). Attendance at this meeting is to include
Management Representatives or delegates, Asset / Operations Managers, other facility and site
management as appropriate, and AzSPU/PU/Asset HSSE&S staff. Representatives from AzSPU
Engineering, Learning and Development, and Emergency Response Team may also be invited, if
appropriate.
The following items are included within the scope of the AzSPU Management Review Meeting,
in order to assess the suitability, adequacy, and effectiveness of the HSSE&S MS:
Review of HSSE Policy.
HSSE&S elements of the Performance Contract.
Status of significant HSSE&S risks, and the corrective actions and resources necessary to
reduce the risks.
High potential environmental / social incident findings.
HSSE&S Objectives, Targets and Management Programs - particularly status of action
completion and engineering modifications listed in the HSSE&S Management Programs.
Summary results of environmental monitoring.
Resource allocation and training.
Key contractor HSSE performance.
Key HSSE&S MS audit findings.
External communication of HSSE&S MS issues.
HSSE&S compliance status - review of HSE compliance risk matrices (Azerbaijan and
Georgia), progress against compliance KPIs, and any significant recurring non-
compliance issues.
Assessment of performance against the AzSPU HSSE Compliance Plan. Input of
direction and advice regarding the following year’s AzSPU HSSE Compliance Plan.
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 4 of 6
CTM task completion.
Understanding of the current compliance landscape and status of “compliance culture”
development in the organisation.
Overall adequacy of compliance program against current needs and future requirements.
The AzSPU-wide Management Review Meeting discussions are carried out taking the items
listed above into consideration. Where an item is not considered applicable, this will be stated,
along with a justification for this decision in the meeting minutes.
All decisions made are formally recorded by the AzSPU Safety & Compliance Systems Manager
or delegate (in the form of meeting minutes and an Action Checklist) and provided to the AzSPU
HSE&TD Vice President, and the personnel responsible for action closure, for review and
approval / acceptance. Documented decisions will be used to upgrade the HSSE&S MS as part of
continual improvement.
In addition to the AzSPU-wide Management Review Meeting, specific issues associated with the
HSSE&S MS and compliance are discussed at the following meetings:
HSE Work Team Meetings - held on a quarterly basis, as described in the AzSPU
HSSE&S MS Work Team Terms of Reference (AzSPU-HSSE-DOC-00032-2).
Face-to-face Safety & Compliance Meetings
- held periodically and attended by
representatives from the Safety & Compliance Systems Team and PU / Asset HSSE&S
representatives.
PU / Asset Performance Review Meetings - held periodically according to operational
needs. The format of these meetings is decided at PU / Asset level and meeting minutes
(or agreed actions) documented.
HSSE&S management issues will also be covered during monthly AzSPU and PU/Asset
HSSE&S meetings. When appropriate, specific HSSE&S issues may also be raised by
Management Representatives at the monthly Azerbaijan Leadership Team (ALT) meetings.
6.0 Key Documents/Tools/References
AzSPU Integrated HSSE&S Management System Scope (AzSPU-HSSE-DOC-00023-2).
AzSPU HSSE&S MS Work Team Terms of Reference (AzSPU-HSSE-DOC-00032-2).
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 5 of 6
Revision Log
Revision Date
Authority
Custodian
Revision Details
January 6, 2006
Gunther Newcombe
Yuliy Zaytsev
Initial version.
December 4, 2006
Gunther Newcombe
Yuliy Zaytsev
Incorporated comments from
PUs regarding scope of the
Management Review Meetings.
Revised key responsibilities.
July 6, 2007
Gunther Newcombe
Yuliy Zaytsev
Responsibilities of CHSSE MS
& Compliance Manager
expanded to include updating
of the resulting Action
Checklists.
List of items to be discussed at
Management Review Meetings
expanded to include the
requirements of the Global
HSSE Compliance Framework.
Additional guidance provided
regarding structure and
recording of meeting minutes.
Clarification provided
regarding the structure of
quarterly Management Review
Meetings.
Additional guidance provided
regarding representatives that
should be present at
Management Review Meetings.
November 12, 2007
Yuliy Zaytsev
Rebecca Heath
Added significant HSSE&S
risks to the Management
Review Meeting agenda items
in response to August 2007
S&OI audit actions.
Position titles updated in line
May 5, 2008
AzSPU HSSE MS &
AzSPU HSSE MS
with AzSPU organisational
Compliance Manager
Senior Advisor
changes.
(Yuliy Zaytsev)
(Rebecca Heath)
List of items to be discussed at
annual AzSPU-wide
Management Review Meeting
expanded to include further
requirements of the BP Global
HSSE Compliance Framework.
PU / Asset MRM requirements
amended in response to
feedback from PU / Asset
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE&S MS Management Review Procedure
Page 6 of 6
personnel. Requirement for
quarterly MRMs removed.
Meeting format to be decided
at PU / Asset level, to allow
more flexibility.
Position titles updated
April 9, 2009
AzSPU Safety &
AzSPU HSSE MS
throughout.
Compliance Systems
Senior Advisor
Manager (Yuliy
(Rebecca Heath)
Key responsibilities updated.
Zaytsev)
Procedure amended to include
other meetings where HSSE&S
MS and compliance issues are
discussed.
Interim revision.
April 30, 2010
AzSPU Safety &
AzSPU HSSE MS
Compliance Systems
Senior Advisor
Requirement for review of HSE
Manager (Yuliy
(Rebecca Heath)
compliance risk matrices
Zaytsev)
(Azerbaijan and Georgia) at the
annual AzSPU Management
Review Meeting added to
procedure.
Reference to BP Group HSE
Compliance Framework
removed.
Control Tier:
2-AzSPU
Revision Date: April 30, 2010
Document Number: AzSPU-HSSE-DOC-00070-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
Page 1 of 23
HSSE DOCUMENT MANAGEMENT
PROCEDURE
AzSPU-HSSE-DOC-00025-2
The AzSPU Review / Revision Process for HSE Tier 2 Procedures
(AzSPU-HSSE-DOC-00072-2) has been incorporated into this procedure and is now
obsolete.
