Saudi Aramco 7180 (5/89) G.I.

NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

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CONTENT:
1 2 3 4 5 6 7 8 PURPOSE SCOPE COMPLIANCE REVIEW OBJECTIVES RESPONSIBILITIES SCHEDULING COMPLIANCE REVIEWS COMPLIANCE REVIEW PROCEDURE COMPLIANCE REVIEW REPORT IMPLEMENTATION OF RECOMMENDATIONS

1.0

PURPOSE:
1.1 To provide guidelines relative to Saudi Aramco requirements to periodically conduct reviews for compliance with the Company loss prevention policy statement per G.I. 5.002, "Loss Prevention Policy Implementation", paragraph 4.13, and as detailed in the Corporate Loss Prevention Manual, section 170, "Compliance Reviews".

2.0

SCOPE:
2.1 2.2 Compliance review program methodology and procedures. Compliance review recommendations (implementation, status reporting and follow-up requirements). Procedures for non-compliance with recommendations. Responsibilities of business lines, the Loss Prevention Department, the proponent department, support departments and the compliance review chairman.

2.3 2.4

3.0

COMPLIANCE REVIEW OBJECTIVES:

3.1 3.2 3.3 3.4 To assess a department's loss prevention program, and to evaluate program implementation. To emphasize parts of the loss prevention program that are working well. To develop recommendations for loss prevention program improvements. To assess equipment and material deficiencies and recommend corrective actions.

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

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3.5

To assess department and employee commitment to and participation in both Company and departmental safety programs and recommend areas for improvement. To review the implementation of recommendations made during previous compliance reviews. To provide information to proponent management for improving the effectiveness of their loss prevention program.

3.6 3.7

4.0

RESPONSIBILITIES:
4.1 Business Lines 4.1.1 Business line heads are responsible for nominating departments for compliance reviews, as well as manager level employees (or above) to serve as chairmen for compliance reviews. Business line heads will ensure that nominated chairmen are available full time for the compliance reviews they chair.

4.2

Loss Prevention Department 4.2.1 The Loss Prevention Department shall be responsible for coordinating the compliance review program. This coordination includes: scheduling the review; selection of the review team chairman; identification of team members (from proponent, support and Loss Prevention departments and in selected cases outside specialists groups) required for each review; notifying the involved personnel; and preparation of review materials/ guidelines such as the format for the compliance review report and the interview questionnaires. The Loss Prevention Department shall be responsible for providing background information on the proposed compliance review to the appointed chairman and team members. The chairman and team members will also be briefed by Loss Prevention on all aspects of the review (e.g. report format, categorization of recommendations as "major", "moderate" or "minor" as outlined in paragraph 7.2).

4.2.2

4.3

Proponent Department 4.3.1 The proponent department will provide review team members (from within their department) with appropriate qualifications and experience as recommended by the Loss Prevention Department. One of these team members shall be appointed as secretary of the review team. It is recommended that the secretary be an experienced engineer who is familiar with the operations to be reviewed. The proponent department will provide access to the review team to inspect it's facilities, interview it's employees and review it's documents as requested by the compliance review chairman. The proponent department shall provide logistical support to the review team as appropriate. This may include items such as housing, food or meal allowances, office space, a full-time dedicated clerk, and security permits.
NEW INSTRUCTION X COMPLETE REVISION 7

4.3.2

4.3.3

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

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OF

4.3.4 4.4

The proponent department will implement (or resolve) and provide status reports on review recommendations as outlined in section 8 of this G.I.

Support Departments 4.4.1 Support departments, such as those in the Engineering Organization, will provide specialists to effectively support compliance reviews. Other organizations may also be asked to provide specialists for compliance reviews and they should make every effort to support these reviews.

4.5

Compliance Review Chairman 4.5.1 The chairman shall have complete procedural freedom (within the general guidelines provided by Loss Prevention during briefings before the review) to direct the course of the review. For example, he may assign specific tasks to the members of the review team or divide the review team into groups in order to efficiently utilize the expertise of the members available to him. The chairman, with assistance from the team secretary, shall finalize the findings of the review team by the end of the review period, in the report format provided by Loss Prevention during briefings prior to the review, and obtain concurring signatures from all review team members. Under exceptional circumstances he shall allow a review team member to record dissents and deviations from the majority view when signing the report. The chairman shall be responsible for providing the review report to the proponent department and other organizations as outlined in section 7 of this G.I.

