896405 - HSSE_v03

HSSE IN TRANSITION THROUGH
PROJECT PHASES
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HSSE
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A Case Study of Pearl GTL

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HSSE in Transition through Project Phases
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FOREWORD
This is the first edition of a book that “tells the story” about a specific subject that is important in the
CSU phase of a project and is part of a series of Books.
It appears that a lot of people in the Shell organisation are very interested in learning from Pearl GTL
and how it could be used to benefit their own projects. This shows that we have an organisation
that wants to be a “learning organisation”, and we should do all that we can to help encourage that
mindset. In addition to technical learnings, there are management and organisational aspects. This
means that telling the integrated story of all these learnings is not so easy. This initiative tries to create
a comprehensive story for specific subjects and could be seen as a contribution to the CSU Lessons
Learned post Train 2 start-up initiative. Also, it could potentially contribute to the WEB based Pearl
GTL Lessons Learned initiative.
Each book is standardised and consists of three parts. The central part is a document of
approximately 40 to 50 pages which ‘tells’ the management-, strategic-, interface- elements
called ‘The Book’. To assist in the initial engagement, a slide set of 15 to 20 slides has also been
developed. ‘The Book’ can be used as back-up and reference material thereafter. The third part
contains all the attachments, hard core examples and deliverables, details and procedures.
The references between the documents are structured: at the start of each paragraph, in bullet format,
the key messages are given; these key messages are also contained in the slide set. In ‘The Book’,
if applicable, cross reference is made to the hard core deliverables (attachments). The index of the
attachments (part 3), contains references to the paragraphs in the book.
Part 1
The Slide Set
The Bullet Points
The Bullet Points
The Attachment No.
The Paragraph No.Part 2
The Book
Part 3
The Attachments
OVERVIEW OF THE STRUCTURE
By design, the content has not been generalised considering the essential details will be lost. The
philosophy is that the book ‘tells the story’ as to how it has been done on the Pearl GTL project. At
the end of ‘The Book’, there is a chapter called “what could be done better”. However, it is for the
individual reader to adjust the total process, including the suggestions for improvement to the specific
circumstances and needs of their project.
This initiative was an attempt to consolidate the experience from multiple groups of people about
specific subjects on a project and to make sure that diverse views and perspectives were included.
I would like to thank all the people who have contributed to the content of these books and for their
assistance in making the processes a success.
As this initiative in itself is a learning experience, feedback and suggestions for improvement are
welcome.
I hope you find it beneficial.
Maurice van den Broek

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TABLE OF CONTENTS
5.8 Asset MS & HSSE MS development. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5.9 Integrated Offshore and Onshore Operational HSSE Case . . . . . . . . . . . . . . . . . . . 26
5.10 Work Process to Identify High Risk and Severity 5 Hazards . . . . . . . . . . . . . . . . . . . 27
5.11 Risks Related to Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
5.12 Identify Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
5.13 Manage Identified Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
5.14 Implementing Control Measures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
5.15 Asset HSSE MS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
5.16 Key points for reflection: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
5.17 Further thoughts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
5.18 Construction and Commissioning HSSE MS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
5.19 Commitment and Policy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
5.20 Implementing Policy through Objectives, Targets and Key Performance Indicators . . . . . 33
6. CSU HSSE ORGANISATION, ROLES AND RESPONSIBILITIES. . . . . . . . . . . . . . . . . . . . . 34
6.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
6.2 CSU HSSE Implementation Team. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
6.4 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
7. HSSE CRITICAL PROCESSES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
7.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
7.2 My starting point - Five Critical Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
7.3 Other Critical Processes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
8. AND FINALLY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
8.1 At the start of a Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
8.2 What should a CSU HSSE Implementation Manager/Safety Lead do?. . . . . . . . . . . . 64
8.3 Culture. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
8.4 Governance and Control: Transition from Construction to Commissioning. . . . . . . . . . .64
8.5 HSSE Management Systems. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65
8.6 HSSE Organisation Roles and Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
8.7 Safety Districts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
8.8 HSSE Critical Processes. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
FOREWORD. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Overview of the Structure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
LIST OF ATTACHMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
1. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. THE CONSTRUCTION SAFETY AND WELFARE STORY AT PEARL GTL. . . . . . . . . . . . . . . . . 6
2.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.2 Leadership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.3 CEO Leadership: CEO Summits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.4 Worker Welfare. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.5 Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.6 Incident and Injury Free (IIF) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2.7 Communication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
2.8 Life Critical Activities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
2.9 Statistics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.10 There was more…. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2.11 Key Messages: Five Focus Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3. HSSE IMPLEMENTATION IN A PROJECT ENVIRONMENT: A PERSONAL PERSPECTIVE. . . . 12
3.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.2 Start Making Sense . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.3 What else?. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
4. HSSE CULTURE TRANSITION FROM CONSTRUCTION INTO CSU. . . . . . . . . . . . . . . . . . 14
4.1 Construction HSSE Culture: IIF. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
4.2 Commissioning HSSE Culture: IIF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
4.3 Start-Up HSSE Culture: Goal Zero. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
5. HSSE MANAGEMENT SYSTEMS IMPLEMENTATION. . . . . . . . . . . . . . . . . . . . . . . . . . . 19
5.1 Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
5.2 Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
5.3 HSSE Manual. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
5.4 HSSE Case(s) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
5.5 Rules. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
5.6 Critical Processes – Procedures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
5.7 HSSE Plans and Journey Book. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

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LIST OF ATTACHMENTS

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1. INTRODUCTION
Where do you start when you want to tell a story about the Health, Safety, Security, and Environment
(HSSE) performance that was achieved by 52,000+ construction workers and a Commissioning and
Start-Up (CSU) organisation of approximately 3,500 Shell employees and contractors (or as we say
at Pearl GTL – Partners)?
Whilst the HSSE “story” will concentrate and focus on what was done and achieved during CSU,
reference and relevance to the fantastic achievements during construction and what lessons were
learnt will be made.
During the periods that the plant was under construction, being within meters of plant under
commissioning, and next to equipment already started up… What was it that helped us stay
in control?
Robust governance with clear controls and standards for each phase, excellent communication, clear
segregation and adequate separation of activities that potentially conflicted, “in the field visible
supervision”, and much more, were all needed to ensure that our people worked and went home
safely. This took an enormous amount of planning, flexibility, organisation and control. We did not
sacrifice hard won performances by succumbing to schedule pressure, as it would have led to short
cuts with the eventual and inevitable deterioration in performance.
If management and supervision had portrayed behavior that put into question whether the Company’s
core values were only words and not deeds at Pearl GTL, the impact on our vast workforce
would have been incalculable. I am happy to say that this did not happen and it is a testimony to
senior leadership that their commitment to HSSE and the welfare of all who worked at Pearl GTL
was paramount. In my 40 years of Company service, I have never seen this level of commitment
demonstrated day-to-day, over the whole course of a project, by so many leaders.
That is not to say that we did everything right, exactly to plan, or without incident. Our story will also
share with openness when things did not go right, when things just went wrong; and in some areas
with hindsight, where we would do things differently.
I hope that there are insights for you to learn. I hope that parts of our story re-enforces what you
already know and do. Above all, if there is only one thing that you gain from reading this story that
is new or you will do differently or better that prevents just one person from being hurt, I am sure that
you will agree that reading our story was well worthwhile.
Colin Hunt, CSU HSSE Implementation manager, Pearl GTL (2008 – 2012).

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2. THE CONSTRUCTION SAFETY AND WELFARE STORY AT PEARL GTL
What could have happened
Unmitigated scenario – projected situation
without case for change
What happened
Mitigated situation – performance on
Pearl GTL
■ 25 predicted fatalities
■ 190 Non Accidental Deaths (NADs)
■ NAD rate of 1.2 deaths/1000man
years, or 2x Sakhalin
■ Large number of riots, strikes with potential
impact on progress (+associated NPV impact)
■ Construction fatality
■ 53 Non Accidental Deaths (NADs)
■ NAD rate of 0.3 deaths/1000man
years, a third of what had been anticipated
and over 30% lower than Sakhalin LNG.
■ Limited number of cases of worker unrest
considering size of workforce, no strikes
(no impact on NPV)
Figure 1: Pearl GTL safety performance versus unmitigated projection.
2.2 LEADERSHIP
The Pearl GTL Managing Director and Qatar Country Chairman, Andy Brown, set the standard for
the entire organisation by committing to stay overnight twice per month at the Pearl village where
Pearl GTL workers lived. This commitment was delivered on, not just fine words, but committed action
over the course of the Project.
An overnight stay would allow early morning attendance at tool box talks. Early morning meant a
4:30 a.m. call from bed and being in attendance on site between 5 a.m. and 5:30 a.m. This would
be followed by various engagements with workers over the course of the day as construction work
progressed. Work would be observed, workers would be listened to, and when needed intervention
would take place while maintaining respect.
The style of leadership adopted at Pearl GTL helped to create a culture that would bring closer all
parties involved in construction and in doing so, strengthen values of respect, team work and care for
each other.
2.1 INTRODUCTION
The construction phase that would result in a massive, complex facility being built, involving the toil
of 52,000 plus workers in conditions of extreme heat, humidity, dust, and sand would present major
challenges to face and overcome. Performance measures of cost, schedule, the safety of people,
their welfare and many more indicators framed the challenge ahead. It was however an analysis by
project leadership during the early days of Construction that clearly placed the safety and welfare of
all workers involved in building Pearl GTL as the biggest challenge of all.
Based on the average industry performance, a project the size of Pearl GTL (>500 million hours
worked, 52,000 people on site at peak, >290 million km driven) would result in approximately 25
fatalities. Senior leadership recoiled at this possibility. The reality that potentially 25 people could lose
their lives building Pearl GTL was an outcome senior leadership would not accept. Things would have
to be different at Pearl GTL.
As a start, Senior Project Leadership identified five key focus areas that were seen as fundamental to
achieve performance that all could be proud of. In doing so, the mindset that was quickly developed
was one fatality over the course of construction was one too many. Other things were done of
course, but the pursuit of excellence in the five key focus areas remained a priority.
The five key focus areas were:
■■ Leadership.
■■ Worker welfare.
■■ Communication.
■■ Life Critical Activities (LCA).
Additionally, Shell chose to work with JMJ associates to implement an Incident & Injury Free (IIF)
program. The IIF program was seen as the vehicle to maximise the contribution of the five focus areas.
1. Leadership would be demonstrated by values and beliefs.
2. Worker welfare would incorporate care for people.
3. Training would develop and enhance skills, not just core discipline but also supervisory skills.
4. Communication would be two-way, listening would be a key focus. Recognition of a job well
done achieved through practices and standards that would contribute to people working safely
would be encouraged.
5. LCA were a focus that required strict compliance.
Implementing these contributions would be hard work, particularly each and every day. Senior Project
Leaders were committed to do this.

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Visible leadership was not enough however. To be seen and heard, to listen and respond was
needed, but there was more. As well as leadership visibility, “servant leadership” was identified as
a preferred leadership style. A manager who works tirelessly to put in place the conditions for their
teams to succeed can be called a servant leader. Is focus given to the people doing work every
day the essence of good supervision and management? Senior Project Leaders advocated and
encouraged all leaders within Pearl GTL to behave and interact with their teams in this preferred style,
which was deemed essential and supportive of the culture that was wanted.
It has to be said that not all managers and supervisors on Pearl GTL lived up to this aspiration. That
was the reality we lived in. I am sure that people will not be surprised hearing that. Over the course
of the Project, the fact that the vast majority of line supervisors and managers modified their approach
in how they led their teams is testimony to the cultural journey taken. But this change is not a given nor
does it come easily. Companies bring culture to Projects such as Pearl. To respect different cultures
is necessary but if the shared vision is to create a unique project culture that to some is different,
unusual, or out of the norm of how they carry out work, then it takes great effort, determination
and belief to bring this about. Looking back, the benefits as seen at Pearl far outweigh the effort
expended to achieve this. This was a critical success factor and over the course of the Project played
a huge part in our success. Senior Project Leadership can be proud of what was achieved.
2.3 CEO LEADERSHIP: CEO SUMMITS
Another important initiative was the yearly CEO summits. CEO’s from the contracting companies and
Pearl GTL Senior Leadership came together to discuss the IIF journey and make concrete commitments
to put in place, agreed requirements, and also to pursue future improvements. This resulted in the
development of an “IIF Commitment Charter”. The Charter was signed by all parties and represented
visible support to the vision for Worker Welfare, Training, Leadership, Communication and LCA.
Posters were made of the signed commitment statements and posted around offices, workshops, mass
halls across the entire construction site for everyone to see.
Figure 2: Andy Brown on-site handing out an award on Safety Day.
Leadership visibility demonstrated by Brown, Rob Kretzers, and other members of the Project Senior
Leadership team was fundamental in creating a culture that would support the ambition that every
worker would go home safely at the end of each working day. Acting as role models for other
managers and supervisors, the premise that if Brown, Kretzers et al, could spend time listening and
encouraging the workforce to carry out work safely, to look out for each other and to take pride in
what they were building, then so could they.
I have too often seen Management Teams go through the motions of making commitment statements,
the fanfare of signing such statements and having them posted across a Project. A tick in the box that
a Management Team can say they have done. The real value is living the commitments made. This is
where credibility, respect and voluntary compliance from workers are earned. The Project Team under
Brown and Kretzer’s leadership delivered on the commitments made.
LOWRES
Please provide
better quality

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Figure 4: Sights of Pearl Village.
Countless recreational events were organised every month (>300) to foster team spirit and keep
morale high. Internet and television was widely available, good catering facilities (at peak, more
than 3 million meals were prepared every month), with a variety of diet on offer with good nutritional
value. Cultural sensitivities were observed that took account of religious beliefs.
Daily buses were provided between the village and Qatar’s capital city of Doha, to avoid a sense of
captivity and separation. The village never once suffered a loss of power, sending a strong message to
all residents regarding the level of quality and care Shell was investing in their home away from home.
To keep a finger on the pulse of worker morale, maintain a sense of vibrancy and help people feel
secure at Pearl Village, a support network was established that consisted of 200 “aunts and uncles”
helping and advising those needing and seeking support. The village had a mayor, a dedicated
welfare team, and two professional psychologists. These people were simply amazing and definitely
unsung heroes. Their time and dedication to all the workers who came and lived at Pearl Village
undoubtedly contributed to the success of the Project.
An environment where people feel valued and cared for, an open community where people are free
and encouraged to participate in countless recreational events, helps to create good team spirit and
a sense of harmony. Whilst it is difficult to measure the level of harmony achieved, the village never
suffered any major riots (unlike other worker residential camps of similar size in the region) or labour
Figure 3: CEO summit commitment poster.
The Commitment Charters developed also helped to re-enforce the “One Project, One Team”
approach that had originated from discussions and actions as a result of the IIF journey. Increasingly
and as a result of IIF engagements, visible communication such as the Commitment Charters helped
to convey consistent messages to all contracting companies on the Project. The call to work each day
would consist of one simple message that would stick in everyone’s minds before starting work, –
working safely, caring for each other, and ensuring an IIF free work place.
2.4 WORKER WELFARE
A village was born in the desert of Ras Laffan Industrial City (RLIC), Qatar. This was to be the home
for thousands of workers from many different parts of the world. An incredible 42,000 beds was
provided to accommodate the lion’s share of all workers involved in Pearl GTL construction. The
village, run and supported by 1800 people, was designed and constructed to leading industry
quality standards. This extended beyond just the living quarters; the village was also home to
$13 million worth of sports and entertainment facilities.

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One of the most significant investments in training was the inspired decision to embark on the IIF
journey during the Construction and Commissioning phases of Pearl GTL. As was said earlier in this
chapter, the IIF program became the vehicle that the five key focus areas of Leadership, Welfare,
Training, Communication and the LCA were implemented across the Project and influenced greatly the
Pearl GTL Culture.
2.6 INCIDENT AND INJURY FREE (IIF)
The following is a short summary of Pearl’s IIF Program:
The IIF message was very much focused on generating a safety-conscious mindset and culture to
complement standards and rule based compliance, focusing on:
■■ Convincing workers to ‘want’ to be safe.
■■ Open dialogue and relationship building.
■■ Challenging leaders at all levels to engage constructively with their workers.
IIF Leadership was across all layers of the organisation:
■■ IIF Steering Committee led by Pearl GTL Managing Director.
■■ IIF Leadership Committees in all Asset delivery Teams.
■■ 500 IIF Champions (trained and full-time).
■■ Trained trainers from the line to lead courses.
The IIF message was further reinforced by 6 Safety Days that included evening celebrations, quizzes,
booths and numerous site meetings. The legendary Indian cricketer Kapil Dev was flown in for these
events to re-enforce the safety message; when the message comes from someone who is a true idol
for a huge majority of the workforce, its impact is significantly amplified. This kind of creativity and
understanding of what motivates a workforce is very important when creating a desired culture, an
IIF culture.
On Pearl GTL, it was recognised that HSSE leadership is best demonstrated through passion, energy,
and belief. Pearl GTL’s industry leading safety record during construction has been partly attributed to
the following key leadership behaviours:
■■ Show care and concern for all people, create a relationship on things important to them (e.g.,
children, community)
■■ Show a degree of personal sacrifice (e.g., attending tool box talks at 5 a.m., staying overnight)
■■ Follow-up when people get hurt to show care and concern (e.g., hospital visits)
■■ Hold people who can help the masses accountable (e.g., when a mess hall is too hot – give them
two weeks to fix it and return to verify progress)
■■ Mingle with people at all levels, sit and chat in their rest shelters
disputes that led to work stopping. We believe that there is a strong link between the welfare success
at the Pearl Village and the safety performance on the project.
2.5 TRAINING
On Pearl GTL, a huge focus was placed on training to ensure a disciplinary competent workforce,
good standards of safe working, and an awareness and understanding of the necessary safe
behaviours expected of all our workers. Additionally, opportunities for personal and professional
development were made available. The provision of opportunities for personal development linked
strongly with the work to provide world class welfare facilities for our workers.
In total, 137,000 individuals attended the Pearl GTL Project HSSE Induction course. On top of this,
contractors also ran their own induction courses.
Further, 383,000 HSSE courses were given, covering topics such as confined space entry, working
from heights, PTW, etc… A full listing is given in the Appendices.
To embark and deliver such a huge training load required a variety of approaches. Whilst the
majority of training was delivered by professional trainers at the first class facility built at the Pearl
Village, encouragement was given to a “train the trainer” approach; whereby willing contractor
companies had their own people trained to deliver training to their peers. This approach allowed
Shell and the PMC to deliver the huge volume of training courses identified as necessary to prepare
our workers for the challenges ahead. By adopting this shared approach to delivery we found an
increased level of responsibility and accountability from the construction contractors to their workers.
“Train the trainer” was not an easy option to take and required a lot of oversight to ensure good
quality delivery, but it was definitely a worthwhile approach.
Leadership training was another important element provided to support development of the Culture
that Senior Project Leadership had identified as key: approximately 5,000 contractors successfully
completed the 7+ day supervisor training, consisting of nine different modules and resulting in special
badges (Bronze, Silver and Gold) for the newly qualified supervisors. This training was accredited
(ILM UK Certificated). This Leadership training was organised by Shell, with a commitment from
contractor management to give their employees enough free time to attend the training.
We also organised a number of computer based training courses that were held in the evenings or
workers free time – these were open to all who desired to broaden their knowledge. These courses
were always fully booked!

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The ability to communicate effectively is hard work, but it is essential that you try and get it as right
as you can. Recognising what it takes to effectively communicate and become organisationally skilled
in good communication is an area of focus that Senior Project Leadership at Pearl GTL strived hard
to achieve.
2.8 LIFE CRITICAL ACTIVITIES
The “Life Critical Activities” implemented at Nanhai were adopted for the Pearl GTL Project with some
slight modifications that were relevant to the ambitions of Pearl GTL, e.g., Worker Welfare. It could be
said that the LCA were the pre-cursor to the Shell Groups 12 Life Saving Rules (LSR). Comparisons can
be made. What can be applauded is the clear focus and simplicity of both the LCA and the LSR.
The LCA were:
Road Transportation Excavation
Personal Protection Equipment (PPE) Electrical Safety
Lifting Confined Spaces
Fall Protection Working in Poor Lighting
Scaffolding Falling Objects
Health and Welfare
In order to ensure compliance to the rules, Pearl GTL adopted the approach that “if you choose
to break the rules, you choose not to work for Shell”. This statement of intent clearly indicates the
importance placed by Shell on the safety of people. Justification given to this approach was for the
workforce to internalise the potential consequences of their violations. The loss of life and the impact
that this would have, to family, to friends, was one level of justification. The other justification given
was that as a Project Leadership team, there would be a zero tolerance to people putting their lives
at risk by not complying with the rules. This approach was structurally agreed with all Contracting
Companies at Pearl GTL.
■■ Focus on recognition, make awards personally
■■ Make time for celebrations and unlocking people’s imagination
■■ Invest in people development (leadership training)
■■ Leaders must stretch themselves and leave their comfort zone.
The IIF Program and journey became the glue and context for the five focus areas identified by Senior
Project Leadership to make Pearl GTL Project different from the Industry norm.
2.7 COMMUNICATION
Good communication is difficult. The number of different nationalities and languages and dialects
spoken by workers at Pearl PTL made communication difficult.
For instructional purposes, when rules for hazardous information need to be understood and complied
with, which involves learning critical steps in a procedure, every effort possible should be made to
ensure communication is effective.
Pictures can tell a thousand words and the eyes interpretation can be a reliable form of
communication. The posters provided during construction were stark and left nothing to the
imagination regardless of the workers language skills or level of education. When our posters
conveyed a message we would strive to make it as simple as possible, with few words. Simplicity
does not always look beautiful, but we were not in a beauty contest so simple words were the order
of the day. If the target audience is predominantly Indian, then do not message in English! Do your
homework and confirm dialect sensitivities, but wherever possible communicate to the majority by
respecting their native language.
Workplace communication will normally result in an outcome or action. Whilst listening is important
it is not sufficient to say “yes, I have heard you” with a smile and a nod of the head. Unless listening
promotes a response or action, then the process of communication is incomplete.
Workplace communication about a task or activity needs to be simple and unambiguous. In this
context listening should be focused on confirming understanding. As part of the leadership journey at
Pearl GTL when, for example, leaders attended tool box talks or carried out safety walks observing
people at work, communication with the workforce would be through the use of a simple question set
of what, how and why. These three principal questions and the answers received prompted active
listening and would end in an outcome or action. The action could be to correct or improve on the
delivery of the task or the outcome could be that a confirmed understanding and agreement of the
task delivery. Good communication was essential during the execution of LCA and when the project
went into the SIMOPS phase.