Authority:
AzSPU Planning,
Custodian:
AzSPU Engineering & HSE
Performance & Learning
Document Management Team
Manager
Leader
Richard Bodley-Scott
Amal Ibadzade
Scope:
AzSPU Functions &
Document
HSE Document Management
Operating Areas
Administrator:
Coordinator
Davud Aliyev
Issue Date:
August 15, 2000
Issuing Dept:
AzSPU HSE & Engineering
Revision Date:
October 15, 2010
Control Tier:
2 AzSPU
Next Review Date:
June 14, 2011
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
Page 2 of 23
1. PURPOSE / SCOPE
The purpose of this procedure is to detail the controls on Health, Safety, Security and Environmental
(HSSE) documentation to ensure the following:
Documents are up-to-date and readily accessible to the workforce to which they apply.
Documents are reviewed and approved prior to initial use.
Approved documents are periodically reviewed, revised as necessary, and approved prior
to re-issue.
Obsolete documents are removed from circulation.
Document owners are notified of upcoming review dates.
Documents are structured, legible, dated (with revision dates), readily identifiable and
maintained in an orderly fashion.
Consistency between related HSSE documents is achieved.
Changes to documentation are communicated to relevant personnel.
This controlled procedure applies to AzSPU Functions and Operating Areas engaged in the drilling,
production, and/or transportation of oil and gas.
This procedure focuses on the use of Dynamic Knowledge (dK) for management of controlled HSSE
documentation, and the use of the OMS Navigator portal for general viewing of HSSE
documentation.
2. DEFINITIONS
Refer to the AzSPU List of HSSE Definitions AzSPU-HSSE-DOC-00021-2. Definitions specific to
this procedure are included below.
Controlled HSSE Document - Controlled electronic document that details critical HSSE tasks and
requires periodic review and/or revision. This includes HSSE manuals, procedures, drawings, or other
documents directly related to HSSE compliance activities including documents that describe the
control of significant environmental and social aspects, hazards or risks. Controlled HSSE documents
do not include records, as these are controlled in accordance with the AzSPU HSSE Records Control
Procedure (AZSPU-HSSE-DOC-00041-2).
Document Control Tier - Controlled HSSE documents are classified in accordance with the Tier at
which the document is applicable. The tiered system for controlled documents is as follows:
-
Tier 1 - Documents applicable at BP Group / Segment level
-
Tier 2 - Documents applicable at AzSPU / Function level
-
Tier 3 - Documents applicable to Operating Areas
-
Tier 4 - Documents applicable to Sectors
-
Tier 5 - Documents applicable to Operating Facilities.
Refer to the AzSPU Management Systems Tier Structure (AzSPU-HSSE-DOC-00313-2) for more
information.
Dynamic Knowledge (dK)
- Web content and document management software specifically
customised for the management of controlled HSSE documentation.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
Page 3 of 23
OMS Navigator - Online tool which provides “one-stop” access to all the information that AzSPU
needs to do its business. It is the portal for the AzSPU population to access all electronic tools and
documentation they require to do their jobs. It is designed to allow AzSPU to easily organize its
documentation into the OMS structure. It should be noted that OMS Navigator is not a document
management system, it is designed to have links embedded from existing document systems (such as
dK). Access to OMS Navigator is via BP Passport machines and via I-Link for third parties such as
contractors.
Permits - Within AzSPU permits consist of project-specific approved documents, permit documents
issued by host governments, project-related agreements, lender required documentation and other
legal requirements (see Appendix 3 for examples of permit documents).
Issue Date - Date that the document was originally issued. Issue date is NOT changed as a result of
revision or review.
Next Review Date - The scheduled date for the next document review (the date should be entered
using the following format: Month, DD, YYYY e.g. July 19, 2010). Review of the document should
occur on or before the Next Review Date, and the review may or may not result in a revision to the
document. Regardless of content revisions, each review or revision is recorded electronically in the
document Revision / Review Log. (NB: If no changes are made to the document but the „next review
date‟ is changed to extend the validity of the document this should be noted in the document Review /
Revision Log). The Document Authority approves the Next Review Date as part of the approval
process.
It should be noted that if small amendments / updates are made to the document (e.g. updates to
position titles, etc) before the Next Review Date these are recorded in the Revision / Review Log. No
change to the Next Review Date on the front cover of the procedure is made unless a full review of
the document has been carried out. For small amendments / updates approval from the Document
Authority is not required.
Revision Date - Date content changes were administered to the document, including changes to the
Revision / Review Log recording the fact that the revision was completed (the date should be entered
using the following format: Month, DD, YYYY e.g. July 19, 2010).
Search Results (Master List) - A list or report that identifies controlled HSSE documents. The list
provides key information associated with the document. The dK interface can be used to produce
dynamically generated master lists.
Standard Document Number - An alpha-numeric number assigned to each document within dK.
The number is established on the basis of functional area (department), document type and sequence
number (see Appendix 1).
Uncontrolled Copy - Copies of all or part of a controlled document taken for information, legal, and
/ or knowledge preservation purposes. It is the responsibility of any person holding an uncontrolled
copy to ensure that the information contained in such a document is still current and valid for
intended use. All hard copies are labeled as “uncontrolled” to prevent unintended use.
3. SPECIFIC REQUIREMENTS
OMS Sub-element 4.1 - Procedures & Practices (4.1.1, 4.1.2, 4.1.3, 4.1.4, 4.1.5)
OMS Sub-element 4.3 - Information Management & Document Control (4.3.1, 4.3.1.1,
4.3.2, 4.3.2.1, 4.3.3)
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 4 of 23
ISO 14001:2004 - 4.4.5 Control of documents
4. K
EY RESPONSIBILITIES
4.1 Document Authority
The Document Authority is accountable for the following (for documents which fall within the
defined scope of their authority):
Assigning a Document Custodian.
Approving and authorising new documents, review / revision of existing documents, and
deletion of obsolete documents (through the relevant Documentation e-MoC, or through
e-mail approval while Documentation e-MoC training is being completed).
Checking that document requirements are consistent with other existing controlled HSSE
document requirements.
Setting the next document review date (in consultation with the CoW Safety Systems
Lead / Specialist).
Informing the HSE Document Coordinator of any changes in Document Authority as a
result of the Organisational MoC process. (NB: Changes in document ownership must be
recorded in the document Review / Revision Log).