4.5.2

4.5.3

5.0

SCHEDULING COMPLIANCE REVIEWS:

5.1 Each year, in the fourth quarter, the Loss Prevention Department shall request business line heads to nominate departments from their respective business lines for the forthcoming compliance review program. Business line heads will also be asked to provide nominees to serve as chairmen for the upcoming program. The Loss Prevention Department will review responses from business lines and compile the final list of departments to be reviewed in the following year. Since the number of reviews is limited, selection shall be based on such factors as criticality of operation, time since the last review, and safety performance. Based on nominations provided by business lines, the Loss Prevention Department will select chairmen and confirm these selections with the management of the nominated persons. Where possible, the chairman and the department to be reviewed should be from separate business lines.

5.2

5.3

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

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OF

5.4

Dates for compliance reviews will be finalized and published by the Loss Prevention Department as soon as practical after response from business lines has been received. Depending on the function of the department to be reviewed, the Loss Prevention Department will request other departments in the Company, or outside consultants, to provide support staff for each review as appropriate. These requests shall be made as soon as practical after the compliance review schedule is finalized. Operating and support departments with significant exposure should be reviewed at intervals of three to five years. A department may be reviewed at more frequent intervals, if warranted and agreed to by the Loss Prevention Department and the management of the department involved.

5.5

5.6

6.0

COMPLIANCE REVIEW PROCEDURE:

6.1 Following discussions on the proposed review with the management of the department or organization being reviewed, the review team will convene on site. The review team members shall assess that the department concerned has an up-to-date loss prevention program document consistent with the requirements of the Corporate Loss Prevention Manual. The compliance review team will evaluate the implementation of the department's program by assessing selected items such as the following (other items may also be appropriate): 6.1.1 6.1.2 6.1.3 6.1.4 6.1.5 6.1.6 6.1.7 6.1.8 6.1.9 Control of responsibility/accountability for meeting Saudi Aramco's loss prevention policy. Operator or craftsman knowledge and training. Implementation of safe work procedures (e.g. work permits, and operating instructions). Disaster/emergency plans and employee preparedness. The loss prevention program (including but not limited to safe operations committee(s), unit safety meetings). Work order systems, maintenance and engineering support. Implementation (or resolution) of previous compliance review recommendations. Communication of fire and safety concerns to all department personnel. Safety administration of contractors.

6.1.10 Major hardware or design deficiencies. 6.2 To assess the items listed in section 6.1, the review shall consist of a detailed look into all areas of loss prevention activity. Key people shall be interviewed, records and files reviewed, procedures investigated, and key meetings shall be attended, if practical. In conducting the

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NEW INSTRUCTION X

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

AIN

OF

review, checklists should be used as a reminder of things to look for, talk about, and/or review. Such checklists will be provided by the Loss Prevention Department representatives. 6.2.1 As a minimum, the following shall be interviewed: department manager, superintendents of operations, engineering and maintenance, and a random selection of supervisors and employees. Both new and old supervisors and employees shall be included. In most cases, 10-15% of the employee population should be interviewed. A safe operations committee meeting should be attended if possible. Particular attention shall be paid to the make-up of the committee, content of the meeting, freedom of exchange of comments, follow-up action on outstanding items and minutes of the meeting, including distribution and publicity of accomplishments. Attendance at a regular safety meeting is important to determine both the quality and effectiveness of the material used and the ability of supervisors to get their message across. If time permits, several meetings should be observed. Particular attention shall be paid to the amount of preparation, visual aids used, subject matter, and both the attentiveness and participation of employees. Files relating to safety, fire, and other loss prevention matters shall be reviewed and the following critical elements of the department loss control program shall be addressed: management directives and statement of policies; safety meeting schedules; safety suggestions, recommendations and pertinent follow-up activity; industrial hygiene surveys; health and medical surveys; safety awards; statistics; inspection reports; letters to supervisors and employees regarding rules, policies, and loss prevention matters; new employee orientation/training; previous compliance review reports and follow-up work; safety training; special medical tests; and investigations of accidents, fires and near misses. Accident logs and reports shall be checked to make certain that all reports are properly completed. Particular attention needs to be paid to evidence of investigation, selection of "cause and correction", and the length of time before reports are submitted and distributed. Spot-checking proposed corrections and discussion with injured employees will indicate management's effectiveness in preventing recurrences. A spot check of written procedures is necessary to determine that hazardous operations (e.g. tank entry, hot work, lockout/tag) are well defined; that safety equipment is properly serviced and maintained; that work permit procedures are complied with; and that personnel are properly trained and certified as required. An inspection of facilities as appropriate to the department being reviewed shall be conducted. Pertinent items to observe are: housekeeping; equipment guarding; dust, fume and noise levels and controls; personal protective equipment; fire protection equipment; flammable liquid storage; safety showers and eye wash stations; emergency equipment; safety valves; mobile equipment, including hoisting devices; safety signs; hazardous waste disposal; and field verification of implementation of a sample of previous compliance review recommendations. Whenever, during the course of an inspection, a serious hazard to life or property is identified, review team members should report these hazards to the responsible supervisor for immediate control.

6.2.2

6.2.3

6.2.4

6.2.5

6.2.6

6.2.7

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

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6.3

Security and environmental assessments are beyond the scope of these compliance reviews. However, since the liaison of plant operations with security personnel is important during emergencies, the review shall confirm how a plant's emergency response plan interfaces with plant security. Where possible, the review team shall hold a simulated fire or disaster drill to assess response capability and emergency control systems. This drill will need to be closely coordinated with operations and other relevant departments. The nature of the drill will depend on the department being reviewed.

6.4

7.0

COMPLIANCE REVIEW REPORT:

7.1 The review team will compile the report from joint and individual assessments. The report will consist of an evaluation of the reviewed department's loss prevention program and an assessment of its implementation. Individual items considered in the review with support findings will be included. The review report will be in the format provided by the Loss Prevention Department during pre-review briefings. The review recommendations shall be divided into "major", "moderate" and "minor" categories. Generally, "major" recommendations will be those safety hazards which cite non-compliance with Saudi Aramco G.I.s, standards, plant operating instruction manuals or the department loss prevention program. However, the team has the prerogative of making other recommendations if they feel it is warranted or if time prohibits a thorough comparison with "applicable" standards. All "major" and "moderate" recommendations shall be numbered and listed in the "Recommendations" section of the report. An appendix to the report will include "minor" recommendations and "punch list" items needing correction (i.e. housekeeping items, etc.). A draft list of "major" recommendations shall be provided to the proponent department's management for preliminary review. The report will be addressed to the proponent department's manager, and "major" recommendations will be discussed with the proponent department's management on the last day of the review. The superintendent of the area Loss Prevention division shall be invited to this review meeting. Copies of the report will be provided to satisfy the reviewed department manager's distribution requirements. Additionally, one copy of the report shall be provided to the Manager, Loss Prevention Department, one copy to the area Loss Prevention superintendent, and one copy to the administrative area head of the department being reviewed. The compliance review team members shall be provided copies of the report upon request.

7.2

7.3

7.4

7.5

7.6

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Saudi Aramco 7180 (5/89) G.I. NUMBER

SAUDI ARABIAN OIL COMPANY (Saudi Aramco) GENERAL INSTRUCTION MANUAL

ISSUING ORG. SUBJECT:

6.006
ISSUE DATE

Approved

REPLACES

LOSS PREVENTION DEPARTMENT LOSS PREVENTION COMPLIANCE REVIEWS

6/8/1993
APPROVAL

NEW
PAGE NUMBER

AIN

OF

8.0

IMPLEMENTATION OF RECOMMENDATIONS:
8.1 Upon receipt of the review report the proponent department manager shall develop an action plan for the implementation of recommendations. The implementation shall be completed expeditiously, and all "major" recommendations shall have estimated dates for completion. The proponent department will track the implementation (or resolution) of all recommendations. The proponent department will provide status reports of the "major" recommendations to the superintendent of the area Loss Prevention division every quarter until implemented or otherwise resolved. These status reports may be in the form of minutes from SOC meetings in which the recommendations are tracked, or they may be in a separate format. Field verification of a sample of implemented compliance review recommendations (as reported by proponent departments) will be formally done as part of the department's next compliance review. If the proponent department disagrees with or is unable to comply with a "major" recommendation, a non-compliance letter shall be obtained from the proponent department's administrative area head. This letter should state the justification for non-compliance. A copy of this letter shall be forwarded to the Manager, Loss Prevention Department. If noncompliance with Saudi Aramco engineering standards is involved it must be processed by utilizing the waiver form SA-6409 (as outlined in Saudi Aramco Engineering Procedure 302).

8.2 8.3

8.4

8.5

Recommended: Manager Loss Prevention Department Concurred: Executive Director Safety And Industrial Security Approved: President And Chief Executive Officer

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