IHSE Audit Report of Uch (November 2024) PDF

GF – HSE – 043(02) INTERNAL HSE AUDIT REPORT Uch Gas Field Ref. Annual IHSE Audit Schedule FY 2024-25 Audit Date: November 15-16, 2024 Audit Session: 64Man-hours Audit Conducted By: Ghulam Mohyu...

GF – HSE – 043(02) INTERNAL HSE AUDIT REPORT Uch Gas Field Ref. Annual IHSE Audit Schedule FY 2024-25 Audit Date: November 15-16, 2024 Audit Session: 64Man-hours Audit Conducted By: Ghulam Mohyuddin (HSE Lead Auditor/ SE Process – Uch) Aoun Rizvi (HSE Auditor/Sr. HSEQ Officer– Uch) Sajjad Haider (HSE Auditor/ S.E. Electrical-Uch) Umair Ashraf (HSE Auditor/ J.E. Mechanical- Uch) Report Prepared By: Aoun Rizvi (HSE Auditor/Sr. HSEQ Officer– Uch) Report Reviewed Muhammad Sameem Hussain Qaiser (HSE Lead Auditor/ Sr. HSEQ by: Officer) Report Checked by: Muhammad Mubashir Abbas (IMS & Energy Mgt. Auditor/ Manager HSEQ- ERM/ CRO) Forwarded For C&P Ghulam Mustafa / Nasir Khan (Field Manager – Uch) Actions: Copy to: Mumtaz Ali Soomro (AED Production) Babar Iftikhar (Manager In-Charge HSEQ) Date: December 06, 2024 Audit Outcome Nonconformit Observation OFI Total y Plan Do Check Act Total Score: Percentage Compliance: Grade: B (Good Compliance Level) Star Rating:  (51-75 Percent) Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 1 1. Objective This was the first Internal HSE Audit of Uch Gas Field, FY 2024-25 in compliance with the Annual Internal HSE Audit Schedule FY 2024-25. The audit was conducted per the already furnished Audit Plan to determine whether activities and related results comply with the planned arrangements as per OGDCL’s Integrated HSE Management System requirements and whether these arrangements are implemented effectively. The Internal HSE Audits are to be conducted at least once in 06 months for each field/plant on a mandatory basis to fulfill the requirements of OGDCL’s Integrated HSE System Manual Rev-8.0 (duly approved by MD/CEO). The Internal HSE Auditors were selected from different organizational functions based on their experience and professional skills. The Internal HSE Auditors were trained in auditing skills by conducting internal training sessions. HSEQ Department maintains the audit-training records of these qualified auditors. 2. Scope 3. Section Audited Functions Standards’ Requirements Plant & Process Mix Feed Separation, Leadership Domain Gas Processing, 1. HSE & ERM Policy Statements OGM/P-HSE-4.1 Compression, 2. Lifesaving Golden Rules OGM/P-HSE-4.2 3. OGDCL’s Process Safety Fundamentals OGM/P-HSE-4.3 Produced water 4. HSE Roles, Responsibilities, Accountabilities, and reinjection / Authorities OGM/P-HSE-4.4 evaporation, sewerage 5. Crisis Management OGM/P-HSE-4.5 & utility/drinking water 6. Structure OGM/P-HSE-4.6 treatment Planning Production Domain Condensate Oil 7. Enterprise Risk Management OGM/P-HSE-5.1 Storage & Dispatch/ 8. Job Vulnerability /Hazard Analysis OGM/P-HSE-5.2 Marketing, 9. Legal & Legal & Another Requirements OGM/P-HSE-5.3 Well Site operations 10. Objectives & Management Program OGM/P-HSE-5.4 Maintenance Mechanical, Support Domain 11. Competence & Awareness OGM/P-HSE-6.1 Electrical, Instrument, 12. Communication & Consultation OGM/P-HSE-6.2 Logistic & Transport Lifting Equipment i.e. 13. Documented Information OGM/P-HSE-6.3 Domain (mobile Crane, crane 14. Control of Records OGM/P-HSE-6.4 mounted truck) Operation management, 15. Operational Planning and Control OGM/P-HSE-7.1 materials shifting, 16. Permit to Work System OGM/P-HSE-7.2 Pick & drop 17. Handling, Segregation and Disposal of Waste OGM/P-HSE- 7.3 HSEQ Domain HSE, Firefighting, 18. Journey Management OGM/P-HSE-7.4 Occupational Health 19. Framework For Hydrogen Sulfide Management OGM/P-HSE- Quality Control QC Lab./ Metering 7.5 Domain 20. Management of Project Contractors & Service Companies Material Raw material, Spare- OGM/P-HSE-7.6 Management parts, chemicals, etc. 21. Use of Personal Protective Equipment OGM/P-HSE-7.7 Management, 22. Framework for Site Restoration OGM/P-HSE-7.8 Domain management of Performance Evaluation 23. Hazards & UBsUCs Identification & Reporting OGM/P-HSE- Waste (hazardous 8.1 and non- hazardous) 24. Monitoring, Measurement & Compliance Evaluation OGM/P- quantification & Safe HSE-8.2 Storage 25. Analysis of Data OGM/P-HSE-8.3 Medical Services Dispensary, 26. Reward, Recognition & Penalties OGM/P-HSE-8.4 Domain Emergency Handling, 27. Internal Audits OGM/P-HSE-8.5 Injury classification, 28. Management Reviews OGM/P-HSE-8.6 Medical Waste Improvement 29. Opportunities for Continual Improvement OGM/P-HSE-9.1 Management 30. Management of Change OGM/P-HSE-9.2 Contractors HSE Protocol for 31. Incident Investigation OGM/P-HSE-9.3 Domain Project (Contractor) Management Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 2 4. Audit Modalities Categories of Audit Findings  Non-conformity (Category 1): As defined in the standardized audit checklist it is either a) a SYSTEMATIC FAILURE, SIGNIFICANT DEFICIENCY in part of the HSE system, or the LACK OF IMPLEMENTATION of such a part, governed by applicable standards or b) an ISOLATED or SPORADIC LAPSE in the content or implementation of procedures or records which could reasonably “lead to” a systematic failure or significant deficiency if not corrected.  