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2.9 STATISTICS
Whilst statistics don’t always tell the whole story, a sample of headline statistics below testifies the
impact of measures taken at Pearl GTL to minimise harm to people. The significance of IIF, (LCA) and
LSR contributed to a project LTIF of 0.12 and TRCF of 1.16, with proud milestones such as:
■■ 8.7 million hours TRC free.
■■ No serious road injuries.
■■ 77 million hours LTI free.
■■ CCIC (contractor) 85 million hours LTI free.
■■ C6 GTL (contractor) 71 million hours LTI free.
2.10 THERE WAS MORE…
The Construction story shared has not told about everything done. Included with this narrative are
attachments that give further in-sight and detail to other work and focus. References are made to Total
Safety Task Instruction (TSTI), to Safety Observation Cards (SOC) and to a simple list of activities and
situations that a Construction Permit (permit to work) was required.
2.11 KEY MESSAGES: FIVE FOCUS AREAS
Leadership Visible, servant leadership.
Incident and Injury Free (IIF).
One project, one team. Project culture.
Welfare Pearl Village, “aunts and uncles”. Village Mayor.
Dedicated welfare team.
Training Discipline competence. Standards of safe working. Awareness and
understanding of safe behaviours expected on the Project.
Leadership training to support desired culture.
Personal development training.
IIF training – convincing workers to want to be safe. Mindset. Open
dialogue, relationship building.
Communication Respect of language/dialect differences.
Visual communication and the use of few/simple words.
Active listening.
Simple set of engagement questions in-line with culture aspirations.
Life Critical Activities 1. Road Transportation, 2. Personal Protection Equipment (PPE), 3. Lifting,
4. Fall Protection, 5. Scaffolding, 6. Excavation, 7. Electrical Safety,
8. Confined Spaces, 9. Working in Poor Lighting, 10. Falling Objects,
11. Health and Welfare
In the event of rules being broken, “just culture” was applied, leading to both formal warnings and
dismissals, as summarised in the following table:
Figure 5: Disciplinary Actions
Pearl GTL was serious about compliance. One of the LSR that was given special attention on Pearl
GTL was road safety. Very early on, senior management understood that a project the size of Pearl
GTL, combined with local road traffic fatality rate that is 8 times higher than that in Europe, would,
without significant intervention, lead to fatal accidents. They took ownership of Road Safety and
developed a Road Transport Safety Case to minimise, and where possible, eliminate exposure to
road safety risks with the following controls:
■■ No self driving for Shell & JK (managing contractor) employees: buses were provided for all
commuters between Doha, Al Khor, Ras Laffan and the Pearl Village.
■■ Driving private vehicles to and from work (with the exception of people living and working in Doha)
was prohibited. This approach saved 30 million km of road travel.
■■ Pearl GTL constructed its own $30 million material unloading Jetty, avoiding the need for more than
120,000 additional lorry loads.
■■ Performance was monitored in more than 5,000 vehicles using the In Vehicle Monitoring System
(IVMS), which flags unsafe driving.
These initiatives resulted in 290 million km driven for Pearl GTL, with NO serious injuries. A great
example of how identifying and mitigating specific risk areas can massively benefit a project’s overall
safety performance.
LCA
3047
4118
705
1
1
57
232
118
24
94
7411
11
12
6
7
29
68
1
16
7
2
4
3
9
7
Verbal
Written
Dismissal
Total
3131
4512
1021

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3. HSSE IMPLEMENTATION IN A PROJECT ENVIRONMENT: A PERSONAL PERSPECTIVE
Try not to be a “Safety Policeman”. Whilst at times you may want to tell people what to do, to
order people to work safely, this type of approach does not work in the long run. Such a mentality
would result in the creation of safety programs that restate the same old regulations and policies that
have been written countless times before. Such safety programs become the domain of the Safety
Policeman that only they read and understand.
This kind of safety approach doesn’t make sense. It doesn’t mean forget everything that you have
learned in the past or that has worked well in similar situations, but the mindless regurgitation
of programs, procedures, regulations and rules without understanding the context of the current
challenge; getting the feel of a Project, sensing the prevailing culture, understanding the current level
of performance and practices of workers and their companies, such an approach simply does not
make sense.
Safety as a program to inflict on an organisation, on a project, does not make sense. Safety as
a principle, as a value, as a part of nature does make sense. This is where a safety professional
coming to a project should start. Focus should be given on how to inculcate into individuals the value
of wanting to protect themselves. If people can look after themselves, they may be willing to look out
for others. When all people on a project can accept personal responsibility for safety, working (and
living) safely ultimately becomes a project wide value and culture. Some may recognise this as an
“Interdependent Safety Culture”, and it is.
This is where a CSU HSSE (Safety) manager should start. It is our job (and others of course) to
promote this collective responsibility. To meet this goal, safety professionals have to stop thinking like
policemen and start recognising their role as advisors who empower people to work (and live) safely.
The inevitable safety program then becomes a direct extension of these principles, with the important
context of knowing where your project is in its journey; wherever possible, keep the program/training
language simple with clear phrases.
Safety instructions need to be clear and make sense. If it does then most of our workers will do
what they are supposed to do, most of the time, without you having to tell them to do it. Voluntary
compliance is essential; otherwise a safety program will not deliver its purpose successfully. .
When I arrived in Qatar in 2008, the Project was 18 months into construction. To my delight, senior
project leaders had already realised that ‘safety had to make sense’. They were just embarking on
an IIF journey. As mentioned, in the “construction experience” chapter of this book, project leadership
had also identified five key focus areas as a strategy to deliver world class safety and welfare for all
workers. The steps taken made sense.
3.1 INTRODUCTION
As a CSU HSSE Manager or HSSE lead during a Project, you have a lot of influence; you are in a
position of responsibility and most importantly will be looked to for advice, guidance, leadership in
your expert field, and the tangible and practical support you can give others to share and resolve
issues. You need to bridge the world of Construction and a Construction organisation and the very
different world of Commissioning and a Commissioning organisation.
Your previous experience will shape your view on work, how you believe work should be done. Your
own personal values and beliefs will also impact the way that you will set out to ensure that HSSE in
transition from Construction into CSU proceeds without incident. Whilst you should use your previous
experiences to guide your views on how things should be done, remember that there will be others
with different experiences that should be respected and if you listen, can give you new insights. My
warning though is there are limits to the number of different views on such matters that you can and
should heed. This is a conundrum that you can only manage before taking action to proceed; this
requires judgment.
Relationships with people through project transition are critical. It is through people that work gets
done. As a CSU HSSE Manager you will need to influence and build relationships, guide and advise
the project organisation so that the safety journey for all on the Project makes sense. Sometimes
relationships prove difficult. Use your professionalism to focus on end results. Strive to secure
relationships that achieve shared goals.
As a starting point from the generalities I have spoken about, I would suggest that one of the first
things that a CSU HSSE Manager/Safety Lead should establish is:
3.2 START MAKING SENSE
On a Project you are never far away from schedule pressure. Depending at what stage you join the
Project, be it at the start or end of construction, as a “CSU” HSSE (or safety) manager you will help
the project organisation navigate through the phases that come during and after construction through
to start-up. To do this, you must understand the nature of work specific to each phase, the different
hazards and risks prevailing. It all sounds complicated, and whilst it is, as a manager you have to
make sense of the current state and prepare for the next transition to come. It’s important to try and
make things as simple as possible.
I have been in the company of many safety professionals, and not all of us make sense, well not in
the way that I think we should go about our jobs. So how do you do this, where do you start? Let me
start by saying what you should not do, and what you should try not to be.

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We can all, relatively experienced and less experienced, benefit from a more rigorous and
independent assessment of proposed implementation plans. Focus would concentrate on examining
the strategies to achieve the plan. Strategies articulate the how implementation will be undertaken.
I would also advocate that examination involves testing and inspection. Inspection and testing is
as relevant for the work and function of people as it is for hardware. This is the fertile ground that
experts, expert teams from outside of the immediate project can add value and support. Such an
approach becomes more learning centered; food for thought.
In the context of my role and future contribution, my job had been made much easier as the ‘right’
safety and welfare philosophy was being pursued. My efforts could now concentrate on making sure
that this would be continued during commissioning and into start-up. I could also start to pay attention
to other necessary work I held responsibility for.
3.3 WHAT ELSE?
Over the following chapters, reference will be made of the main work I became involved with as the
CSU HSSE manager, which can vary from project to project. The good news is that as CSU HSSE
managers/safety leads, we do not embark on this journey alone. There are stated requirements,
standards and procedures that can guide this journey. Our tasks and accomplishments have been
written in a variety of documents by expert teams within the Company.
In addition to what’s written, there is also a network of subject matter expert teams. Numerous teams
cover all /most of the topic areas detailed in the HSSE Control Framework. If we as CSU HSSE
managers do not entirely understand what is written in the library of HSSE documentation available,
or further explanation is required, such teams and the various corporate wide HSSE Focal Points can
advise and make sense of the documents. (So the theory goes!)
My experience of leveraging such expertise is mixed. This in part (a large part) is of my own doing.
I do not look for fault elsewhere but look at my own inadequacy to capatalise on this expertise.
What I would like to see, however, is a discussion on the type of business model that can be best
utilised to leverage expertise within the Shell Group. I am suggesting that the current situation can be
improved. Contact and exposure to experts at time of audit, gate/stage reviews, etc. is insufficient
and too formal.
That being said, most of the documentation available (and there is a lot of it), focuses on describing
“what has to be done”, setting requirements and meeting standards; this is necessary, helpful and
gives direction. Allied to the network teams one could argue that adequate resource is available to
managers that will implement HSSE in a project environment.
I personally would have benefitted from perspectives on “how” to implement stated requirements and
meet standards. I do not think that I was active enough to leverage the expertise of the Subject Matter
Expert (SME) teams. I had experience of implementation during my time at Stanlow and during the
CSU of the Nanhai Petro-Chemical complex in China. I had achieved a reasonable level of success,
so that was it; I would pursue the same, tried and trusted path of implementation.

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4. HSSE CULTURE TRANSITION FROM CONSTRUCTION INTO CSU
values, behaviours, and mindset had to be consistent. Whilst the rules would change to reflect the
changing hazard profile, the other enablers to culture would be continued:
Leadership, welfare provision, communication, training and dependent on the Project phase, LCA or
Life Saving Rules.
GENERATIVE
HSSE is how we do business
round here
PROACTIVE
We work on the problem that we
still ﬁnd
CALCULATIVE
We have systems in place to
manage all hazards
REACTIVE
Safety is important, we do a lot
every time we have an accident
PATHOLOGICAL
Who cares as long as we're
not caught
Increasing
Trustand
Accountability
Increasinglyinformed
Figure 6: Cultural ladder.
4.1 CONSTRUCTION HSSE CULTURE: IIF
Much has already been said in this book about the construction HSSE culture as described by the IIF
journey and the five key focus areas of:
Leadership,
Welfare,
Training,
Communication, and
Life Critical Activities (LCA).
The way work was carried out during Construction, the way that people interacted, whether to inquire
or to intervene, the rules applied, the discipline shown, how engagement between people happened,
care for self and others, all contributed to the working culture that could be felt and visibly seen.
Using a very simple definition of culture; “The way things are done and seen to be done”, then
what was seen and carried out during construction was not just relevant to the hazards and risks
prevailing, but much, much more. As a simple example, whilst building the plant, structures at height
would be incomplete, therefore it was a Construction rule as communicated via the LCA, that any
person working from height (> 1.5 m) would only do so wearing a lifeline and harness, which would
require tie-off. Now whilst this makes sense, if you’re working above ground without other appropriate
safeguards, it was a construction rule from a specified point during the project that all workers
working on the construction site would wear a lifeline and harness, regardless of whether they were
at height or not. A lifeline and harness for this period became standard PPE. To some this may seem
an over-reaction. If the means justifies the ends, then at Pearl GTL there was no fatality or major injury
from working at height. There was no ambiguity. The focus instead shifted to making sure that when
workers were at height during this period then appropriate tie-off was ensured.
This particular element of the working culture during Construction would be modified as parts of the
plant were subject to Commissioning controls. As sections of the plant were handed over into the
Commissioning organisation, the risk profile changed. Working at height on completed structures with
handrails, etc., would no longer require a lifeline and harness to be worn as standard PPE. We were
now experiencing HSSE controls in transition. This had to be managed carefully.
The “one team, one project” cultural ambition, plus the essential mindset and behaviours that came
about from the IIF journey describes the Construction HSSE Culture. This culture was a day-to-day
focus. It was something that had to happen every day. The end point of the construction HSSE culture
was when the last construction activity was completed. In many cases and situations towards the end
of Construction this would mean construction activities being completed in Commissioning controlled
areas, where commissioning rules applied. Cultural transition was essential to keep people safe. The

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■■ Follow up when people get hurt to show care and concern (e.g., hospital visits).
■■ Hold people who can help the masses accountable (e.g., when a mess hall is too hot – give them
2 weeks to fix it and return to verify progress).
■■ Mingle with people at all levels, sit and chat in their rest shelters.
■■ Focus on recognition, make awards personally.
■■ Make time for celebrations and unlocking people’s imagination.
■■ Invest in people development (leadership training).
■■ Leaders must stretch themselves and leave their comfort zone.
Would be continued…
The decision to continue with the Incident and Injury Program and maintain a clear focus on the
five key areas of leadership, welfare, training, communication and LSR during Commissioning made
sense.
Construction
Rob Kretzers
Marty Schweers
Project Man.
IC/EPCM
(Const. Manager)
Constr. PTW
Construction
Rob Kretzers
Marty Schweers
Project Man.
IC/EPCM
(Comm. Manager)
Comm. PTW
Comm. HSSE
LSRs
Operational
Utilities S&P
Rob Kretzers
Steve Johnson
SU Leader
Shell
Shell MS
Shell HSSE Rules
LSRs
Shell PTW
SU Leader
Shell
Post Handover
Roel Cornelisse
Steve Johnson
Comm. PTW
HSSE Authority
Operational control
Safety Disctrict Owner
HSSE Control
Constractor’s MS
Project HSSE Rules
LCAs
PTW
Figure 7: Leadership Transition
Individual and company HSSE performance can perhaps best be assessed on the following scale,
known as the “cultural ladder,” which progresses with increased information, trust and accountability:
1. Pathological - Who cares as long as we’re not caught?
2. Reactive - Safety is important. We do a lot every time we have an accident.
3. Calculative - We have systems in place to manage all hazards.
4. Proactive - We work on problems we find.
5. Generative - HSSE is how we do business.
World class HSSE performance requires more than mechanically applying a management system. It
requires involvement of an entire organisation - from top to bottom. This involves three key elements:[
■■ Personal responsibility - understand and accept what should be done and what is expected.
■■ Individual consequences - understand and accept there is a fair system for reward and discipline.
■■ Proactive interventions - work safely because it is the right thing to do, want to make interventions
and actively participate in improvement activities.
4.2 COMMISSIONING HSSE CULTURE: IIF
The Project’s IIF journey continued into commissioning. Why not?
The IIF message was very much focused on generating a safety-conscious mindset and culture to
complement standards and rule based compliance, focusing on:
■■ Convincing workers to ‘want’ to be safe.
■■ Open dialogue and relationship building.
■■ Challenging Leaders at all levels to engage constructively with their workers.
IIF Leadership was across all layers of the organisation:
■■ IIF Steering Committee led by Pearl GTL Managing Director I.
■■ IF Leadership Committees in all Asset delivery Teams.
■■ 500 IIF Champions (trained and full-time), - (IIF Champions would be maintained but not in the
same numbers due to the reducing workforce).
■■ Trained trainers from the line to lead courses.
HSSE leadership as demonstrated through passion, energy and belief would continue. Pearl GTL’s
industry leading safety record during Construction would be seen with pride and a demonstration of
what could be achieved in Commissioning. Leadership visibility, as demonstrated by:
■■ Show care and concern for all people, create a relationship on things important to them
(e.g., children, community).
■■ Show a degree of personal sacrifice (e.g., attending tool box talks at 5 a.m., staying overnight).

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would also be a significant and distinctive change to the Project landscape. This “red army” was the
future Shell operators and technicians who would support the commissioning work to come.
Perhaps the most distinctive feature to appear on the Construction landscape was the kilometers
of fencing that started to be erected across the Project to physically separate construction and
commissioning activity. This fencing stood 2 m tall. Purple tape was wrapped around this fencing with
posters that showed a caged tiger (see Figures 8 and 9).
Purple became the colour of commissioning activities. The caged tiger was symbolic and represented
the hazards of commissioning and the message that commissioning hazards were potentially
dangerous and could result in serious harm. The caged tiger represented the same potential danger,
if released in an uncontrolled manner, the “tiger hazard” could harm.
Figure 8: Commissioning Tiger.
Fencing was insufficient as the only physical barrier to restrict access to a Commissioning area. All points
of access and egress were guarded. Guards were trained to collect and check commissioning badges.
These badges had photographic proof of identity and were only given to workers after they had attended
commissioning induction training. In addition, guards would collect mobile phones, lighters, matches and
other potential sources of ignition before entry was granted. Guards would know how many people had
gained access into a given commissioning area as all ID badges were retained at the entrances. Badges
were collected by workers when leaving fenced Commissioning areas after work was completed.
As can be seen in (Figure 7), the decision to maintain the key elements that contributed to a successful
culture being established in construction and relevant for commissioning was helped by the unified
transition of people and organisational control. The exceptions to this as can be seen in (Figure 7) is
the HSSE Management System and Plan, the transition from LCA rules to LSR and PTW transition from
a construction to a commissioning environment.
To support this transition we had to put in place safeguards that would demonstrate to all workers
that working in a Commissioning area was different than Construction, what was different, what
precautionary measures would be mandated and why? We communicated simply (with as few words
as possible) with pictures and posters, in the main languages prevailing, and through the enormous
efforts during Induction training for all workers due to work in commissioning areas.
The change of requirements and rules that would accompany transition through the phases of the
project would need careful consideration so that clarity was given. Particularly vulnerable would
be workers who had worked in Construction and would now be asked to carry out work in
Commissioning areas. Control requirements were very different. We had workers, worker teams
working in a Construction environment one day and a Commissioning environment the next. This had
to be managed. Tool box talks each and every day were given and were essential. They focused
on the work to be done, how work was to be done, what could go wrong and with increasing
importance as the project transitioned, where this work would be carried out, in a Construction or
a Commissioning controlled area. Emphasis would then be given to what controls needed to be in
place, why, and the discipline needed to comply at all times.
Making sense of such stated precautions would be given and supported by constant reminders to all
that safety was their responsibility. Additionally, workers were reminded and encouraged to look out
for the safety of their fellow workers.
As transition progressed, elements of the working culture changed. Whilst some Senior Leaders
would transition through the phases of Construction into Commissioning, some would leave and new
people arrive. Leadership demonstrated during Construction and the preferred Leadership style would
continue through Commissioning. Welfare standards would be maintained. In the areas of Training,
Communication and LCA a changing emphasis would be demanded. As an example, during
Commissioning, emphasis would be given to the LSR.
Whilst it has already been stated that the main elements of the Construction culture were relevant
and continued in Commissioning, things changed in what workers started to see, how work was
controlled differently, how access requirements to enter and work in a Commissioning area were
different. What seemed like a “new” army of people all wearing the same uniform of red coveralls

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Construction work could still be carried out in commissioning areas, but would be subject to a more
rigorous regime of commissioning control. The decision to declare a commissioning area was not
taken lightly, and in certain cases individual lines were wrapped in purple tape and barricaded.
Similarly, commissioning zones within a bigger construction area were established and in only these
zones would commissioning rules and control be applied. A pragmatic but controlled transition would
be pursued.
The Commissioning organisation took responsibility for zones and areas of plant and equipment and
all work carried out on plant and equipment in zones and areas under commissioning. This was a
major change. Hazards that were invisible to the naked eye under hot pressure could move silently
from one part of the Plant to another by the operation of a valve that demanded a level of oversight,
control and permission different from what had been seen in general during Construction.
Rules and compliance had been a requirement during construction. Rules and compliance became a
point of work control in Commissioning to a degree greater than had been seen during Construction.
To help manage an increasing rule based and compliance driven culture, commissioning work would
increasingly become subject to a simple control philosophy that asked consideration of:
■■ Supervision,
■■ Standards,
■■ Surveillance,
■■ Separation,
■■ Synchronisation,
■■ Planning,
■■ Preparation, and
■■ PTW.
This was referred to as the 5S and 3P framework. This will be further discussed in the SIMOPS book.
4.3 START-UP HSSE CULTURE: GOAL ZERO
Transition from a Commissioning HSSE culture to a culture relevant for the start-up of plant and
equipment of Pearl GTL involved a continuation of what had been established in the previous phases
and an appreciation and level of preparedness of what was to come. In addition, a detailed
knowledge and understanding of the hazards and risks of starting up plant and equipment and
thereafter daily operating and routine maintenance at Pearl GTL would drive the cultural journey. As in
commissioning, levels of permission to access and carry out work would be subject to strict rules and
standards during start-up of the plant and for future operation.
Do not let the Purple Tiger out of the Cage
Chemicals
Steam
Fuel Gas
Hot Water
Do not touch any Valve,
Spade or Blind
Do not cut any
Commissioning Pipe
without Permit
Purple Pipe ==
Purple will
Bite you
Figure 9: Commissioning Tiger Information.
For those workers carrying out physical work, not just visiting the area, a PTW would be required.
The permits issued would identify hazards assessed with the proposed work and the environment that
the work was to be carried out, in addition to stipulating control measures designed to reduce risk.
Observation of workers and compliance to controls stated on permits in Commissioning areas was
a daily activity. The application of PTW was very different for areas under Commissioning than had
been experienced during Construction.
The decision point of when to declare an area a “Commissioning Area” and as such subject to
commissioning controls would come when the main prevailing hazards, risk profile and major
consequences were resultant from commissioning activities. A formal walk-down of the area and
an assessment of its commissioning readiness would be made by an independent team of HSSE
Inspectors and area representatives. A punch list of outstanding work would be made. The punch
list would form the basis of an assessment and agreement for a zone or an area to transition from
Construction to Commissioning control.

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LSR are an integral part of the total rule set that all people working and visiting Pearl GTL must comply
with. In addition, Shell’s golden rules of “comply, intervene and respect”, are behavioural imperatives
of the HSSE Culture required and expected. There is also site and local area rules that are defined to
instruct, clarify, and give direction to all who come to work or visit Pearl GTL.
The HSSE cultural journey continues at Pearl GTL. There are values and behaviours that all are asked
to commit to. The focus areas originally identified by Project Senior Leadership in the early days
of Construction are retained. The rule set and work permissions are aligned to the expectations as
detailed in the HSSE Control Framework. Goal Zero is now the vehicle that drives and builds further
the Pearl GTL culture.
Pearl GTL values and beliefs statements can be found in Attachment 4.2.
The beliefs, values, and mindset that had been so successful in developing a very positive and
enabling HSSE culture during Construction and Commissioning IIF would be carried forward by the
“Goal Zero” journey that everyone in the Shell Group now pursue.
Leadership visibility and the close connectivity with front line workers, Shell workers or Partner
Contractor Companies, remains as a key focus as it did in Construction and Commissioning. A
strong belief in Servant Leadership as lived daily by Brown, Wael Sawan, Roel Cornelisse, Steve
Johnson and their management team can be seen and felt. CEO’s from the main Partner Contractor
Companies are invited annually to meet, discuss, and commit to the safety and welfare of their
people working at Pearl GTL. This continues the approach started in Construction.
The huge camp that was once home to the vast workforce during Construction and Commissioning is
in transition. However, welfare provision for all non-Shell workers is a contractual obligation for Partner
Contractor Companies. Management of this provision is applied to ensure standards are maintained
and any issues resolved in timely manner.
Communication is given in an open and honest way. Listening to the concerns and issues of front line
staff is actively pursued both formally and informally. Feedback from conversations that take place
during Goal Zero engagements and walks around the site are reflected upon by teams and an
emphasis to take necessary action, if applicable, is given. “No” is an acceptable answer in some
conversations, given with reason and respect.
Continued emphasis is given to the discipline competence of all who work at Pearl. During 2013,
a huge effort is being given to the development of Front Line Leaders, and a core component of
this development training is HSSE; this includes Process Safety. The content and design of this
development training is given in Front Line Leaders Development Training Materials (Attachment 4.1) in
this book

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5. HSSE MANAGEMENT SYSTEMS IMPLEMENTATION
accommodated. A “freeze” on new or updated standards was taken. This was necessary. This
allowed documentation to be taken to a point of readiness to use. In parallel, a gap analysis was
maintained which would be subject to address at an agreed point. For Pearl GTL this was particularly
sensitive as the HSSE Control Framework standards started to be issued circa 2008 and on.
It was at this time that I had just joined the Project and was starting to prepare for the development
of the Operations HSSE Case, and the HSSE Manuals and Procedures that would follow. It was
necessary to freeze standards for implementation; aiming at a moving target does not make for effective
or efficient development work. This approach adopted by Pearl GTL was communicated appropriately.
At this point I would like to make reference to an operational set of standards that are particularly
important and an area of implementation that people at Pearl GTL worked hard to deliver. These
standards come under the umbrella title; Ensure Safe Production (ESP).
ESP is one of the business processes under Global Asset Management Excellence (GAME). ESP is a
basic, standardised, operational work process that ensures operation (of a processing plant) within
well-defined, well-understood limits. Operation within these limits is continuously achieved through
a defined and well-followed set of operational and organisational behaviors at all levels. ESP’s
main principles are shown in Figure 10 below and it is implemented by its sub-processes which are
described below:
■■ Initial Setup to gather all constraints, limits, responses in a central database.
■■ Validate targets to ensure no one can make demands outside of safe limits (across any interface to
operators).
■■ Monitor and control conditions to manage everything in the shift-to-shift work process.
■■ Learn and improve in a structured way, supported by tools. This ensures that the desired
behaviors “sticks forever” by engraining formally in management systems and people’s personal
accountabilities.
The ESP process is described in more detail in the ESP section of Attachment 5.1 – Standards.
5.1 INTRODUCTION
I will talk later in this chapter how HSSE MS was developed and transitioned in each of the phases
of the project.
I would first like to start by describing the main steps to take to develop a HSSE MS, the context and
considerations. I will talk about standards and the importance of the HSSE Manual. The processes of
hazard identification, risk management and the assignation of people to carry out tasks and activities
deemed critical to maintain barriers from threats. This work forms part of the HSSE Cases developed
for Pearl GTL. A rule set that includes the Life Saving Rules (LSR), Golden Rules, Asset Rules and
Area Asset Rules. A set of procedures that describes how to apply and implement critical processes
identified as part of HEMP. Finally, the role of the annual HSSE Plan developed throughout the
phases of the Project into the Plan and Journey Book of the Run and Maintain organisation.
5.2 STANDARDS
Standards are at the heart of the development of the Pearl GTL HSSE MS. This was our starting point.
Shell Group standards were core but other standards applicable to ensure Pearl GTL complied with
regulations applicable to Qatar and RLIC were ensured. Examples of such standards included:
■■ Shell HSSE Control Framework (although in 2008 this work was still in its infancy).
■■ Applicable Qatari statutory requirements, including international agreements and protocols to which
Qatar is a signatory.
■■ Qatar Petroleum/RLIC requirements,
■■ Internationally accepted industry norms and standards (e.g., API Recommended Practices,
IP Codes) as defined in the HSSE/SD premises for the project.
■■ Guidance from international institutions and organisations (e.g., WHO).
The standards applied at Pearl GTL for HSSE can be found in (Attachment 5.1 – Standards). The
Project adopted HSSE/SD standards for the implementation phase as specified in the Project Guide
1B (SGSI) which can be found in (Attachment 5.2 – Shell Guides). The standards for the Run and
Maintain organisation are defined in the HSSE/SD premises for the Operational phase.
To ensure that compliance to standards was met, a process and assigned responsibilities was
implemented so that new, and changes to requirements applicable to Pearl GTL were known and
addressed in a timely fashion.
Over the life of a project, particularly projects of the size and duration of Pearl GTL, care should
be taken to adopt an appropriate and pragmatic approach in the development of documentation
derived from stated requirements in standards. When an organisation is developing a Management
system in a project environment there is only so much change to standards that can be

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Policy and Objectives
■■ Adopt the Group HSSE Policy and Commitment.
■■ Establish, implement and maintain measurable HSSE objectives and targets, and integrate them into
business plans.
Organisation, Responsibilities, Resources, Standards and Documents
■■ Establish and maintain an organisation that delivers HSSE requirements and effective HSSE
management.
■■ Define and assign HSSE roles, responsibilities and authorities to individuals.
■■ Ensure personnel have the competence needed to perform their HSSE roles and responsibilities.
■■ Identify HSSE critical positions and ensure that individuals in these roles are competent.
■■ Maintain HSSE information that is current and readily available.
Risk Management
■■ Identify HSSE-critical activities and their associated hazards and effects, assess the risks and select
controls that manage them to ALARP.
■■ Manage changes to facilities, processes and organisation to ensure continued risk management.
■■ Apply Product Stewardship throughout the product life cycle.
Planning and Procedures
■■ Incorporate HSSE requirements into Business and Operational Plans and Procedures.
■■ Maintain procedures and work instructions for HSSE critical activities.
Implementation, Monitoring and Reporting
■■ Implement requirements to meet objectives and targets.
■■ Establish and monitor HSSE Performance Indicators and take action to improve.
■■ Log, investigate and learn from incidents.
Audit
■■ Provide assurance that all elements of the HSSE Control Framework are in place and effective using
a risk-based Assurance Plan.
Management Review
■■ Regularly review the suitability and effectiveness of the HSSE Control Framework and implement
opportunities for improvements.
Managing Abnormal
Situations
Console Op
Proactive
Outside Op
Proactive
Safe Limits
Database
Validated Targets
User Deﬁned
Alerts
Start of Shift
Orientation
Shift Handover
Shift Team Meeting
& Planning
End of Shift
Reporting
Figure 10: ESP Pyramid.
5.3 HSSE MANUAL
After the appraisal of relevant standards to apply and comply with, the work of meeting stated
requirements can start. What should be recognised is the procedures, rules, guidance, plans, job
aids, etc., that all come together to make up the HSSE MS should have context. Developing an
effective HSSE MS requires consistency in approach, the use of complimentary language and
where appropriate, reference and linkage. The ability of non-HSSE professionals to easily navigate
documents that are parts of the sum that is the HSSE MS should be the benchmark.
The HSSE Manual is the principal document describing the organisation and arrangements to deliver
HSSE performance. A good HSSE manual does this in the context of the hazards and risks of the
entity. What is written in this manual and how it is written is critical. People at a site, on a project
should recognise what is written in a HSSE Manual. Simplicity is key.
The main sections of the HSSE Manual are:
Leadership and Commitment
■■ Leaders create and sustain an organisational culture that supports effective HSSE management
through their personal behaviour.
■■ Leaders demonstrate commitment and leadership to HSSE through measurable actions.
■■ Leaders ensure HSSE Requirements are communicated and understood at all levels.
■■ Leaders insist on compliance with HSSE Requirements and take appropriate action to
correct deficiencies.