4.2 Document Custodian
The Document Custodian is responsible for the following (for HSSE documents that fall within the
defined scope of their ownership):
Document creation in accordance with the AzSPU HSSE Standardised Document
Management Procedure Template (AZSPU-HSSE-DOC-00025-A1).
Review, update and revision of documents.
Deletion of documents when they are considered obsolete.
Monitoring of relevant Tier
2,
3,
4 and 5 HSSE document review schedules and
maintenance of documents accordingly.
Incorporation of lessons learned from audits, incident investigations, CTM task
verification, and management reviews into document review / revisions.
Ensuring that document requirements are consistent with existing related Tier 2, 3, 4 and
5 HSSE documents, and communicating with document owners if this is not the case. As
part of this process, Document Custodians should rationalize and consolidate procedures
(where practical), with obsolete procedures deleted from the dK system.
Initiation of a Documentation e-MoC for new documents, review / revision of existing
documents, and deletion of obsolete documents (only applies to Document Custodians
that have received the appropriate Documentation e-MoC training. In the interim
Document Custodians may use the old system of document approval (i.e. e-mailed
approval from Document Authority). Once training has been received, the Document
Custodian is responsible for initiating a Documentation e-MoC for creation, review /
revision, and deletion of documents).
Identification of reviewers (from the Review Committee) in the Documentation e-MoC
for the creation and review / revision of controlled documents, and incorporation of their
comments into the document. Reviewers may also be consulted by the Document
Custodian during the process of deletion of a document.
Identification of an approver and authoriser
(generally Document Authority) in the
Documentation e-MoC for creation, review / revision, and deletion of documents.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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Completion of Appendix 2 - „dK Minimum required Information Form‟ for creation,
review / revision, and deletion of controlled documents and submission of form to HSE
Document Coordinator.
Communication of document creation, review / revision, and deletion to affected BP
employees and contractors.
Ensuring that the revision and review history is maintained within the Revision / Review
Log of the document.
Having an understanding of OMS Elements, Sub-elements, and Essentials and attributing
each document correctly against these.
Informing the HSE Document Coordinator of any changes in Document Custodian as a
result of the Organisational MoC process. (NB: Changes in document ownership must be
recorded in the document Review / Revision Log).
4.3 HSE Document Coordinator
The HSE Document Coordinator is responsible for:
Ensuring that new and revised controlled HSSE documents are issued in dK.
Ensuring documents can be located, current versions are available, and obsolete
documents are archived / deleted from dK.
Maintaining the Controlled HSSE Document Master List using the dK system.
Checking that controlled documents are in the standard document format, that new
documents are numbered in accordance with Appendix 1, and that the document Tier
provided by the Document Custodian is in compliance with the AzSPU Management
Systems Tier Structure (AzSPU-HSSE-DOC-00313-2).
Forwarding facility Aspect & Impact Registers, and Objectives, Targets and Management
Programmes to the ISO Specialist for an additional assurance check prior to dK upload.
Issuing the AzSPU HSSE dK Documentum Dashboard on a monthly basis to key
personnel
(and sending out notifications of overdue documents to Custodians
/
Authorities one week prior to issue of dashboard).
Communicating the completed „dK Minimum required Information Form‟ and the dK
document hyperlink to the OMS Navigator Coordinator each time a controlled HSSE
document is created, reviewed / revised, or deleted (in the dK system) so that the OMS
Navigator system can be aligned accordingly.
Signing off that post implementation actions have been closed out in the relevant
Documentation e-MoC.
Organising and conducting dK training.
4.4 OMS Navigator Coordinator
The OMS Navigator Coordinator is responsible for updating the OMS Navigator system each time a
controlled HSSE document is created, reviewed / revised, or deleted in the dK system. This
information is communicated to the OMS Navigator Coordinator by the AzSPU HSE Document
Coordinator.
4.5 CoW Safety Systems Lead / Specialist
The CoW Safety Systems Lead / Specialist are accountable / responsible for:
Preparing and maintaining Tier 2, 3, 4 and 5 HSSE document review schedules and
issuing these to relevant personnel on a regular basis.
Driving a consistent document review process.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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The COW Safety Systems Lead / Specialist may also initiate an e-MoC for documentation review /
revision, based on the HSSE document review schedules.
4.6 ISO Specialist
The ISO Specialist is responsible for:
Conducting additional assurance checks (both formatting and content) of facility Aspect
& Impact Registers and Objectives, Targets and Management Programmes prior to dK
upload.
Liaising with the relevant Document Custodian if any amendments are required to the
Aspect & Impact Registers, and Objectives, Targets and Management Programmes.
4.7 Review Committee Members
Review Committee Members (selected by the Document Custodian) are responsible for conducting
reviews of newly created and reviewed / revised documents and adding any comments into the
relevant Documentation e-MoC. Reviewers may also be consulted by the Document Custodian during
the process of deletion of a document.
5. PROCEDURE
HSSE documentation will be managed in accordance with this procedure to ensure that it is
appropriately controlled, authorised and periodically reviewed.
The HSE Document Coordinator will manage all controlled HSSE electronic documentation in the
dK system, and will maintain the Controlled HSSE Document Master List using the dK system.
All HSSE documentation creation, review / revision, and deletion will be controlled through the
AzSPU e-MoC system (Documentation e-MoC), see Sections 5.1-5.3. NB: This only applies where
the Document Custodian has received the appropriate Documentation e-MoC training. In the
interim Document Custodians may use the old system of document approval (i.e. e-mailed
approval from the Document Authority). Once training has been received, the Document
Custodian is responsible for initiating a Documentation e-MoC for creation, review / revision,
and deletion of documents.
The review / revision process consists of the following:
Planned review, which is generally done on an annual / biannual basis, where the whole
document is reviewed and updated (as required).
Revision, which can be conducted at any time, in response to changes which affect the
documented process.
In both cases the process outlined in Section 5.2 is to be followed, unless the revisions made to the
document are considered to be so small-scale that consultation with the Review Committee members,
and approval from the Document Authority, are not required (it is the responsibility of the Document
Custodian to determine whether this is the case).