Observation (Category 2): As defined in the standardized audit checklist it is an AREA OF CONCERN, a process, document, or activity that is CURRENTLY CONFORMING or a WEAK PRACTICE which, if not improved, RESULTS IN A NONCONFORMING system, product or service.  Opportunity For Improvement – OFI (Category 3): OFI is a RECOMMEND BEST INDUSTRIAL PRACTICE which results in the improvement of HSE management system. Scoring Criterion for Audit Findings Compliance Level (Against Each Requirement) Score Documentation and implementation is totally absent 0 Documentation is partially available but not completely implemented 2.5 Documentation is completely available but partially implemented Or 5.0 Implementation is there but documents partially in place Documentation & implementation is in place to a larger extent 7.5 Documentation and implementation is fully in place 10 Audit Grade & Star Rating Audit Grade Star Rating Percentage Compliance A Excellent Compliance Level  More than 76 Percent B Good Compliance Level  51 – 75 Percent C Poor Compliance Level  Less than 50 Percent Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 3 5. Audit Score Sheet Plan HSE & ERM Policy Statements OGM/P-HSE-4.1 05 OGDCL’s Lifesaving Golden Rules OGM/P-HSE-4.2 10 Process Safety Fundamentals (PSFs) OGM/P-HSE-4.3 ??? Leadership Roles, Responsibilities, Accountabilities, and Authorities 12.5 OGM/P-HSE-4.4 Crisis Management OGM/P-HSE-4.5 27.5 Structure OGM/P-HSE-4.6 ??? Enterprise Risk Management OGM/P-HSE-5.1 12.5 Job Vulnerability /Hazard Analysis OGM/P-HSE-5.2 10 Planning Legal & Other Requirements OGM/P-HSE-5.3 7.5 Objectives & Management Program OGM/P-HSE-5.4 15 Competence & Awareness OGM/P-HSE-6.1 32.5 Communication & Consultation OGM/P-HSE-6.2 32.5 Support Documented Information OGM/P-HSE-6.3 7.5 Control of Records OGM/P-HSE-6.4 7.5 Sub Score (A) 180 Do Operational Planning and Control OGM/P-HSE-7.1 42.5 Permit to Work System OGM/P-HSE-7.2 27.5 Handling, Segregation and Disposal of Waste OGM/P-HSE- 7.3 17.5 Journey Management OGM/P-HSE-7.4 15 Operation Framework For Hydrogen Sulfide Management OGM/P-HSE-7.5 5 Management of Project Contractors & Service Companies 12.5 OGM/P-HSE-7.6 Use of Personal Protective Equipment OGM/P-HSE-7.7 32.5 Framework For Site Restoration OGM/P-HSE-7.8 7.5 Sub Score (B) 160 Check Hazards and UBsUCs Identification & Reporting OGM/P-HSE- 27.5 8.1 HSE Monitoring, Measurement & Compliance Evaluation 52.5 Performance OGM/P-HSE-8.2 Evaluation Analysis of Data OGM/P-HSE-8.3 12.5 Reward, Recognition & Penalties OGM/P-HSE-8.4 7.5 HSE Audit OGM/P-HSE-8.5 32.5 Management Reviews OGM/P-HSE-8.6 17.5 Sub Score (C) 150 Act Opportunities for Continual Improvement OGM/P-HSE-9.1 12.5 Improvemen Management of Change OGM/P-HSE-9.2 22.5 t Incident Investigation OGM/P-HSE-9.3 25 Sub Score (D) 60 560 Audit Score (Sub Score 550 A+B+C+D) /1020 Percentage Compliance 53.92% 6. Good Practices Observed  Well-maintained housekeeping within plant boundaries of Uch-I & Uch-II.  TBT Manual in URDU developed by HSE section and distributed to all sections.  First Aid Box usage data maintained by Process Uch-I section.  PPE matrix posted on board in plastic cover by Instrument section. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 4 7. Audit Findings 6.1 PLAN (CONTEXT, LEADERSHIP, PLANNING & SUPPORT) REF. RESPONSIBI # FINDING CLAUSE/ RECOMMENDATION LITY SEVERITY 1. Although HAZOP study of Uch-I & Lifesaving In next HAZOP Studies all I/C Process Uch-II Plants carried out: Golden Rules remaining areas of Plant Uch-I & Uch-II however limited scope covered OGM/P-HSE- operations Uch-I & Uch-II i.e., 4.2/ in Studies i.e., Amine and Gas Gathering/separators Dehydration areas only. Nonconformity Boilers, Hot Oil Heaters, Fire hydrant networks, CCRs be covered. Matter to be dealt on early basis. 2. Recommendation regarding F & Although feasibility study has G system integration with ESD been completed by M/S highlighted in HAZOP Study Uch-I Nextreme; however keeping in 2023: However, progress on this notice the criticality of F & G critical issue found slow. system effectiveness OGDCL’s regarding emergency Lifesaving handling, matter to be Golden Rules expedited. OGM/P-HSE- I/C Instrument 4.2/ Although a feasibility study Observation has been completed by M/S Nextreme, the criticality of the F&G system's effectiveness in emergency handling necessitates expediting the matter. 