Legal Law

Health, safety and environmental management for the 21st century: my experience in Kazakhstan


This article summarizes my experiences in developing a highly successful HSE (Health, Safety and Environmental Management) program within PetroKazakhstan (a Canadian owned oil company) which had very few HSE systems and programs before I arrived. . In this document, I try to present as clear a picture as possible of where the organization PetroKazakhstan was when I arrived and what actions I took on the path to HSE success.

My arrival:

I had never been to Kazakhstan or any of the former Soviet republics before. I researched the country online and found that Kazakhstan was not the barren arctic wasteland I had imagined, but a beautiful and diverse country with mountains and plains (called steppes) and even a part of the Caspian Sea, the largest in the world. Freshwater lake. PetroKazkhstan’s headquarters were located in Almaty, a beautiful city that was a mix of Asian and European architecture and culture.

My first day on the job was January 4, 2004. Like all new staff, I had to meet the people, understand the organization, and find a place to live. I rented a nice apartment in a perfect location called Samal 2. This area is close to the mountains and my apartment was next to RamStore, a mall with a grocery store which made my initial experience very pleasant. I only had a 2 minute walk to meet my needs.

The job:

My position, Director of HSE, was a new position reporting to the President. Previously, there was a Director of HSE and Training located in the oil field, but his role was primarily related to training. My first task was to go to the oil fields and see what was going on there and talk to people both in HSE and in operations. PetroKazakhstan (PK) had 2 main operating groups, one called PKKR, which was the oil producing side and the other called PKOP, the refinery. PK also had rail freight terminals, oil storage facilities, and retail gas stations.

My visits:

I had decided before leaving on my field visit that I would:

Get to know as many key people as possible and hopefully persuade them to tell me about HSE in their areas, the good, the bad and the ugly.

Visit oil field operation sites and see for myself, assessing the hazards and the risk measures taken to control them.

Review company HSE policies and procedures.

Make a summary of the gaps I saw and evaluate the gaps vs. best HSE management systems in the industry

Our 10-point HSE plan (based on a gap analysis against industry leaders) included:

Improving HSE Management Leadership: We needed to understand how company managers/supervisors viewed their role in HSE. We then needed to develop workshops identifying key HSE roles and responsibilities for managers and supervisors. Performance targets for HSE would be included in management’s Annual Performance Appraisal.

Incorporate risk assessment and management: Hazard identification training should be provided for all workers, as well as Introduction to Risk Management for all managers and supervisors.

Improve HSE Training – HSE training plans were not developed for each site based on risk. New training plans for workers based on risk needed to be developed, as well as training for supervisors on how to assess their workers on HSE performance.

Develop HSE systems for contractors: There were no HSE management systems for contractors. HSE programs for contractors were identified as a critical need. It was suggested that an experienced HSE specialist contractor be hired to start the programme.

Build Design Safety – PK had relied on EPC contractors to ensure design safety in the past. A “security by design plan” would require uniform security design procedures for all future EPC contracts. A key requirement would be a mandatory design safety plan.

Update Operations and Maintenance Plans – There were many gaps in operator training, as well as a lack of standard operating procedures (SOPs) on many key job tasks. A contractor was proposed to develop operator training and SOPs. Maintenance and integrity procedures needed to be reviewed and updated. A proposal for a computerized integrity maintenance system was suggested.

New reporting and documentation system: Various HSE reports are generated within PK, but not to uniform standards and not combined for review by senior management. A centralized and uniform HSE database and reporting system was proposed.

Improve crisis and emergency plans: In general, the emergency response plans were very good and complied with Kazakh law. However, PK lacked a corporate crisis management plan. We proposed that all local site emergency response plans be reviewed and updated and that workers be trained in accordance with these plans. The plans must also be translated into the two languages ​​used in the field, ie English and Russian. Hiring an experienced emergency response consultant to develop a Corporate Crisis Management Plan was seen as a logical way forward.

Renew incident investigation and prevention: Since there were no uniform accident investigation procedures or accident reporting forms, we proposed that new incident investigation procedures and forms be developed. Training would be provided to all environmental/safety engineers and supervisors on root cause analysis and accident investigation principles.

HSE System Assessment and Improvement: Plans for HSE system audits were to be developed that would review these 10 points annually and report the results to senior management.

What did we do first?

When faced with 25-30 gaps in the HSE system, what would you do first? I have always gone back to my basic core belief that you prioritize based on risk. This is what we did. For example, the refinery had no PPE (personal protective equipment) requirements, so we wrote a PPE regulation and began procuring PPE. At the same time, we secured a training company to come for PPE training. The accident reporting and investigation system was not a reliable indicator of accidents that occurred on the ground. Very few contractor accidents were reported and few supervisors knew how to complete an accident investigation form. The typical cause of an accident was “negligence.” The typical corrective action was to “send the wounded to the clinic.” The same accidents were repeated over and over again. We immediately reviewed the accident procedure and forms and then implemented an incident investigation training program. A fatal accident in February 2004 prompted me to review and update the Hot Work Permit system and start implementing HSE Management for Contractors. Until then, contractors were on their own as to how to get their job done. The fatal accident changed all that. We started by issuing senior management rules that all contractor activities would be overseen by a local site supervisor. We also changed the Permit system to require local site supervisors to sign off and audit the work. Meanwhile, the Permit system was reviewed and training provided.

On a broader scale, he knew that the company needed to understand its risks and how to manage them. I engaged a well-respected risk management company to perform a QRA (quantitative risk assessment) and update our Emergency Response System. The QRA would identify our core process and HSE risks and provide recommendations to reduce these risks. Our Emergency Response System was basically limited to what the Kazakhstan government required. We needed a corporate crisis management plan that would monitor and direct actions at the time of a major incident.

These necessary measures were fully endorsed by PK’s senior management and were fully supportive in ensuring that the 10 points for HSE success were implemented.

Summary and results

By the end of the first year, every phase of PetroKazakhstan’s HSE performance had improved significantly. The 10 elements of the PK HSE Safety Management System were implemented with better results in HSE, morale and productivity. The keys to PK’s HSE success were:

– Identification of HSE gaps vs. Industry Best Practices

Development of a “Fit for Purpose” HSE Management System

Senior management involvement and support

Measurement of HSE gaps, assessment of gaps with corrective actions taken

Celebrate HSE success often

Note: I handed over my HSE Director position to my Deputy HSE Director (a local Kazakh) after the assignment year ended in December 2004. I left with the confidence that PK would become an industry leader in HSE . In August 2005, the China National Petroleum Corporation acquired PetroKazakhstan.

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