The Document Custodian must also ensure that the requirements of his document are consistent with
other related Tier 2, 3, 4 and 5 HSSE document requirements. If other HSSE procedures require
update as a result, it is the Document Custodians responsibility to communicate this to the other
document owners. As part of this process any duplicated procedures (at different Tier levels) must be
removed from the system and made obsolete (as described in Section 5.3).
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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5.1
Creation of Controlled HSSE Documents
HSE & Engineering Leadership Team (or their delegates)
* Review Committee:
co-ordinate creation of HSSE documents
• Members of AzSPU HSE
Leadership Team (or their
delegates)
Appropriate Authority assigns a Custodian for the new
• Technical Authorities / Subject
document
Matter Experts
Document Custodian creates initial draft of document in
accordance with the AzSPU HSSE Standardised Document
Management Procedure Template.
Document Custodian also checks and ensures consistency
with existing related HSSE procedures in dK.
Document Custodian initiates a Documentation e-MoC,
INITIATE
identifies the risk ranking, completes justification, and
attaches the document to the e-MoC
Document Custodian verifies and co-ordinates the e-MoC
VERIFY
and identifies Reviewers (relevant members of Review
Committee*) and the Approver (Document Authority) in the
e-MoC system
REVIEW
Reviewers conduct review of document and add any
comments into e-MoC system
Document Custodian updates document based on comments
and re-attaches to e-MoC
APPROVE
Document Authority approves document in e-MoC system
Documentation
e-MoC process
Document Custodian completes any pre-implement actions,
including completion of the ‘dK Minimum Required Info Form’
PRE-IMPLEMENT
(Appendix 2) which he provides to the HSE Document
& AUTHORISE
Coordinator.
Document Authority authorises e-MoC.
HSE Document Coordinator checks that all post
POST-
implementation actions have been closed out in the e-MoC
IMPLEMENT
and uploads document into dK
HSE Document Coordinator passes dK link and ‘dK Minimum
Required Info Form’ to OMS Navigator Coordinator so that
document can be accessed through OMS Navigator system
Document Custodian communicates document creation to
CLOSE
affected employees and contractors, delivers any required
procedural roll out meetings, and closes out MoC
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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5.2
Review/Revision of Controlled HSSE Documents
* Review Committee:
COW Safety System Lead / Specialist prepare and distribute Tier 2, 3, 4
• Members of AzSPU HSE
and 5 HSSE document review schedules on a regular basis
Leadership Team (or their
delegates)
• Technical Authorities / Subject
Matter Experts
Document Custodians are responsible for monitoring relevant HSSE
document review schedules and maintaining their documents
accordingly.
Alternatively a document revision may be required (outwith the review
schedule) due to a change in process, or due to lessons learned from
audits, incident investigations, CTM task verification, management
review, etc.
Document Custodian carries out initial update of document.
Checks updated requirements are consistent with
requirements in existing related HSSE documents in dK.
Communicates with Document Custodians of related Tier 2,
3, 4 and 5 documents to ensure requirements are consistent
and rationalize and consolidate procedures (if practical)
Document Custodian (or COW SS Lead / Specialist) initiates
INITIATE
a Documentation e-MoC, identifies the risk ranking, and
completes justification. Document Custodian attaches the
updated document to the e-MoC.
Document Custodian verifies and co-ordinates the e-MoC
VERIFY
and identifies Reviewers (relevant members of Review
Committee*) and the Approver (Document Authority) in the
e-MoC system
Reviewers conduct review of document and add any
REVIEW
comments into e-MoC system (meetings held as necessary)
Document Custodian updates document based on comments
and re-attaches to e-MoC
APPROVE
Document Authority approves document in e-MoC system
Documentation
Document Custodian completes any pre-implement actions,
e-MoC process
including completion of the ‘dK Minimum Required Info Form’
PRE-IMPLEMENT
(Appendix 2) which he provides to the HSE Document
& AUTHORISE
Coordinator.
Document Authority authorises e-MoC.
HSE Document Coordinator checks that all post
POST-
implementation actions have been closed out in the e-MoC
IMPLEMENT
and uploads revised document into dK
HSE Document Coordinator passes dK link and ‘dK Minimum
Required Info Form’ to OMS Navigator Coordinator so that
document attributes can be updated in OMS Navigator
system
Document Custodian communicates document review /
CLOSE
revision to affected employees and contractors, organizes
and delivers any required procedural roll out meetings, and
closes out MoC
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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5.3
Making Controlled HSSE Documents Obsolete
Need for document deletion identified through:
* Review Committee:
- Process change / abandonment
• Members of AzSPU HSE
- Consolidation of procedures
Leadership Team (or their
- Employee recommendation
delegates)
- Continual process improvement
• Technical Authorities / Subject
- Corrective action
Matter Experts
- Management Review
Document Custodian initiates a Documentation e-MoC,
identifies the risk ranking, completes justification (which
INITIATE
explains the reason for document deletion) and attaches the
document proposed for deletion to the e-MoC
Document Custodian verifies and co-ordinates the e-MoC
and identifies Reviewers if applicable (relevant members of
VERIFY
Review Committee*) and the Approver (Document Authority)
in the e-MoC system
Reviewers conduct review of document and add any
REVIEW
comments into e-MoC system (if applicable)
Document Custodian ensures Reviewers are in agreement
regarding document deletion (if applicable)
APPROVE
Document Authority approves document deletion in e-MoC
system
Documentation
e-MoC process
Document Custodian completes any pre-implement actions,
PRE-IMPLEMENT
including completion of the ‘dK Minimum Required Info Form’
& AUTHORISE
(Appendix 2) which he provides to the HSE Document
Coordinator.
Document Authority authorises e-MoC.
POST-
HSE Document Coordinator checks that all post
IMPLEMENT
implementation actions have been closed out in the e-MoC
and makes document obsolete in dK system
HSE Document Coordinator passes dK link and and ‘dK
Minimum Required Info Form’ to OMS Navigator Coordinator
so that document link can be removed from OMS Navigator
system
Document Custodian communicates document deletion to
CLOSE
affected employees and contractors and closes out MoC
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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5.4 Notification of Upcoming HSSE Document Review
The CoW Safety System Lead / Specialist prepare and maintain Tier 2, 3, 4 and 5 HSSE document
review schedules and issue these to relevant personnel on a regular basis.
