ATC-2015 Presentation

SPE-PAPG ANNUAL TECHNICAL CONFERENCE 2015

HEALTH, SAFETY AND ENVIRONMENT – A COMPARISONWHAT SHOULD BE THE PRIORITY FOR UPSTREAM OIL INDUSTRY IN PAKISTAN?

Naeem A Subhani

(Presenting Author)

Head HSE & CR - KUFPEC Pakistan

Author:

Naeem Ahmad Subhani

Co-author:

Muhammad Mehmood Khan

2Naeem Ahmad SubhaniHealth, Safety and Environment – A ComparisonWhat Should Be The Priority For Upstream Oil Industry In Pakistan?

PRESENTATION SCHEME

• Objective

• Significance

• Introduction

• Regulations & Guidelines

• Enforcement

• Fines & Penalties

• Risk assessments

• Conclusions

• Recommendations


OBJECTIVE

To discuss significance of and comparison between occupationalhealth, safety with environment and priority for the E & Pindustry in Pakistan.


DEFINITIONS

• Health (Occupational): The ability of a worker to function at anoptimum level of well-being at a worksite as reflected in terms ofproductivity, work attendance, and disability compensation.

• Safety: The condition of being protected against physical, social,spiritual, financial, political, emotional, occupational, psychological,educational, or other types or consequences of failure, damage,error, accidents, harm, or freedom from the occurrence or risk ofinjury, danger, or loss.

• Environment: The nature, as a whole or geographical area inparticular, affected by human activities. Ecology, air, water,minerals, living organisms, and other external factors surroundingand affecting.


• Health and Safety - Personal issue of individuals or internal issuefor the companies but tangible due to its immediate adverseeffects.

• Environment - Widespread long term adverse impacts in form ofemissions, discharged effluents and impact on communities whichare not tangible in nature and difficult to quantify.

• Mandatory requirements in Health, Safety and Environment setpriority for the industry to address these issues.

• Expectations of regulators in environment compliance are farmore

• Need to treat both issues fairly and due attention paid to both.

SIGNIFICANCE


REGULATORY FRAMEWORK

• Health & Safety

• Mines Act 1923• Safety in Drilling & Production Regulations 1974• DGPC guidelines

• Environment

• Environmental Protection Act 1997• EIA/IEE Regulations 2000• NEQS 2000• Environmental Pollution Act 2014• Provincial Environment Protection Acts


ENFORCEMENT

• DGPC• CIM Directorate• EPA Federal• EPA Directorates Provincial• Department of Explosives (DOE)• Pakistan Nuclear Regulatory Authority (PNRA)


FINES & PENALTIES

• Penalties on Environmental Violations

• May extend to PKR One Million Max.• PKR 100,000 per day if violation continues

• Penalties on H & S Violations

• Nominal fines and penalties defined in Mines act• One year imprisonment and fines up to PKR 4000


• Full Governmental support

• Ministry of Environment (Climate Change)

• Updated laws and regulations matching international

• EPA offices fully resourced and funded

• Provincial EPAs enforcing regulations

• Media campaign on environmental issues

• NGOs focus

• International funding

• Experts available in Pakistan

• Educational institutions teaching Environment

FOCUS ON ENVIRONMENT


• Little Governmental support

• Ministry of Petroleum after M/O Labor & Manpower

• Outdated laws and regulations not matching internationallegislation

• CIM office under resourced and not funded

• No provincial setups so far in view of 18th amendment

• Media campaign of Health & Safety issues is less

• NGOs focus is minimum

• International funding is negligible

• Experts rarely available in Pakistan

• Educational institutions not teaching as subject

FOCUS ON HEALTH & SAFETY


• How many die due to unsafe conditions?

• How many die due to lack of training/awareness?

• How many get disabled during accidents?

• How many die due to poor safety standards?

• Health impacts due to poor working conditions?