3. Although awareness sessions on Refresher session need to be Risk assessment procedure conducted for Sectional I/Cs. OGM/P– HSE -5.1have been Further Sectional I/Cs who conducted: however, some of have already gone through the sectional I/Cs found with lack this training to communicate HSE of awareness on execution of Roles/Responsi this to sectional employees HSE risk assessment activity and bilities/Account including officers and staff its importance during Job abilities & through regular TBTs. executions at site. Authorities All Sectional I/Cs OGM/P-HSE- Refresher sessions be 4.4/ conducted for Sectional I/Cs. Additionally, Sectional I/Cs Observation who have already undergone this training communicate this to sectional employees, including officers and staff, through regular TBTs." 4. The latest HSE and ERM policies HSE Roles, Ensure the latest HSE and ERM I/C Medical; were found not available in the Responsibilities policies are made readily I/C PF & Medical and PF sections. , available in all Sections. Corrosion Accountabilities Additionally, neither the & Authorities sectional In-charges OGM/P-HSE- Conduct targeted training demonstrated an understanding 4.4/ sessions for sectional In- of the Life-Saving Golden Rules charges and staff on the Life- and Process Safety Observation Saving Golden Rules and Fundamentals, nor had these Process Safety Fundamentals. been effectively communicated to their staff. Furthermore, in the Display Health, Safety, and PF section, HSE roles and Environment (HSE) roles and responsibilities were not responsibilities in the PF displayed, and no records or section and ensure that staff documentation of staff HSE roles HSE roles & responsibilities Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 5  & responsibilities or job and job descriptions are descriptions were available for documented and readily review. available for review. Moreover in the PF section, Health, Safety, and Environment (HSE) roles are not displayed, and no records or documentation of staff HSE roles or job descriptions were available for review 5. Head count system near Main store office at Uch-I Plant for head counting of employees during emergency situation has been made functional: However, its effectiveness need to be ensured by Field management as no action witnessed regarding below mentioned :  Data entry of Private Crisis Management Field HSE MRC Drivers. Prior attention required by  Vehicles entry through PTW OGM/P-HSE- Field Management for 4.5/ system. effective implementation of  Entry/Exit control for Nonconformit Head Count System. Guests/Visitors. y  Security section’s control regarding PPE compliance.  Entry/Exit data communication during emergency situation.  Provision of restriction at Exit side for control.  Data entry regarding Last LTI and Safe man-hours. 6. During visit of Fire Pumps station at Uch-I certain observations were made which are as under:  01 Jockey pump found out of Fire Hydrant network operation. Crisis automation related work to be  Identification Tags found Management addressed on priority basis. missing at electrically driven OGM/P-HSE- I/C Process; 4.5/ I/C Mech.; Fire pumps panels. Moreover, regarding matter of I/C PF & Corr.;  Matter of CP system re- Nonconformit CP system operation decision I/C Electrical examination for Fire hydrant y to be taken from Head office network Uch-I communicated for its custodianship. to Head office: however, follow up in this concern found low. 7. Regarding ERP Uch following Crisis Sectional I/Cs to start Field HSE MRC gaps were found identified: Management extensive and consistent TBT  Although Draft Prepared on OGM/P-HSE- program for its sectional 4.5/ roles/responsibilities of ER employees regarding Teams and shared with all Nonconformit Emergency handling protocols. concerned, Awareness y Refresher session to be sessions conducted: conducted for ERT members. However, during recently conducted Mock up drill dated 20/11/2024, effective role play towards emergency handling by some of the ERT members found unsatisfactory.  Emergency Mock up drill Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 6  report prepared and distributed to all concerned for corrective actions against gaps identified: however same found not discussed in Quarterly HSE MRC Meeting. 8. It was observed that in their In Ensure that dispensary staff absence or during unavailability Crisis receive appropriate first aid of FMO, the dispensary staff Management training and certification, and OGM/P-HSE- lacks adequate training or maintain supporting 4.5/ I/C Medical certification in first aid, as no documentation to verify their supporting documentation could Nonconformit competency in handling first be provided to verify their y aid cases in the absence of the competency. Facility Medical Officer 9. Hands-on fire extinguishing Provide hands-on fire training for medical staff and Crisis extinguishing training for ambulance drivers was not Management medical staff and ambulance OGM/P-HSE- conducted, and no evidence of drivers, and maintain I/C Medical; 4.5/ such training was available for documentation to I/C HSEQ review. Nonconformit demonstrate completion and y competency in fire safety procedures. 