It is the responsibility of the Document Custodian to periodically review the relevant schedules and
ensure that their procedures are reviewed and updated accordingly.
In line with this, the HSE Document Coordinator will issue an AzSPU HSSE dK Documentum
Dashboard, on a monthly basis, to key personnel throughout the AzSPU. The dashboard will
summarise the following information:
Numbers of Tier 2-5 HSSE documents uploaded.
Numbers of Tier 2-5 HSSE documents past their review date.
Numbers of Tier 2-5 HSSE documents requiring review in 30, 60 and 90 days.
Numbers of Tier 2-5 HSSE documents uploaded to dK that month and total for year.
Number of HSSE permits uploaded to dK that month and total for year.
Number of dK training sessions and attendees that month and total for year.
One week prior to the issue of the dashboard the HSE Document Coordinator will send e-mail
notifications to Document Custodians and Authorities whose procedures are overdue.
5.5 HSSE Document Numbering
Controlled HSSE documents shall be numbered in the dK system in accordance with Appendix 1, in
order to identify document scope (e.g. AzSPU), Function (e.g. HSSE), document type (e.g. document,
record, permit, etc) and Tier level (2-5).
It should be noted that all permit documents are numbered as Tier 2. The applicability of these
documents is then detailed in the AzSPU HSSE Legal Registers. All permit documents are ‘hidden’
in dK, these documents can only be accessed by using the hyper-links in the following AzSPU
HSSE Legal Registers:
Register of HSSE Drivers AzSPU-HSSE-DOC-00038-A1 (this includes all project-specific
approved documents, e.g. PSAs, ESIAs, ESAPs, etc)
Register of Azerbaijani HSSE National Legislation AzSPU-HSSE-DOC-00038-A2
Register of Georgian HSSE National Legislation AzSPU-HSSE-DOC-00038-A6
Register of International HSSE Guidelines and Regulations for Azerbaijan AzSPU-HSSE-
DOC-00038-A4
Register of International HSSE Guidelines and Regulations for Georgia AzSPU-HSSE-DOC-
00038-A8
AzSPU Azerbaijan ESIA Permit Register AzSPU-HSSE-DOC-00038-A5
AzSPU Azerbaijan Other HSSE Permit Register AzSPU-HSSE-DOC-00038-A7
5.6 HSSE Document Structure
AzSPU HSSE controlled documents will conform with the structure of the AzSPU HSSE
Standardised Document Control Procedure Template
(AZSPU-HSSE-DOC-00025-A1). All
documents uploaded into dK must include the following attributes as a minimum:
Title
Scope (e.g. Az Export Pipelines)
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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Issue date
Revision date
Next review date
Authority (position title and name)
Custodian (position title and name)
Document Administrator (position title and name)
Issuing department
Control Tier
The above information will be recorded on the front page of the document. A number of additional
attributes will also be used by the HSE Document Coordinator / OMS Navigator Coordinator to
categorise the document within the dK / OMS Navigator systems, e.g. OMS Element, Sub-element,
Essential, ISO 14001 reference, etc.
All controlled documents will incorporate a Revision / Review Log to record the following:
Revision / Review date
Authority name (position title and name)
Custodian name (position title and name)
Revision / Review details
It should be noted that document attachments are not required to conform with the structure of the
AzSPU HSSE Standardised Document Control Procedure Template.
5.7 Approval, Assurance and Issue of Controlled HSSE Documentation
Approval for dK HSSE document upload will be obtained from the Document Authority through the
e-MoC system (see Sections 5.1 and 5.2).
Prior to uploading controlled documents to dK the HSE Document Coordinator will ensure that they
are approved, legible and conform with the AzSPU HSSE Standardised Document Management
Procedure Template
(AZSPU-HSSE-DOC-00025-A1). One week will be allowed following
submission of the document to the HSE Document Coordinator, to allow sufficient time for this
formatting review, prior to dK upload.
In the case of facility Aspect & Impact Registers and Objectives, Targets & Management Programme
documents, additional assurance (in terms of both formatting and content) will be provided by the
ISO Specialist. It is the responsibility of the HSE Document Coordinator to forward these documents
to the ISO Specialist for review prior to upload. The ISO Specialist is responsible for liaising with the
relevant Document Custodian to ensure that the document is suitable for upload.
The controlled version of all HSSE documentation will be uploaded to dK.
5.8 Communication of HSSE Documentation Creation, Review / Revision / Deletion
The Document Custodian is responsible for communicating information regarding creation, review /
revision and deletion of documents that he is the owner of.
There are a number of routes for communicating this information:
Through notification e-mail to affected employees and contractors.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
Page 12 of 23
Through dedicated procedural roll-out sessions. The Document Custodian is responsible for
organizing these meetings and ensuring key personnel are present.
Through Work Team Meetings (AzSPU-HSSE-DOC-00032-2) and other forums.
5.9 Uncontrolled HSSE Documentation
All printed copies are considered uncontrolled. Each controlled document posted in dK includes a
footer stating that paper copies are uncontrolled and are valid only at the time of printing. It is the
responsibility of the person holding an uncontrolled copy to ensure that the information contained
within the document is current and valid for its intended use.
5.10 Linkage Between dK & OMS Navigator
dK is a document management system.
In contrast, OMS Navigator is a portal that provides access to all AzSPU‟s documentation in
different document systems (e.g. dK, engineering Documentum, etc).
Based on this, dK should be used by the HSE Function for document control processes (e.g. upload,
storage, identification of Document Authorities, preparation of overdue procedure lists, etc).
OMS Navigator should be used for general viewing of documentation.
In order to ensure that information in dK is consistent with that in OMS Navigator, the HSE
Document Coordinator liaises with the OMS Navigator Coordinator. Each time a document is
created, reviewed / revised, or deleted in the dK system the HSE Document Coordinator provides the
dK document hyperlink and the completed „dK Minimum Required Information Form‟ (Appendix 2)
to the OMS Navigator Coordinator so that the OMS Navigator system can be updated accordingly.