• Compensation to affected persons in accidents

• Lack of awareness about workers rights

• Enforcement, legislation and rulings

OUTCOMES OF OHS NON COMPLIANCE


• Contractors activities take more lives due to following:• Competitive rates

• Temporary nature of jobs

• Unskilled labor and lack of supervision

• Standards not define in contracts

• Contractor Management• Majority of activities carried out by contractors

• Management of contractors need enforcement

• Contractor OHS workshops is good initiative by MNCs

WEAK AREAS IN OHS


• How many die due to poor environmental conditions?

• How many got awareness about environment?

• How many get disabled due to pollution?

• Awareness about environment due to media & NGOs

• Enforcement, legislation and rulings in environment

OUTCOMES OF ENVIRONMENTAL VIOLATIONS


• Detailed assessment to identify risks to environment is a legalrequirement i.e. IEE/EIA to initiate the project

• No OHS assessment required for the projects to commence likeSafety Case or HSEIA

• Monitoring and regular reporting required in environmentregulations e.g. project initiation and close out reports

• OHS data required to be shared on yearly basis that includesincidents & work hours record.

• Work commencement notice, notification of Mines Manager &Safety officer, and placement of doctor at field are required.

RISK ASSESSMENTS


• Sampling of effluents and air emissions is legal requirement tomeet NEQS to maintain the environmental quality (Proactive)

• OHS incidents reporting (Reactive) focuses on compensationto workers. Regulator hardly intervenes in investigations dueto limited technical knowledge.

• Proactive HSE performance indicators like training, audits,inspections, and observation program

PROACTIVE OR REACTIVE


• World bank, Asian Development Bank and DFIs ask forenvironmental assessments and compliance

• OHS is small part of environmental reports at the end whichsets the priorities for the Government

• Offices of donor agencies appoint environmental specialists tomonitor the projects.

• NGOs are mostly focus on environment

• Who cares about OHS ?

DONOR AGENCIES & NGOs


• Legislation in Environment is nine times more in volume thanin H & S in USA

• EPA budget is 15 times more than in H & S in USA

• Fines & penalties in environment are far higher

• Regulators are different for Environment and H & S

• Regulators in the UK have signed MOU to integrate efforts andutilize resources for common site visits

COMPARISON WITH ADVANCED WORLD


• Universities awarding degrees in Environment

• PhDs are available in field of Environment

• H & S has not been given due importance in Pakistan

• Qualified H & S professionals are rarely available in Pakistan

• Job opportunities are more in Environment

EDUCATIONAL FRAMEWORK


• NEBOSH & IOSH of UK have contributed in certifying many

• BCSP is striving to introduce CSP certification

• HSE Training Consultants have been developed in Pakistan

• HSE practitioners being reasonably rewarded

• Job openings in the middle east after certifications

TRAINING RESOURCES & JOBS IN HSE


• Motor way Police has set higher standards

• Training and awareness been given in road safety

• Enforcement and penalties have shown results

• Emergency Rescue services have been advancing

• NGOs have invested in rescue services

• Fire Service department improving in large cities

• National Fire Training Institute needs improvement

• Civil defense department also needs attention

ROAD SAFETY & EMERGENCY RESCUE SERVICES


• ILO in OHS Since 1974

• Role of MNCs From early 80s

• Role of SPE

• Role of PEPPCA

• Anticipated Role of ASSE

ROLE OF VARIOUS ORGANIZATIONS


• More importance has been given to Environment in Pakistanto satisfy stringent legal requirements

• Less attention paid to OHS although accidents of seriousnature are still happening

• OHS in Pakistan is not developed like in advance world andneed equal attention, if not more, to save lives, sufferings,property damages and loss of productivity

CONCLUSION


• OHS regulations need revision and department to bestrengthened with resources: Government to take lead

• Seasoned HSE professional should run the CIM office like EPAoffices are being run by professionals

• Integration of CIM and EPA offices, close coordination or EPAmay lead both

• Introduction of OHS courses and degree program in view ofupcoming projects

• Industry associations and NGOs in HSE field should contributefor enhancing HSE governance

• Opening of ASSE chapter is another initiative promoting HSE

RECOMMENDATIONS


THANKS

ATC-2015 Presentation

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