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Operations HSSE Case
■ Identify hazards in all areas and rate using RAM
■ Identify High Risk and Severity 5 Hazards
■ Analyse hazards (step 3) using HEMP tools to
check if operational controls reduce risks to ALARP
■ Identify remedial action and execute
■ Document
■ HSSE Critical Tasks
■ HSSE Critical Elements
SU &
Operations
Commissioning
Construction
Pearl GTL HSSE-MS
Design
HSSE Case
Figure 11: Operations HSSE Case
These eight sections that comprise the HSSE Manual are the basis and fundamentals to implement
HSSE Governance.
5.4 HSSE CASE(S)
HSSE Cases were developed for the Design, (Design HSSE Case), for the Operation (Offshore and
Onshore Integrated Operational HSSE Case) and for Road Transport (Road Transport HSSE Case).
Pearl GTL Design HSSE Case can be found in Attachment 5.3 – Construction. The responsibility to
develop the Design HSSE Case was the Technical HSSE Manager and Technical Engineering team.
The Operations HSSE Case can be found in Attachment 5.4 – HSSE Ops Cases. The responsibility
to develop the Operations HSSE Case was the CSU HSSE Implementation Manager.
The Road Transport HSSE Case can be found in Attachment 5.5. The responsibility to develop the
Road Transport HSSE Case was the Transport Safety Advisor.
The HSSE Cases are fundamental to demonstrate that Risk Management has been applied. The
development of HSSE Cases is a major piece of work. Management of the process to ensure
appropriate rigor, consistency of approach, the participation of appropriate trained and competent
people, provision of experts as needed and more, is essential. The vital importance to ensure that the
cases are kept evergreen should be clearly documented in the HSSE Manual.
Below (Figure 11) shows how HSSE has been implemented in the design of Pearl GTL and translated
into construction. During the start-up of Pearl GTL, all HSSE risks and hazards were identified and
assessed and all safety critical tasks and elements were documented to become part of the Pearl GTL
HSSE-MS as shown below.

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The asset rules are framed to target the following:
Asset Rule Types
1 Rules for Every Person Entering Site 6 Entry into High Risk Areas
2 Moving Around Site 7 Operations Rules
3 Precautions for Entering Plant/Unit Areas 8 PTW Rules
4 Use of Equipment and Materials 9 Management of Change Rules
5 Driving On Site
Figure 13: Asset Rule Types
The rules within each of the categories mentioned above are in the asset rules document in
Attachment 5.6 – Critical Processes.
5.6 CRITICAL PROCESSES – PROCEDURES
What is critical? The processes identified as barriers to threats during HEMP meet this definition. It is
to these processes that a high importance for implementation is attached. These are the processes I
concentrate on first to establish a minimum level of control. They are:
■■ Permit to Work (PTW),
■■ Management of Change,
■■ Incident Management,
■■ Emergency Preparedness and Response,
■■ Contractor HSSE Management,,
■■ Safe Place, Safe Person,
■■ Safety District ownership,
■■ Training and Competence (limited to Critical Process implementation),
■■ Asset Rules, and
■■ Asset Induction.
Procedures to implement these critical processes can be found in Attachment 5.6 – Critical Processes.
In addition, further comment on the implementation of the critical processes will be given later in this book.
5.5 RULES
5.5.1 Life Saving Rules and Golden Rules
The LSR and Golden Rules are Shell group wide mandatory requirements.
Figure 12: Life Saving Rules
The Golden Rules are:
■■ comply with the law, standards and procedures.
■■ intervene on unsafe or non-compliant actions.
■■ respect our neighbours.
The HSSE Golden Rules are about changing how we act. They are three rules that give a framework
for how we must all behave all of the time, in every operation and activity, if we are to achieve
further improvement in our HSSE performance. The thinking behind the rules is well established
in many of our HSSE programmes such as Hearts and Minds. They also fit well with important
new Group initiatives such as Enterprise First – with its emphasis on leadership, accountability and
teamwork - and compliance.
5.5.2 Asset (site wide) Rules
In addition, Pearl GTL has a set of asset (site wide) rules mandatory and applicable to all personnel
working at Pearl GTL. This rule set can be found in Attachment 5.6 – Critical Processes.

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As can be seen from what is written above, HSSE Plans were written through transition of the different
phases of the Project; so that these Plans represented a consistent approach, main objectives were set
that prevailed throughout all phases. These main objectives included:
■■ Visible and felt HSSE Leadership,
■■ Flawless Construction and CSU/SIMOPS HSSE interfaces,
■■ Simplified HSSE systems to enable compliance,
■■ Effective Stakeholders Engagement.
To achieve these objectives, Pearl GTL identified focus areas and deliverables which are summarised
in Table 3 below. These focus areas and deliverables would take into account the stage of the Project
and were updated annually. (Refer to Attachment 5.8 – HSSE Plans).
Focus Area Deliverables
Leadership ■■ Visible and felt leadership through effective communication of common
shared values on Safety.
■■ Establishing a strong compliance mind-set.
■■ Recognising performance achievements.
■■ Transition IIF program to CSU/Asset Team.
■■ 2 Safety Days per annum used to energise project personnel.
Environmental
Performance and
Control
■■ Achieve environmental Consent to Operate.
■■ Implement compliance/emissions reporting.
■■ Finalise Hazardous Waste Management Plan and work with RLIC to
establish long term solution.
■■ Oil Spill response preparedness in place and drilled.
■■ CO2
Pilot Project taken to FID.
Road Safety ■■ Maintain implementation of Road Safety standards through Land
Transport Policy/HSSE Case.
■■ Develop site Transport Plan.
Contractor HSSE
Management
■■ Contract Holders to develop and implement robust risk based HSSE
Plans. This to include mobilisation plans for new contractors (for Support
Services, Project and Production contractors).
■■ Formal surveillance program in place to monitor compliance and drive
performance improvement.
Worksite Hazard
Management
■■ Identify Workplace hazards from across Shell Group and embed in to
work instructions and practices to reduce incidents.
■■ Operationalise output from HEMP and assure effectiveness of controls.
5.7 HSSE PLANS AND JOURNEY BOOK
HSSE Plans are a statement of what the organisation wants to achieve in a defined period of time.
They are recognisable through the objectives set, the (key) Performance Indicators that monitor,
measure and report on progress. Furthermore, the main strategies and actions chosen to achieve
objectives are defined, resourced and allocated responsibility.
Good plans satisfy the What, When, Why, Where, Who and How. Good Plans are simple. Plans
are subject to review and when plans are assessed as not meeting expectations then they should be
subject to adaptation. Plans should take account of the ambitions of the organisation, but should be
realistic and cognisant of the capabilities available to deliver. A plan should create tension to achieve
but not be too unrealistic. It takes skill to develop a good plan. It is not an administrative exercise that
collects a number of actions to do. How good is your HSSE Plan?
The HSSE Plans developed and implemented during the phases of the Project contributed to an
excellent Project HSSE performance. The following narrative gives a brief description of the HSSE
Plans for each phase of the Project.
Construction HSSE Management Plan: Procedures required for the IC, EPCM, Early Works
Contractors and sub-contractors during the construction phase of the project. This procedure was
prepared by the PMC (refer to Attachment 5.3 – Construction). This plan was updated annually
throughout the phase of construction. HSSE has been implemented in the design of Pearl GTL and
translated into construction (refer to Attachment 5.3 – Construction).
Commissioning HSSE Management Plan: The PMC Commissioning HSSE Management Plan was
developed to provide instruction and guidance to IC/EPCM regarding activities during CSU that had
a HSSE consequence. (Refer to Attachment 5.7 – Commissioning). This Plan was updated annually
during the phase of commissioning.
Asset Operations HSSE Management Plan: This is applicable during the normal run and
maintain phase. The permanent Shell Operations and Maintenance teams, house contractors and
subcontractors are subject to the aims and objectives of the Plan. They participate in the delivery of
the strategies and actions detailed in the Plan (refer to Attachment 5.8 – HSSE Plans).
The Journey Book sets out a longer term direction and strategy, a 5-year horizon with an annual
update plan (refer to Attachment 5.8 – HSSE Plans).

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The measures included in the focus areas and deliverables were monitored against targets set and
assessed using a simple set of criteria – “good”, “average” and “bad”. Other criteria can be used.
This qualitative criterion was used to directionally indicate performance trends, was compared to
previous years and was used to identify areas for improvement in the years to come.
Attachment 5.8 – HSSE Plans gives examples of targets set. A look ahead for a defined period
was also created. This was normalised to a 5 year look ahead. An example from 2010 is given in
Figure 15.
Focus Area Deliverables
Asset Integrity and
Process Safety
■■ Finalise and implement Operations Process Safety Manual.
■■ Implement Management of Change Procedure, start during CSU.
■■ Roll-out and implement SIMOPS Plan.
■■ Design Engineering Manual 1 & 2 (DEM1, DEM2) implementation plan
in place.
HSSE & SP Control
Framework
■■ HSSE Control Framework gap analysis carried out and impacts
identified and managed through Management of Change process.
■■ Implementation of the CSU/Asset HSSE MS.
■■ Implement and test Emergency response capability in place before
each stage of transition.
■■ Training and Competence: Implementation and Assurance plans
in place.
■■ Security and Emergency Readiness: Ensure interface agreements with
external parties (RLIC/QP) in place.
Health ■■ Implement One-Health-IT and core Health Management Standards
■■ Maintain implementation focus on workers welfare including transition
to operational work patterns.
■■ Maintain measures to minimise risk/impact from communicable
diseases.
Security ■■ Monitor security situation and respond using pre-established threat level
criteria/measures.
■■ Develop security organisation and facilities and, implement in line with
CSU requirements.
Social Performance ■■ Actively support and influence the RLIC Community Outreach Program
(COP) and the Al Khor Information Office operation.
■■ Social Performance Plans in place.
Figure 14: Focus Areas

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No 2010 TARGETS 2009
Actual
2011
Target
2012
Target
2013
Target
2014
Target
2015
Target
Measure Green Orange Red
1 Fatalities 0 - >0 2 0 0 0 0 0
2 Non-Accidental Death (no/103 yrs) <0.2 >0.2 >0.7 0.24 0.15 tbd tbd tbd tbd
3 TRCF (Rec. Injuries/ million hrs) <1.2 <1.5 >1.5 1.56 <0.8 <0.8 <0.8 <0.8 <0.8
4 TROIF (Occ. Illnesses/million hrs) <0.6 >0.75 >1.00 0.63 <0.6 <0.5 <0.5 <0.5 <0.5
5 RTIF (Road Transport Incident/million Km) <4 <8 >8 4 4 3 3 3 2
6 Land Transport Appraisal Scores/Quarter (% contractors on target) >95 >85 <85 70% >95 >95 >95 >95 >95
7 Contractor readiness to start checklist signed off complete for each contractor 100% >95% <95% - 100% 100% 100% 100% 100%
8 LSR compliance audit confirms implementation of Just Culture versus Fountain Reports >95% <95% <90% - >95% >95% - - -
9 Crisis exercise carried out 1 0 0 1 1 1 1 1 1
10 Emergency Response drills (no/month per ADT or Area) 1 0 0 - 1 1 1 1 1
11 PTW compliance audit results >95% >90% <90% - >95% >95% >95% >95% >95%
12 Equpt NOx
& SOx
controls meet design specification >95% >90% <90% - >95% >95% >95% >95% >95%
13 Waste management plans in place and all waste accounted for. 100% <90% <90% - 100% 100% 100% 100% 100%
14 Completion of Pre-startup Safety Reviews and no outstanding High actions 100% >95% >90% - >95% - - - -
15 HEMP Bow-ties completed and controls in place by RFSU 100% >95% >90% - 100% 100% 100% 100% 100%
16 HSSE Control Framework Assessment Implementation as per plan consistent with Qatar Shell strategy
17 RLIC Community Outreach (community meeting/ yr) 3 1 0 3 3 3 3 3 3
Figure 15: KPIs
5.8 ASSET MS & HSSE MS DEVELOPMENT
The development of the Asset Operations HSSE Management System started when I joined the
Project in 2008. At this time the Construction HSSE Management System and the Construction HSSE
Plan prevailed and controlled how work was being carried out in construction. The Project was over
18 months away before pre-commissioning and commissioning work would start. The huge Steam
Blow program would announce to the Project that parts of the Plant were ready for commissioning,
but that had yet to come. The development of the Commissioning HSSE Management System and
Plan would start in the early part of 2009, before the start of the Steam Blow program as a joint
cooperative venture between the PMC and Shell. As the Shell CSU HSSE Implementation Manager I
would play a role in this development work. However, there was just over 18 months to look ahead
and start to shape what the future HSSE MS would look like, as for the structure and content.
It was decided to initially pay attention to the structure and main content for the Pearl GTL Asset
Management System, of which the HSSE MS would be a part of. I would venture to propose that this
is a very logical place to start as it enables and promotes context. The HSSE MS should be resultant
from the hazards and risks identified during the development of the HSSE case(s), which in turn is
representative of the processes and work that will be carried out in the asset.

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Figure16 below is the first draft of the Asset Management System Portal. This would be refined over
the period that followed prior to start-up.
Standards were at the heart of the development of the Pearl GTL HSSE MS. Looking ahead to
what the operational phase management system and HSSE MS would look like based on our
understanding of requirements, an overall structure as represented by Figure 16 was developed.
Sitting behind this portal was a comprehensive listing of activities and control processes that
documentation, procedures, guidance, rules, job aids, etc., would be developed to assist and direct
performance. This listing is found in Attachment 5.9 – Manuals.
All of this work was taking place in the first half of 2008. In parallel to defining and designing
the Asset Management System, work started on the Operational HSSE Case. This proved to be a
challenging but highly enjoyable exercise.
5.9 INTEGRATED OFFSHORE AND ONSHORE OPERATIONAL HSSE CASE
A core team was assembled to deliver this important piece of work. This team would deliver the
Integrated Offshore and Onshore Operational HSSE Case. The team comprised:
■■ Technical HSSE Manager Pearl GTL,
■■ CSU HSSE Implementation Manager,
■■ Regional Head Technical Safety – Offshore Operations expert,
■■ Technical Safety Engineer, and
■■ Risktec Consultancy.
The team insisted that the same facilitation support (same person), would be provided by Risktec
for each and every one of the Bowtie Workshops. We considered this essential from a quality and
consistency perspective. Each Bowtie Workshop would have one, often two members of the core
team in attendance. In total, 10 Bow tie workshops were facilitated. On average, these workshops
lasted approximately five working days. The Project was divided into five distinct operational areas
– Utilities, which included Air Separation Units (ASU), Water Treatment and Steam and Power, Feed
Gas Processing (FGP), Gas-to-Liquids (GTL), Liquid Processing Units (LPU) and two Offshore Platforms
and Pipeline to shore facilities.
As a core team there was considerable experience of how to develop a HSSE Case. Critically, there
was expertise of both Offshore and Onshore operations. The two distinctive worlds of Upstream and
Downstream met and became Pearl GTL. The standards used to develop this integrated HSSE Case
would be complimentary both Upstream and Downstream.
The initial design and development of the Asset Management System took account of work that was
started as early as 2006. It importantly took reference from Shell Group standards. A key standard
used to ensure requirements were considered and addressed was, “Manufacturing Site Requirements
Manual” (DSM – 0515002 – SP – 01, dated 4th
February 2008) (see Attachment 5.9 – Manuals).
As I will share, this document was as current a standard that we could use as our work started in
earnest in March of 2008. We also secured support, expertise and facilitation from SGSI. This
proved highly beneficial and an approach I would advocate.
Attachment 5.9 – Manuals details the workshop design that was organised to gather input into the initial
development of the Asset Management System. The outcome from the workshop that included the initial
portal design to allow web access to the Management System is also given Attachment 5.9 – Manuals.
Governing Process and Activities
Core Work Processes and Activities
2. Purpose &
Scope
4. Objectives
& Strategies
5. Organisation
Responsibilities
Resources &
Competences
6. Risk
Management
1. Introduction
7. Processes,
Assets &
Standards
8. Planning
9.
Implementation
& Monitoring
10. Assurance
& Review
Monitor &
Control Well
Production
Ensure Quality
Products &
Raw Materials
Ensure Safe
Production
Management
of Change
Provide
Technology
Support
Perform
Reliability
Centered
Maintenance
Provide
Instrumented
Protective
Funtions
Perform
Maintenance
Execution
Ensure
Equipment
Integrity
Perform
Turnarounds
Develop &
Maintain
Competences
& Organisation
Procure Goods
& Services –
Asset Interface
Provide
Laboratory
Services
HSE CASE
ROADMAP
Optimise
Supply Chain
Transfer &
Store Products
& Feedstock
Deliver
Products to
Customer
Mass Balance,
Loss & Prod.
Reporting
Ensure Plan
Delivery
Execute Master
Planning and
Manage Capital
Investment
Develop &
Implement
Projects
Account for
Financial
Resources –
Asset Interface
Our
Process Safety
Commitment
Mitigate
Threats to
Availability
Monitor
Operating
Windows
Account for
Stocks –Asset
Interface
Account for
Hydrocarbon
Resource Vol.–
Asset Interface
3. Document
Control
Asset MS
HSSE Manual
and MS
Elements
Permit to Work
and Safety
Regulations
Asset Rules
and Standards
HEMP
Critical
Processes
Asset Related
HSSE Policies
Execute Well &
Reservoir
Management
Emergency
Preparedness
& Response
Enabling and Supporting Processes and Activities
Manufacture
Provide
Asset
Availability
Manage
Change
& Tech
Services
Lead Asset
Business
Process
Make
Products
Enable Asset
Manage
Hydrocarbon
Supply Chain
Engineering
Organisation
Technology
Organisation
Asset Proﬁle
& Area
Manuals
Enable Asset
Organisation
Asset
Leadership
Team
Manual of
Authorities
Operations
Organisation
Assure
HSSE in
the Asset
HSSE
Organisation
Figure 16 – First draft of Pearl Asset MS Portal including HSSE MS.

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5.10 WORK PROCESS TO IDENTIFY HIGH RISK AND SEVERITY 5 HAZARDS
As a brief reminder, I would like to share the work process that was followed at Pearl GTL to identify
High Risk and Severity 5 hazards, assess the associated HSSE risks, demonstrate what measures
(barriers) have been put in place to reduce these risks to ALARP levels and demonstrate how these
hard and soft barriers will be assured for the lifecycle of the Pearl GTL facilities. The definition of High
Risk and Severity 5 hazards is demonstrated through the diagram.
Slight
damage
Minor
damage
Moderate
damage
Major
damage
Massive
damage
Slight effect
Minor
effect
Moderate
effect
Major
effect
Massive
effect
No damage No effect No impact
Slight
impact
Minor
impact
Moderate
impact
Major
impact
Massive
impact
Assets Environment Reputation
A B C D E
Heard of
in the
Industry
Has happened in
the Organisation
or more than
once per year
in the Industry
Has happened at
the Location
or more than
once per year in
the Organisation
Has happened
more than
once per year
at the Location
Never
heard of in
the Industry
Slight injury or
health effect
Minor injury or
health effect
Major injury or
health effect
PTD or up to
3 fatalities
More than
3 fatalities
5
0
1
2
3
4
No injury or
health effect
People
CONSEQUENCES INCREASING LIKELIHOOD
SEVERITY
Figure 17 – Risk Assessment Matrix
Illustrates the process to manage risk and set control measures:
Identify Major
Risks
Risks Reduction
Philosophy
Document in
an Accessible
MS
Theoretical
Control
Measures
Implementing
on-site
Figure 18: Managing Risks and Setting Control Measures
Please read the HSSE Case that was developed for the Operational phase of Pearl GTL. I do not
offer this work as best practice. I venture to say that it is imperfect. It tries to tell what has been done
to identify hazards associated with the Process and the activities that will take place at the Asset in
the presence of such hazards. It describes how we have assessed the risk that the hazards identified
present. We recognise that the assessment and analysis carried out based on current knowledge and
understanding is adequate but will require ongoing insights and further work. More can always be
done? We learnt after start-up of the Asset that we had not identified all threats that could cause the
release of a hazard with negative consequences.
Learning from what happens elsewhere and what happens at the asset must be utilised to further
enhance the HSSE Case. Learning from incidents is a very powerful process to use as input for
updating the case. It is preferable that these incidents are near misses.
The people now responsible to maintain the Pearl GTL Operational HSSE Case must ensure that
this work is kept evergreen. Opportunities to update and enhance work that demonstrates hazard
recognition and understanding is fundamental. Being able to demonstrate that the level of risk
exposure is kept to an agreed and acceptable level is a duty of care to all who work at the entity
and to the community that the entity exists. The HSSE Case is the cornerstone of how an entity meets
the HSSE Policy Commitments of the Shell Group.
The Operational HSSE Case is in Attachment 5.4 – HSSE Ops Cases.

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Figure 19: Safety Showers
5.12 IDENTIFY RISKS
Teams from all areas of the Asset, Offshore, Utilities, FGP, GTL, and LPU under the support and
facilitation of the HSSE Case(s) team and Risktec Consultancy qualitatively assessed the High Risk and
Severity 5 Hazards associated with all operations and plant of Pearl GTL. This included:
■■ Offshore: Platforms (Pearl 1 and 2), wellheads, structures, process plant and utilities, export risers
and pipelines. The risks associated with the onshore pipelines and beach valves. In addition, boat
and helicopter activities.
■■ Onshore facilities: FGP, GTL, LPU, Tanks, Jetties and Corridors, Utilities; Steam and Power, Water
Treatment and Air Separation Units.
The risks were classified and segregated into different categories namely, HSSE. No major risks
were identified in the areas of HSSE. However, 37 major risks were identified in safety and duly
documented. These risks are listed in Attachment 5.4 – HSSE Ops Cases.
5.13 MANAGE IDENTIFIED RISKS
Having indentified the major risks, the risk reduction philosophy for offshore and onshore areas was
defined. For offshore, an integrated design and operations Risk Reduction philosophy was developed
on the basis of three major principles:
1. The philosophy was tailored for high-pressure sour gas.
2. A policy for minimisation of leak paths was pursued by using corrosion resistant alloy as the main
material of construction.
3. Exposure to live sour gas plant was minimised by efficient planning of maintenance activities.
5.11 RISKS RELATED TO IMPLEMENTATION
The major risks identified that could impact implementation of the HSSE Cases included:
1. Design to Reality: It is essential to translate the Design HSSE case into tangible solutions in the plant
and assign roles to verify that these solutions have been implemented.
2. Communication of procedures: Once HSSE tasks have been identified, it is essential to
communicate these tasks and procedures to all layers of the organisation. How this is done
depends on the preferred organisational model employed. At Pearl GTL, we focused on an area
by area communication process that was enabled by the Asset HSSE team for consistency. The
central HSSE team tied to ensure that clarity was given and any ambiguity resolved.
3. Assigning Accountabilities: All HSSE roles/positions need to be assigned to competent individuals.
This process was verified through a variety of means (interview, assessment, written testing). Once
satisfied sign-off per individual was undertaken and letters of authorisation issued.
4. Measuring performance: During implementation, supervision monitored the actual performance of
tasks benchmarking what was observed against performance acceptance criteria that had been
defined. Gaps in observed performance would be subject to remedial action.
For more understanding of these risks, refer to Attachment 5.3 – Construction and Attachment 5.4 –
HSSE Ops Cases.
I would like to share one simple example of the difficulty to ensure that when designing to reality, the
reality outcome is the same in all parts of the project.
Example: Safety Showers would be sited at different locations of the Asset as identified and required.
The IC would reference standards to ensure that the Safety Showers selected met DEP requirements.
This is what they did and what happened. However, one fundamental requirement of a Safety
Shower is to apply water when a mechanism on the Shower is activated. If there are more than one
means to activate the shower – by standing on the base plate, or by activating a lever using your
hand, then you apply different solutions and can create confusion.
The use of a Safety Shower in an emergency situation, when a state of panic and urgency exists
requires unconscious competence. You need to know where the nearest shower is, but the action to
activate should require little or no thinking. It should be a natural reaction that has been taught.
If you have Safety Showers that can be operated differently, but are still DEP compliant, the reality of
the design to the user is different. This should be avoided.