Document Custodians are required to have an understanding of the OMS Elements, Sub-elements and
Essentials, as each HSSE document needs to be attributed against these so that it can be correctly
categorized in the OMS Navigator system.
Document Custodians must provide reference to applicable OMS Elements, Sub-elements and
Essentials in
„Section
3
- Specific Requirements‟ of each procedure and provide the same
information in the „dK Minimum Required Information Form‟ (Appendix 2). The E&P OMS Manual
will assist with this. In addition, if the document has already been uploaded to OMS Navigator (i.e. if
reviewing / deleting an existing HSSE document), current document attributing can be found by
accessing OMS Navigator (see Appendix 2 for instructions).
6. KEY DOCUMENTS / TOOLS / REFERENCES
AzSPU HSSE Standardised Document Management Procedure Template (AZSPU-HSSE-
DOC-00025-A1).
AzSPU Management Systems Tier Structure (AzSPU-HSSE-DOC-00313-2).
Tier 2, 3, 4 and 5 HSSE document review schedules (distributed by CoW Safety System Lead
/ Specialist)
AzSPU HSSE dK Documentum Dashboards (distributed by HSE Document Coordinator).
E&P OMS Manual
AzSPU e-MoC system
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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Revision / Review Log
Revision / Review
Authority
Custodian
Revision / Review Details
Date
July 2000
G. Vidrine / F. Askerov
G. Stacey
Initial Issue
August 2000
G. Vidrine / R.
G. Stacey
Consistency with BP EMS guidelines
Gallagher
April 25, 2004
L. Emmons
L. Gandilova / S.
Consistency with EMS requirements
Sultanova
December 12, 2005
Gunther Newcombe
Yuliy Zaytsev
Updated to incorporate WG comments and
address dK system requirements
June 01, 2006
Gunther Newcombe
Yuliy Zaytsev
Wording changed in para 4.1 and minor
editorial changes were made
November 15, 2006
Gunther Newcombe
Yuliy Zaytsev
Flow diagrams in Sections 5.1 to 5.4
revised to allow for e-mail approval by the
document Authority and incorporation of
notification list.
Revision to flow diagram in Section 5.1 -
re-ordering of certain steps.
Complete revision of flow diagram in
Section 5.4 to more accurately represent the
present system for external documents.
Appendix 2 added to procedure outlining
HSSE&S controlled documents minimum
information requirements for upload into
dK.
Appendix 3 added providing cross-
references between the different
management systems.
Appendix 4 added providing guidelines
regarding documents that require upload
into the dK system.
December 7, 2007
Yuliy Zaytsev (AzSPU
Rebecca Heath
Document reviewed and reissued.
HSSE MS
(AzSPU HSSE MS
Requirement for content assurance review
& Compliance
Senior Advisor)
by HSSE MS & Compliance Team added.
Manager)
Clarification also provided regarding:
Period of time required for formatting
review by AzSPU HSSE Document
Coordinator.
Next Review Date definition (in line with
November 2007 external ISO 14001
audit recommendations).
Notification list requirements for new
documents.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
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AzSPU HSSE Document Management Procedure
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March 05, 2008
Yuliy Zaytsev (AzSPU
Rebecca Heath
In response to August 2007 S&OI audit
HSSE MS
(AzSPU HSSE MS
findings the following revisions have been
& Compliance
Senior Advisor)
added to the procedure:
Manager)
AzSPU HSSE MS & Compliance Team
to issue dK Documentum Dashboard on
a monthly basis.
AzSPU HSSE Document Controller to
issue e-mail notifications to document
Custodians listing the documents that
require review in 30, 60 and 90 days.
If documents become overdue for a
period of more than one month the
AzSPU HSSE Document Coordinator
will notify the document Authority so
that corrective actions can be
implemented.
May 19, 2008
Yuliy Zaytsev (AzSPU
Rebecca Heath
Document revised to take into account
HSSE MS
(AzSPU HSSE MS
findings of April 2008 internal audit
& Compliance
Senior Advisor)
concerning discrepancies between Tier 2
Manager)
procedures.
Appendix 4 amended so that it is in
agreement with the AzSPU Record Control
Procedure (AzSPU-HSSE-DOC-00041-2).
For example: requirement for
environmental monitoring reports to be
uploaded to dK removed.
September 17, 2008
Yuliy Zaytsev (AzSPU
Rebecca Heath
Section 5.8 amended. Distribution of CDs
HSSE MS &
(AzSPU HSSE MS
only practical on a 3 month time-frame
Compliance Manager)
Senior Advisor)
rather than 1 month.
February 4, 2009
Yuliy Zaytsev (AzSPU
Rebecca Heath
Position titles corrected throughout.
Safety & Compliance
(AzSPU HSSE MS
Tier level descriptions amended to reflect
Manager)
Senior Advisor)
recent updates to AzSPU organisational
structure.
Definitions of external and internal
documents revised. Definition of permit
added.
Clarification provided on „Next Revision
Date‟ description.
Document Authority and Document
Custodian responsible for informing
AzSPU HSSE Document Coordinator of
changes in document ownership.
Clarification provided regarding:
- control of external HSSE documents;
- numbering of permit documents;
- formatting / structure of document
attachments; and
- generation of uncontrolled documents on
CD for sites without access to dK.
Reference to procedural MoC removed
from flowcharts.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 15 of 23
June 14, 2010
Yuliy Zaytsev (AzSPU
Rebecca Heath
Document updated to remove reference to
Safety & Compliance
(AzSPU HSSE MS
HSSE&S Management System and align
Manager)
Senior Advisor)
with OMS.
Document scope expanded to include
requirements in AzSPU Review / Revision
Process for HSE Tier 2 Procedures - ToR
(AzSPU-HSSE-DOC-00072-2). Latter
document now obsolete.
Responsibilities section amended to reflect
re-organisation and new procedural
requirements.
Flowcharts for creation, review / revision,
and deletion of controlled document all
updated to reflect use of the AzSPU e-MoC
system (Sections 5.1 - 5.3).
Notification of upcoming HSSE document
review now provided through Tier 2, 3, 4
and 5 HSSE document review schedules.
Requirement added for ISO Specialist to
provide additional assurance review in the
case of facility A&I Registers and Os, Ts &
MPs prior to dK upload.