10. AED available in dispensary to Crisis Medical section to take prior handle critical patient situations Management step for purchase of new AED. I/C Medical found nonfunctional. OGM/P-HSE- 4.5/ Nonconformit y 11. Risk Register found developed by all of the sections: however certain gaps identified which need to be incorporated in Risk Enterprise Risk Assessment. Management  Psychological hazards OGM/P-HSE- Risk Register need to be Field HSEMRC (Travel sickness/Height 5.1/ updated with regard to phobia/fatigue) highlighted observations by all Occupational hazards Observation concerned in next revision. (Prolong standing/Prolong sittings/shift work/exposure to high noise/chemicals/repetitive work/heavy load lifting) not identified.  Activities found written in Control column while Controls found written in Activity column. Moreover, risks identified not communicated to workers and other stockholders. 12. During review of Prod section Enterprise Risk Incorporate condensate oil I/C Production Risk register review of Prod Management storage tank internal cleaning section below mentioned OGM/P-HSE- and ATA job activities into the 5.1/ observations were made: Risk Register, ensuring  The condensate oil storage Observation thorough hazard identification, tanks internal cleaning risk assessment, and the activities that had been implementation of appropriate done in controls in alignment with ISO ATA--24 not documented in 45001 and ISO 14001 the Risk Register, leading to requirements. potential oversight of Reassess the risk ratings for associated risks. the condensate oil tank and  The risk ratings for the bowser filling platform, taking condensate oil tank and into account the absence of bowser filling platform were essential safety systems, and Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 7  quantified as medium in the implement the necessary Fire Risk Register, despite the and Gas detection system and absence of critical safety fixed foam water system to measures such as the Fire mitigate identified risks. and Gas (F&G) detection system and fixed foam water system in the area. 13. HSE Regulatory Matrix need to Legal & Other be reviewed w.r.t compliance Requirements HSE Regulatory matrix need to OGM/P-HSE- be reviewed annually. Field HSE MRC annually by concerned sectional 5.3/ I/Cs: however same found being not practiced. Observation 14. As per Boilers Rules 2009”No Legal & Other Prior action is required against person shall operate a Boiler Requirements this critical issue. unless he holds a certificate of OGM/P-HSE- I/C Mech.; 5.3/ I/C Process competency issued by the Boiler Shortage of certified boiler Examination Board”: however, Pakistan Boilers engineer to be fulfilled for safe non-compliance in this concern Rules 2009/ boilers operation. observed. Nonconformit y 15. HSE Objective and Targets found Objective & HSE Objectives & Targets be not developed for 2024 by Store Management formulated based on SMART section keeping in consideration Program philosophy. the injury/ loss prevention, Risk OGM/P-HSE- S=Specific reduction and improvement. 5.4/ M=Measurable I/C Store A=Achievable R=Realistic Observation T=Time Bound 16. Although In-house HSE Training plan 2024 has been developed All sectional I/Cs to comply but frequency of execution was Competence & with HSE Annual Training not being followed by most of Awareness planner in true letter and spirit OGM/P-HSE- the sections. 6.1/ to enhance employee’s Field HSE MRC Moreover, training attendance awareness. record depicted least Observation Sectional I/Cs to ensure their participation of Sectional I/Cs participation in trainings too. and Staff. 17. During visit of well site, it was Communication observed that sign boards on & some of the wells found missing. Consultation Sign boards need Moreover, already installed sign OGM/P-HSE- repainting/rewriting and also I/C Production 6.2/ in Urdu language. boards needs repainting / rewriting. Observation 18. At some areas of Uch-I Plant, Communication Pipelines color coding found & Consultation faint. Also, direction of flow OGM/P-HSE- 6.2/ Repainting/rewriting required. I/C Process Uch-I found missing at some points. Observation 19. Although TBT Program FY 2024 TBTs effectiveness be was being practiced in most of evaluated on the prescribed the sections, TBT Manual in Communication format by concerned I/Cs and URDU developed and distributed & Consultation I/C HSEQ. Moreover, to all concerned: however, it was OGM/P-HSE- competent sectional staff to All Sectional I/Cs found that frequency of 6.2/ be given chance to conduct execution was not being TBT. followed. Moreover, its Observation effectiveness not being ensured by sectional I/Cs. 6.2 DO (OPERATION) # FINDING REF. RECOMMENDATION RESPONSIBI Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 8  CLAUSE/ LITY SEVERITY 20. Boiler start up SOP found not Operational Boiler Start up SOP need to be developed. Planning & developed and distributed to Control all concerned. I/C Mech. OGM/P-HSE- 7.1/ Nonconformit y 21. During visit at Store area below mentioned observed:  Backside tyres of Fork lifter Millet FD30MT were found in Operational very poor condition may Planning & result in some incident during Control Highlighted observations to be operation. Also, its lights were OGM/P-HSE- rectified on priority. nonfunctional. 