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Figure 21: Comparison between HEMP and HSSE-MS
5.15 ASSET HSSE MS
5.15.1 Introduction
By mid 2008, a number of parallel work streams had been started; overall structure of the Asset
Management System, Integrated Offshore and Onshore HSSE Case and the Asset HSSE MS.
This book will not tell the story of how the Asset Management System was eventually developed,
although there are interesting insights to share. From a very positive start, structure and content listing,
the hard work of authoring documents did not proceed exactly to plan, despite an extensive process
of on-going review and management. Understanding why there was difficulty is for others to share
and explain. This HSSE book will not report or give an opinion.
For the Asset HSSE MS, we had a clear view on what was required; the challenge to do this will
now be shared.
Link between HEMP and HSE-MS
Corrective Actions
Implementation Monitor 5 S’s
Process Safety
Metrics LOPC/PSI
Process Owner
Reviews
Maint Mgt
Systems (i.e. SAP)
Management
Review
Internal/Ext.
Audits
LFI/Causal
Learning
Critical Processes
■ Management of Change
■ Contractor HSSE Management
■ Emergency Management
■ Competency Management
■ Document Management
■ HSSE Compliance Mgmt
■ Permit to Work
■ Personal Protective Equipment Mgmt
■ Security Management Process
■ Mechanical Integrity
■ Process Control
Internal/Ext.
Standards
Recommendations
Input from Hemp
Critical Activities
Critical Equipment
Barriers
Critical Human
Barriers
Action Item Execution
& Tracking
Position Specific Deliverables,
Frequency-Sequence-Time-specific actions
each with Q standards
each with Q-Records of results
data specified to right IT systems
Level 2 Level 4 Level 7
A similar philosophy for onshore facilities was followed which included risk management and risk
reduction during the three phases of design: Concept Selection, Concept Definition and Detailed
Engineering and Implementation of Shell Global Solutions Technical Assurance Framework for
Engineering Procurement and Construction (EPC) phase. Detailed documents can be found in
Attachment 5.3 – Construction.
5.14 IMPLEMENTING CONTROL MEASURES
The identification of control measures resultant from HEMP results in what is called hard and soft
barriers that either prevent a hazardous event from happening or mitigate the consequences of
an event.
Simplistically, for effective control and mitigation, a preference to have in place hard barriers
as a means of control should be pursued. However, this cannot be achieved in all cases and a
combination of hard and soft barriers is normal. The effectiveness of soft barriers is human factor
dependent and as such, all things being equal, will not offer the same level of risk reduction as a
maintained hard barrier.
Area Operations Managers are responsible for ensuring that aspects of the Operations HSSE Case
are effectively implemented in their respective Area. Pearl GTL follows a standard process for ensuring
effective implementation of barriers. The process is described in Figure 20 and details of this process
are given in Attachment 5.4 – HSSE Ops Cases.
Listing all
Safety Critical
Items
Test Ops
Performance
Standard
List all HSSE
Critical Tasks
Personal
Responsibilities
assigned
Inspection
and Audit
Figure 20: Implementation of Hard and Soft Barriers
A list of definitions related to HEMP can be found in Attachment 5.4 – HSSE Ops Cases. The
relationship between HEMP and its implementation in HSSE-MS is described in Attachment 5.4 –
HSSE Ops Cases (Link between HEMP and HSSE-MS).
Whilst the development of the HSSE Case identified critical processes that would be documented in
Procedures, Rules, Instructions etc., such as PTW, Management of Change, Incident Management,
Emergency Preparedness and Response, from experience and from what is now included in the
HSSE Control Framework, the development of procedures to implement key processes is a default
requirement. We did not have to wait until these processes had been identified as a result of HEMP
before developing procedures.

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What How Who
HSSE and SP Plan ■■ Integrate the Annual HSSE
and SP Plan and the UIQ
Business Plan
■■ UIQ VP Production
■■ UIQ VP HSSE & SD
HSSE Cases to demonstrate
management of risk
Develop and implement:
■■ Design HSSE Case
■■ Integrated Offshore and
Onshore HSSE Case
■■ Transport Safety Case
■■ Technical HSSE Manager
■■ CSU HSSE
Implementation Manager
■■ Transport Safety Adviser
HSSE Manual ■■ Demonstrate HSSE
Governance
■■ UIQ HSSE MS Systems
Manager
Rules ■■ Life Saving Rules
■■ Golden Rules
■■ Asset Rules
■■ CSU HSSE Implementation
Manager
Procedures to manage
HSSE/SP Risks
Develop and define HSSE
controls covering the key risk
areas including the following:
■■ Asset Integrity and
Process Safety
■■ Personal Safety
■■ Contractor HSSE
■■ Road Safety
■■ Environment
■■ Health
■■ Security
■■ UIQ HSSE Systems Manager
■■ CSU HSSE
■■ Relevant UIQ HSSE/SP
Section Mgrs
■■ Relevant Pearl GTL Asset Line
Mgrs
HSSE Critical Processes:
■■ PTW
■■ Management of Change
■■ Emergency Preparedness
and Response
■■ Safe Place and
Safe Person
■■ Contractor
HSSE Management
■■ Asset Induction
Develop procedures and define
HSSE controls
■■ CSU HSSE
■■ Technology Manager
■■ ER Manager
■■ CSU HSSE
■■ CSU HSSE
Manager
5.15.2 Asset HSSE MS Composition
The Asset HSSE MS comprised of Manuals, Cases, Rules, Procedures, Guidance, and Plans and was
enabled through Instructions and at the task level through Job Aids.
The structure of the Pearl GTL Asset HSSE MS was traditional. Refer to Attachment 5.9 – Manuals.
To address the challenge ahead and develop the Asset HSSE MS, the approach adopted so that
work could be framed with purpose and objectives, started with seeking answers to a question set
used to make sense of challenges: What, When, Why, Who, Where, and How.
By doing this, a systematic plan, what needed to be done, when, by whom, etc., was formulated.
Further clarity and context was given by agreeing with stakeholders what success criteria would be
used so that a regular update on progress could be given.
The approach used is simple and systematic. That said, my honest reflection on my own success to
achieve what I set out to do is 6/10, could have done better. I was more successful in planning what
needed to be done, when and by whom. The agreement with stakeholders on the success criteria
and the discipline of informed and regular updates on progress, whilst this happened, should have
been better. I also did not manage completion of a few procedures on the agreed time frame. Whilst
they were completed upfront of start-up, that did not excuse failing to deliver to the agreed plan.
So what was developed, what did the plan look like?

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What How Who
Process Safety
■■ Refer to Attachment 5.11 –
Process Safety
■■ Technical HSSE Manager
Safety Regulations
■■ Develop and
provide guidance.
■■ Refer to Attachment 5.12 –
Safety Regulations
Manager
Trade Standards
■■ Develop trade standards
and practices for work and
activities, e.g., Scaffolding,
Pipe fitting, Crane lifting and
Rigging, etc.
Manager, Engineering
Discipline Managers and
Contractor Management
Table 5-1
The structure and content of the Asset HSSE MS that was developed is given as (Attachment 5.10 –
HSSE Management System)
5.16 KEY POINTS FOR REFLECTION:
■■ A CSU HSSE Manager should take responsibility and propose how a HSSE Plan is to be
implemented through the use of appropriate strategies.
■■ Network existing Group expertise and resources (documents, people and examples of good
practice) so that the HSSE Plan to be implemented benefits from expert views and in-sights into
what and, importantly the how to implement.
■■ Submit to an assessment of capability to implement the HSSE Plan. Assessment should focus on the
Leadership to deliver and the organisational competence and capability to implement.
5.17 FURTHER THOUGHTS
When a project organisation is “heavy” with relatively experienced personnel, not just in HSSE, as
was the case for Pearl GTL, acceptance of how processes are documented for implementation –
PTW, Management of Change, Incident Management, Emergency Preparedness and Response,
Work Place Hazard Management etc. can and did result in a variety of views from a number of
sources internal to the Project. In a perfect world, a collegiate approach to the development of how
such processes are documented and implemented is the ideal course to follow. Or is it?
I do not want to sound contradictory, whilst I previously have argued that others views should be
listened to, this should be qualified. Often such views are not collaborated against standards or
verified practices. You can get caught up in a beauty contest. Endless discussions can ensue on
What How Who
Incident Management
■■ Incidents, including near-miss,
are reported into the Fountain
Incident Management (FIM).
■■ Any staff
■■ Classification of the actual
severity and potential risk
rating to be confirmed.
■■ UIQ HSSE Incident Data
QC Analyst (also Fountain
Gatekeeper) – initial rating,
thereafter confirmed by Asset
HSSE Manager.
■■ Agree the appropriate level of
investigation required.
■■ UIQ HSSE Incident
Data QC Analyst (also
Fountain Gatekeeper)
■■ In consultation with,
■■ The Responsible Supervisor
■■ Relevant HSSE Section Heads,
e.g., Health, CSU, Technical,
Environment, etc.
■■ Operations Managers.
■■ Assign actions resultant from
investigation
■■ Incident Owner
■■ Follow-up and close-out
actions with satisfactory
supporting evidences.
■■ Responsible Supervisor/
Incident Owner
■■ UIQ HSSE Incident Data
QC Analyst (also Fountain
Gatekeeper)
Learning From Incidents (LFI)
process
■■ Review and record alerts
and incident reports from
other Shell and external
sources, Qatar Shell Pearl
GTL Incidents, observations
and findings.
■■ HSSE/SD Department (LFI
Coordinator)
Review of Significant and
High Potential Incidents
■■ Incidents that have been
classified as Significant or
with High Potential have to be
reported and reviewed as per
the UI SIR Procedures.
■■ HSSE/SD Department (Asset
HSSE Manager and Asset
Operations Manager)

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5.18 CONSTRUCTION AND COMMISSIONING HSSE MS
Before sharing what was developed for Construction and Commissioning, the transition of
Construction HSSE MS developed by the PMC to Commissioning HSSE MS jointly developed by
PMC and Shell to the Asset HSSE MS developed by Shell, is shown in Figure 22 below:
Pearl GTL HSSE MS through the phases of Construction, Commissioning and into Asset:
Qatar Shell HSSE/SP MS
Pearl GTL Construction
HSSE (PMC)
Pearl GTL Commissioning
HSSE (PMC/Shell)
Pearl GTL Asset/
SU Ops HSSE (Shell)
Pearl GTL Asset HSSE
Standards and Procedures
CSU HSSE Implementations
Figure 22: Org Chart
The Construction HSSE MS was owned by the PMC. The Construction HSSE MS sets out to direct
the work of all Contracting Companies with respect to desired HSSE standards (refer to Attachment
5.3 – Construction). The Construction HSSE MS includes the Construction HSSE Plan which sets out
the goals, objectives, strategies and performance indicators for all Contacting Companies building
Pearl GTL.
The Commissioning HSSE MS is jointly owned by Shell and PMC and all details can be found in
Attachment 5.7 – Commissioning. The Commissioning HSSE MS covers the key phase of the Project
that is called SIMOPS. How this key phase was managed will be discussed in the SIMOPS book.
periphery items. Judgment has to be made on whether others opinions and views would be better
than what’s proposed? However, there is a limit to how many different views can be accommodated
before a piece of work loses context and instead becomes disjointed.
Requirements have been determined for most of the HSSE critical processes. The role of the CSU
HSSE Manager or delegates within his /her team is to procedurally document how these processes
are to be implemented. Previous experience on how this has been done will be used and is very
relevant. The time to improve comes after use, with knowledge, understanding and in-sight.
Reflecting on my own experience, a number of processes were allowed alternative views to enhance
the procedural content. As a result they took longer to complete, in some cases much longer. In
hindsight, I should have taken more personal responsibility and insisted that a procedure as written
was available for comment, review and update only after use. For any document to be issued it will
be reviewed and approved, this is limited to functional line approval and selective personnel for
comment. This should have been sufficient.
Interestingly for one critical process, PTW, I flatly refused to listen to others experience or views.
This was not out of ignorance or denial, but from a pragmatic standpoint. In my opinion PTW is
pivotal in Work Place Hazard Management. It involves work planning, work place preparation,
the selection of isolation strategy as applicable, risk management, the participation of authorised
signatories in assessment and work approval, and when work starts, the duty to supervise, monitor,
ensure standards of work, ongoing communication and more. It is important that all such elements
are coherently documented. I did not want to spend too much time on endless discussions on permit
types, or the pros and cons of “this is what we did at my last location”; regardless of how much better
it seemed to be from others perspectives. There is a point when you have to say, “this is it, this is what
we shall go with”, until the organisation has some practical implementation experience. After using the
procedure I would welcome “users” views based on their practical experience of implementing what
had been developed. This is what I did and I was glad to accept responsibility.
I must say I received more challenge and comment about the PTW procedure implemented at
Pearl GTL than anything else.
At times I felt as though I had to constantly justify what had been developed. What I could say with
conviction was the PTW procedure being implemented had been successful at a major Operating
Refinery Complex, used in a start-up Greenfield project in China and had been independently
audited by the Shell Group and external Regulators as “fit for purpose”. I had confidence and
conviction at what was being proposed for implementation. Looking back I am satisfied I chose the
course of action I did.

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The activities carried out in implementing the HSSE/SP objectives is given in Figure 23 and represents
the Asset phase, post start-up into normal operation.
Activites
Communicate Shell
HSSE&SP Policy
Develop Pearl GTL Aset
HSSE&SP Objectives
Set Annual Targets for
Continuous Improvement
Align Targets using HSSE
Management Review,
Performance and Plan
Pearl GTL Production LT
and HSSE Manager
Formulate Asset HSSE&SP
Objectives Strategies & KPI
Pearl GTL Production LT
and HSSE Manager
Post at all Strategic Locations
and discuss Policy at all Levels
Pearl GTL Asset
HSSE Manager
Figure 23: Activities Pyramid
For further insight into the HSSE objectives set for the Asset (Normal Operation phase), refer to the
Asset Manual given in Attachment 5.9 – Manuals.
In all three major phases of the Project; Construction, Commissioning, Start-Up and Operation, a
unified approach and partnership between Shell the PMC and the ICs resulted in a clear aspiration,
focus and commitment to achieve the highest levels of HSSE performance.
5.19 COMMITMENT AND POLICY
Shell has an ambition to have zero fatalities, no incidents that harm people, or put its neighbours or
facilities at risk. This ambition was shared across the total Project and all companies associated with
the Construction and Commissioning of Pearl GTL.
The Shell policy on HSSE as summarised below was a commitment made by all involved with Pearl GTL:
■■ Pursue the goal of no harm to people.
■■ Protect the environment.
■■ Use material and energy and efficiently to provide our products and services.
■■ Respect our neighbours and contribute to the societies in which they operate.
■■ Develop energy resources, products and services consistent with these aims.
■■ Publicly report on our performance.
■■ Play a leading role in promoting best practice in our industries.
■■ Manage HSSE & SP matters as any other critical business activity.
■■ Promote a culture in which Shell employees share this commitment (for Shell, read ALL Project personnel).
The Qatar Shell HSSE commitment can be found in the ‘commitment and policy’ document in
Attachment 5.9 – Manuals.
5.20 IMPLEMENTING POLICY THROUGH OBJECTIVES, TARGETS AND KEY
PERFORMANCE INDICATORS
In each stage of transition, Construction, CSU/Normal Operation, the leadership team in place were
accountable to ensure that the HSSE MS for that phase of the Project was adequate to standard
requirements and implemented effectively.
Through the organisational arrangements in place the leadership teams were responsible to:
■■ Communicate the Shell HSSE & SP Commitment and Policy,
■■ Participate in the development of HSSE & SP objectives,
■■ Develop strategies, KPIs and targets to drive continuous performance improvement.
In addition, the Leadership Team was responsible for:
■■ Developing the annual HSSE and SP Plan which is aligned with the HSSE and SP objectives
and targets,
■■ Publishing and communicating the HSSE and SP objectives, targets and plans through the
respective line organisation.

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6. CSU HSSE ORGANISATION, ROLES AND RESPONSIBILITIES
6.2 CSU HSSE IMPLEMENTATION TEAM
6.2.1 Establish and maintain an organisation that delivers HSSE requirements and
effective HSSE management:
Prior to my arrival on the Project, recruitment of my team had already started. The initial number of
positions assigned was four. Two of the four positions had already been selected. The roles defined
were HSSE Advisors/Trainers. To be perfectly honest this is not what I wanted; I did not know what
was wanted. This would require analysis. The analysis would then propose organisation (numbers)
and competence. I had to first understand the challenges to face.
To further compound the situation, selection of the initial personnel for the CSU HSSE Implementation
team was by CV a‑ssessment and telephone interview. This type of selection process, regardless
of perceived efficiency and cost considerations is an imperfect process, both for the interviewer
and interviewee.
If part of the role to be carried out is as a HSSE trainer, then consideration of the ability to
communicate, to instruct, to demonstrate, to lead and qualify, to explain and clarify and much more
are core skills and attributes that a “Trainer” should possess. I personally do not have the competence
to properly assess whether an interviewee is competent to deliver such a skill set from reading their
CV or by a telephone interview. I am not suggesting that telephone interviews should not be used as
a means for selection. For certain roles and with the combined use of other means of verification, a
telephone interview can be fit for purpose. However, I would argue it is the least preferred method for
certain roles.
I temporarily put a hold on further recruitment so that I could take stock of what organisational
resource was needed. I first had to understand the challenges to face as CSU HSSE Implementation
manager for Pearl GTL; this was done after conversations with my line manager, VP HSSE/SD Qatar.
Clarity of my expectations allowed for an informed assessment of the potential resource that would
be needed. Furthermore, in the context of what was being carried out elsewhere on the Project, for
example, were other parts of the Project organisation carrying out HSSE training? I was able to use
this information to further define organisational needs and help to better understand any gaps and
areas of focus that the CSU HSSE team could act upon and deliver.
Until a Manager understands the scope of what is required of their team, the context of the total
work and the timeframe to deliver, a fit for purpose analysis of resource (numbers of people and
competence set) cannot be effectively done. This is particularly sensitive in a project environment.
Others may argue that archetype organisations for project phases such as CSU HSSE are known and
are a basis for following. I do not disagree with this assumption but contend that analysis is always
6.1 INTRODUCTION
The requirements (what) that was needed to deliver a HSSE team (people) to implement effective
HSSE Management through the phases of the Project is stated as part of the Shell Group HSSE
Control Framework. As CSU HSSE Implementation Manager, I attempted to implement these
requirements. They are given below:
■■ Establish and maintain an organisation that delivers HSSE requirements and effective
HSSE management.
■■ Define and assign HSSE roles, responsibilities and authorities to individuals.
The CSU HSSE Implementation Manager was one of the managers in the HSSE LT that reported to
the VP HSSE/SD Qatar. As with other functional teams, the organisational composition of the HSSE
LT changed through the project phases. However, a number of the managers transitioned through all
of the phases. These managers included;
■■ VP HSSE/SD Qatar.
■■ Corporate SD and Environment Manager.
■■ Technical HSSE and Environment Manager.
■■ Country Occupational Health Manager.
■■ Senior Logistics HSSE Manager.
These managers provided continuity and were a positive source of project knowledge. In addition
two further roles transitioned through all phases of the project although the incumbents in these roles
changed. They were:
■■ Country Security Manager, and
■■ HSSE Systems Manager. This role would eventually transition into HSSE culture and systems
manager in the Asset Operate phase.
I, as CSU HSSE Implementation Manager, arrived during the Construction peak activity
approximately 18 months before the start of Commissioning. I would be part of the HSSE LT reporting
to the VP HSSE/SD Qatar. This role would transition to the Asset HSSE Manager after start-up.
During Construction and Commissioning the PMC HSSE Manager would also be part of the HSSE LT
reporting to the VP HSSE/SD Qatar and to the PMC LT.

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the bulk of Commissioning work had been completed and importantly support the critical SIMOPS
phase. I now had presence and influence in Construction through these four managers and became
intimate in the knowledge of schedule progress. This knowledge allowed for appropriate preparation
time for the phases to come, in a reality of when pre-commissioning and commissioning activities
would start.
6.2.4 Opportunistic Recruitment
As I was preparing for pre- Commissioning, Commissioning and the SIMOPS challenge, my
assessment on how best to support safe working through these phases was crystalised. Within
the CSU Services team there happened to be, not by chance, four very experienced Operational
Supervisors whom I was already acquainted. I was aware of their core skills and where they could
add value. These four Operational Supervisors were an excellent fit for what I wanted.
The future Asset organisation would be divided into four distinct operating areas; Feed Gas
Processing (FGP), which also included Offshore Wells and Platforms (2), Utilities (Air Separation
Units, Water Treatment and Steam and Power), GTL and Liquid Processing Units (LPU) and associated
tankage/Jetty facilities. In time, I allocated one of these experienced Operational Supervisors to each
of the four distinct Operating areas.
Whilst these four Operational Supervisors were officially part of the CSU Services team, they became
default full-time members of the HSSE team. They also and importantly became part of the Asset
Teams during start-up. They made their invaluable contribution in an Operational HSSE Advisory role.
The intent was to salt these Supervisors into the Area Asset Teams to support the development and
capability building of HSSE requirements, and help to enable clear line responsibility for HSSE. But
this work was to come during 2011, before this we also had pre-Commissioning, Commissioning and
SIMOPS to support.
6.2.5 CSU HSSE Inspection Team
An assessment on the work that would be required during the phases of pre- Commissioning, CSU
was undertaken. This was my responsibility. The initial assessment proposed 20 HSSE Inspectors. This
assessment was supported and the recruitment began in earnest in 2009. The 20 inspectors would
be allocated five per Safety District/Asset area.
They were called HSSE Inspectors, but in reality, and by design and intent, their purpose was to
carry out roles that supported the implementation of trade standards of work that resulted in safe
work outcomes. The HSSE Inspection team therefore needed to be competent in a variety of trade
discipline skills. This is what we recruited.
needed to define requirements that are specific for the challenges each project can bring. An analysis
can be done relatively quickly by a CSU HSSE manager and in doing so instill ownership and
responsibility for what is proposed.
6.2.2 So What Happened Next?
With the support of my functional line manager, VP HSSE/SD Qatar, and the superintendent for
HR recruitment, I identified the need for an experienced HSSE professional to provide fundamental
competence within the team. Previous experience in a project environment was essential. This
senior HSSE advisory position would also bring considerable offshore expertise to offset my lack of
experience in this area and complement my onshore/downstream competence.
Personnel already recruited would be asked to adapt and carry out a different set of role requirements
within the team. To their credit they did this willingly and over the course of the Project made a
valuable contribution, but not in the role that they were originally recruited.
By the third quarter 2008, my team numbered four, plus me. A plan of what was to be achieved by
the CSU HSSE team had been agreed. In chapter (4), examples of work as detailed in the HSSE
Plans can be seen. The main focus areas of Integrated Offshore and Onshore HSSE Case, Asset
HSSE MS, Asset Rules, Procedures to implement critical processes, etc., would be started. With
the support of the Senior HSSE Adviser in my team, this work was undertaken. The work of the rest
of my team would involve the definition of HSSE requirements for the growing CSU Operational
and Maintenance teams that were working from an office based environment separate from the
construction site. In addition, the work of the CSU HSSE team was directed to support effective HSSE
Management and to develop, maintain and make available for the use of all CSU personnel, relevant
HSSE information. At this time elements of performance reporting was also started. The Senior HSSE
Advisor would oversee this work, coach and guide the team to deliver on this work and support the
growing CSU community.
6.2.3 Preparing for CSU
The year of 2008 came and went. Time had been spent ensuring that the growing CSU community
was being looked after from a HSSE context. Work was on-going with the Asset integrated Offshore
and Onshore HSSE Case and elements of the future Asset HSSE MS. As the Project entered 2009
and on, the relevance of what was needed to transition from Construction to Commissioning and
SIMOPS implications became more urgent and would need to be planned and resourced.
During 2009, my functional HSSE Manager, VP HSSE/SD Qatar transitioned four Shell Construction
HSSE managers/leads into my team. This proved to be a very positive move. The work of these
four managers would not finish at the end of Construction. All four incumbents stayed in place until

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Rob
David Katie
TommyScottCliveRichardBrucePaulRicardoArnoldTommyJohn
CedricTonyDeanBillyMedel
Colin
Erik PeterChuta Zahid
JoeyPete Pete KelvinNirav GajGeoff Harun
Pearl GTL HSSE Team
Figure 24: Pearl HSSE Team.
6.2.6 So what did the HSSE Inspectors do?
I will talk about the work of walk-downs on systems to be handed over from Construction to
Commissioning, and then ready for start-up in the SIMOPS book. This was a major piece of work.
However, equally as important was the start of day, start of activity presence and support for work
teams across the Project. The tasks were determined to be a key focus; this would happen every day.
The emphasis was to support safe working by being present at the start of the activity to help set-up
work conditions that would lead to a successful outcome. Setting up the conditions for success at
the outset of an activity is most productive. Attendance at TBT also happened and this enabled the
inspectors to connect with supervision of work parties.
Recruitment and selection of the HSSE Inspectors was by telephone interview. An assessment of each
interviewee was made and recommendations to recruit or not was approved by myself and the HR
and Recruitment Superintendent for the CSU phase. An auditable trail was established.
A combination of short-term international assignments from Shell locations and 3rd
Party personnel
were chosen for the initial 20 places. From the original 20 selected, nine were STIAs and 11 were
3rd
Party personnel. Some of the 3rd
Party personnel were already known to me having worked
together in previous locations.
Whilst I have commented previously that telephone interviews are not ideal for the skill set that had
been identified for the role of a HSSE Inspector, the process proved effective. In addition, testimonies
from the Shell Line Organisation for STIA positions and the fact that a number was already known
and as such could be testified, resulted in a selection process that was transparent and enabled the
recruitment of a valuable resource.
The majority of recruits into the HSSE Inspection Team were from an operational background,
either senior operators or in some cases operations supervisors. In addition, a flavor of trade
discipline personnel, scaffolding, crane lifting, rigging and piping were also added to the mix.
This proved essential.
The work rotation of the HSSE Inspectors was six weeks in country at site, of which they worked
10-hour days, six times a week; they would then take two weeks leave. A tight control and
management of rosters ensured that at any one time, a minimum of four HSSE Inspectors were
available per Asset Area.
In total, 24 HSSE Inspectors would eventually be selected over the duration of pre-Commissioning,
CSU. The average length of contract was 18 months with some HSSE Inspectors staying after start-up
to support Asset work.
See below at what I call the HSSE team “Rogues Gallery.” All of this team worked tirelessly during
the Commissioning and Start-Up of Pearl GTL. There were over 10 different nationalities as can be
seen by the country flags below each picture. Unfortunately, not all of the team is pictured, but they
are remembered. A great bunch of people; and it was my privilege to lead and support.

