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HSE Awareness Part 2 2024 eni corporate university Program Day Topics Day 1 Day 2 HSE and Sustainability 1. E...

HSE Awareness Part 2 2024 eni corporate university Program Day Topics Day 1 Day 2 HSE and Sustainability 1. EHS definition 2. Road to Sustainability HSE management System - Planning 1. Context Analysis 2. Leadership 3. Policy 4. Safety culture 5. Risks and opportunities 6. Four year and annual plan 7. Legal requirements (and other ones) 1st DAY 8. Workers’ consultation and participation 9. Roles and Responsibility 10. HSE management System - Support 1. Training, information and skill building 2. Communication 3. Documented information 4. IT and Knowledge sharing Exercise n. 1 Policy Exercise n. 2 Environmental assessment 2 eni corporate university EHS Management System - Operations SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Planning PDCA in ENI upstream Manual Policies and objectives HSE risks and opportunities Context of the organization Four year and annual plans …continuos Compliance obligations improveme Worker’s consultation and participation nt… PLAN Support and Operations ACT Leadership DO Organization and responsibilities HSE Management (& emergency) Energy efficiency management CHECK HSE R&D Management of change Asset management Training, information and skills building Performance evaluation and improvement Communication Monitoring Management of relations with vendors and owners of rights on Company Non conformities, accidents and corrective assets actions Documented information Audit (including process safety ones) Information systems and knowledge Reporting sharing Management review 3 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Operations 4 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Operational basic principles in HSE General The Organization shall plan, implement, control and maintain processes needed to meet requirements of the IMS and to implement actions by… Source - ‘ENI→ The integrity in our operations’ policy Details Establishing criteria for the processes Implementing process controls in accordance with the set criteria Maintaining and retaining documented information to the extent necessary to have confidence that the processes have been carried out as planned Adapting work to workers 5 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Asset Management Asset Management aims at keeping the ability of an asset to perform the function required to achieve business objectives, including people’s safety and environmental protection. …taking into account: 1 - All asset systems and sub-systems 2 - Regulatory and technical compliance 3 - Achievement of the best operational and safety performances and the maximum profitability during the whole life cycle 4 - Needs and requirements of relevant stakeholders 6 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Asset Management related to asset life cycle Design phase Attention to: corrosion and material conditions, Technical maintenance, phase structural integrity of wells and pipelines in accordance with HSE principle Operational phase 7 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Many kind of changes…many management kinds Scope & pure contractual Pay great attention to: changes cost and schedule Project overruns Technical Development design change Design phase consequences in HSE, costs, planning and Execution strategy contracts,… CHANGE Asset Operational Process Next slide phase Organization 8 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Changes in operational phase (1/3) modification to the physical configuration of structures, systems, equipment, items or buildings; removal of equipment or items from the service; change to the use of an equipment or item; Hardware/ Asset modification of the equipment or spare philosophy software (sparing) of the items; alteration of the structure or equipment (e.g. Operational temporary flowlines, pipes, hoses), if not provided for in Process the plant operating manuals; phase repairs; replacement of equipment or components with an alternative not identical to the original (not "Like for Organization Like"); modifications to control systems (alarms, blocks, performance controller parameters, including inhibits or overrides; Modifications to raw materials, chemicals, plant and site settings,… …and many more 9 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Changes in operational phase (2/3) Hardware/ Deviation from the PtW procedure; Asset software changes to operating procedures or technical standards; Operational changes to maintenance, inspection and Process Procedure phase integrity plans, frequencies, procedures and standard performance (frequency reduction and scope of application) of the SECEs; Organization deferred scheduled / corrective maintenance of SECE. 10 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Changes in operational phase (3/3) Hardware/ Asset software Operational Changes to the organization of Process Procedure Company and the Contractor that phase affect HSE tasks, including emergency; Organization any change in the organization, which may affect the workload / shift duration of the operations and maintenance personnel; any change in the organization, which may affect relevant facilities and structures 11 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Duration-related changes Temporary ‘It refers to an interim implementation to temporarily handle a situation or condition, until a permanent solution is implemented or the pre-change situation/ condition is restored to normal at the end of the validity of the change’. The temporary modification must follow the same phases of the MoC process of the permanent change. Temporary changes should not be valid for more than 6 months Urgent ‘It occurs when there is an immediate impact on production / costs with a consequent significant financial loss and Permanent the time constraint‘ ‘A permanent change refers to an alteration or modification of the Limited to exceptional circumstances. current state, where it is not If in emergency, the local Operations can expected that there will be a return decide, supported by the relevant local to the pre-modification status’ engineering and HSE functions. In any Change case, this decision requires the execution of a summary risk analysis to be shared duration with the higher hierarchical level. 