7.1/ I/C Store  Although new Diesel dispensing unit is available at Observation Store shed: however, its installation is still pending.  Ladder installed at Diesel storage tank found unsafe as no side railing provided. (Picture attached) 22. During visit of Uch-II MCC, exit Operational Emergency Exit sign need to door found without HazCom Planning & be pasted at door. sign. Moreover, its direction of Control Exit door opening be outward I/C Electrical OGM/P-HSE- opening needs to be set right. instead of existing one. 7.1/ (Picture attached) Observation 23. Unsafe Platform and access Operational Side support to be provided at ladder provided at T-20 Reflux Planning & open end of platform. condenser water regulation Control Moreover, its approach ladder I/C Mech. OGM/P-HSE- valve at Uch-I Plant. (Picture cage to be extended 01 meter 7.1/ attached) upward. Observation 24. No identification tags found on Operational Identification Tag to be Gas cylinder placed in Uch-I Planning & provided on cylinder. plant area near Boilers. Control OGM/P- HSE-7.1/ I/C Mech. Moreover, its Integrity certificate not witnessed. Observation (Picture attached) 25. Amine leakage observed at Heat Operational Suitable solution to eliminate exchanger 20E-200A Uch-I. Planning & heat exchanger leakage is (Picture attached) Control required. OGM/P-HSE- I/C Mech 7.1/ Observation 26. Coupling protection cover of Operational Rotary pump at Dehy area Uch-II Planning & Protection covers to be found missing creating a caught Control OGM/P- provided on pump coupling. HSE-7.1 I/C Mech. Uch-II in hazard. (Picture attached) Observation 27. In the PF Section, SOPs/Work Operational Develop and implement Instructions for various Planning & SOPs/Work Instructions for all maintenance activities (both in- Control maintenance activities as house and outsourced) have not OGM/P-HSE- identified in the Risk Register, I/C PF been developed, despite being 7.1/ ensuring that these procedures listed as existing control align with the listed control measures in the Risk Register. Observation measures. 28. During visit of lab, ineffective Operational Exhaust fan with sufficient ventilation fan observed at Planning & suction capacity to be installed. I/C Lab; Fuming Hood which can result in Control I/C Electrical Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 9  accumulation of toxic fumes OGM/P-HSE- during testing/analysis work 7.1/ creating a health hazard for Observation working staff. 29. Inspection/Maintenance of Flare Operational To ensure flare stack stack recommended in HAZOP Planning & mechanical integrity and Study of Uch-I: same has been Control smooth flare operation, Annual I/C Mech.; OGM/P-HSE- added in Mech section’s PM flare PM be ensured during I/C Process 7.1/ plans: however, found not ATAs. Uch-I carried out in recently executed Observation Uch-I ATA in October 2024. 30. Electrical DB near Turbine area Operational DB Cover to be provided. Uch-I observed without Planning & protection cover creating an Control OGM/P-HSE- I/C Electrical electric shock hazard. (Picture 7.1/ attached) Observation 31. During checking of MAC T-20 Operational Dehy. area, although its Planning & indication on CCR-I control panel Control MAC Alarms to be made OGM/P-HSE- I/C Instrument found functional: however, its functional. 7.1/ alarm malfunctioning witnessed. Observation 32. Steam Drum (LP-III Boiler) Low Operational Mentioned control is required level alarms found not provided Planning & to be provided at PLCs of for smooth and safe operation. Control Boilers Control room for safe OGM/P-HSE- I/C Instrument and smooth operation of 7.1/ Boilers. Observation 33. Medical equipment such as the Develop and implement Operation Theatre and comprehensive SOPs/ Work Centrifuge were in use in the Operational Instructions for all medical medical dispensary, but their Planning & equipment used in the Control Standard Operating Procedures dispensary, including the OGM/P-HSE- I/C Medical (SOPs) & Work Instructions have 7.1/ Operation Theatre, Centrifuge, not been developed. and any other relevant devices, Observation ensuring that these procedures align with safety, operational, and regulatory standards. 