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See Attachment 6.1 – Job Descriptions for the HSSE inspector’s job description.
6.3 Safety Districts
Safety Districts are a geographical area of the Pearl GTL complex. These individual districts were
further divided into zones during project transition. These zones would enable the transition of a
district from one phase (Construction) to the next phase (Pre-Commissioning/Commissioning). As
Safety Districts transitioned specific HSSE requirements for that phase would be identified and
implemented.
Safety Districts were a critical organisational design that enabled appropriate HSSE transition through
the phases of the Project.
A Safety District was a predefined area based on the Contract Work Breakdown Structure (CWBS)
(refer to Attachment 6.2 – Safety Districts) in which the Safety District Owner (SDO) was responsible
for HSSE within its boundaries.
A Safety District was subject to organisational control. A SDO was nominated for each Safety District.
A detailed list of roles and responsibilities was developed for SDOs. See Attachment 6.2 – Safety
Districts for details the roles and responsibilities for SDOs during the Construction and CSU phases.
Figure 25 shows organisational control and transition of Safety Districts through the phases of the
Project. Figure 26 shows the geographical breakdown of the Pearl GTL Site into Safety Districts post
start-up.
The establishment of Safety Districts and the Organisational Control and governance of these
Safety Districts during the Project phases into the normal Run and Maintain phase is a critical
organisational undertaking.
Core HSSE Team
Senior HSE Adviser - 1x GTL - 1x
Utilities - 1x Utilities - 1x
LPU - 1x LPU - 1x
FGP - 1x
ER Ofﬁcer - 1x
On Scene Commanders - 4x
Team Leaders - 4x
ER Technicians - 15x +
FGP - 1x GTL Site - 25x
HSE Advisers - 3x
* HSSE transition from Construction to Commissioning
** Experienced Operational Supervisors seconded to support HSSE Critical Processes implementation
*** Experienced Operational and Discipline Engineering and Supprt staff (Scaffolding, Electrical, Piping, Crane Lifting, Rigging)
Area Operational
Supervisors**
Construction HSSE
Managers*
CSU HSSE Implementation Manager
HSSE Inspectors*** Emergency Response
Follow-up monitoring and where necessary intervention would happen throughout the course of the
day. For the start of day, discipline to prepare the team for the work challenge ahead became more
effective, the need to intervene and make corrections during work activity became less needed.
Observations of safe working became more common and as such would result in positive feedback.
This is what we wanted more of.
Thousands of work parties would carry out work every day. Judgment on what activity to support
would have to be taken. The work of the HSSE Inspectors had to be leveraged effectively. This was
done by knowledge of activities planned over future periods (one week look ahead). This plan would
be discussed weekly and decisions on areas of concern or potential high risk would be selected as a
primary focus.
The advantage of recruiting discipline skilled personnel to the role of a HSSE Inspector results in
interventions being made that with knowledge and in-sight correct practices that are unsafe and
show “How” safe work can be undertaken. Being able to explain why work is observed as unsafe
and how this work can be carried out safely is not a skill resident in all personnel carrying out work
activity observations. Whilst it is a necessary and important first step to recognise when work is being
carried out unsafely, being competent to explain why, and then offer alternatives establishes respect
and working relationships. This was a big part of the daily work of the HSSE Inspectors.
Their presence was a constant over this critical period of time. As part of the overall CSU HSSE
Team, the HSSE Inspectors worked closely with the four Construction HSSE Managers, the four
experienced Operations Supervisors that had become part of the “team” and the original four Asset
HSSE Advisors. At the peak of activity there was almost 40 dedicated CSU HSSE staff.
At times there did not seem to be enough resource. However, it is with pride that I can say that
schedule pressure, particularly when walk-downs were required before handing over areas and
equipment from Construction to Commissioning did not result in short cuts to responsibilities being
carried out.

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6.3.1 Maintain HSSE information that is current and readily available
Each SDO and the organisation controlling work in a Safety District must, amongst many other things,
ensure that HSSE information is current for the hazards and risks associated with work being carried
out at that time. Whilst this is a critical responsibility normally, as a Safety District transitions through
major phases of activity, Construction to Commissioning and into CSU, the discipline to stay in control
and maintain HSSE information that is current to the prevailing work and conditions, and is readily
available, is a major task. At Pearl GTL the PMC played a pivotal role in coordinating and supporting
this work.
To fulfill this organisational responsibility, the PMC through the SDOs implemented a simple set of
rules and guidance that details the Commissioning HSSE strategy for safe working from Ready for Pre-
Commissioning (RFP) through Ready for Commissioning (RFC) into CSU and Run and Maintain. The
topics included below have been defined to manage and mitigate foreseeable HSSE issues assessed
as likely to happen during pre-commissioning and commissioning of a major oil and gas facility that
was Pearl GTL.
In no order of importance the following provided a logical progression of activities and approval
steps that supported safe transition through the phases from construction to commissioning and start-
up. This will be covered in more detail in the SIMOPS book.
6.3.2 RFP Certificates
The IC/EPCM generated RFP certificates for each system ready for transition. RFP was seen as a key
HSSE, as well as progress milestone and constituted a company witness point. At RFP, overall field
HSSE responsibility for a system passed from the IC/EPCM Construction Manager to IC/EPCM
Commissioning Manager. The RFP certificate was signed by these two persons.
Construction punch lists which were still open at RFP were attached to a RFP certificate, so that the
commissioning manager acknowledged remaining construction work which must be closed under his
system control and which represent potential SIMOPS situations to manage. The RFP certificate was
stored in the system compilation file. Standard (template) checklists were used to ensure a consistency
of approach at RFP and mitigate any over sites and omissions (see Attachment 6.2 – Safety Districts
Doc. No. 5887-ON-GL-CO-001 Project Handover Guidelines)
6.3.3 RFC Certificates
The IC/EPCM generated a notice of RFC with a completed system dossier and punch list. Following
successful review and punch out by the Company the Company issues/generates a notice of system
RFC status acceptance. RFC is a key completions milestone (with implications to HSSE management)
and is a notifiable hold point with the Company.
Construction
Rob Kretzers
Marty Schweers
Project Man.
IC/EPCM
(Const. Manager)
Constr. PTW
Construction
Rob Kretzers
Marty Schweers
Project Man.
IC/EPCM
(Comm. Manager)
Comm. PTW
Comm. HSSE
LSRs
Operational
Utilities SP
Rob Kretzers
Steve Johnson
SU Leader
Shell
Shell MS
Shell HSSE Rules
LSRs
Shell PTW
SU Leader
Shell
Post Handover
Roel Cornelisse
Steve Johnson
Comm. PTW
HSSE Authority
Operational control
Safety Disctrict Owner
HSSE Control
Constractor’s MS
Project HSSE Rules
LCAs
PTW
Figure 25: Handover of Safety Districts
■ Plot size is 1.5km x 1.5km
■ 35 proprietary technologies
■ 3400 individual systems
■ 534,000 unique Tag numbers
■ 2058 Pumps, 228 Compressors
■ 2277 Heat exchangers
■ 1215 vessels
■ 1 mill ﬂange connections
Buildings
Buildings
Tankage
Tankage
FGP
FGP
LPU
LPULPU
GTL + Utilities
+ Flare + Infra
GTL + Utilities + Flare + Infra
Off Plot/Jetty
Water Treatment
Water Treatment
Site Prep
ASU
ASU
C1
C3
C4
C5
C6
C7
C8
C9
C2
Figure 26: Safety Districts

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This was achieved by issuing a formal Livening up Notice (e.g., notice of commissioning for high
voltage electrical equipment in line with Project Electrical Safety Rules) to all interested parties,
defining the impending change in plant status with enough detail to enable clear understanding of the
nature and location of the changes. Interested parties then signed, copied and displayed the notice
in prominent locations within their site organisation as well as conducting tool box talks with personnel
and vendors to make them aware of the changes. The original was returned to the Commissioning
Manager and placed in the system dossier. Refer to Attachment 6.2 – Safety Districts PMC plan
5887-ON-PL-CO-00 for full details.
6.3.6 Live Site Induction
By the time RFC was reached for the first system, many personnel had worked within a purely
construction environment for more than 2 years. The IC/EPCM prepared and conducted classroom
Safety training with respect to the additional new hazards present due to commissioning and start-up
activities. Training was given to all personnel who were required to work in a Commissioning Safety
Area/Safety District including third parties such as Asset Delivery Teams (ADT), and visiting vendor
service personnel. Access to a Commissioning Area required mandatory CSU Training (Induction),
which was then registered and confirmed by badge/helmet sticker. The Safety Induction training was
conducted in one or more languages to be sure of full understanding by the participants. The Safety
Induction training included the following minimum content:
■■ Livening up Notices.
■■ PPE Requirements,
■■ Commissioning Area Safety Rules.
■■ Commissioning PTW.
■■ Site emergency procedure during commissioning.
■■ Go/No-go Events.
■■ Blind isolation requirements.
■■ Control of battery limits.
■■ Working with nitrogen.
■■ Understanding H2
S dangers.
■■ Commissioning Safety Signs and Notices.
■■ Energised systems.
■■ Control Room Rules.
■■ SIMOPS recognition.
■■ Area specific risks (e.g., ASU will have Cryogenic Hazards).
Certain HSSE elements included above were communicated to the work force who continued to
carry out construction work outside a Commissioning Safety area /District, e.g., PPE requirements
Following RFC, systems that were at a point of being energised or pressurised for the first time, the
system status changes were notified by issuing a Livening up Notice (LUN) to all affected parties.
Overall field HSSE Responsibility for a system remained with the IC/EPCM Commissioning Manager.
Construction punch lists items that were still open at RFC were added to the Company punch list,
forming a consolidated system punch list and were attached to the RFC certificate, so that the
Commissioning Manager acknowledged any remaining construction work that was then closed under
his/her system control and which represent potential SIMOPS situations. The RFC certificate was
stored in the system compilation file. Standard (template) checklists were used to ensure a consistency
of approach at RFC and mitigate any over sites and omissions (see Attachment 6.2 – Safety Districts)
6.3.4 Commissioning Safety Area segregation/Access Control
The IC/EPCM Commissioning Manager required one or more systems from IC/EPCM Construction
Manager so as to generate a geographic area which was practically segregated from a
surrounding Construction area. The IC/EPCM Commissioning Manager declared this geographic
area a Commissioning Safety area (Safety District) when one or more of the systems within it
reached RFC. The geographic area was then segregated from the remaining areas still under
construction. Segregation was implemented by barriers/fences with warning signs. Purple coloured
tape and warning signs were used on fencing to clearly communicate to all an area under
commissioning control.
The practical aspects of segregation are discussed further in 5887-ON-PL-CO-xxx (Attachment 6.2 –
Safety Districts). Access to Commissioning safety areas were limited to area commissioning personnel
and work parties sanctioned to be in the area working under a PTW.
All personnel in the commissioning area had undergone the commissioning safety training (see
Attachment 6.2 Safety Districts - Live site induction) or be hosted and accompanied at all times by
Commissioning Engineers. Trained security guards were used to ensure access control.
The IC/EPCM planned the number and content of each Commissioning Safety area/Safety District.
Accordingly, the SDO then considered the planned system RFC order, to achieve RFSU for the start-up
blocks in line with the overall project schedule and own contract requirements.
6.3.5 Livening up Notices
The IC/EPCM made all interested parties aware when plant and equipment within an RFC system was
to be made ‘live’ for the first time (i.e., applying Electrical Power, Air, Hydraulics, or test media etc.).

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on signs their use and meaning. The signs were standard and uniform throughout the GTL complex.
Attachment 6.2 – Safety Districts PMC plan 5887-ON-PL-CO-00 gives reference of details.
6.3.9 Construction and Pre-commissioning PTW
Pre-Commissioning work was carried out under a Construction area PTW until the system reached
RFC or until the geographical area in which the system was located was declared a Commissioning
Safety area/Safety District by the IC/EPCM and Shell CSU HSSE.
For work on HV or LV electrical equipment or mechanical work on electrically driven equipment or
generation equipment, an Electrical PTW was used.
6.3.10 CSU PTW
The CSU PTW came into force when a geographical area (Safety District/Zone) was declared
a Commissioning Safety area. The CSU PTW was used for all work inside the Commissioning
Safety area/District. The Commissioning PTW was very different from the Construction PTW.
The Commissioning and Start-Up PTW was an adaption of the Shell Asset (Run and Maintain)
Operational PTW system.
For work on HV or LV electrical equipment or mechanical work on electrically driven equipment or
generation equipment on electrical , PTW was used.
The Adapted PTW Process for Commissioning is given in Attachment 5.6 – Critical Processes and the
Asset Electrical Rules and Regulations that include the Electrical PTW are also found in Attachment
5.6 – Critical Processes.
Any work that was carried out at an instrument or electrical interface and required power on in a
cable, both parties signed the PTW. Any work that was carried out along a pipe which connected
two or more contracts and which was not segregated by battery limit or system limit blind, all
responsible parties signed the PTW.
Whilst it was a contractual obligation that the IC/EPCM/COMPANY put in place the Commissioning
PTW system, the reality was that this extensive implementation activity was undertaken by the Shell
CSU HSSE team, my team. This was a tremendous undertaking that was completed in a timely
manner (3 months before the first commissioning area was planned). Activities to achieve this
requirement included:
■■ Identification and definition of the PTW organisation for the Safety District, this included roles and
responsibilities.
during steam blowing, H2
S toxic clips etc. This communication was given by the IC/EPCM by safety
awareness sessions/safety TBT.
6.3.7 PPE Requirements
The IC/EPCM and Shell CSU HSSE identified when CSU activities required additional PPE. This
ranged from ear defenders for any activity within determined distance of steam blowing activities,
wearing goggles rather than light eye protection (safety spectacles) within areas that contained
corrosive chemicals, dust masks during catalyst loading activities to more stringent PPE requirements
when hydrocarbons were introduced, e.g., toxic clips.
Figure 27: Gas Detector
6.3.8 Commissioning Safety Signs and Notices
Once a system reached RFC and the livening up process had begun clear indication on the
equipment and in the area concerned by the use of European standard signs and notices both ISO
graphical symbols and written text was given. Signage was multi-lingual or graphical and this helped
the work force in that area understand the risks. The Site Commissioning Induction included instruction

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To enable a smooth transition a number of potential challenges/issues were identified for mitigation.
Examples of such are listed below:
■■ Clearly defined emergency response roles and responsibilities, particularly during the transition
between Construction and Commissioning.
■■ Communication Systems.
■■ Arrangements with RLIC Emergency services.
■■ Availability of fire and gas detection systems.
■■ Availability and operability of plant fire-fighting equipment.
■■ Spill recovery equipment and response teams.
■■ Protocols for unhindered access and egress of emergency services to all parts of the Project,
■■ To establish mutual aid arrangements with government agencies and RLIC.
6.4 SUMMARY
A clear understanding of challenges, what is to be achieved, the risks, time-frame to achieve, are all
ingredients needed to determine resources. This will result in numbers of people with a particular skill
set. This is the relatively easy part.
How this is all organised, the way of working, scope of authority and independence to act is more
difficult. Developing a “winning team” to deliver takes time and a lot of effort. As a manager you must
get to know your people, strengths and weaknesses, pieces of a jigsaw that you will want to become
a coherent whole.
It was not just through my work as the CSU HSSE Implementation Manager that things would be
done but through the efforts of my team. This became my focus. I offer no scientific formula to be
successful. I can say that it is hard work, but it is essential that managers focus their time and effort to
get this as “right” as possible. I am not saying that I did this. It is for others to comment. The challenge
of motivating 40 people to consistently deliver in a project environment against tight schedules, last
minute requests of support, changing priorities, is the biggest I faced during my time on the Project.
Getting the best from your team is the work of a manager.
In addition to getting the people part as right as you can, you can be helped or hindered in your work
if the organisation of work and responsibilities is less than optimum. In this respect the simple division of
the site (from a HSSE perspective) into geographical Safety Districts was a positive development.
■■ Training and authorisation of permit applicants/receivers for Construction and Commissioning teams
in a Commissioning Safety District.
■■ Production of permits in languages other than English (which was mandatory).
■■ Ensuring that trained permit receivers were fluent in English.
■■ Simplification of Construction punch list clearance work in Commissioning areas that did not involve
opening up live process systems or ones under commissioning, e.g., painting, housekeeping,
insulation, etc.
■■ Limiting the number of jobs under permit control, especially high risk jobs such as confined space entry,
hot work, and electrical work. The number of permits was determined by the number and availability
of operations and commissioning personnel to control the work and SIMOPS considerations.
6.3.11 Punch List Clearance
Punch list items were cleared in a timely manner (most of the time!) to minimise Construction works
in Commissioning Safety areas/Districts. Failure to do this resulted in residual Construction punch list
items being subject to the more stringent Commissioning PTW system. Particular emphasis was given
to ensure that any Construction work that included Confined Space entry or hot work was completed
ahead of an area being declared a Commissioning Safety District. Whilst this was not achieved in all
cases, the principal is a sound one to follow.
6.3.12 Electrical Safety Rules during Commissioning
The same project electrical safety rules were applied throughout the lifetime of the Project from
Construction through RFU, RFC, RFSU and Run and Maintain Operations.
Account was taken of the increased complexity and expansion of the plant electrical systems/
loads during RFC through to RFSU period (refer to Attachment 5.6 – Critical Processes Document no.
T-4.599.556 QSGTL Pearl GTL Project Electrical Safety Rules). This expansion required additional
personnel to be trained and appointed in the various levels of electrical competency to complete the
work in a safe and timely manner.
6.3.13 Site emergency response and evacuation plans during Commissioning
The contractor’s emergency response procedures and resources were applied during the construction
period. These were reviewed and amended as required to cover responses to new potential hazards
created by Contractor Pre-Commissioning activities. Site emergency procedures recognised the
potential impact of SIMOPS and must recognised that additional barriers were needed to be erected
to segregate Commissioning Safety areas/Districts from areas still under Construction. By the start
of hot commissioning the emergency response capability of Shell’s operating organisation was in
place and functioning. The PMC agreed with Shell the planning and management of this transition.

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7. HSSE CRITICAL PROCESSES
7.2 MY STARTING POINT - FIVE CRITICAL PROCESSES
7.2.1 PTW
I have spoken previously in this book about the approach I adopted to the development of the PTW
Procedure that implemented this critical process. I talked about the difficulty I faced to convince the
Pearl GTL organisation that what was being offered was proven and fit for purpose. I briefly talked
about the support I received and the detractors. Fortunately, support came in the guise of Senior
Leadership, always a good source of support.
Whilst as the author of the procedure I do not doubt that there may be better ways to detail the steps
that need to be taken to implement PTW. The good news is that with the development of the 8-step
process now documented in the HSSE Control Framework, in addition to the pillars of influence, this
standardisation will reduce the variability on how PTW is documented and implemented across the
Shell entity. That said, what I had written did comply with the 8-step process as developed by PTW
experts within the Shell Group.
An internal analysis was carried out after the CSU of train 1 at Pearl on the adequacy and
effectiveness of the PTW system. Without bias or a need to justify what was in place, the
overwhelming majority of implementation failings identified were people related not process. The
organisations competence was in its infancy, not surprising. This lack of maturity would be overcome
in time. Isn’t it the case that on many occasions, an organisation can look to blame the process rather
than look at the inadequacies of the people implementing the process as the cause to solve?
7.2.1.1 Getting the organisation at large behind the PTW system you have chosen to implement
A lot of experienced people, not just from within the Shell organisation, but from other companies
within the oil and gas community came together in Qatar to help start-up Pearl GTL “mega-project”.
Most, if not all of these people had experience of PTW. Everybody seemed to have a view on what
a good PTW system looked like!
I had chosen what system was to be implemented. I was convinced that it would provide adequate
control of work. I listened to other’s experience respectfully and without being too defensive
articulated the virtues of what was to be implemented. To some people this approach simply said I
was not listening. Perhaps that was true.
There is comment made in sections to come on the training effort expended to enable PTW system
implementation. This was also the opportunity, so I thought, when any misgivings, misunderstandings,
or even untruths could be dispelled and explained away concerning the Pearl GTL PTW process.
Little did I know that the fun had only started!
7.1 INTRODUCTION
The following processes are what I call, critical to implement effectively. This has been based on
my experience of working in a project environment and in Run and Maintain Operations. Processes
that are identified as barriers that can mitigate the potential of threats that can result in “loss” or that
minimise adverse consequences can be called “critical”. In Figure 28 below I include 10 Critical
Processes. I must admit this is a lot. As a rule of thumb, I would use no more than five as a number to
initially focus on developing procedures, training and authorisation (as required) to implement.
Critical
Processes
PTW
MOC/
TPC
Emergency
Response
Incident
Mngt
Contractor
HSSE
Safe Place
Safe Person
Site
Local Area
Induction
Asset
Rules
Safety
District
Training
Competence
Figure 28: Critical Processes
Using this latter rule to guide my focus from the 10 processes featured above, I concentrated on the
following five processes as the starting point of my work. They were:
■■ Permit to Work (PTW).
■■ Emergency Preparedness and Response.
■■ Incident Management.
■■ Management of Change.
■■ Contractor HSSE Management.
I will now discuss these five critical processes.

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7.2.1.3 Training effort
Having confidence in the design of the process so that authority can be given to the organisation at
large, strong messaging that it will work, and confidence that it will provide the necessary steps and
controls to manage safe working, is an essential undertaking. As a pre-cursor to effective training,
trainees benefit from the simple fact that if what they are to be trained in works, and if implemented
professionally through their authority and competence, then excellent workplace controls will be
delivered. We did this despite some initial resistance.
The number of people trained in the Pearl GTL PTW system was huge. In the table below, I give some
indication of the training effort. In addition, I also give an indication of time taken to authorise PTW
signatories. I was very fortunate to have a number of excellent people that shouldered the majority
of the training effort. They know who they are and I am deeply appreciative of their commitment and
professionalism. They were at the sharp end of training and with patience and politeness consistently
delivered the training content. The effort in delivering the amount of training that Pearl GTL carried out
in PTW is only partly described in the table below. The amount of coaching and on-going advice
given daily is substantial and does not stop. This constant effort is required if you want to implement
an effective PTW system.
7.2.1.4 PTW training – Commissioning phase
PTW Role Permit
applicant/
Acceptor
AGT PTSW
signatory
AE ASI FPS
People trained 3074 112 361 56 88 25
Training Course
duration
4 hours 4 hours 8 hours 16 hours 16 hours 16 hours
Authorised 2145 79 183 36 59 18
Interview hours 1000 hours 80 hours 200 hours 40 hours 60 hours 20 hours
Table 7 -1: Training Statistics
■■ For permit applicant/acceptor training approximately 125 courses were delivered.
■■ For AGT training approximately 12 courses were delivered.
■■ For PTSW training approximately 25 courses were delivered.
■■ For AE, ASI FPS training (combined course), approximately 20 courses were delivered.
The number of times I was challenged on what the proposed permit(s) looked like, why certain
signatories were involved in authorising work, why one permit could not be used to cover multiple
activities and work parties, and more, seemed daily. The phrase, “we did not do it like that at my
previous location/company” was a common cry from some in the organisation who found the
process being proposed different from what they had previously experienced and worked with.
Whilst I readily recognise that all processes can be improved, any changes made have to be
reviewed in context of the whole process and how each procedural step connects. Perceived
improvements suggested by people who perhaps do not appreciate how the total process has
been put together, can have an unintended negative effect. The process owner for PTW must
remain mindful. It can come down to personal conviction by saying “no” to changes until after
implementation. More insightful conversations within the organisation can take place after experience
with the process. I chose to engage and listen but chose to make no changes until after the Asset had
a minimum of 12 months experience. The intention was then to set up a PTW users group and allow
the natural processes of performance improvement take place within managed review. I now leave
this to my successor.
Of course this did not satisfy all, but we moved forward. At the front of my own mind was the simple
fact that during commissioning, when major parts of the plant were still under construction, there was
at peak times almost 50,000 people who deserved to have in place a process that was proven and
had delivered excellent workplace controls in similar situations. That was my proposal to the CSU
Start-Up Manager and that is what was delivered.
7.2.1.2 Does previous experience in PTW help or hinder implementation?
People generally find it difficult to unlearn. If people’s previous experience is not too different from
what is being implemented then acceptance is more readily given? However, if people’s perception
of what is being implemented is very different from previous experience, then the level of acceptance
and the ability to unlearn proves more difficult.
Principles and the intent of PTW systems should be common. Experiences that share the same or
similar steps in implementing a process can only help. In the past, whilst the principles and intent of
PTW systems had common goals, the steps taken to achieve these goals could vary. This had to be
recognised and managed.
In the future it is hoped that this becomes less of an obstacle. Standardisation of the PTW process
through the Groups 8 steps process will help with this.

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■■ For permit applicant/acceptor training approximately 25 courses were delivered.
■■ For AGT training approximately 15 courses were delivered.
■■ For PTSW training approximately 15 courses were delivered.
■■ For AE, ASI FPS training (combined course), approximately 10 courses were delivered.
Delivery of training effort was approximately 450 hours. This is only calculated on the basis of 1
trainer per course. For ASI, AE, FPS training two trainers were required to deliver the courses.
Not included in the table, but carried out to give general awareness to the start-up/Asset organisation
was a 4 hour introduction to PTW. Approximately 1500 people were trained. This amounted to 400
hours of training delivery. A conservative approximation of PTW training delivered for the start-up/
Asset organisation accounts for 0.5 FTE over a two year period.
7.2.1.7 Authorisation interviews
From the table above almost 1100 hours were expended interviewing candidates. This does not
include re-interviews for candidates that did not meet the required standard first time. Initial failure rate
varied per signatory role interviewed, but approached 10% approximated across all interviews. There
were a higher percentage of deferrals for the more critical signatory roles of AE, ASI and FPS. For
these roles the knowledge and understanding requirement was high. I personally involved myself with
all interviews at these levels to ensure a consistent standard was achieved. What is also of note is
that for all ASI, AE, FPS and PTSW signatories there would be a minimum of two interviewers.
The referral rate was lower for the start-up phase compared to the commissioning phase. This was
due in part to the fact that during the start-up phase more coaching and support was given by the
Asset HSSE team to proposed signatories. This was seen as a longer term investment. For both the
commissioning and start-up phases a pool of 20+ HSSE Inspectors supported signatories with a clear
focus on all work carried out under PTW. In addition we salted in an experienced Fire Permit signatory
in each operating area (x4) to oversee PTW implementation during commissioning and start-up.
Signatory authorisation during the start-up phase was approximately 1350 hours. This is the
equivalent of 0.75 FTE over an 18-month period for PTW authorisations for the start-up phase.
Acronyms;
■■ AGT = Authorised Gas Tester.
■■ PTSW = Permit to start Work.
■■ AE = Authorised Engineer.
■■ ASI = Authorised Safety Inspector.
■■ FPS = Fire Permit signatory.
Delivery of training effort was approximately 1000 hours. This is calculated on the basis of 1 trainer
per course. For ASI, AE, FPS training two trainers were required to deliver the courses.
Not included in the table but carried out to give general awareness to the commissioning
organisation at large, was a 4 hour introduction to PTW. Approximately 4500 people were trained.
This amounted to 1000 hours of training delivery.
A conservative approximation of PTW training delivered during commissioning accounts for 1.0 FTE
for two years upfront and during the commissioning phase.
7.2.1.5 Authorisation interviews
From the table above almost 1400 hours were expended interviewing candidates during commissioning.
This does not include re-interviews for candidates that did not meet the required standard first time. Initial
failure rate varied per signatory role, but approached 25% approximated across all interviews. There
were a higher percentage of deferrals for the more critical signatory roles of AE, ASI and FPS. For these
roles the knowledge and understanding requirement was high. I personally involved myself with all
interviews at these levels to ensure a consistent standard. What is also of note is that for all ASI, AE, FPS
and PTSW signatories there was a minimum of two interviewers.
In total, when time is allocated to interviews the commitment was approximately 1800 hours. This
is the equivalent of 1.0 FTE for one year carrying out authorisations in PTW for the commissioning
phase organisation.
7.2.1.6 PTW training – Start-Up/into Normal Operating phase
PTW Role Permit
applicant/
Acceptor
AGT PTSW
signatory
AE ASI FPS
People trained 936 567 394 42 68 68
Training Course
duration
4 hours 4 hours 8 hours 16 hours 16 hours 16 hours
Authorised 822 328 244 33 23 17
Interview hours 450 hours 325 hours 250 hours 30 hours 20 hours 20 hours
Table 7-2: Training Statistics

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Figure 29: Permit Office
7.2.1.9 What about PTW systems in the future – what will they look like?
Discussion in the future about further PTW standardisation is welcomed. The 8 steps given above can
enable a more consistent PTW design. The universal development of an electronic PTW system within
the Shell Group will further enable more consistency in approach, certainly in the area of HOW PTW
is implemented, and WHAT it looks like. In addition, opportunities to make breakthrough performance
in overall workplace hazard management through electronic integration of processes aligned and
supportive of PTW, such as incident data, incident learning’s, isolation, cumulative risk assessment,
etc., is positive and welcomed.
To summarise: The number of FTE required to deliver initial training for the commissioning and start-up
phases and carry out authorisation interviews was 3.50 FTE over 2 years.
7.2.1.8 Measure the Design of the PTW System to be Implemented against Standards
The adequacy of PTW design at Pearl GTL when measured against the recently published Shell
Group guidance and tools on measuring an effective PTW system is very positive. The eight steps to
effective implementation are all included in the Pearl GTL’s design. These are:
1. Planning and work scope.
2. Assess hazards and determine controls.
3. Implement controls.
4. Review and verify.
5. Issue permit.
6. Work party pre-job discussion.
7. Execute and supervise.
8. Verify job complete, closed and handed back.
Making sure that the PTW system being implemented has the defined process steps indicated above,
allows the operating entity assurance of an adequate process design. The on-going, day-to-day rigor
of ensuring what is written is followed, and authorised signatories professionally and competently
carry out their defined roles, and responsibilities requires daily management attention.

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Work Preparation Choosing the correct
work method
Controls during work
Disconnecting safety systems
■■ Disconnect
■■ Override
■■ Temporary plant change
■■ Protecting cables/hoses
■■ Earthing
■■ Location for gas cylinders
when used/stored
■■ Noise affecting
communication with user
■■ Ignition sources
■■ Static electricity
Personal Protective Equipment
■■ Hazards present
■■ Potential exposure
■■ Parts of the body to
be protected
Emergency plans
■■ Raising the alarm
■■ Site response
■■ Special response
■■ Protecting rescue team
■■ First aid facilities
■■ Information for medical teams
■■ Firefighting equipment
■■ Personal monitors
■■ Escape equipment
Figure 30: Hazard Identification in PTW Process
7.2.1.10 Job Aid used by Permit signatories to identify work hazards
Work Preparation Choosing the correct
work method
Controls during work
Preparing process equipment
■■ Safe isolation of plant
■■ Special isolations
■■ Depressurise
■■ Drain
■■ Ventilate
■■ Wash
■■ Purge
Preparing machinery
■■ Isolate power supply
■■ Disconnect engine starter
Preparing Electrical systems
■■ Isolate electrical supply
Preparing radioactive sources
■■ Remove source
■■ Shield source
Preparing work area
■■ Carry out at ground level
■■ Move work items to
safer areas
■■ Ensure good access
and egress
■■ Clean area
■■ Ventilate
■■ Temporary access
■■ Fall protection
Establishing an exclusion zone
■■ Size of zone
■■ Barriers
■■ Signs
■■ Manning
People in the work party
■■ Minimum number in
work party
■■ Supervision
■■ Perform rescue in
an emergency
■■ Skill/experience of activity
■■ Skill/experience using tools
■■ Knowledge of hazards
■■ Knowledge of QSGTL safe
systems of work
■■ Age/maturity
■■ Fatigue
■■ Medical condition
■■ Attitude
Tools and equipment
■■ Correct tools to sue
■■ Restrictions for use
■■ Hazards to the user
■■ Interaction with hazards in
the area
■■ Damage to plant/
equipment/buried cables
and services
■■ Certified for zone
■■ Inspection before and
during work
■■ Inspected by who/
frequency?
■■ Consequences of tool/
equipment failure
■■ Transporting to/from
work place
■■ Heat/sparks from tool
■■ Protecting cables/hoses
Gas testing
■■ Flammable
■■ Toxic
■■ Oxygen content
■■ Carried out by whom?
■■ Frequency
■■ Protecting the people
carrying out the tests
Protecting people in the vicinity
■■ Process releases
■■ Flying debris
■■ Falling into excavations
■■ Structures falling during
construction/demolition
■■ Impact with moving
equipment/vehicles
■■ Notify adjacent areas
Maintaining integrity of plant
and equipment
■■ Plant change
■■ Inspection before and during
work Inspection by who/
frequency?
■■ Staying within
design conditions
■■ Vehicle impact
■■ Dropped loads
■■ Flying debris
Preventing fires
■■ Area zone classification
■■ Release of
flammable material
■■ Oxygen ingress

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7.2.2 Incident Management
7.2.2.1 Introduction
When things go wrong, we have to act; as a minimum we need to understand what went wrong.
We need to gather facts. An appropriate level of investigation will reveal what were the main causes
to the incident. We can then look at how we can prevent the incident from happening again.
Of course we all want to work in a Goal Zero culture that typifies personal responsibility and the care
and awareness to look after ourselves and others, to intervene. But unfortunately things go wrong. So
what should a Site HSSE Manager/ CSU HSSE Manager do when incidents happen?
1. Encouragement to report all incidents is a cultural imperative to achieve Goal Zero.
2. Reporting what went wrong and what caused the incident must be fact based.
3. Reporting and initial fact based investigation are normally sufficient steps to take with low
consequence/low potential consequence incidents. Communication of what went wrong and
why, are final steps to make the organisation at large aware so that they can avoid/minimise
such incidents.
4. The level of investigation applied to incidents will normally depend on one or all of the
following factors:
a. Extent of injury or damage.
b. Potential for injury or damage.
c. Potential for repetition.
A site HSSE Manager/CSU HSSE Manager should be able to give advice on the analysis of findings
from incident investigations. The purpose of analysis is to establish the critical events and underlying
causes of the incident such that corrective measures are more robust and sustainable in preventing
future incidents. This requires investigators to have a clear understanding of the cause and sequence
of activities and why one situation progressed to the next.
For those incidents that warrant further analysis, application of methodologies such as TRIPOD is
recommended. It should be understood that the basis for good TRIPOD analysis is a thorough and
factual root cause analysis that includes amongst other things, a sequential time-line of contributing
events. The site HSSE Manager/CSU HSSE Manager must understand that certain investigations
should not be restricted to the unsafe acts/conditions or active failures that will only conclude that
human failures caused the incident. What TRIPOD can demonstrate is that unsafe acts/conditions do
not occur in isolation but are influenced by existing preconditions, which may originate from failures in
the top level of the organisation and line management. Such activities and decisions are removed in
time and place from end of the line operations, where the incidents occur. The so called latent failures
7.2.1.11 Permit to Start Work certificate
Figure 31: Permit to Start Work Form
LOWRES
Please provide
better quality

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7.2.2.2 Incident reporting during Construction
During construction incident reports were generated through a process of observation enabled by a
very simple Safety Observation Card (SOC) that encouraged positive and negative reporting. This
was a paper based system, with the SOC being collected centrally, analysed and reported. When
you consider 50,000 pairs of eyes available on site, incentivised to observe and report on safe/
unsafe work and conditions, the number of reports submitted was very large.
Quite a number of staff were involved in carrying out data analysis. At peak manpower numbers and
activity during construction, the equivalent of 10 FTE were involved in data analysis and reporting.
The quality of reporting overall was satisfactory. Report cards were submitted in the many native
languages that made up the diverse workforce at Pearl GTL. Emphasis was given to spot near misses,
unsafe acts and conditions.
Keep it simple was the motto.
The use of LCA as a focus for observations and corrective action supported the achievement of an
excellent safety performance during construction. LCA included those activities assessed as potentially
life threatening during the construction phase. LCA have been discussed in detail in the construction
story section of this HSSE book.
In addition, a successful initiative called “IIF” helped transform the mind-set of the workforce at large.
This transformation imbued values and behaviours such as empowerment, openness and honesty,
and encouraged the workforce to speak up. IIF focused on a belief system that all incidents could be
prevented. In the context of Incident Management, the culture to openly and constructively report was
given further impetus by the IIF program.
To summarise, incident reporting during the construction phase was enabled and given focus by the
IIF program, LCA and incentivising the workforce.
7.2.2.3 Incident reporting during commissioning
Commissioning of equipment and sections of the Plant took place whilst major construction works
were still being carried out. In the areas of the plant undergoing commissioning activities, a new focus
on the additional hazards associated with commissioning works was orchestrated through a major
communication and training exercise that involved bulletins, posters, banners, TBT, town hall meetings
etc, etc.
may lie dormant within the system for a long time, and their adverse consequences may only become
evident when they combine with other factors to breach system defenses.
TRIPOD analysis reveals that latent rather than active failures are the precursors to incidents.
Identifying and correcting the latent failures rather than merely correcting the active failures induced
by them (symptoms), is more effective in meeting the ultimate objectives of the investigation.
A site HSSE Manager/CSU HSSE Manager is principal in determining what incidents require a better
understanding of why they happened. To apply TRIPOD analysis methodology requires trained and
competent facilitators. To maintain competence requires regular application.
A site should have a core group of facilitators. The number of facilitators depends on the size of the
site. As a rule of thumb facilitators should be carrying out TRIPOD analysis on incidents, as a minimum
twice per year to retain competence. For a site the size and complexity of Pearl GTL, a trained cadre
of approximately 6 facilitators would suffice. An ambition to learn more about incident causation
by the application of TRIPOD methodology at a Site that is reporting 2000 incidents per year must
be selective and managed. But if one simply says that 1% of incidents from a database of 2000
reported, will be subject to TRIPOD analysis, then 20 TRIPOD analysis will be carried out, which will
mean that from a cadre of 6 trained facilitators they would each have the opportunity to lead in at
least 3 per year. A Site may decide to do more. I simply give a basis that can be discussed.
A more fundamental challenge is the basic ability of investigation to get to facts and causes. The
organisation at large should have competence in root cause analysis. All Front Line Supervisors should
have an appropriate level of competence to ensure that facts and immediate causes are identified in
all incidents.
A Site HSSE Manager/CSU HSSE Manager should advise the organisation at large of the core
critical competence requirements to enable effective Incident Management.
Creating the appropriate focus when incidents happen is important. When incidents are happening
regularly in a particular area, visiting the SDO to establish what has gone wrong and then having
a conversation on what can be done to prevent and minimise such incidents, can create a positive
climate for effective response. This can also be applied with contractor partners when activities are
not going as planned. Involve contract holders to reinforce the culture that all incidents are taken
serious, that action taken must satisfy the site’s requirements for effective Incident Management, and
the desire to work in a Goal Zero environment.

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7.2.2.5 Tips for effective Incident Management implementation
■■ Work at developing a culture that encourages openness to report. This may require incentivising.
■■ Be sympathetic and manage the possibility that language could be a barrier to communication.
Have the organisational competence that can process reports from a variety of different languages.
■■ Make it simple for the workforce to report. During construction when we had 50,000 workers,
paper worked well. There was a trade off, with staff needed to interpret, collate and analyse this
data. This was considered a positive trade off.
■■ You need to educate (train) and continually make the workforce at large aware of what you want
them to report, what types of incident.
■■ Tools such as the 3 what’s worked well particularly in commissioning and now in the operate
phase. This simple mental model asking 3 basic questions gave incident reporting structure.
■■ The LCA provided clear context for people to report against.
■■ The competence to report incidents factually, investigate incidents to identify immediate causes, is
a fundamental organisational competence and capability requirement. This is an absolute minimum
to have in place. This should be a clear focus to establish.
■■ Organisational competence to carry out in-depth analysis (e.g., TRIPOD) is essential if the
organisation is to benefit from more than the identification of immediate causes. It is necessary in
some incidents to pursue identifying underlying causes, the application of methodologies such as
TRIPOD is essential in this achievement.
■■ Do not train too many TRIPOD facilitators – I did. Start small, say about 4 – 6 persons, and build
into their roles and responsibilities the requirement to carry out between 2-4 investigations/analysis
per year.
Thus far I have not commented on the impact that the Shell Group’s Life Saving Rules had on incident
reporting. The Life Saving Rules also provide a focus and context for people to report incidents.
A word of caution: As we moved through the phases of construction, commissioning, start-up and
into operation of Pearl GTL, each phase had been distinctive in the type of incident and the number
of such incidents reported. From time-to-time, campaigns were carried out that focused on certain
activities to correct performance and seek improvement. In doing so a disproportionate amount of
data was generated for a particular activity or rule. This approach can skew data and the overall
data analysis. If this is not taken into account, efforts may be directed in the wrong areas. I do not
dispute that all 12 LSA=R are important. During start-up, I must confess that I encouraged focus on the
more operational, process safety hazards and risks and had to bring balance to analysis that showed
that our No. 1 bad actor after campaigns were carried out, was, a violation in the use of seat belts.
The Site HSSE Manager/ CSU HSSE Manager must provide proportion to the analysis carried out
and reported, and direct resources and focus appropriately.
To help in the quality and consistency of incident reporting, training the workforce in simple concepts,
such as 3 what took place. As in construction, emphasis was given to spot near misses, unsafe acts
and unsafe conditions. The 3 “what’s” observation process supported this emphasis:
■■ What could go wrong?
■■ What could cause it to go wrong?
■■ What can be done to prevent it from happening?
Keep it simple was again the motto.
Proof that the training had been effective would be seen in the type and quality of incident reporting.
Reports that spoke of smells, noise, vibrations, and leaks were submitted. The majority of reporting still
came via SOCs. It was easier for the workforce at large to report in this way.
Slowly and as more start-up personnel became involved in commissioning work the FOUNTAIN
Incident Management system was used.
The commissioning phase benefitted from the cultural work undertaken in construction. The workforce
at large had worked with an “IIF” mind set through construction. Many construction personnel were
involved in commissioning. The focus of LCA in construction was replicated in commissioning with
an equivalent program that identified commissioning activities in life critical terms. Furthermore, the
PTW system used in commissioning was the system that was to be used in the start-up and operating
phase of the plant. The PTW system provided a further framework and lens through which to observe
how work was carried out, the hazards and the adequacy of control measures identified. All of this
resulted in continued healthy reporting levels.
7.2.2.4 Incident reporting during start-up
The use of tools and processes to encourage reporting through planned observations, on-going
training and awareness sessions that identify typical workplace hazards all contributed to deliver a
healthy level of incident reporting during start-up. During the start-up year of 2011, approximately
2000 incidents were reported. It is pleasing to report that the 2000 incidents reported during start-up
were done so via the FOUNTAIN Incident Management system. This migration into an electronic
environment enabled better efficiency and more effective data collation and analysis. Trending of
data also started to happen. That said, and at the time I write this, incident analysis is still an area
that requires further work. We are not learning quickly enough. Focus cannot solely be learning from
what has happened. Incident Management should also be applied from the activities and tasks to
come. Incident Management has to be seen as a pro-active not just a reactive process.

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As process owner of PTW, I had decided to make no changes to the proposed PTW system until
after 12 months of implementation experience. My colleagues in Technology instead decided to
consider improvement proposals in light of feedback given during training. This was a different model
of implementation for MoC when compared to the “no change” approach adopted for PTW.
The effort expended by my colleagues to accommodate modifications to the MoC procedure has
not been qualified in time. However, to put this effort in to context, at the time of start-up at Pearl GTL
when this MoC procedure was implemented, there had been 20 revisions.
7.2.4 Training
Two levels of training were carried out for the start-up organisation. A four hour awareness session
was given to all start-up personnel. This awareness training focused on how to recognise when a
change required the application of the MoC procedure, and the benefits of applying a process
to design, review and authorise changes. This included an in-sight to the different discipline and
competent people involved in the change process and why an authourised procedure to manage
change was necessary. This latter justification was graphically explained to all through major industry
incidents that had their major cause as a failure to adequately manage change.
For those discipline personnel that would be signatories within the Pearl GTL MoC process, one day’s
training was given followed by interview before formal authorisation. Written into the MoC procedure
is the competence requirements for the different discipline signatories. In addition, authorisation
requirements are also stated. Evidence that application of the process by the trainee signatory is
required before authorisation is given. The interview will concentrate on the role of the signatory in
real examples, so that knowledge and understanding can be verified.
During a major start-up, as in Pearl GTL, there is the necessity to pump prime the process so that a
core number of signatories are available to actually implement the process from day one. One of
the stated requirements of the Pearl GTL MoC (Plant Change) procedure was that a number of (20+)
Plant Changes, were needed before the trainee signatory could attend an authorisation interview.
This could not be done with a new organisation implementing the process for the first time. Exemption
was given to a core group of signatories so that the process could be applied. Thereafter, all future
signatories complied in full with authorisation requirements.
7.2.5 Monitoring the initial implementation effectiveness of MoC during start-up
A number of Key Performance Indicators were developed to monitor the implementation effectiveness
of MoC. The process owner for MoC had the responsibility to define and collect data to monitor
effectiveness. MoC implementation was monitored in two main forums, the HSSE Steering Committee
and the Technical community. As a minimum these forums met monthly.
7.2.2.6 Summary
Incident reporting, investigation and analysis, learning from incidents and the effective implementation
of corrective and preventive measures identified from investigation, are essential elements that need to
be implemented to achieve an adequate level of Incident Management. I am sure you are all saying,
“yes, I know that”, but an equal emphasis needs to be placed on all of these elements. Whether
it is inadequate investigation, inappropriate analysis, slow action closure or a combination of, if
each element of Incident Management is not carried out effectively, there will be lost opportunity in
learning, repeat failures, and a message sent to the organisation that nothing positive is coming from
the process. This can result in people reporting less.
The 3 phases of the Project benefitted from a positive cultural intervention program. IIF started in
construction and prevailed in all 3 phases. This cultural intervention was fundamental. Empowering the
organisation to be open, honest, proud and caring for self and others encourages people to report on
what they see as wrong, as going wrong and the belief that if they report, things will be done.
The continuation of IIF in the operate phase of Pearl GTL has been carried forward by work under
the “Goal Zero” and “Pride in Production” banner. Focus given by LCA in construction, an emphasis
on hazard awareness in commissioning, simple tools such as the3 What’s and the Safe Place Safe
Person program in the operate phase, have all contributed structurally to enable a positive level of
incident reporting.
The Incident Management Procedure documents are available in Attachment 5.6 – Critical Processes.
7.2.3 Management of Change
At Pearl GTL the process owner for Management of Change (MoC) is the Technology Manager. The
MoC procedure that has been implemented owes its development to the procedure used at Stanlow
Manufacturing Complex, thereafter implemented at the Nanhai Petro-Chemical Plant in China. Over
this period there have been modifications to the original Stanlow procedure based on experience,
in-sight and the requirements stipulated in the Group’s HSSE SP Control Framework.
The Pearl GTL MoC procedure referred to herein does not include Organisational Change, which is a
separate procedure. The focus is on Plant Change.
In a similar process of engagement as with the introduction of PTW, the proposed Pearl GTL MoC
procedure (Plant Change Procedure) was subject to comparison with other procedures that people in
the organisation had experienced before. Despite the fact that the process owner could demonstrate
that the proposed procedure to implement this critical process satisfied the requirements stipulated by
the Shell Group, people in the organisation looked to further enhance what was being proposed.

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Initiation/Change Reconition
Concept
Approval
Shelved and
terminated
UM Approval
(implementation)
Record in Unit register
Basis of Design (BOD)
And Technical Development
Management Review and Approval
20K$
UM Approval
(Dvelopment BDEP)
BDEP
Shelved and
terminated
Shelved and
terminated
Installation/Execution
(Field) Rediness Review
Records Update and Closure
■ Initiator supported by Process engineer (Purpose, priotisation and
50% cost estimate
■ Area Asset Manager
■ Process Engineer requests/confirms register number
■ Process Engineer leads BOD
■ Authorised Technologist/Mechanical Engineer,
Authorised Instrument Engineer defines requirements
for specialist approval
■ Technical specialist sign [Process Safety and Inspection: mandatory
■ Authorised Technologist, Nominated Engineer, Authorised Instrum
Engineer sign
■ Area Asset Mgr
■ Project Engineer supported by Process Engineer [BDEP, 10% cost]
■ Contract board
■ Engineering Mgr and/or Project Engineer and Contractors
■ Process Engineer provides “Work Copy” PEFS to Plant Operation
■ Authorised Mechanical Engineer/Technologist/Instrument Eng.
■ Plant Operations Nominee
■ Plant technologist provides
■ Led by Project Engineer, or Process Engineer
■ Copy of MOC is filed by Project Engineer
■ Maste copy of MOC is kept by Plant Technologist with red marked
“As Built Copy”
Engineering
Required
Section of MOC Process Roles
A1-A4
C-D
A5
E
B
N
N
N
N
Y
Y
Y
Y
Y
N
Figure 32: MOC/TPC Flow Scheme
The table below represents the KPI used during start-up year (2011).
Key Performance Indicators Target
1. The number of changes raised during the reporting period (month) Track
2. Number of PCR taken into operation without readiness review completed Zero
3. PCR documentation not updated within 90 days of PCR implementation Zero
4. Temporary PCR overdue for review Zero
Table 7-3: MOC KPIs
The above were the set of KPI that were initially tracked.
The number of changes being carried out was deemed important initially as a crude measure to
monitor the amount of change taking place. The amount of change during start-up and in the first 12
months of operation was considerable. Much of this was necessary to correct/improve on equipment
and equipment design parameters not meeting start-up requirements. A large proportion of these
changes were software. As well as giving a crude number as an indicator, further granularity was
also given in the type of change (software, hardware etc.).
KPI 2 monitored the level of organisational (mainly operations) readiness and preparedness to accept
the change and to understand the implications of the change. This could include training, awareness,
procedural updates etc. If the number of changes is large, the work load on the Operations nominee
(in steady state operation this is normally an Operations Day Supervisor) is extremely high, and from
Pearl GTL’s experience, cannot be done by one person.
KPI 3 is self explanatory. This focused on trying to ensure that documentation was kept current. A big
effort is required to do this.
KPI 4 focused on the review and continued authorisation of Temporary Plant Changes.
KPI 2 3 were the most challenging indicators to satisfy.

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9. The emergency response role of the operations shift Supervisor, the site shift Manager and the FIT
Lead professional fire fighter in the initial response to incident emergency would be critical and
the capabilities to carry out these roles effectively would need to be assured.
10. A 24/7 call out system that would enable professional support and management of incident and
emergency situations at Pearl GTL would be established.
The assumptions made were the basis for the initial work to set up an emergency response capability.
Perhaps some in the organisation at Pearl will disagree with the remarks I will now make, but from my
own personal perspective and as one who had responsibility to enable the delivery of an agreed
and acceptable emergency response capability, this work did not go entirely smoothly and the
amount of effort needed to get over the finishing line was underestimated.
From the initial assumptions made and based on practical experience, we changed the fundamental
philosophy of how we would implement first intervention to incident and emergency situations.
I will give a flavor.
The overwhelming majority of our operator cadre at Pearl was Asian, with the majority being of
Indian origin.
We embarked on training our operators in emergency response drills. Considerable effort was
expended. This was met with a reluctance to participate by the operations cadre. The operators
argued that it was not their role and was certainly not their previous experience or expectation of
what they should do.
In time we better understood why we had met with this reluctance, the reasons being multi. What we
did have to quickly conclude was that a major part of the original design, the make-up of FIT, would
need to be different.
In addition to recruiting four professional Lead Fire Officers (equivalent of Station Officers in the
UK Fire Service) we recruited an Emergency Response Team Leader. This was both necessary and
proved essential based on the changing assumptions.
The Emergency Response Team Leader brought a wealth of experience and professional in-sight in
what was needed as an initial organisational set up that would be adequate and capable to meet
the potential challenges of Commissioning and Start-Up.
During commissioning, the commissioning Manager for the asset area became the de-facto
operations nominee and was responsible to ensure that commissioning staff were prepared and
knowledgeable of the change proposal.
7.2.6 Emergency Preparedness and Response
7.2.6.1 Initial design of the Emergency Response Organisation
The initial strategy for Emergency Response was heavily aligned to experience from European and
North American sites. The intention was to train all operations shift staff in basic fire fighting and
emergency preparedness duties. Thereafter, based on aptitude, select and then further train, a cadre
of “auxiliary” Fire Fighters. Initial estimates based on bench-marking indicated that the cadre of
operators to be trained as auxiliary fire fighters would approximate 60 people, 15 per shift. This team
would be known as FIT, First Intervention Team. There would be a First Intervention team for each
operational shift.
Furthermore, our initial organisational design included four Lead professional Fire Officers that would
manage FIT on each of the shifts.
A number of assumptions were made to arrive at this initial design:
1. Shift Operations personnel would embrace the challenge of Fire Fighting duties and we would
have no trouble in selecting 60 of the best to assume additional responsibilities as auxiliary Fire
Fighters to form a First Intervention Team.
2. Pearl GTL FIT would be required to attend to incidents classified as incipient, tier 1, tier 1
escalating as defined in NFPA standards.
3. The capability of the resident full time Fire Fighting Brigade at RLIC would cater for all incidents at
tier 1 escalating situations and assume incident command whenever attending incidents at Site.
4. The equipment selected to enable FIT carry out emergency response activities would be
proportionate to intervention at tier 1 incidents.
5. 20 – 25 Pre-Incident Plans would be developed (a minimum of five per each operational area).
These Pre-Incident Plans would be the basis of training exercises that would familiarise and
prepare the Pearl GTL FIT for potential incident scenarios.
6. Approximately six months prior to first gas into Pearl GTL joint exercises with RLIC Emergency
Services would be carried out to confirm adequacy and readiness to respond.
7. A minimum of four hours per calendar month would be allocated for every member of FIT to
enable fire fighting training and emergency preparedness drills. This would take place outside of
normal duties.
8. Original organisational design identified synergy with Security Department with FIT operational
teams reporting to the Site Security Manager.

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Self Contained Breathing Apparatus
The Senior HSSE Advisor who worked in my team could write a book on the experience about the self
contained breathing apparatus that was selected for Pearl GTL. There are a number of discussion notes
given as attachment? That go some way to give a flavor of the challenges we faced to provide an
adequate critical piece of safety equipment for people working in potentially hazardous environments.
The story started with a simple observation that based on religious sensitivities we wanted to respect,
not all of the potential wearers of breathing apparatus would be clean shaven. This necessitated a
review of the type of mask that could be worn to provide the necessary protection for all wearers.
A prospective Company provided a hood mask that allowed people with beards/facial hair the
necessary protection, and their product was already being used in Shell Oman. We felt confident that
after communicating with our colleagues in Oman and after trial testing at Pearl, we would have a fit for
purpose solution. This was done and the initial reaction was extremely positive, that was until personnel
were asked to carry this equipment as part of their normal PPE in designated areas of the Plant.
Feedback that the equipment was too heavy and cumbersome to carry was acted upon. We looked
at a variety of means to carry the equipment so that the load was ergonomically distributed across
the body. We embarked with the supplier on efforts to reduce the overall weight. Lighter materials
were used and the overall weight was reduced. This took time to achieve, unfortunately for some, too
much time.
Further work is currently on-going to strictly apply the carrying of self contained breathing apparatus in
areas of the plant where a release of Hydrogen Sulphide (H2
S) above a concentration that is greater
than immediately dangerous to life and health, (IDLH) can occur. Whilst it is easy to map these areas, it
is less straight forward to practically apply this rule. Until this is done to the satisfaction of Management
the carrying of self contained breathing apparatus continues in all areas that H2
S is present.
The capability of the resident full time Fire Fighting Brigade at RLIC is being established and
developed. A pragmatic agreement has been reached that based on the local incident scenario, if
deemed appropriate, overall command of the unified response will be under the leadership of the
Shell lead professional Fire Officer (On-Scene Commander). The wisdom to recruit four professional
Fire Officers has proved invaluable. Furthermore, this has been supplemented by a further four
professional fire fighters to act as deputies. A strong professional cadre of lead Fire personnel has
been assessed as critical at this stage of maturity of the Pearl GTL organisation.
The Pearl GTL Emergency Response organisation is led by the Emergency Response Lead who reports
into the HSSE Line organisation. This is a departure from the original assumptions.
The FIT would be fulltime and cover the Site 24/7. The on-duty team numbered? and comprised?
In addition to being ready and capable to address incident and emergency situations at tier 1 and
tier 1 escalating scenarios and as a necessary part of an integrated and unified response force if
and after RLIC Emergency Services were called, the Pearl FIT also addressed other day to day tasks
that helped to support activity on Site. These included:
■■ Confined Space Entry attendance, (*)
■■ Issuing and maintenance of critical items of PPE, e.g., breathing apparatus, respirator masks, toxic
gas detectors (personal and activity meters), etc.
■■ Routine inspection and maintenance of fixed fire-fighting equipment (fixed and mobile),
■■ Carrying out drills and exercises internal to Pearl GTL with Operations staff. Carrying out planned
and agreed drills and exercises with RLIC Emergency Services.
(*) Initially I was not aware of the amount of stand-by situations for confined space entry work that
FIT were being involved with during Commissioning until I started to look at the FIT daily log. Their
stand-by attendance was not needed for the vast majority of work identified (90%). A culture of risk
aversion was resulting in FIT resources being deployed for hours at Site, when adequate response
could have been given (5 minutes) to any point at Site when needed.
Considerable time and effort went into the design and procurement of essential items of equipment for
emergency preparedness and response. I will give example of two items:
7.2.7 Quick Attack Trucks
Based on the Land Lease Agreement that Pearl GTL was subject to, advice was given by RLIC on
what vehicles and equipment we could purchase and operate. This made sense and matters of
equipment compatibility were achieved. This resulted in the purchase of two Quick attack trucks that
could deploy personnel and equipment to incidents based on a tier 1 level assessment.
Work on identifying what we could purchase in the market place began at the end of 2008. Both of
the vehicles that we eventually purchased finally arrived at site in 2011 prior to major commissioning
operations (first gas in). One could say just in time. However, what we had to do during the vast majority
of commissioning work was to rely and operate the emergency response vehicles that were provided for
Construction.
We did not intend for this to happen. We had agreed with the purchaser dates on delivery of the
Quick Attack trucks to be prior to the main commissioning work starting. Do not underestimate lead
times and the potential for delays in the procurement and delivery of such items. We were fortunate
that we had an adequate fall back provision.

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7.2.7.1 Emergency Response organisation and arrangements
The organisational arrangements in place at Pearl GTL are framed in statements that are shared with
RLIC Emergency services. It should be noted that the emergency response context for Pearl GTL covers
onshore and offshore facilities.
Often language used to describe such arrangements is phrased subjectively. Words such as
“prompt” or “appropriate” abound in procedures. Pearl GTL have attempted to qualify statements of
commitment so that prompt is given in time, appropriate is given in resource terms of numbers, skill,
equipment, etc. This is useful and can be measured.
It is a given that the response to any emergency within the sphere of Pearl GTL operations is
directed towards:
■■ Saving life and care for the injured,
■■ Protection of the Environment,
■■ Protection of our assets,
■■ Protection of the company reputation.
The Emergency Response Plan written describes the organisation and arrangements devoted to
emergency preparedness and response measures. This document is reviewed and updated on an
annual basis.
The procedure for activating a response to any emergency starts with a phone call or an alarm and is
kept as simple as possible:
EMERGENCY CALL RECEIVED BY SECURITY CONTROL ROOM (SCR)
4419/‘Sierra Zero’ on the radio (WPS3 Ch 12 or 15)
Figure 34: Emergency Response Process
A number of documents were produced to enable an adequate and appropriate level of Emergency
Preparedness and Response capability. They include:
■■ Response to different types of alarms,
■■ Building and site evacuations,
■■ Responding to major off-plant releases,
■■ Fire Prevention and fire extinguishing.
These and additional procedures can be found in Attachment 5.6 – Critical Processes.
Ongoing training is being carried out as per the developed pre-incident plans. This is the primary
vehicle being used to raise the capability of the Shift Manager and area Shift Supervisors in their
roles and duties when incidents and emergency situations arise. The professional lead fire officers
on shift organise and deliver a planned number of exercises per year involving all operational shift
personnel. This is an on-going commitment to maintain readiness.
As has been shared, a number of the original assumptions that led to the initial design of the Pearl
GTL Emergency Response capability have been changed or modified. The flexibility to adapt
to prevailing circumstances was essential. I am sure that the Emergency Response organisation
will continue to adapt to ensure that Pearl GTL has the level of emergency preparedness that
satisfies commitments.
Figure 33: Quick Attack Truck on Training Exercise

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Figure 36: First Intervention Team on Training Exercise
7.2.8 Contractor HSSE Management
7.2.8.1 Introduction
At Pearl GTL we like to call, we do call our Contractor personnel, our Partners. This is not meant to be
a play on words. All through the Project phases it has been the objective backed up by commitments
made by Shell and partner Companies leadership that all who work at Pearl GTL will be treated with
respect and afforded the same care and welfare whilst carrying out work.
Whilst it makes sense to have in place a committed and goal aligned organisation, increasingly
certain work activity, particularly in maintenance and maintenance services are now routinely
contracted to other companies to carry out on behalf of Shell. To select a Company to carry out work
on behalf of Shell is critically important and as such defined process steps must be followed.
7.2.7.2 FIT response to incidents and emergencies
For all incidents and emergencies the First Intervention Team (FIT) will be directed by the on duty FIT
Commander. If assessment by the On-Scene Commander determines escalation (tier 1 escalating to
tier 2), RLIC Emergency Services are requested to respond. This is described in detail in the Pearl GTL
Emergency Response Plan given in Attachment 5.6 – Critical Processes.
If the incident is escalated to obtain support from the RLIC Emergency Services, the Bronze
Commander remains in command of Pearl GTL Operational emergency response and establishes
a Unified Command with the senior RLIC Fire Officer on scene. RLIC will remain in direct control
of the RLIC Fire Crew and directs actions based on Unified Command decisions with the Bronze
Commander. This chain of command is the default agreed protocol.
Figure 35 below represents the chain of command during the response to an emergency. Not
shown is the Site Shift Manager who will play a key role to ensure appropriate communication is
given to Site personnel. In addition the Shift Manager will work to mitigate the impact of the incident
emergency on unaffected areas of the Site operation to maintain continuity.
Security
Supervisor
SERT FIT MERT OPERATORS
FIT MERT SERT
Bronze
Commander
Shift
Supervisor
RLIC
Commander
Figure 35: Chain of Operational Command during Emergency Response

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Contract
HSE Risk
Hazard
Environment
Assessment
High
HSSE
RISK
High
Capability
Questionnaire
Past HSSE
Performance
On Site Audit
(if required)
Deviation
Tender Board
Mode 1
Mode 2
Not to be
Invited to Tender
Bid if Amber
Green Band
Contractors
are Available
Mode 3
Mode 1
Contractor
Capability
Assessment
to manage
HSSE
Risks
Historical
Performance
shall be
Evaluated
to Determine
Acceptability
No
Assessment
Required
Contract
Clauses
Contractor HSSE Management
Planning: Assess HSSE Risk and Contractor Capability
Mode 2
Mode 3
Mode 1
Mode 2
Mode 3
■ Activity
■ HSSE Risks
■ Contract Mode
Medium
HSSE
RISK
Low
HSSE
RISK
Shell
Yellow
Guide
Other
HSSE Risk
Assessment
Figure 37: Contractor HSSE Management Assessment
The Contractor HSSE Management process at Pearl GTL was applied in three phases:
■■ Planning – assess HSSE risks and the capability of contractors to manage those risks. The stoplight
method was used, in which contractors were categorised into three bands – green, amber and red
– according to their management capabilities.
■■ Execution – required engagement protocols with contractors according to their HSSE
management capabilities.
■■ Analyse and improve – we captured and shared learning both at the contract and Contracting
Procurement (CP) category level.
From a HSSE perspective there is a role to play in the selection, on-boarding and thereafter,
relationship at work with Contractor Companies carrying out work on behalf of Shell.
To enable an effective and efficient process a number of documents were developed for Pearl GTL to
ensure that agreed steps were followed. These included:
■■ QSGTL Contracting Policy and Procedures Manual,
■■ Health, Safety and Environmental section (V1) of General Contract conditions,
■■ Contractor HSSE Management Plan for Pearl GTL (Road Map),
■■ Template for monitoring Contractor performance at work,
■■ Spreadsheet capture of key HSSE Contract data.
The documents developed were as a result of the standard requirements given in the HSSE
Control Framework.
In the following text a summary of the main steps followed will be given. The detail behind each of
the steps is given in the documents referred to.
7.2.8.2 Process steps followed to select a Contractor Company to carry out work
Figure 37 outlines the process to follow to determine Contractor capability to carry out work and the
assessed level of risk associated with that work.

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Records
Record/Document
Planning
Contract scope risk assessment records
Contractor HSSE performance feedback
HSSE capability Questionnaire and associated documents
Categorisation (stoplight) record
Execution
Contract HSSE Plan
Reports on contractor HSSE performance
Minutes of meeting with contractor
Analyse/Improve
HSSE performance records
Referenced Documentation
Document Title
1. DSM 2500004-PR-01
2. International Association of Oil and Gas Producers – Report no. 423 June 2010
7.2.8.3 Pearl GTL Implementation:
As described, the Contractor HSSE Management process was implemented in three phases.
7.2.8.3.1 Planning Phase
The Planning phase focused on the identification, assessment, evaluation and selection of a
Contractor Company according to their management capabilities. This phase covers the pre-award
and selection of the Contractor Company.
Key document – Readiness to Start Procedure, see attachment?
7.2.8.3.2 Execution Phase
The Execution Phase focused on the Contract HSSE Plan:
Planning
Task steps
Assess and analyse HSSE risks
Categorise mode of Contract
Confirm Contract Holder’s Competence
Select Contract HSSE Clauses
Identify eligible contractors
Evaluate HSSE Capability Questionnaire
Evaluate Contractor HSSE Performance in previous work
Evaluate need for a HSSE MS Audit
Band Contractors
Define Evaluation Criteria, Issue Tender/Bid
Evaluate Bids/Select Contractor for Award
Execution
Task Steps
Define and Approve Contract HSSE Plan
Execute Pre-Mobilisation and Mobilisation Activities
Monitor implementation of the Contract HSSE Plan
Analyse/Improve
Task Steps
Sharing Learning and Good Practice
Steer HSSE Improvements
Closeout of Contract HSSE Performance Report

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HSSE Training and Competence
■■ Demonstrated evidence of pre-site training (e.g., basic health and safety training, induction,
discipline skills attainment etc.), for all Contractor employees on Site,
■■ A programme of HSSE training for each calendar year for all Contractor employees on Site was made,
■■ Supervisor training for HSSE Leadership was identified (to be delivered),
■■ A programme for Tool Box Talks (TBT). Each Supervisor must be involved in one TBT per week,
(Note: these were in addition to the pre-job discussion that the Supervisor undertook prior to any
work activity starting),
■■ A programme was put in place for the assessment and development of discipline skill training for
each type of employee,
■■ A system was put in place for the retention and updating of training and competence records,
Safe Visits (SPSP)
■■ One Safe Visit per week to be carried out by Contractor in support of the Site Hazard
Management programme.
Hazard spotting and reporting
■■ A programme was put in place to encourage employees to report on hazards (unsafe acts, unsafe
conditions, near misses). Many of our Contractor partners incentivised their workers to contribute.
Accident reporting
■■ All injuries must be treated and reported to the Site Medical Facilities.
Housekeeping
■■ A system was put in place that included Supervisor and Worker responsibilities for maintaining a
standard of housekeeping before work started.
HSSE Publicity
■■ A plan was put in place for providing and maintaining publicity (posters, Goal Zero messaging,
TBT, etc),
■■ Displays were maintained of HSSE performance information at prominent locations within the
Contractor Offices/Accommodation.
For Mode 1 contracts the plan was owned by the contractor and developed with input and review
from the Contract Holder (CH) and approved by the Contract Owner (CO).
For Mode 2 contracts the plan is owned by the contractor with input from the CH, HSSE staff and
approved by the CO.
The HSSE Plan documented the level of HSSE risk in the contract scope (that included work in sub
contractor yards and workshops if they were mode1, 2 activities) and documented the interface
arrangements for HSSE management between parties (e.g., contractor, sub contractor and company)
that ensured responsibilities for maintaining control were understood.
Contract HSSE Plan specified:
■■ Depending on the Mode (1, 2) and the level of Risk (Low, Medium, High) the Contractor HSSE Plan
contained the appropriate information to manage the hazards associated with the work.
Monitoring the implementation of the Contract HSSE Plan:
■■ CH and Contractor Representative were visible in promoting Qatar Shell Pearl GTL’s commitment to
HSSE (HSSE Commitment Statement, attendance at TBT and joint meetings, recognition awards etc).
■■ CH and Contractor Representative monitored the day to day implementation of the Contract
HSSE Plan. This included as a minimum the timely close out of actions assigned, current HSSE
performance, and any changes in the HSSE risk profile of current and future activities within
the contract scope. For mode 1 and 2 contracts the CH and Contractor Representative were
responsible for checking the work of the Contractor against the requirements of the Contract
HSSE Plan.
The content and implementation of the Contract HSSE Plan was carried out in the following steps:
Contractor HSSE Organisation was defined.
■■ The reporting relationships and HSSE responsibilities of individuals within the contractors
organisation on Site, were detailed and documented,
■■ The competence and qualifications of HSSE professionals within the contractor company were
detailed and documented,
■■ The format and frequency of Site Contractor HSSE meetings giving details of workforce involvement
were stated,
■■ Identification of individuals responsible for activity work planning (e.g., work method statements),
and implementation monitoring on Site, were stated,
■■ Arrangements for obtaining HSSE advice (implementing new/updated HSSE requirements) and for
communicating through the organisation while on Site were stated.

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Stoplight banding is only used for:
■■ On-boarding of a new contractor,
■■ Contract extension of an existing contractor,
■■ Contractor not used on Site during the past 3 years.
Steer HSSE Performance improvements
The CH steers HSSE performance improvement during the contract. HSSE staff annually update and
review with the CH/CO and Category Manager/CP the stoplight bands of the current portfolio of
contractors in order to recognise and improve performance.
The CH steers performance by monitoring the activity and achievement of the contractor on a day to
day basis by being aware of work activity, progress and any issues. Part of the steer also comes via
the longer review of the contractor in the annual portfolio review with HSSE, CO and CP. Agreement
on the need for actions to improve performance by an individual contractor or the whole portfolio is
then taken.
Close-out of Contract/HSSE Performance Report
For medium and high HSSE risk contracts a documented report authored jointly by the CH and
Contractor is produced and includes HSSE performance attained during the life cycle of the contract.
This includes lessons learnt. The report is signed off by the CH, CO and Contractor Representative,
noting those aspects not agreed.
Governance
Mode 1 Contractors: All mode 1 contractors are asked to conform to and comply with the Qatar
Shell Pearl GTL HSSE MS. Alignment with the Qatar Shell Pearl GTL HSSE Objectives, Strategies,
Key Performance Indicators (KPI) and Targets is pursued. Progress against the Contractor HSSE Plan
is reviewed and signed off by the CH, CO and Contractor Representative on an annual basis. Those
aspects that have not been achieved, achieved fully are noted in the review and sign-off.
Mode 2 Contractors: All mode 2 contractors have that their own HSSE MS interfaces with the Qatar
Shell Pearl GTL HSSE MS and this interface is specific in reporting agreed HSSE performance data
(as a minimum all relevant elements of the KPI) in addition to progress against the Contractor HSSE
Plan. Progress against the Contractor HSSE Plan is reviewed and signed off by the CH, CO and
Contractor Representative on an annual basis. Those aspects that have not been achieved, achieved
fully are noted in the review and sign-off.
Sub-Contractors
■■ The Contractors had to ensure that all subcontractors work to the Site did so to the HSSE standards
prevailing at Pearl GTL,
■■ They also had to demonstrate methods for controlling and monitoring subcontractors HSSE
performance. They did this by supervising and approving method statements and by workplace visits.
Compliance with the Contractor HSSE Plan
Pearl GTL (CO, CH, HSSE staff) monitor individual contractors on their HSSE performance and their
record in implementing the HSSE Plan.
7.2.8.3.3 Analyse and Improve phase:
Pearl GTL are in the Analyse and Improve phase now with most of the main Contractor partner
companies that have been working at Pearl since commissioning and start-up. As has been stated
many times before in this book, the journey that Pearl GTL is now on is a Goal Zero journey. Shell
Pearl GTL, and the Contractor partners are on this journey together.
Work continues that started in Construction to develop a “one site one team” culture. It started with IIF
but is now being continued through “Goal Zero”.
In addition there are contractual steps that are followed. These include:
Carry out review and report to the Contract Board
■■ HSSE staff in collaboration with Contracts and Procurement (CP) staff and Contract Holder (CH),
review annually with the relevant Contract Board the stoplight bands of Contractors involved in
Medium and High HSSE Risk contracts. These reviews are used to discuss issues and strategies
and obtain guidance from Senior Management, and to obtain benchmarks from CP files.
■■ The objective of this meeting is to review long term trends in stop light banding, recognise problem
areas with certain contract skills and to agree to actions to address such problem areas.
Note: The intention is not to review the stoplight banding of an individual contractor company. Once
a company is stoplight banded (at the beginning of the contract) the company keeps that band until
contract end. The intention is to review the contract banding of the whole portfolio of contractors. The
expectation is that over time there should be a decreasing number of contract companies which are
banded amber or red. This progress over years will be reviewed annually.

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De-mobilisation
Execution
Mobilisation
Evaluation and
Contract Award
Tender Period
Close-out
Planning and
Invitation to
Tender
Prepare preliminary
Contract Management
Plan
Establish: Contract
Strategy, Contract
Scope Schedule
HSE Assessment
HSE Speciﬁcation
Pre-qualify Contractors
(if Required)
Finalise Tender
Document
Contractor
prepares Preliminary
Contract HSSE Plan
Review Tender
Hold Local Kick-off
Meeting
Contract Award
Finalise
Contract HSSE Plan
Monitor Contract HSSE
Plan Implementation
and Performance
Maintain Same Level
of Vigilance as
during Execution
Contract Performance
Report
Feedback to Work Category
Custodian for Update of Register
and Future Pre-qualiﬁcation
Figure 38: HSSE Managements of Contracts Flowchart
7.2.8.4 Contractor (Partner) HSSE Forum
As a minimum, all mode 1 and mode 2 contractor companies are represented at the Contractor
(Partner) HSSE Forum. The client representation includes all mode 1 and mode 2 CH and HSSE staff.
Contract Owner’s are encouraged to attend.
The Forum is chaired by a Contractor Representative. A rotating “Chair” is encouraged on an annual
basis to allow all contractor companies to demonstrate HSSE Leadership.
7.2.8.5 Contractor CEO Forum
On an annual basis all CEO’s from mode 1 and mode 2 contractor companies meet at Site to review
HSSE performance (to include Worker Welfare) and progress made against the “Pride in Production
Commitment Charter”. All Companies working on behalf of QSGTL are committed to a Goal Zero
journey in HSSE performance.
HSSE Objectives, Strategies, KPI, Targets and Contractor HSSE Plan
All mode 1 and mode 2 contractors report against the Site HSSE Objectives, Strategies, KPI and Targets.
The Contractor HSSE Plan as detailed in section 8.2.3 (see Attachment 5.6 – Critical Processes) is
aligned to the achievement of the Site HSSE Objectives, the implementation of the agreed Strategies,
and the reporting against the KPI and targets.
Guidance has been given to all Contractors working at Pearl GTL on the structure to follow to develop
their HSSE Plan. The guidance follows the chronological sequence of events in contract management
as defined in the procedure ‘HSSE Management of Contracts’. In particular it refers to the following
aspects of the Contract Management Plan:
■■ HSSE Kick Off Meeting (HSSE Workshop);
■■ Endorsement of Contract HSSE Plan;
■■ Pre-Execution Audit/RTS Compliance Audit;
■■ Monitoring Implementation of QSGTL HSSE Management System and Requirements, including (The
HSSE Monitoring Programme);
■■ Contract Performance/Progress Report.

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Whilst it cannot be done for all workers nor done for all trades, I would argue that a sample testing
of workers from prospective Contractor Companies is undertaken prior to Contract award. As an
example this could be for hazardous activities such as High Pressure water jetting, scaffolding, crane
lifting and rigging, pipe work, electrical etc.
Another example is the quality and role of Contractor Supervision. I firmly believe that the role of
Supervision is critical. This is often spoken about but most of the time nothing positive or practical is
done to support and guide Contractor Supervision in what is required of them. Contractor Supervision
are at the sharp end of trying to satisfy the client. Performance is often recognised in terms of
flexibility; speed of delivery and in certain examples putting up with work conditions that are not as
free of hazard as they should be.
At Pearl they are embarking on a Front Line Leader development program. This is for Shell staff
principally, but is being extended to include Contractor Supervision. This makes sense.
And finally; the process steps are well defined to Manage Contractor HSSE performance. To do this
effectively and efficiently requires a lot of hard work and a healthy awareness to verify and assure
that what services have been asked for are being delivered to the standard that is expected.
Below is a personal note sent by David Martin and Paul Massih in 2011 that frames the critical
importance of the role of Contractors and the imperative to manage and improve Contractor
HSSE performance?
7.3 OTHER CRITICAL PROCESSES
The “other” five critical processes include:
■■ Safe Place Safe Person – observation and intervention program,
■■ Site and Local Area Induction program,
■■ Site and Local Area rules,
■■ Safety Districts and SDOs,
■■ Training and Competence (this is limited to the requirements to implement the ten critical processes
as mentioned above). This is applicable to all of the other nine processes.
7.3.1 Safe Place Safe Person
This program is specifically designed to focus attention on the duty of care that a Safety District owner
has key responsibility to assure. That is to provide a safe place of work and to ensure that people
working within the boundaries of the Safety District are trained and competent in the tasks and
activities that they are asked to perform and aware of the hazards prevailing in the Safety District.
7.2.8.6 Summary
Contractor HSSE Management is a critical HSSE process that takes time and a lot of on-going effort
to establish. Furthermore, work that aligns and shares common purpose to create a shared culture
(Goal Zero) does not stop. Increasingly we are asking Contractor partners to undertake work that is at
the sharp end, where hazards and risk from our processes and equipment are present. A duty of care
and a shared responsibility for safe working must be in place. earl GTL is striving to achieve this.
If I can end this section with a few thoughts and personal observations about the experiences I and my
team had carrying out the steps to establish a level of Contractor HSSE Management that was adequate.
It all starts with discipline competence. The skills required to carry out work that we want to take place.
This requirement is initially focused at the individual level and then the team. Focus then moves to the
Supervisor of the team, what his/her attitude and behaviours are, and then finally to Management
and their role in enabling and supporting their workers and work to be executed. We are asking the
Contractors to bring a discipline expertise to work that meets our expectations. As a client it is our
responsibility to know and recognise what discipline competence and expertise looks like.
If I take the example of a pipe fitter; the ability to read drawings, make and break a flange, torque,
etc are basic trade discipline skills you would expect of all personnel of that trade. After start-up we
had a number of leaks from pipe-work and equipment that required maintenance. Concerns increase
when leaks from the same equipment continues post maintenance intervention. Repeat failures
require analysis. If analysis indicates ineffective maintenance an understanding of what that means is
essential. One of the measures that we implemented post start-up has been the setting up of a pipe
fitting rig in the Site Central Workshops area. A number of tasks are performed on this rig by pipe
fitters from our Contractor partners so that a determination and assessment of skill can be ascertained.
Not all personnel have met the required standard to pass this assessment. On-going work to improve
on this situation is happening.
The example I give begs a number of questions. A reputable company earns its status by the
quality of the work and service it provides. If, as we did at Pearl GTL, offer contracts to reputable
companies, what are the guarantees that work will be executed in a way and each time to our
satisfaction? It rests with the individual/team. It is therefore a requirement of the Contractor to ensure
that all of the people under their employ are skilled in the tasks that they are asked to perform. In
a Project environment where a large number of people are required, reputable companies have to
considerably add to their core workforce. This is not without risk. My contention is; for a worker to be
recognisable as a worker of a particular company they need to have a reasonable length of service
with that Company.

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7.3.2 Site and Local Area Induction program
7.3.2.1 Site Induction
Before any person can carry out unsupervised work at Pearl GTL they must undertake the Site
Induction. For consistency this is delivered by CD, but there is always an Induction host who is present
throughout the Induction engagement.
Whilst the messages as part of the induction, to inform about Site Rules, Local Area Asset Rules
(Safety Districts), the main hazards at Site, what to do in an emergency, the behaviours expected
from all who work at Pearl GTL, and more, engagement with the audience to establish understanding
and clarification is key. There is always a “test for understanding” of the main messages from the
Site Induction CD. This is a written/multi choice answer examination. Normal workers will take
approximately 15 minutes to complete. There is a pass/fail criteria.
All workers at Site will undertake refresher training of the Site Induction on a three yearly interval. The
detailed site and local are induction presentations are included in Attachment 5.6 – Critical Processes.
A special presentation on Pearl GTL H2
S induction is available in Attachment 7 – Resources.
7.3.2.2 Local Area Asset Induction
In addition to the Site Rules, which are applicable to all areas, there are also complimentary Local
Area Asset (Safety District) rules that are written specifically to address the hazards and work
environment conditions that are unique to that Asset/Safety District. In addition and of significant
importance, Local Area Inductions are accompanied with a Site visit. This is an opportunity to show
workers new to the area, what has been spoken about, to see exactly where muster points are,
where windsocks are situated, etc. Visualisation is seen as a necessary reinforcement of the verbal
messages given during induction.
7.3.2.3 Site and Local Area Rules
Pearl GTL has a rule set that is mandatory to observe and follow. Compliance is taken seriously and if
violations to rules are observed a zero tolerance to accept non compliance is applied. All violations
are investigated to determine the reasons why. A Just Culture approach is adopted to ensure fairness
and consistency of approach to all workers.
There are three key sets of rules applied:
■■ Shell’s Golden Rules,
■■ Shell’s Life Saving Rules, and
■■ Pearl GTL Site and Local Area Rules.
In essence Safe Place and Safe Person has been designed to observe the behaviours of people
carrying out work in a Safety District, and the attitude and behavior of personnel providing a safe
place of work for people working in a Safety District.
The most basic responsibility for providing a safe place to work is to ensure that minimum standards
of housekeeping are in place. Depending on the scope of your housekeeping program, assets can
positively influence safe working by providing housekeeping standards to be proud of. At Pearl GTL
we took account of accepted theory on Behavioural Safety – Human Factors, that is that 80% of work
related accidents are down to employee behavior or human factors, in the form of acts and omissions.
Furthermore, if we recognise that there are many reasons why employees engage in ‘at-risk’ behavior at
work, for example, cutting corners to save time, ergonomic factors, reinforcement of at risk behavior by
the action of supervisors, misunderstanding at-risk behavior and instinctive risk-taking behavior. It follows
that if housekeeping conditions at a place of work are poor there is an increased likelihood that there
will be behavioural slips or lapses by workers. This will inevitably result in accidents.
The housekeeping program implemented at Pearl GTL is not unique. Pearl GTL provide a safe place
of work through discipline, the efforts to provide, the urgency to correct and the firm belief of a duty of
care. However, the maintenance of acceptable standards does not come without regular inspection. At
Pearl, all Safety Districts are visited by an independent team on a monthly basis. All areas of the Safety
District are assessed and scored. This involves both quantitative and qualitative measures. The results
are tabulated. There are four categories of attainment that have been linked to the Qatar Airways
loyalty program, Gold, Silver, Burgundy, and a category that is “on notice” to immediate improvement.
SDOs want to know why any area within their Safety District is below the Gold standard. So they
should. The results of these housekeeping inspections are communicated asset wide each month and
will be discussed at the monthly Asset HSSE Steering Committee as necessary.
Details of the Pearl GTL Housekeeping program are given in Attachment 5.6 – Critical Processes.
The second part of the program is “Safe Person” and this is focused on the behaviours of people at
work. This is done by observation. At Pearl we call this “Safe Visit”. The observations carried out are
against measurable categories of work and the behaviours of workers carrying out the work. This
approach is a task oriented view of behavior, and it treats safe behavior as a critical work related skill.
Details of the Pearl GTL Safe Visit program are given as Attachment 5.6 – Critical Processes.

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The Site rules are framed to target the following:
Asset Rule Types
1 Rules for Every Person Entering Site 6 Entry into High Risk Areas
2 Moving Around Site 7 Operations Rules
3 Precautions for Entering Plant/Unit Areas 8 PTW Rules
4 Use of Equipment and Materials 9 Management of Change Rules
5 Driving On Site
Table 7.4: Asset Rule Types
This rule set can be found in Attachment 5.6 – Critical Processes).
7.3.3 Safety Districts and SDOs
Much has already been said about Safety Districts and the role and responsibilities of a Safety
District Owner.
The key documents and presentations can be found in Attachment 6.2 – Safety Districts.
7.3.4 Training and Competence
Training and Competence as a critical process was for the initial purposes of implementation restricted
to the training and competence defined to implement the other nine processes already given:
■■ PTW.
■■ MOC.
■■ Emergency Preparedness and Response.
■■ Incident Management.
■■ Contractor HSSE Management.
■■ Safe Place Safe Person.
■■ SDOs.
■■ Induction, and
■■ Site and Local Rules.
See Attachment 7 – Resources.

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8. FINALLY
hardware. This is the fertile ground that experts, expert teams from outside the immediate Project
can add value and support.
10. Do not be a “Safety Policeman” – Whilst at times you may want to tell people what to do, to
order people to work safely, this type of approach does not work. Such a mentality results in the
creation of safety programs that restate the same old regulations and policies that have been
written countless times before. Such safety programs become the domain of the Safety Policeman
that only they read and understand. This is not a practice that should be encouraged.
8.3 CULTURE
11. Culture transition – Strive to achieve a “one team, one project” culture. The mindset and behaviours
that came about from the Incident and Injury journey describes the Construction HSSE Culture at
Pearl GTL. Culture is a day to day focus. The end point of a Construction HSSE culture is when
the last construction activity is completed. The transition of the right behaviours, values and mindset
through phases of a Project journey is essential to keep people safe. Whilst rules change to reflect
the changing hazard profile, the enablers to culture are consistent and should be continued.
12. Safety is a value – Safety as a program to inflict on an organisation, on a project, does not
make sense. Safety as a principle, as a value, as a part of nature does make sense. Focus
should be given on how to inculcate into individuals the value of wanting to protect themselves.
If people can look after themselves, they may be willing to look out for others. When all people
on a project can accept personal responsibility for safety, working (and living) safely ultimately
becomes a project wide value and culture.
8.4 GOVERNANCE AND CONTROL: TRANSITION FROM CONSTRUCTION
TO COMMISSIONING
13. What is the point of transition? – The decision point when to declare an area a “Commissioning
Area” and as such subject to commissioning controls comes when the main prevailing hazards,
risk profile and major consequences are resultant from commissioning activities. A formal walk-
down of the area and an assessment of its commissioning readiness should be made; this
should include a punch list of outstanding work. The punch list forms the basis of assessment
and agreement for a zone or an area to transition from Construction to Commissioning control.
A pragmatic but controlled transition should be pursued.
14. What is the Commissioning organisation responsible for? – The Commissioning organisation
should take responsibility for zones and areas of plant and equipment and all work carried
out on plant and equipment in zones and areas under commissioning. This requires a certain
organisational skill set. Hazards that are invisible to the naked eye, under pressure, hot, move
silently from one point to another by the operation of a valve demand a level of oversight, control
and permission different from what is seen in general during Construction.
A distillation of 30 considerations from the content of this book that I would advocate as a point
of reference.
8.1 AT THE START OF A PROJECT
1. Pursue excellence – define key focus areas and commit to deliver. For the Pearl Project
Construction and Commissioning phases, this resulted in Five focus areas:
a. Leadership.
b. Worker Welfare.
c. Training.
d. Communication.
e. Life Critical Activities (LCA).
2. Culture – create a culture that maximises the value in contribution of the focus areas chosen to
achieve excellence.
3. Leadership – Establish visible, servant leadership at all levels within the organisation. This must
include Contractor partners.
4. Welfare – Showing respect and care matters. Provide an environment where people feel valued.
Manage this as a critical success factor.
5. Training – provide training that ensures standards of discipline competence. Provide development
training to explore potential. Recognise safe working as a skill in the same way that the quality of
an outcome and speed of delivery is measured.
6. Communication – The ability to communicate effectively is hard work, but it is essential that
you try and get it as right as you can. Recognise what it takes to effectively communicate and
becoming organisationally skilled in good communication. Use simple words to convey a
message and take time to actively listen and confirm understanding.
7. LCA – The identification of activities that can kill or seriously hurt people should be a priority
focus. Pearl GTL started with 11 activities and worked hard to deliver excellence in each activity.
8.2 WHAT SHOULD A CSU HSSE IMPLEMENTATION MANAGER/
SAFETY LEAD DO?
8. Ask for support – leverage expertise from within the Shell Group (and outside if needed) and
form a partnership/collaboration to resolve issues and meet goals.
9. Knowing what to do is essential, knowing how best to do work is real value – We can all,
relatively experienced and less experienced, benefit from a more rigorous and independent
assessment of what we plan to do. A good plan articulates how goals set can be achieved.
Focus should concentrate on examining the strategies to achieve a plan. Strategies articulate
how implementation is undertaken. Furthermore, advocating examination of proposed strategies
to include testing and inspection is as relevant for the work and function of people as it is for

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■■ Asset Rules, and
■■ Asset Induction
18. What does a typical HSSEMS comprise? – A set of Manuals, Cases, Rules, Procedures,
Guidance, and Plans enabled through Instructions and at the task level through Job Aids.
19. Who should get involved in the development of documents that comprise the HSSEMS? – In a
perfect world a collegiate approach of experts and practioners in the development of how such
processes and procedures are documented and implemented is the ideal course to follow. Or
is it? In a Project environment when time is a critical element to manage there is a real risk that
if too many views on matters are listened to, progress can be slow with little or no value seen
from engagement. Be careful not to get involved in a beauty contest of different views about
how a practice or process has been implemented previously. Endless discussions can ensue on
periphery items. There is a limit to how many different views can be accommodated before a
piece of work loses context and instead becomes disjointed, and you run out of time and become
late to implement. External to the Project validation by expertise within the Shell Group to what is
developed and then a focus on implementation should be the approach to follow. Thereafter and
based on practical experience of implementation, internal views can be listened to for improvement.
20. What is a HSSE Plan? – HSSE Plans are a statement of what the organisation wants to achieve in
a defined period of time. They are recognisable through the objectives set, the (Key) Performance
Indicators that monitor, measure and report on progress. Furthermore, the main strategies and
actions chosen to achieve objectives are defined, resourced and allocated responsibility.
21. How do you recognise a good HSSE Plan? – Good plans satisfy the What, When, Why,
Where, Who and How. Good Plans are simple. Plans are subject to review and when Plans are
assessed as not meeting expectations then they should be subject to adaptation. Plans should
take account of the ambitions of the organisation, but should be realistic and cognisant of the
capabilities available to deliver. A Plan should create tension to achieve but not be too unrealistic.
It takes skill to develop a good Plan. It is not an administrative exercise that collects a number of
actions to do. How good is your HSSE Plan?
22. Implementing a HSSE Plan is a key activity – A HSSE Manager should take responsibility and
propose how a HSSE Plan is to be implemented through the use of appropriate strategies.
Networking and utilising Group expertise and resources (documents, people and examples of
good practice) so that the HSSE Plan to be implemented benefits from expert views and in-sights
into what and, importantly how to implement is strongly recommended. Do not be afraid but
welcome the opportunity to submit to an assessment of capability to implement the HSSE Plan.
Assessment should focus on the Leadership to deliver and the organisational competence and
capability to implement.
15. Rules and compliance to rules become a point of work control in Commissioning to a degree
greater than is seen during Construction. To help manage an increasing rule based and
compliance driven culture, commissioning work is helped by implementing a simple control
philosophy that asks consideration of;
■■ Supervision,
■■ Standards,
■■ Surveillance,
■■ Separation,
■■ Synchronisation,
■■ Planning,
■■ Preparation, and
■■ PTW.
This is known as the 5S and 3P framework.
8.5 HSSE MANAGEMENT SYSTEMS
16. What are the first steps to take to develop a HSSEMS? – Developing a Management System
requires an understanding of context and considerations. Key are standards and the importance
of the HSSE Manual. The processes of hazard identification, risk management and the
assignation of people to carry out tasks and activities deemed critical to maintain barriers from
threats must take place. This work forms part of the HSSE Cases. A rule set that includes the Life
Saving Rules, Golden Rules, Asset Rules and Area Asset Rules provides clear boundaries that
must be observed and followed. A set of procedures that describes how to apply and implement
critical processes identified as part of HEMP will be required. Finally the role of the annual HSSE
Plan developed throughout the phases of the Project into the Plan and Journey Book of the Run
and Maintain organisation will drive the organisation and performance forward.
17. What are critical processes? – The processes identified as barriers to threats during HEMP
meet this definition. It is to these processes that high importance for implementation should be
given. These are the processes that require effort first to establish a minimum level of control.
They are:
■■ PTW,
■■ Contractor HSSE Management,
■■ Safe Place, Safe Person (Behavioural Safety),
■■ Safety District ownership,
■■ Training Competence (limited to Critical Process implementation),

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unsafe and how this work can be carried out safely is not a skill resident in all personnel carrying
out work activity observations. Whilst it is a necessary and important first step to recognise when
work is being carried out unsafely, being competent to explain why, and then offer alternatives
establishes respect and working relationships. This can be a big part of the daily work of trade
discipline skilled people temporally seconded to support HSSE standards during Project phases.
The majority of recruits into the HSSE team at Pearl were from an Operational background, either Senior
Operators or in some cases Operations Supervisors. In addition, a flavor of trade discipline personnel,
Scaffolding, Crane Lifting, Rigging and Piping were also added to the mix. This proved essential.
8.7 SAFETY DISTRICTS
27. What are Safety Districts? - Safety Districts are a geographical area of a Project. There can be
many Safety Districts, but there has to be an organisational logic to the number. Furthermore,
each district can be further divided into zones during Project transition. These zones would enable
the transition of a district from one phase (Construction) to the next phase (Pre-Commissioning/
Commissioning). As Safety Districts transitioned specific HSSE requirements for that phase would
be identified and implemented. Safety Districts are a critical organisational design that enabled
appropriate HSSE transition through the phases of the Project.
28. Who is responsible for the governance of a Safety District? – A SDO is responsible for work and
HSSE performance within the geographical boundaries of a Safety District. As for all roles, a
clear set of responsibilities and accountability must be established for a SDO.
29. Typical responsibilities of a SDO - Each SDO and the organisation controlling work in a Safety
District must, amongst many other things, ensure that HSSE information is current for the hazards
and risks associated with work being carried out at that time. Whilst this is a critical responsibility
normally, as a Safety District transitions through major phases of activity, Construction to
Commissioning and into CSU, the discipline to stay in control and maintain HSSE information
that is current to the prevailing work and conditions, and is readily available, is a major task. At
Pearl GTL the PMC played a pivotal role in coordinating and supporting this work. To fulfill this
organisational responsibility, at Pearl the PMC through the SDO implemented a simple set of rules
and guidance that detailed the Commissioning HSSE strategy for safe working from RFP through
RFC into Commissioning and Start-Up and Run and Maintain. The topics included below have
been defined to manage and mitigate foreseeable HSSE issues assessed as likely to happen
during pre-commissioning and commissioning of a major Oil and Gas facility that was Pearl GTL.
The list given is not exhaustive but indicative of what needs to be done:
■■ RFP Certificates.
■■ RFC Certificates.
■■ Commissioning Safety Area segregation/Access Control.
■■ Livening up Notices.
8.6 HSSE ORGANISATION ROLES AND RESPONSIBILITIES
23. What should a HSSE team do? - The requirements (What) that is needed to deliver a HSSE team
(People) to implement effective HSSE Management through the phases of the Project is stated as
part of the Shell Group HSSE Control Framework. They are given below:
■■ Establish and maintain an organisation that delivers HSSE requirements and effective
HSSE management.
■■ Define and assign HSSE roles, responsibilities and authorities to individuals,
24. Until a Manager understands the scope of what is required of their team, the context of the total
work and the timeframe to deliver, a fit for purpose analysis of resource (numbers of people and
competence set) cannot be effectively done. This is particularly sensitive in a Project environment.
Others may argue that archetype organisations for project phases such as CSU HSSE are known
and are a basis for following. That is an assumption to respect and take notice of, but contend
that analysis is always needed to define requirements that are specific for the challenges each
Project can bring. An analysis can be done relatively quickly by a CSU HSSE Manager and in
doing so instill ownership and responsibility for what is proposed.
25. Ensure that your team has the capabilities to face up to the challenges that each of the Project
phases presents - When preparing for pre- Commissioning, Commissioning and the SIMOPS
challenge, assessment on how best to support safe working through these phases is necessary.
Whilst it is a given that the HSSE organisation will work to ensure HSSE standards and
requirements are implemented, in the different phases of Project work the question of how best
this is done needs to be discussed and agreed. It is usual to have a core element of professional
HSSE expertise. As this core is added to during the phases, be it Construction or Commissioning,
the necessity and value to “temporarily” second trade discipline skilled personnel into the HSSE
team can prove invaluable, not only as experienced at Pearl, but also in China on the Nanhai
Petro-Chemical complex start-up. At Pearl a mix of trade discipline skilled people were recruited
with a very clear and simple purpose; to carry out roles that supported the implementation of
trade standards of work that resulted in safe work outcomes. The HSSE Inspection team therefore
needed to be competent in a variety of trade discipline skills. This is what was recruited.
26. What benefits result from having trade discipline skilled people seconded to a HSSE team during
a project? - The advantage of recruiting discipline skilled personnel into a HSSE team results in
interventions being made that with knowledge and in-sight correct practices that are unsafe and
show “How” safe work can be undertaken. Being able to explain why work is observed as

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To implement each critical process requires discipline and a standards approach that assures
compliance to the Shell Group Control Framework. Training to make target audiences aware and
knowledgeable about requirements is the next step. For those that will be active in implementing each
process, further training and practice is required to enable skill. It is normal that selection criteria are
used for those chosen to actively implement critical processes. After training but before authorisation
is given to carry out the role, a process of assurance that examines a person’s readiness to carry out
given responsibilities should be undertaken. This is often done by interview that would include as a
minimum, the Process Owner of the Critical Process.
Live Site Induction that included:
■■ PPE Requirements,
■■ Commissioning Area Safety Rules.
■■ Commissioning PTW.
■■ Site emergency procedure during commissioning.
■■ Go/No-go Events.
■■ Blind isolation requirements.
■■ Control of battery limits.
■■ Working with nitrogen.
■■ Understanding H2
S dangers.
■■ Energised systems.
■■ Control Room Rules.
■■ SIMOPS recognition.
■■ Area specific risks (e.g., ASU will have Cryogenic Hazards).
■■ Construction and Pre-commissioning PTW.
■■ CSU PTW.
■■ Punch List Clearance.
■■ Electrical Safety Rules during Commissioning.
■■ Site emergency response and evacuation plans during Commissioning.
8.8 HSSE CRITICAL PROCESSES
30. Pearl GTL HSSE Critical Processes:
■■ PTW,
■■ Contractor HSSE Management,
■■ Safe Place and Safe Person – observation and intervention program,
■■ Site and Local Area Induction program,
■■ Site and Local Area rules,
■■ Safety Districts and SDO,
■■ Training and Competence (this is limited to the requirements to implement the critical processes
as mentioned above).

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Neither the whole nor any part of this document may be disclosed to Non-Shell
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