12 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Exercise 3 → Management of change In groups, 30 mins 1. Read CSB Safety Bulletin case no.1 (group 1 ) & case 2 (group 2) 2. Express your point of view on effectiveness of Management of change and… 3. …on actions that should have been made. 13 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Supplier relationship management Suppliers are valuable partners! Their choice and performance must be always monitored and communication must be kept at high level for allowing good co-operation and smooth operations. Contractors The Organization shall coordinate its procurement, in order to identify hazards and to assess and control risks arising from mutual impact of organization and contractors’ people, Selection considering third interested parties too Assurance and qualification Procurement (supply chain management) Outsourcing The organization shall ensure that outsourced Operations functions and processes are controlled, that the arrangements are consistent with legal (and other) requirements and consistent to the intended outcomes of the IMS. The type and degree of control to be applied shall be defined within the IMS 14 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Supplier relationship management TARGET→ Evaluating and selecting contractors on their ability to meet the specified requirements and standards, and to operate in compliance to the Law and to ENI’s HSE IMS. Selection Pre-qualification: develop a list of approved Assurance and contractors in different discipline who meet selection qualification criteria determined by the organization, taking into account risks related to the different activities. Typical selection criteria: Financial data Operational capabilities and delivery performance (time, Operations budget, quality, past activities and contracts,…) People competence and qualification HSE Management System implementation and performance data and/or related certification Legal compliance history. 15 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Supplier relationship management TARGET→ Assuring a smooth implementation of operational tasks and integration to ENI’s principles Defining roles and responsibilities (internal manager and Selection contractors manager) Assurance and Controlling access to the site qualification Providing training with respect to the role of contractors, areas of operations, hazards Pre-jobs meeting (responsibilities, tasks and activities, hazards and risk assessment, substances, equipment, emergency, etc.) Controlling of contractors and sub-contractors (materials, Operations equipment) Inspecting Assuring medical healthcare and first aid and emergency management 16 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Supplier relationship management TARGET→ Monitoring contractors compliance against applicable regulations and external standards Performing regular contractors audit Selection Reviewing performance and completion of jobs Assurance and Keeping a high level of communication and cooperation qualification Manage non foreseeable events Operations 17 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Supplier relationship management - operations It is the contractor’s responsibility to ensure that all its personnel and sub-contractors adhere to contractual and general HSE requirements and continuously strive to meet the highest HSE standards. In executing all contracted jobs, Contractors are committed to apply and require their Subcontractors to apply the following: Country Laws for Safety, Health and Environment Protection Company’s Contractual Requirements and Obligations, “HSE Policy”, Policy on “Safe Driving”, requirements on prevention of Alcohol and Drug Abuse Any violation made by Contractors and Subcontractors is subjected to HSE Disciplinary Policy. It means formally expressing a negative feedback that will affect the Contractor’s integrated qualification rating and/or fining to the Contractors and Subcontractors of relevant expenses 18 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Emergency and Crisis Management Definitions EMERGENCY Event that is leading, or is likely to lead, to serious harm to people, environment, asset or properties, image or reputation and/or assets. An emergency situation requires a reaction and a control by an organization, according to Emergency Plans issued to this purpose CRISIS An event or sequence of events of extreme concern or danger, able to disrupt the organization capability to re-conduct the situation under control with its own resources. A crisis is of such significance as to require an exceptional response at the highest level, in view of the serious impact that may result on the reputation. 