Section 5.8 - „Communication of HSSE
Document Creation, Review / Revision,
Deletion‟ added to procedure.
Section 5.10 - „Linkage Between dK &
OMS Navigator‟ added to procedure.
Section 5.4 - „Control of External HSSE&S
Documents‟ removed from procedure.
Documents external to dK should be
uploaded to the appropriate storage system
(e.g. engineering Documentum, etc) and
accessed through OMS Navigator, not dK.
Appendix 2 updated to align with OMS.
Appendix 3 Management Systems Cross-
Reference Tool removed from procedure.
July 6, 2010
Richard Bodley-Scott
Rebecca Heath
Small revisions made to Figure 5.2 based
(AzSPU Planning,
(AzSPU HSE MS
on feedback from Sangachal Terminal
Performance &
Senior Advisor)
representatives.
Learning Manager)
Document Authority and Custodian updated
in line with AzSPU re-organisation.
AzSPU HSSE Standardise Document
Management Procedure Template (AzSPU-
HSSE-DOC-00026-2) has been placed as a
child document to this procedure and is
now AzSPU-HSSE-DOC-00025-A1.
Standard date format (i.e. month, dd, yyyy)
added so that review date and next review
date are consistent.
Sept 24, 2010
Richard Bodley-Scott
Rebecca Heath
Provision added for use of old
(AzSPU Planning,
(AzSPU HSE MS
documentation approval system for
Performance &
Senior Advisor)
Document Custodians which have not yet
Learning Manager)
received Documentation e-MoC training.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 16 of 23
Oct 15, 2010
Richard Bodley-Scott
Amal Ibadzade
New Appendix 4 to include guidance
(AzSPU Planning,
(AzSPU Engineering &
for updating HSSE Procedures in
Performance &
HSE Document
Response to AzSPU Sector Leadership
Learning Manager)
Management Team Leader)
Re-organisation
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
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AzSPU HSSE Document Management Procedure
Page 17 of 23
APPENDIX 1 - AzSPU HSSE Control Documents Numbering Matrix
The document name/number scheme is made up of a collection of individual nodes (separated by
dashes) which reflect the scope of that document within the AzSPU.
AZSPU
FUNCTIONAL AREA
DOCUMENT TYPE
SEQUENCE NUMBER
TIER
This value will be stored in the object_name field within the dK system. The HSE Document
Coordinator should put the “English friendly” title of the document in the title field within dK. The
auto-number utility can be used to generate the next available document number.
No extension (.xls, .doc, .ppt) should be included with the document number when it is loaded into
the dK system. The system will determine the appropriate file type associated with the application
which makes the extension an unnecessary part of the object name.
AZSPU
Preceding tag added to all AzSPU documents.
FUNCTIONAL AREA
The functional area which has issued and will manage this content within the AzSPU. The following is the list of
the currently accepted values for this node:
HSSE HSSE
OPS
Operations
ENG
Engineering
DOCUMENT TYPE
The document type as defined within the dK system. The following is the list of the currently accepted values
for this node:
DOC
Document (procedure or other controlled document)
PMT
Permit (or other regulatory document specifying compliance requirements).
REC
Record (e.g. correspondence, transmittal or any other historical document not subject to regular
review and revision.
SEQUENCE NUMBER
A 5-digit sequence number which will be used to provide a unique identifier to the entire document number
string. This number does not need to be unique across all documents, but only within the entire document
number string. For example, a sequence value of “00012” may be found for a DOC (document) type and it may
also be found within a REC (record) type i.e. the entire document number string must be unique, but not
necessarily the individual sequence number node.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
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AzSPU HSSE Document Management Procedure
Page 18 of 23
TIER
The document control Tier associated with this content. The following is the list of the currently accepted values
for this node:
1 Documents applicable at Group / Segment level (not used)
2 Documents applicable at AzSPU / Function level
3 Documents applicable at Operating Area level
4 Documents applicable at Sector level
5 Documents applicable at Operating Facility level
U Uncontrolled document, web site address, or other document not requiring full conformance to document
control. Content controlled in an alternate location, outside of dK, will always have the U Tier designation.
A Attachment to a controlled document
AZSPU-HSSE-DOC-00023-2
Document uploaded to dK at the AzSPU / Function (Tier 2) level.
AZSPU-HSSE-DOC-00001-3
Document uploaded to dK at the Operating Area (Tier 3) level.
AZSPU-HSSE-DOC-00001-A1
Document uploaded to dK that is an attachment to another document and
should not be used in a stand-alone manner.
AZSPU-HSSE-PMT-00023-2
Permit uploaded to dK at the AzSPU (Tier 2) level.
AzSPU-HSSE-REC-00020-2
Record uploaded to dK at the AzSPU (Tier 2) level.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
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AzSPU HSSE Document Management Procedure
Page 19 of 23
APPENDIX 2 - AzSPU dK Minimum Required Information Form
Required Information for all HSSE documents
(newly
issued,
revised,
and
for
document
deletion):
Document Title:
dK reference (for existing documents):
Scope:
Issue Date:
Revision Date:
Next Revision Date:
Authority - position title/name:
Custodian - position title/name:
Issuing Department:
Control Tier:
Function / VP Group:
Operating Area:
Facility:
OMS Elements *:
OMS Sub-elements *:
OMS Essentials *:
ISO14001 Reference:
Keywords (words by which document may
be found if document number is not known
- optional):
* Please refer to the E&P OMS Manual.
If the document has already been uploaded to OMS Navigator (i.e. if you are reviewing / deleting an
existing HSSE document) you can search for the document in the Navigator system in order to check the
current OMS attributing 1. Please revise the attributing, if necessary, by inserting the applicable OMS
Elements, Sub-elements and Essential information into the relevant rows above. If the attributing in OMS
Navigator is correct please copy the information into the relevant rows above.
1 In the „Navigator‟ screen select Location as: E&P, AzSPU, All, All, All
Type the document title or keyword into the box in the top right hand corner of the screen and press enter.