34. Regarding PTW System following discrepancies were observed: All permits be closed properly  Permits issued during Uch-I i.e., signed by relevant October ATA found not Permit to Work authorities and data entries in closed properly. System close out column. I/C Process Uch-  TBT record found not OGM/P-HSE- TBT record be maintained on I; maintained on some of the 7.2/ back side of permits. I/C Mech. permits. Refresher training session on  No lifting plan observed for Observation PTW system be conducted for heavy lifting jobs within all concerned. the plant area and well site. 35. Handling, Medical waste found stored in a Segregation Medical Waste Management drum in front of the dispensary and Disposal of Guidelines provided vide without proper identification and Waste INTEGRATED WASTE I/C Medical segregation. Additionally, the OGM/P-HSE- MANAGEMENT area was not enclosed by a 7.3/ HANDBOOK be implemented in fence. true letter & spirit. Observation 36. Housekeeping of overall waste Handling, Housekeeping in Waste yard yard in was not quite good. Segregation needs attention to eliminate Weeds/Grass growth was and Disposal of biological hazards. Waste creating a biological hazardous OGM/P-HSE- I/C Store condition for workforce. 7.3/ Observation Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 10 37. Section waste register found not Handling, Waste register to be maintained in Instrument Segregation maintained. section. Moreover, Sectional and Disposal of Section I/C to develop strategy Waste I/C Instrument Reps. found with low awareness to manage sectional waste on OGM/P-HSE- regarding the philosophy behind 7.3/ account of available data of maintaining waste register. waste generation. Observation 38. Produced water generated from Ensure that produced water operational activities was not generated from operational documented in the Production activities is accurately section's waste register. Handling, recorded in the Production Segregation section's waste register. and Disposal of Establish a systematic process Waste for identifying, quantifying, and I/C Prod OGM/P-HSE- documenting all waste streams 7.3/ in compliance with regulatory and organizational Observation requirements. Regularly review and update the waste register to maintain accurate and comprehensive records. 39. Daily operational activity of Ensure that the hazardous backwashing pressure/side liquid waste generated from stream filters and softeners at backwashing pressure/side Uch-I generates hazardous liquid stream filters and softeners is waste, which was not included or Handling, accurately documented and quantified in the section's waste Segregation quantified in the section's register of Process Section. and Disposal of waste register, in compliance Waste OGM/P-HSE- with waste management I/C Process Uch-I 7.3/ requirements. Additionally, implement regular reviews of Observation the waste register to verify the inclusion of all operational waste streams and maintain alignment with environmental regulations. 40. Reference Journey Management procedure, following gaps were found:  Although monthly inspection of OGDCL and Journey Inspection data to be Hired vehicles was carried Management maintained on prescribed out: however, data was not OGM/P-HSE- checklists. I/C Mech.; being maintained on 7.4/ Spare Safety belt connector I/C TPT prescribed inspection Nonconformit clamps to be removed from checklist. y vehicles.  In some of the vehicles, spare Safety belt connector clamp provided which inhibits the safety belt alarm. 41. During Uch-I ATA low quality PPEs (Gloves, Helmets etc.) observed being used by Management of contractor staff especially Project Scaffolders. Contractors & Moreover, during Confined Service Strict compliance in this Space Entries no rescue Companies concern is required by Field I/C Mech.; arrangement i.e., use of life line OGM/P-HSE- Management and concerned I/C HSEQ witnessed. 7.6/ I/Cs. Also, ATA Contractor was bound Nonconformit to provide competent staff for y execution of ATA activities: however partial compliance seen in this concern during ATAs. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 11 42. Adequate inventory of required Use of Personal PPEs not maintained by Protective Mechanical, Instrument and Equipment Sufficient PPEs inventory stock I/C Mech.; Telemetry Sections as OGM/P-HSE- to be made available for safe I/C Instrument; 7.7/ execution of routine activities. I/C Telemetry mentioned in PPEs matrix. Observation 43. Irrelevant activities addressed in Use of Personal PPEs matrix of store section. Protective Moreover, some of the staff was Equipment PPEs matrix need to be OGM/P-HSE- I/C Store observed in loose address. reviewed. 7.7/ Observation 6.3 CHECK (PERFORMANCE EVALUATION) REF. RESPONSIBI # FINDING CLAUSE/ RECOMMENDATION LITY SEVERITY 44. Unprotected DB observed in UBUC Badminton court creating an (Hazards) electrical hazard. Also, no identification & DB Cover to be provided. Reporting switches identification I/C Electrical OGM/P-HSE- witnessed. (Picture attached) 8.1/ Observation 45. Iron rods emerging from access UBUC road creating a trip hazard, may (Hazards) Concrete flooring is required to result in human injury. Issue identification & be carried out. Reporting already communicated: I/C Mech. OGM/P-HSE- however, no corrective action 8.1/ witnessed yet. (Picture attached) Observation 46. Drain channel without cover UBUC Drain channel cover/Screen to observed near MCC Room Uch-II (Hazards) be provided. creating a fall hazard. identification & Reporting (Picture attached) I/C Mech. OGM/P-HSE- 8.1/ Observation 47. It was observed during the audit Ensure that all oxygen cylinders HSE that Hydro testing /pressure Monitoring, undergo timely hydro testing of oxygen cylinders for Measurement testing/pressure testing and are the fiscal year 2023-24 had not & Compliance properly labeled with the been conducted, and the Evaluation testing date and expiration I/C Medical Oxygen cylinders lacked proper OGM/P-HSE- date to ensure compliance with identification and labeling 8.2/ safety and regulatory indicating the pressure testing requirements. Nonconformit date and expiry date(Picture y attached) 48. Although spirometry and Implement a consistent annual audiometry tests were HSE schedule for spirometry and conducted for baseline Monitoring, audiometry testing for all identification, it was observed Measurement employees and ensure that all & Compliance that these tests were not personnel undergo the required Evaluation I/C Medical conducted consistently on an OGM/P-HSE- tests in compliance with health annual basis, and not all 8.2/ monitoring procedures. employees have undergone the required testing. Observation 49. Some of the HSE inspections / HSE PMs with Job plan to be I/C Telemetry monitoring i.e., PSVs, ESDs are Monitoring, incorporated in SAP for were executed through PMs in Measurement inspections/monitoring. & Compliance SAP: however same found not All inspection parameters to be Evaluation witnessed in Telemetry section. OGM/P-HSE- incorporated in the form of Job 8.2/ plan/tasks in PMs. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 12  Observation 50. Calibration of Clamp meter used HSE Calibration to be done through for Earthing continuity found due Monitoring, Third party. since 05/03/2023. Measurement & Compliance Evaluation I/C Telemetry OGM/P-HSE- 8.2/ Nonconformit y 51. Inspection of Main Communication HSE Inspection record of main Tower near Admin building not Monitoring, Communication tower to be witnessed in Telemetry section’s Measurement maintained. & Compliance monitoring plans / checklists. Evaluation OGM/P-HSE- I/C Telemetry 8.2/ Observation 52. At Camp area, below mentioned observations were made.  PPE (Aprons, Head PPE purchase to be done for Covers/Hats, Shoes etc.) HSE catering staff. noncompliance observed by Monitoring, Scheduled cleaning to be catering staff. Measurement ensured by Admin sections to  Periodic Hygiene ic & Compliance I/C Admin; maintain hygienic living inspection / Physical Evaluation I/C Security; conditions. examination of catering OGM/P-HSE- I/C Medical 8.2/ Hygienic inspection of catering staff was not conducted staff to be ensured by I/C being ensured. Nonconformit Medical.  Stray Dogs seen in Camp y Strict control at Security gates area. required regarding Dogs entry.  Poor housekeeping observed in living rooms / washrooms. 53. Although Well site Fire HSE New inspection tags to be extinguishers were inspected, Monitoring, affixed. Record maintained: however, Measurement & Compliance dates of inspection not updated Evaluation I/C HSEQ accordingly on Extinguishers. OGM/P-HSE- 8.2/ Observation 6.4 ACT (IMPROVEMENT) REF. RESPONSIBI # FINDING CLAUSE/ RECOMMENDATION LITY SEVERITY 54. Corrective and preventive Opportunities Although Fire detectors have actions found slack as the For Continual been arranged by Instrument review of previous internal Improvement section. Civil work is in I/C Process Uch-I; OGM/P-HSE- audits revealed that Diesel progress: I/C Instrument 9.1/ Storage tank area Uch-I found However matter to be without Fire detector. Observation expedited. 55. Corrective and preventive Opportunities Prior action is required against I/C Production actions found slack as the For Continual long pending issue regarding review of previous internal Improvement Explosive License. OGM/P-HSE- audits revealed that Explosives 9.1/ license for the storage of Crude Oil and HSD (from Provincial Nonconformit Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 13  Inspectorate of Explosives) not acquired yet to fulfill the y regulatory requirements. 56. Corrective and preventive actions found slack as the Procurement case for purchase review of previous internal of H2S detectors is in progress audits revealed that following at HO; however the highlighted issues still found open: finding be addressed on priority  F&G system of gas to avoid any untoward incident. gathering area of Uch-I Opportunities plant found out of service. For Continual Consultancy data has been  Foam pouring system not Improvement received from M/S Haseen installed at Condensate Oil OGM/P-HSE- Habib Pvt Ltd: however, matter I/C Telemetry Storage tanks and 9.1/ needs prior attention and Condensate Oil Loading action. areas of Uch-I Plant. Nonconformit y These observations also highlighted in previous audits since 2021, however matters are still pending. 57. During high wind storms, Flare CPR to be initiated by of Uch-I get extinguished and Opportunities Concerned section to rectify take much time in re-ignition For Continual this repeated operational issue. which results in release of un- Improvement flared toxic gasses and OGM/P-HSE- I/C Process Hydrocarbons creating a risk of 9.1/ Uch-I Fire and Health risks: however, witnessed no CPR raised by Nonconformit y concerned section regarding this repeated operation failure. 58. MoC procedure found being Management of All the Engineering changes / practiced in different Change OGM/P- modifications be properly modification jobs. However, HSE-9.2/ documented and be Field HSE MRC modification in P&IDs/Layouts accompanied by relevant Observation not witnessed in some of the documents before close out. sections. 59. Incident Although record of occupational Investigations illness and injuries is available: OGM/P-HSE- Data to be maintained on I/C Medical however not being maintained 9.3/ prescribed format. on prescribed template. Observation Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 14 8. Key Personnel Interviewed S/No. Name Designation Department/Section 01 Arif Nadeem C.E Instrument Instrument 02 Rab Nawaz Laghari C.E Electrical Electrical 03 Tasaduq Hussain S.E Process Process Uch-I 04 Khurshid Ahmed S.E Process Process Uch-I 05 Muhammad Imtiaz Dy. Chief Lab Lab 06 Muhammad Afzal D.C.E Telemetry Telemetry 07 Saad Ahmed Abbasi S.E Telemetry Telemetry 08 Nazir Ahmed S.E Production Production 09 Saleem Jan J.E Production Production 10 Muhammad Afzal C.E Mechanical PF & Corrosion 11 Nadeem Ahmed J.E Corrosion PF & Corrosion 12 Muhammad Hashim Sr. Admin Officer Admin 13 Tahir Majeed S.E Process Process Uch-II 14 Muhammad Afzal S.E Mech Mechanical 15 Syed Umair Ashraf J.E Mech Mechanical 16 Ghulam Shabbir Channa Sr. Store Assistant MMD 9. Problems Faced/Areas Missed  10. Instruction for HSE Audit Corrective Action Plan and Follow-up Auditee (Area/ Location InCharge) MUST SUBMIT HSE AUDIT CORRECTIVE ACTION PLAN to HSEQ Department within a week (after receiving of the audit report) in the following format: Probable Cause(s) Action(s) Responsibil Target # Audit Finding (In perspective of PDCA Recommende Cycle) ity Deadline d Lead Auditor/ HSE Rep. shall follow-up the audit to determine if corrective actions have been implemented effectively and submit Audit Follow-up Status Report in the following format: Audit Further Audit Finding Action Action(s) Finding’s Follow-up # (Ref. Audit Recommended Actually Closure Required Report) (Ref. Audit Report) Taken Status (Yes/ No) When there is sufficient objective evidence that the corrective action(s) are effective, audit shall be closed out. If more work is needed to fully implement the corrective actions, a new follow-up date shall be agreed upon and audit shall be closed out accordingly. 11. Pictorial/ documented evidence. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 15 Iron rods emerging from access road near Main Store Unprotected DB observed in Badminton court creating a trip hazard, may result in human injury. creating an electrical hazard. Also, no switches Issue already communicated: however, no corrective identification witnessed. (Action by I/C Electrical) action witnessed yet. (Action by I/C Mech) Poor housekeeping observed at back side of Faint sign board observed near Diesel storage tank HSEQ Office. Bricks, Grass visible in attached Uch-I Plant. Need to be repainted and written in URDU picture. (Action by I/C Admin) Language for easy understanding. (Action by I/C Process) Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 16 Electrical DB near Turbine area Uch-I observed Drain channel without cover observed near MCC without protection cover. Room Uch-II creating a fall hazard. Moreover, concrete slabs place nearby be removed from area. Coupling protection cover of Rotary pump at Uch-II MCC, exit door found without HazCom sign. Dehy area Uch-II found missing. Moreover, its direction of opening needs to be set right. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 17 Hydro testing /pressure testing of oxygen cylinders Unsafe Platform at T-20 Reflux condenser water for the fiscal year 2023-24 had not been conducted, regulation valve. No support provided at side and the Oxygen cylinders lack proper identification opening. Moreover, its ladder cage to be extended 01 and labeling. meter upward with back chain. Amine leakage observed at Heat exchanger 20E- No identification tags found on Gas cylinder placed in 200A. plant area near Boilers. Moreover, its Integrity certificate not witnessed. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 18 Ladder installed at Diesel storage tank found unsafe Medical waste is stored in a drum in front of the as no side railing provided. Moreover, ladder rungs dispensary without proper identification and are not proper. segregation. Additionally, the area is not enclosed by a fence. Ref. Section 08 (Performance Evaluation) of OGDCL’s Integrated HSE System Manual Page 19