19 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Emergency and Crisis Management Recovery Mitigate Respond Prepare 20 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Emergency and Crisis Management Mitigation This phase involves activities that prevent a disaster, reduce the chance of it happening, or reduce its damaging effects. Mitigation activities should be undertaken long before a disaster occurs as part of a long-term strategy to reduce or prevent the loss of life and property damage likely to occur from a variety of natural and technological disasters. Preparedness Since mitigation alone cannot prevent or eliminate the impact from most disasters, it is necessary to make plans and preparations for disaster events. Preparedness activities are undertaken to improve the ability to respond quickly and efficiently in the aftermath of an incident. 21 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Emergency and Crisis Management Response The preparedness phase lays the groundwork for the response phase, which involves actions taken immediately after the onset of a disaster. Stated differently, response activities occur during the initial impact of a disaster. It is intended to provide emergency assistance for casualties, including search and rescue operations, and the provision of shelter and medical care. This phase also involves damage assessment, which provides the basis for federal assistance. Recovery The recovery phase commences after the initial impact. Recovery activities are geared towards returning all systems to normalcy, and can continue long beyond the emergency period immediately following a disaster. They can be broken down into short-term and long-term activities. 22 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Emergency and Crisis Management Oil & Gas Industry possible Emergencies Major injuries or health effects Major Environmental damage Pipeline emergencies Marine vessel emergencies Plant emergencies Wells emergencies Transport emergencies Security threats 23 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Performance evaluation 24 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming How can I measure a process? 25 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming How can I measure a process? Setting checkpoints, assigning indicators (y/n, KPIs, alarm levels), measuring and using equipment and tools 26 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming Back to FLOW Ltd, who is responsible for performances? Legal Non ex. Issue CEO CFO HSE Exploration Drilling Supervisors Workers Affairs Dir Setting business strategy Setting indicators Implement strategy Implement operations Monitor operational results Provide feedback Review strategy Use ‘RACI method’_ R – Responsible, A – Accountable, C – Co-operate, I - Informed 27 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming Back to FLOW Ltd, who is responsible for performances? Legal Non ex. Issue CEO CFO HSE Exploration Drilling Supervisors Workers Affairs Dir Setting business A+R C C C C C I (I) (I) strategy Setting indicators A+R C C C C C I Implement strategy A+R A+R A+R R R I (C) (C) Implement A+R A+R I (C) (C) operations Monitor operational A+R A+R I (C) (C) results Provide feedback A+R A+R A+R R R I (C) (C) Review strategy A+R C C C C C I (I) (I) A potential solution… 28 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 What are KPIs? ‘Ratios of defined data that it is Selection – They must fit possible to use to control and the purpose, the process evaluate different aspect of the and the objective performance’ Active Source of data – It must be Reactive accurate and reliable (data quality) Types General Effectiveness - related KPIs Efficiency - related Interpretations – Numbers Organizational must be understood and HSE mediate to context, events,… Historical Time-related Scope Critical …and many other ones! Basis of quantitative analysis 29 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 KPIs – some examples on HSE General Certification and Audits Environment Injury frequency rate No. of certifications Gross energy Injury severity rate No. of Health Audits consumption Fatality rate No. of Safety Audits Freshwater Health expenditure consumption No. of Environmental No. of Health Audits Waste personnel GHG emissions No. of HSE Integrated No. of HSE training Audits NOx emissions hours/employees SO2 emissions No. of HSE staff/1000 employees Oil spills No. of auditors Quantity of oil spilt 30 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Yes or No? KPIs or not? 1. % employee satisfaction 2. No. of involved employees 3. General perception of ‘Quality’ 4. $ budget/yr. 5. Increase in market 31 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Yes or No? KPIs or not? 1. % employee satisfaction 2. No. of involved employees 3. General perception of ‘Quality’ 4. $ budget/yr. 5. Increase in market 32 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 KPIs - Active and reacting Active Purpose: Checking compliance to the HSE (leading) activities KPIs Purpose: Investigating, Reactive analyzing and recording HSE (lagging) management system failures ACTIVE (examples) REACTIVE (examples) The extent to which plans and objectives Unsafe Acts have been set and achieved Unsafe conditions Whether a organization for HSE has been Lost time incidents appointed Major accidents & fatalities Whether a HSE policy has been published Criticism made by stakeholders The numbers of staff trained in HSE Criticisms made by regulatory agency Number of risk assessments completed staff Extent of compliance with risk controls … … 33 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Yes or No? Leading (LE) or lagging (LA)? 1. Extent of compliance with statutory requirements 2. Frequency of HSE audits 3. Injuries per year 4. Health Surveillance reports 5. Sickness leave 34 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Yes or No? Leading (LE) or lagging (LA)? 1. Extent of compliance with statutory requirements LE 2. Frequency of HSE audits LE 3. Injuries per year LA 4. Health Surveillance reports LE 5. Sickness leave LA 35 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What is an audit? 36 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What is an audit? ‘Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled’ – ISO 19011:2018. 37 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Audit overview CRITERIA FINDINGS Limits and What seen Outcome of an perimeter of while auditing audit, after the audit: They can be considering of location, records, the audit organizational statements of Results of the objectives and units, activities Set of policies, fact or other evaluation of all audit and processes, procedures or information evidence findings time period requirements which are related to set Technical/ IMS used as a relevant to the criteria audit, Legal reference for audit criteria They can be Compliance comparison and verifiable positive and audit, Process with audit negative safety audit/ evidences (related to BART selected assessment criteria) SCOPE EVIDENCES CONCLUSIONS 38 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Why auditing? 1. For addressing and understanding risks and opportunities? 2. For getting a certification? 3. For enhancing performance, looking for continual improvement? 4. For finding non conformities? 5. For suggesting corrective actions 6. To determine the effectiveness of the management system 7. To show opinions to the Management 8. To fine and find who is guilty? 39 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Why auditing? 1. For addressing and understanding risks and opportunities? 2. For getting a certification? 3. For enhancing performance, looking for continual improvement? 4. For finding non conformities? 5. For suggesting corrective actions 6. To determine the effectiveness of the management system 7. To show opinions to the Management 8. To fine and find who is guilty? 40 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Upstream audit process focus Ensuring that the management system is able to achieve its objectives and manage the risks. Identifying problems or potential deviations. Providing hints for continuous improvement. Maintaining a high level of attention from personnel at any level Checking the uniformity of execution of the Management System throughout sites. Assessing compliance with the reference standard (ISO 14001 and ISO 45001). In addition to this, an indirect benefit is allowing auditors to improve their skills and provide a more and more added value to the Upstream division. 41 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Kind of Audit & audit team First party (internal audit) Second party Third party (certification audit) Company audited by a Company auditing Suppliers certification body in order to Company ‘self-audit’ and Contractors or audited by achieve the certification on a Customers specific international standard. WHO CONDUCTS THE AUDIT? An AUDIT TEAM Made by AUDITORS Led by a LEAD AUDITOR 42 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What are auditor’s principles? 43 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What are auditor’s principles? Integrity Impartiality Professionalism Discretion on confidentiality Independency from the scope of audit Evidence and risk based approach. 44 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What are auditor’s principles? 45 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Brainstorming What are auditor’s principles? Personal skills, General knowledge of the auditing process, Specific knowledge of the auditing standard, Specific skills as lead auditor (in case). 46 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 More on auditor’s skills Planning and organization of work Auditing techniques Conducting business in a timely manner Prioritizing of activities and focus on the relevant issues Focused standard principles, ISO 14001 or Collecting information by an effective 45001 or company’s procedures… (and/or use of interviews, observations, surveys, company related management system document review and the reference documentation– for Sampling and interviewing techniques internal audit only) Collecting audit evidences Preparing the audit report HSE law of hosting country Maintaining confidentiality and security of collected information HSE theoretical and technical knowledge Organizations must establish requirements for competence and experience for their internal auditors 47 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Improvement 48 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Non conformities and corrective actions Non-conformities may be detected during Audits, emergency drills and real emergencies, arise from UPS/Geographical Areas HSE Management Review. A comprehensive database is in place collecting all non-conformities and corrective actions, including related deadlines, responsibilities and analysis of the non-conformities causes. The status of actions is monitored and kept up to date on a regular basis. Gap to be filled = ‘Major/ Something could be improved Positive practice already Minor Non conformity or – ‘Opportunity for put in place – ‘Strenghts’ observation’ improvement’ (not binding) 49 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Non conformity basic and mandatory elements What is the "rule" that has been If there is not a requirement, we can not Requirement broken? For example, there may be formulate a non-compliance, the requirement a legal requirement must be stated in the notice of non-compliance. If there is not a deficiency, we can not formulate Misalignment with respect to the Deficiency a non-compliance, the deficiency must be stated requirement in the notice of non-compliance. If there is not an objective evidence, we can not It's the "proof" that the requirement make a note of non-compliance; objective Evidence is not met evidence ("proof") must be indicated in the notice of non-compliance. Incidents and injuries must be considered as Non conformity (major or minor, depending on severity) 50 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Incident reporting, investigation and statistics Each and any NC, including incidents and near miss, must be: notified, investigated, reported, treated in the short time to fix the problem , treated in the long term in order to prevent further occurrence, analysed on a statistical viewpoint. That’s vital for the continual improvement of the IMS. 51 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Example of possible causes (1/2) Failure to warn Inadequate guards / barriers Failure to obey rules Inadequate PPE Failure to follow procedures Defective tools / equipment Removing safety devices Congestion / disorder Improper lifting Inadequate warning system Failure to use PPE Defective product Servicing operating equipment Excessive exposures Failure to identify hazards / risks Inadequate ventilation Failure to communicate / coordinate Inadequate illumination Unethical actions Inadequate HSEQ exposures Failure to analyze, react, and/or correct Inadequate data / indicators 52 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Example of possible causes (2/2) …. Personal Factors Inadequate capability Stress System design weaknesses, missing or inadequately Lack of knowledge designed policies, programs, plans, processes and procedures will affect conditions and practices Lack of skill generally throughout the workplace. Defects in Improper motivation system design represent hazardous system Abuse and Misuse conditions. Job / System Factors System implementation weaknesses, failure to Inadequate leadership initiate, carry out, or accomplish safety policies, Inadequate engineering programs, plans, processes, and procedures. Defects Inadequate purchasing in implementation represent ineffective management behavior11 Inadequate maintenance Inadequate tools and equipment Inadequate work standards ……………………. 53 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Management review The “management review" subprocess completes the cycle for continuous improvement of the management system, and paves the way for the following planning cycle. Corporate and BU HSE Functions and employees are responsible to review, at planned intervals, and with respect to their respective scope, the HSE Management System to ensure its adequacy, suitability and The review makes also use of the data effectiveness. and information made available by the control system (monitoring, auditing and reporting) 54 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Management Review - input The “management review" considers the following input elements: changes in the context of the organization; fulfillment of the compliance obligations; risks and opportunities including the HSE relevant risks control level assessment, including direct and indirect environmental aspects; results of the technical audits, gap analysis, compliance audits, system audits, process safety audits; HSE reports and records; HSE training activities; identification of improvement opportunities; status of non-compliance and corrective actions undertaken and their effectiveness; Input HSE objectives progress status and analysis; HSE performance evaluation and benchmarking, including analysis of Process Safety KPIs and statistical analysis of non-compliance occurred; HSE critical issue assessment; needs and expectations and communications received from relevant interested parties identified in the context analysis; suitability of resources; information from other functions or others Business Units; progress of the improvement actions defined in previous management reviews; any modifications within the mapping of the Subsidiaries clusters in reference to the need for implementation of the management systems and their certifications, as indicated by HSE MSG 55 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Management Review - output “Management review" considers the following input elements: evaluation of the effectiveness of the IMS; improvements opportunities; modification needed in the IMS, included resources; Output corrective action in case objectives not achieved; opportunity to integrate the IMS with others internal business processes; possible implications for the strategic direction of the organization “Management reviews" are periodically held on six months/annual basis depending on functional level- They are also held in case of relevant change of the Management System conditions. The Management review is actually a formal report, communicated to all relevant parties. 56 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Management Review escalation “Management review" regulatory instrument defines: responsibility and periodicity of the reviews (at employer, business unit and Eni corporate HSE function level), considering the implementation timings required by various levels; review structure and elements in relation to management system phases; corrective actions; representatives of various levels to the reviews (including, for the employers’ management review, their proxies); management review reporting to the company’s top managers. 57 eni corporate university SASC1103B – HSE Awareness – Rev 2.0 del 02/2024 Let’s recap

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