Applicable OMS Elements, Sub-elements and Essentials will be displayed in the first column of the resulting
table next to your document title.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 20 of 23
APPENDIX 3: dK Upload Guidelines
It is recommended that the following HSSE documents are uploaded into the dK software system:
Documents
Procedures
Strategies
Policy documents
Manuals
Guidelines
Terms of reference
HSSE instructions
Registers of drivers
Activities, products and services (APS) lists
HSSE&O Risk Matrices / Registers
Aspects and impacts registers
Objectives, targets and management programmes
Oil spill / emergency response plans
Audit / inspection schedules
Facility HSSE plans
Records
Internal and external AzSPU audit reports
MENR Acts (reports on external inspections)
AzSPU audit checklists and protocols
Annual management review documents (slide packs, minutes and actions)
External environmental reports (those submitted to MENR and other statutory bodies)
Accreditation certificates
Permits
Permits - documents issued by host governments, e.g. sewage discharge permits, approval
letters.
Project-Specific Approved Documentation - documents developed by AzSPU and approved
by host government, e.g. Environmental and Social Impact Assessment
(ESIAs),
Environmental Addendums / Technical Notes / Statements, Oil spill response plans (if
approved by Government), etc.
Project-Related Agreements - documents signed with host countries, e.g. Production Sharing
Agreements (PSAs), Host Government Agreements (HGAs), Inter Government Agreements
(IGAs).
Lender Required Documentation - e.g. Management and Monitoring Plans, Environmental
and Social Action Plans (ESAPs), Supplementary Lender Information Packages (SLIPs),
Public Consultation and Disclosure Plans (PCDPs), Resettlement Actions Plans (RAPs), etc.
Other Legal Requirements - e.g. applicable national legislation, international and other
countries legislation and regulations.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 21 of 23
APPENDIX 4: Guidance for Updating HSSE Procedures in Response to AzSPU Sector
Leadership Re-Organisation
This is a temporary guidance document, covering transition period after
1st of June,
2010 re-
organisation until full alignment of the requirements listed below is achieved.
The sections below refer to sections in AzSPU HSSE documents and summarise some of the
common changes that are required to align documents with the new organisational structure and
OMS.
1. Front Cover
Title:
Ensure that all references to the ‘AzSPU HSSE Management System’ are removed from the document
title, headers and footers, and the rest of the text.
The HSSE MS is now part of the wider Operating Management System.
E.g. The ‘AzSPU HSSE MS Document Management Procedure’ is now entitled the ‘AzSPU HSSE
Document Management Procedure’.
Scope:
Replace ‘AzSPU Operational PUs’ with ‘AzSPU Functions & Operating Areas’
Control Tier:
Consult the revised AzSPU Management Systems Tier Structure (AzSPU-HSSE-DOC-00313-2) in
order to determine the tier of your document.
2. Purpose / Scope
Replace ‘This controlled procedure applies to Operational PUs engaged in the drilling, production,
and/or transportation of oil and gas’ with ‘This controlled procedure applies to AzSPU Functions and
Operating Areas engaged in the drilling, production, and/or transportation of oil and gas’.
Throughout the document:
Replace references to ‘Performance Unit’ with ‘Operating Area’.
Replace references to ‘Facility’ with ‘Operating Facility’.
Remove references to Assets as these no longer exist.
3. Specific Requirements
Reference needs to be included to OMS Sub-elements and Essentials applicable to the document.
A description of the OMS Sub-elements and Essentials can be found here E&P OMS Manual.
If you are reviewing an existing HSSE document you can search for the document in the OMS
Navigator system in order to check the current OMS attributing2. Please revise the attributing, if
necessary.
2 In the ‘Navigator’ screen select Location as: E&P, AzSPU, All, All, All
Type the document title or keyword into the box in the top right hand corner of the screen and press enter.
Applicable OMS Elements, Sub-elements and Essentials will be displayed in the first column of the resulting
table next to your document title.
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/
AzSPU HSSE Document Management Procedure
Page 22 of 23
4. Key Responsibilities
A significant number of AzSPU position titles have changed as a result of the re-organisation.
The table below provides information on major changes in position titles, in order to clarify roles and
responsibilities, and to aid with adjusting the responsibilities section of HSSE procedures.
Old position title
New position title
HSE & Technical Directorate Vice President
HSE & Engineering Vice President
Vice President Communications & Internal
Vice President Communications, Internal
Affairs
Affairs and Security
Operations Manager
Area Operations Manager (AOM)
Delivery Manager
Area Operations Manager (AOM)
Performance Unit Leader
Area Operations Manager (AOM)
Asset Manager
Area Operations Manager (AOM)
Communications & External Affairs
(C&EA)
Communications Manager; and
Manager
External Affairs Manager
HSE Manager
Health & Safety Manager
(Offshore &
Midstream) and Regulatory Compliance &
Environment Manager
Safety and Compliance Manager
Health & Safety Manager
(Offshore &
Midstream)
Environmental Manager
Regulatory Compliance & Environment
Manager
HSE & TD Permitting & Regulatory Affairs
Permitting and Regulatory Affairs Manager
Manager
Supply Chain Manager
Chief Procurement Officer
PU/Asset Maintenance Manager
Area Engineering Support Team Leader; and
Maintenance Superintendent (Sangachal); and
Maintenance & Logistics Manager (Exports)
Benefits Manager
Reward Manager
Waste Operations Manager
Waste Management Manager
Transport Manager
Land Transportation and Travel Manager
Transport Supervisor
Operations Transportation Team Leader
HSE Team Leader
H&S Team Leader and Compliance &
Environment Team Leader
PU / Asset Engineering Team Leaders
Area Engineering Support Team Leader /
D&C Engineering Team Leader
HSE Management System Team Leader
/
COW/Safety Systems Lead/Specialist; and
Advisor
ISO Specialist; Audit and Performance Team
Leader/Advisor
Engineering
& HSE Documentation
Management Team Leader/Coordinator
HSE Management System Document
HSE Document Management Coordinator
Coordinator
Crisis Management & Emergency Response
Crisis Continuity Management & Emergency
Team Leader (CM& ER TL)
Response Manager (CCM&ER Manager)
Control Tier:
2-AzSPU
Revision Date: October 15, 2010
Document Number: AzSPU-HSSE-DOC-00025-2
Print Date: 2/1/2011
PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED
VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu/