Military reference books and manuals (2009-2023, Volume 4)

Best Practice Guidance For Waste Management for Waste Transportation, Storage, Treatment and Disposal

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Executive Summary

Waste management is a critical component for BP HSE Policy. ìNo Damage to Environmentî -

the principal of the company, which cannot be achieved without proper management of wastes

generated by companyís activities.

This document is aimed at providing more detailed information to waste management providers in

order that they can understand / work towards best practice and to set out standards that should be

achieved at existing and potential facilities used by BP and its contractors. This document is not

legally binding but it does provide guidance to the reader on the general principles against which

BP audits waste. The guidanceís purposes are:

• To promote best international practice in waste management within Azerbaijan and

Georgia

• Provide local enterprises with better and more detailed understanding of BPís expectation

in waste management

• Increase Safety & Environmental awareness among local waste management companies

BP Exploration (Caspian Sea) Ltd. is looking forward to working with local waste management

service providers.

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Table of Contents

1.0 Introduction

1.1 Purpose

1.2 Scope

1.3 Waste Management Approach and Principles

2.0 Waste Categories

3.0 Requirements for Waste Transporters

3.1 Definition

3.2 Operational controls

3.3 Waste Transfer Notes

4.0 Requirements for Treatment, Storage and Disposal Facilities

4.1 Environmental Management System

4.2 Waste management standards

4.3 Record keeping

5.0 Outline of waste treatment, storage and disposal Facilities Specific standards

6.0

Containers

6.1

Definition

6.2

Design standards

6.3

Operational requirements

6.4

Monitoring /inspections

6.5

Secondary Containment

7.0

Tanks

7.1

Definition

7.2

Design Standards

7.2.1 Corrosion Protection

7.3

Operational requirements

7.4

Inspections

7.5

Leak detection

7.6

Release Prevention and Response Plan

7.7

Secondary Containment for Tanks

8.0

Landfarming/bioremediation treatment Processes

8.1

Definition

8.2

Design standards

8.3

Operational requirements

8.4

Monitoring & Inspection

8.5

Groundwater monitoring

9.0 Surface Impoundments

9.1

Definition

9.2

Design Standards

9.3

Monitoring & Inspections

9.4 Groundwater monitoring

10.0 Incinerators

10.1

Definition

10.2 Permitting

10.2

Operational controls

10.3 Monitoring & Inspections

11.0 Landfill Sites

11.1

Definitions

11.2 Permitting

11.3 Design Standards

11.4 Operational Controls

11.5 Inspections & Monitoring

11.6 Groundwater monitoring

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BEST PRACTICE GUIDANCE FOR WASTE MANAGEMENT FOR WASTE

TRANSPORTATION, STORAGE, TREATMENT AND DISPOSAL COMPANIES

1.0 INTRODUCTION

1.1 Purpose

BP works with local companies to promote environmentally sound and internationally acceptable

waste management practices and to promote development of waste management infrastructure.

Appropriate transportation, storage, processing

(re-use, recycle,) and disposal of wastes is

important to eliminate or minimize threats to the environment and human health.

This document is aimed:

• To promote best international practice in waste management within Azerbaijan and

Georgia

• To provide more detailed information to waste management providers in order that they

can understand / work towards best practice and to set out standards that should be

achieved at existing and potential facilities used by BP and its contractors.

• To increase Safety & Environmental awareness among local waste management

companies

1.2 Scope

This document is not legally binding but it does provide guidance to the reader on the general

principles against which BP audits waste handlers. It details a set of standards for the waste

management process therefore the minimum expected generic and facility specific requirements

are identified. These requirements include:

• Legislative compliance

• Design and engineering standards

• Operational controls

• Contingency measures

• Documentation and record keeping

The requirements identified in this document form the basis of the audit process that BP will use

to evaluate new and existing waste management companies.

This document takes into account current standards and infrastructure availability. It is

recognized that standards and availability infrastructure will change over time, and this document

may become outdated or may be updated as needed. If contractors ever have questions regarding

current acceptable waste management practices, please contact:

Environmental manager at Central HSE ñ Andrew Foster

Environmental advisor at Central HSE ñ Khabiba Bagirova

Ayaz Hasanov

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1.3 Waste Management Approach and Principles

The Waste Management Hierarchy is a principle used as a basis to promote sustainable waste

management. The following waste management approach and principles reflect BPís Waste

Management strategy:

• Waste avoidance is the most preferred option, followed by minimisation of quantities

and hazards of waste generated; in addition, reuse, recovery and recycling should be

preferred over treatment of waste with disposal being a last resort (Box 1).

• Proximity Principle, which states that wastes should be managed as close to source of

generation as practicable, and that countries and preferably regions should be self

sufficient in terms of waste management.

• Duty of Care, whereby a waste producer has a duty to ensure that a waste is properly

managed even after that waste has been transferred to a third party.

• Use of Best Available Technology Not Entailing Excessive Cost (BATNEEC)

• Polluter Pays Principle, whereby any party causing pollution should pay the cost of

mitigating that pollution. Waste should not be abandoned, dumped or discharged in

uncontrolled manner.

Box 1: Hierarchy of waste management practices

Each waste stream should be managed according to the following hierarchy of techniques, in

which the technique chosen should be the first in the hierarchy that is safe and practicable:

• Consider waste generation and consequences from the outset of any activity

• Eliminate or minimise the quantities and hazards of waste streams by choice of

project/facility design, product substitution, procurement practices, and operation

procedure

• Re-use as a material

• Re-use as a fuel (when the waste provides legitimate fuel value)

• Process and re-use as a material

• Process and re-use as a fuel

• Incinerate and re-use or landfill the ash

• Landfill (not applicable to waste water). Disposal through incineration or landfill are

the least desirable environmental options

• Discharge to a receiving water course (applicable only to wastewater) after appropriate

treatment

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2.0 WASTE CATEGORIES

Wastes generated from operational activities fall into two main categories, hazardous and non-

hazardous. These can be defined as:

Non-Hazardous Waste (Source: AzBU Environmental Management System Manual and

Procedures)

Wastes that do not exhibit one or more of the characteristics of hazardous waste such as

ignitability, corrosivity, reactivity, toxicity, which are biodegradable or inert and cannot cause any

harm to people and environment. Examples include: Paper and Card, Food, Scrap metal (no

hydrocarbons), Wood.

Hazardous Waste (Source: AzBU Environmental Management System Manual and Procedures)

Wastes that exhibit one or more of the characteristics of hazardous waste such as ignitability,

corrosivity, reactivity, toxicity, which are mutagenic, teratogenic, infectious, irritant carcinogenic,

ecotoxic and undegradable, flammable and highly flammable, explosive, e.g. which can be

harmful to health and can cause damage to the environment (land, water contamination, air

pollution). Examples include: Oil Filters, Oily scrap metals, oily plastics, Oily rags/ absorbents,

Diesel/Crude oil (including tank bottom sludge, oily waters), Lubricating Oils, Pigging waxes,

Batteries, etc.

Note ñ radioactive wastes are not included in this classification but have their own class due to

their specific nature.

Hazardous wastes are identified for the following characteristics: (Source: AzBU Environmental

Management System Manual and Procedures)

Explosive:

substances and preparations which may explode under the effect

of flame or which are more sensitive to shocks or friction than

dinitrobenzene

Oxidizing:

substances and preparations, which exhibit highly

exothermic reactions when in contact with other

substances, particularly flammable substances

Highly flammable:

liquid substances and preparations having a flash point below

21ºC (including extremely flammable liquids), or substances and

preparations which may become hot and finally catch fire in

contact with air at ambient temperature without any application

of energy, or solid substances and preparations which may

readily catch fire after brief contact with a source of ignition and

which continue to burn or to be consumed after removal of the

source of ignition, or gaseous substances and preparations which

are flammable in air at normal pressure, or substances and

preparations which, in contact with water or damp air, evolve

highly flammable gases in dangerous quantities

Flammable:

liquid substances and preparations having a flash point equal to

or greater than 21ºC and less than or equal to 55ºC

Irritant

non-corrosive substances and preparations which, through

immediate, prolonged or repeated contact with the skin or

mucous membrane, can cause inflammation

Harmful:

substances and preparations which, if they are inhaled or ingested

or if they penetrate the skin, may involve limited health risks

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Toxic:

substances and preparations (including very toxic substances and

preparations) which, if they are inhaled or ingested or if they

penetrate the skin, may involve serious, acute or chronic health

risks or even death

Carcinogenic:

substances and preparations which, if they are inhaled or ingested

or if they penetrate the skin, may induce cancer or increase its

incidence

Corrosive:

substances and preparations which may destroy living tissue on

contact

Infectious:

substances containing viable microorganisms or their toxins

which are known or reliably believed to cause disease in man or

other living organisms

Teratogenic:

substances and preparations which, if they are inhaled or

ingested or if they penetrate the skin, may induce non-hereditary

congenital malformations or increase their incidence

Mutagenic:

substances and preparations which, if they are inhaled or ingested

or if they penetrate the skin, may induce hereditary genetic

defects or increase their incidence Substances and preparations

which release toxic or very toxic gases in contact with water, air

or an acid. Substances and preparations capable by any means,

after disposal, of yielding another substance, e.g. a leachate,

which possesses any of the characteristics listed above

Ecotoxic:

substances and preparations that present or may present

immediate or delayed risks for one or more sectors of the

environment

3.0 REQUIREMENTS FOR WASTE TRANSPORTERS

3.1 Definition

A transporter is any party that moves wastes from one site to another for treatment, storage or

disposal.

3.2 Operational controls

Transporters have a duty to ensure that:

• Relevant Legislative permits and license from authorities are in place

• Vehicle design is suitable for waste transportation and appropriate maintenance is

provided.

• Compliance with the Waste Transfer Note (WTN) system (Attachment 4) and appropriate

documentation to track the shipment and receipt of such waste

• Packaging of wastes is appropriate to prevent unplanned release or spilling of waste (e.g.

waste skips should be covered with a net to prevent loss of contents)

• Labelling, marking and placarding of the packaged waste identify the characteristics and

dangers associated with its transport

• Proper handling of hazardous waste discharges, accidental spillage including reporting

and cleanup so unplanned discharge is not a hazard to human health or the environment

(note ñ discharges on BP leases or facilities should be reported to BP immediately).

• Record keeping and reporting requirements are met

• Any concerns regarding transport of waste (e.g. non-compliance report) are identified

and appropriately documented

• Waste transporting personnel have appropriate competency (relevant training and etc.)

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3.3 Waste Transfer Notes

Waste Transfer Notes (WTN) are numbered records of waste movements (at a minimum in

triplicate), which enable tracking, and recording of wastes from cradle to grave (i.e. point of

generation to final disposal).

•

WTNs must accompany all waste consignments.

•

WTNs must include: Waste type, volume/quantity, classification, hazards, special

handling requirements, contact details of the Generator and person responsible,

Generating site name if different, Transporting company, Driver Name & registration of

vehicle.

•

WTNs must be completed by the generator with the required details and the appropriate

signatories.

•

Transfer notes must be signed by the responsible personnel on site and transporter of the

waste.

•

A copy of the transfer note must be taken by site personnel (Originator) and filed.

•

Original transfer note must be provided to the person collecting the waste for transport.

•

The transfer note will accompany the waste during transport. Material Safety Data Sheets

(MSDS) must be attached, where appropriate, as must lab analyses if relevant.

•

Waste transport company is responsible to obtain a signature from the waste disposer and

then return the WTN to the appropriate responsible person as a representative of the

Generator

•

The completed transfer notes must be retained at each site for future audit and review.

I.e. Generator ñ Transporter ñ Disposal Contractor; 3 identical copies of the WTN must

be completed and the loop closed back with the Generator.

•

Site representatives must not release the waste, nor sign the WTN, if there are any

concerns about the standard of transportation vessels/facilities or final destination of the

waste. Likewise, transporters must not take control of the waste unless satisfied that the

waste fits the WTN description.

•

Appropriate information from all transfer notes is to be copied onto the waste register for

all wastes.

4.0 REQUIREMENTS FOR TREATMENT, STORAGE AND DISPOSAL FACILITIES

4.1 Environmental Management System

All waste management treatment, storage, and disposal companies should have a documented

environmental management system (EMS), preferably using the ISO 14001 structure, to enable

appropriate environmental risk management and legal compliance whilst ensuring continuous

improvements. Environmental Management System is a part of the overall management system

that includes organizational structure, planning activities, responsibilities, practices, procedures,

processes and resources for developing, implementing, achieving, reviewing and maintaining the

environmental policy.

At a minimum, key elements of the EMS should include:

Environmental Policy

o An environmental policy developed, signed and committed to by management,

and kept current.

The policy should identify management support and commitment for compliance with legal

environmental requirements, pollution prevention, and continual improvement.

Plan

o Identification of environmental aspects and impacts

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o Legal Requirements

o Roles and Responsibilities

o Operational Controls

o Training Program

o Record and Document Management

Check

o Monitoring and Verification

o Audit Program

o Reporting of Environmental Events

o Corrective and Preventive Action

Act

o Management Review

4.2 Waste management standards

All facilities should:

•

Have all appropriate national / local permits to achieve legislative compliance for each

type of waste handled on the site. The relevant permit identifies the standards and

requirements applicable to the specific activities conducted at that facility, including both

the general facility standards and standards applicable to each type of process at the

facility eg Ecopassport, Technical Reglament

•

Be sited appropriately: Certain types of terrain may increase the dangers associated with

managing wastes. For example, waste sites should be at a safe distance from residential

and commercial areas. Geological and hydrological factors should be considered in the

design and siting of any new facilities to minimize the potential for release of

contaminants to the environment and protect human health.

•

Provide detailed plans and engineering reports describing the site location, design,

construction, operation, maintenance, monitoring and mitigation plans and inspection

plans.

•

Identify waste and have labelling specifying chemical/physical hazards of waste and

hazardous/non-hazardous waste classification of waste containers and locations. Labels

should be clearly identified on each container and all old labels removed. (Attachment 2)

•

Ensure that wastes are appropriately treated prior to disposal. Be able to demonstrate

operational controls and efficiency of reuse/recycling/treatment/ disposal facilities

•

Ensure that non-hazardous solid waste is not mixed with hazardous waste. Any

hazardous waste mixed with non-hazardous means that it should all be reclassified as

hazardous (this may also have cost implications).

•

Ensure that wastes are not diluted (by adding water, air or soil to waste) in order to reduce

concentrations of hazardous constituents, or commingled with other incompatible

hazardous waste types.

•

Keep records of waste managed at the facility, including registers/manifests for wastes

received and dispatched (Attachment 1), WTN, and operational records to document

waste management activities. Material Safety Data Sheets (MSDS) should be kept onsite

where possible. (Attachment 3)

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•

Comply with good practice regarding the storage of wastes as described below:

•

To avoid dangerous accidents; fires, or explosions, special care should be taken in

handling ignitable, reactive, or incompatible wastes. Facilities handling ignitable and

reactive wastes should be able to demonstrate that these wastes are protected from

ignition sources. Such protection includes ìNo Smokingî signs placed where ignitable

and reactive wastes are stored, designation of separate smoking areas away from

operational areas and additional handling requirements.

•

Take precautions against the combined storage of wastes that might react dangerously

with one another or with the receptacle in which they are stored.

•

Classify wastes. If the composition of a waste stream is unknown, or may have changed

(i.e. it may have been contaminated with another waste) the waste stream should be

analysed to determine its hazards and properties and it may result in reclassification.

•

Have routine regular inspection provisions. The owner/operator should regularly inspect

the facility for a minimum of malfunction, deterioration and operator error. The

inspection should follow a written inspection schedule and checklist that identifies the

areas to be inspected. Areas where spills are more likely to occur (such as loading and

unloading areas), should be inspected daily when in use. Specific inspections or

requirements may also be included in the schedule. Any problems identified during the

inspections should be remedied in a timely manner. The owner /operator should record

inspections and repairs in a log or summary.

•

Monitoring of waste streams and emissions: Owners and operators of waste facilities

should conduct monitoring, acceptance testing, data analysis, and inspections to ensure

that the facility is in compliance with its legislative permit and performance standards.

The operators should be able to demonstrate that the waste management process has

minimum impact on human population and environmental media (air, surface water

including wetlands), ground water, and soil. All records should be kept and maintained.

Results of the monitoring should be available to the public.

•

Develop a Release Prevention and Response Plan and have spill equipment- (sand bags,

absorbent socks, spill kits) in order to eliminate or mitigate the potential impact of any

leak or spill. The plan should outline the short and long term actions to be taken to

prevent and to mitigate a leak or a spill.

•

Maintain and routinely test emergency equipment, including alarms, fire extinguishers,

and procedures for contacting local authorities (police, fire department, hospitals and

emergency response teams) involved in emergency responses at the facility. Maintain at

least minimum aisle space (to accommodate personnel and equipment during

emergencies).

•

Designate an emergency coordinator to guide emergency response activities, train

employees in evacuation and use of extinguishers and make available contact

information.

•

Review Contingency plans and amend when the applicable regulations or facility permits

are revised, or when there are changes to the facility, the list of emergency coordinators,

or the list of emergency equipment. A valid copy of the contingency plan should be

maintained at the facility.

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• Provide new personnel and refresher training in the proper handling of wastes through an

established training program. Training records should be kept and reviewed on a regular

basis.

• Have security provisions to prevent accidental or unauthorized entry into the operational

area of a facility via a barrier (e.g. a fence) that completely surrounds the area of the

facility and controls entry at all times through gates or entrances. This can also be

provided by a 24 hour surveillance system that continuously monitors and controls entry

onto the operational areas of the facility (e.g., television monitoring, guards)

4.3 Record keeping

To keep track of waste activity at the facility the owner and operator should keep written

operating records on site describing all waste received; methods and dates of treatment storage

and disposal; and the location of wastes within the facility. All information should be cross-

referenced with the waste transfer note number. Other information that the waste facility should

keep in its operating records includes:

o Waste analysis results

o Details of emergencies requiring contingency plan implementation

o All monitoring inspection data (should be kept for three years) and resulting

actions

All records and plans should be available for inspection/audits.

5.0 OUTLINE OF WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES

SPECIFIC STANDARDS

Waste may be treated, stored or disposed of in several different types of facilities. The following

sections describe the facility specific standards that should be adhered to at each of the following

types of

waste storage, transportation and disposal facility:

o Containers (Section 7)

o Tanks (Section 8)

o Landfarming/Bioremediation Treatment Facilities (Section 9)

o Surface Impoundments (Section 10)

o Incinerators (Section 11)

o Landfill Sites (Section 12)

o Other facility types (Section 13)

These requirements form the basis of the audit process that BP uses to evaluate new and existing

waste management service providers.

6.0

CONTAINERS

6.1

Definition

A container is a portable device in which a material is stored, transported, treated or otherwise

handled.

6.2

Design standards

• Containers should be in good condition and suitable for the waste type. Containers that

are deteriorated or damaged should not be used.

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•

Containers should be made of or lined with materials that will not react with, and are

compatible with, the waste to be stored, so that containment of the waste is not impaired.

6.3

Operational requirements

•

Wastes should be stored in such a manner in order to minimize risk to the environment

and human health.

•

Containers should generally be kept closed, except when adding or removing waste. In

addition, containers should not be handled, opened or stored in a way that might cause

them to leak.

•

Incompatible wastes, or incompatible wastes and materials, should not be placed in the

same container.

•

Containers holding ignitable or reactive waste should be located at safe distance from the

facility's perimeter. Risk assessment is required to determine the distance. i.e. A storage

container holding a hazardous waste that is incompatible with any waste or other

materials stored nearby in other containers or tanks should be separated from the other

materials or protected from them by means of a closed drainage, bund, wall, or other

device.

•

Waste should not be placed in an unwashed container that previously held an

incompatible waste or material, as there is risk of a reaction and potential for cross

contamination. Containers should be washed to minimize potential for cross

contamination.

•

If a container or tank holding waste is not in good condition, or if it begins to leak, the

generator should transfer the waste from that container/tank to a one that is in good

condition, or manage the waste in some other way that eliminates potential risk to human

health or release to the environment.

6.4

Monitoring /inspections

•

Owners and operators should visually regularly inspect container storage areas for leaking

and deteriorating containers.

•

Regular inspections should be documented. Any remedial actions should be included in

the inspection notes along with planned completion dates.

6.5

Secondary Containment

Containers/tanks holding liquid hazardous wastes should have a secondary containment system at

container storage areas. Secondary containment is emergency short-term storage 110% of storage

capacity of largest container designed to contain leaks from containers, tanks and the like. An

example of a secondary containment system is a graded walled concrete pad that contains any

leaked liquids by diverting them in to a closed drainage system and then to a tank for

accumulation.

A secondary containment system should be designed, installed, and operated to ensure that:

o The secondary containment system is free of cracks, has no connection with the open

drainage system and is able to contain the spill.

o No waste is released to the surrounding soil, ground water or surface water

o Construction materials or liners are compatible with the waste to be stored or treated in

the container or tank

o The foundation can resist failure due to normal movement of surrounding soils

(settlement, compression, or uplift)

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7.0

TANKS

7.1

Definition

Tanks are devices used to store or treat waste. In order to ensure that a tank can hold waste for its

intended lifetime, the waste facility owner /operator should ensure that the tank is suitably

designed and installed. An independent, qualified, registered engineer should certify that the tank

meets engineering and regulatory requirements.

7.2

Design Standards

o Waste tanks should be installed properly and designed to protect against corrosion.

o The tank should have sufficient structural strength to prevent failure

o The tank should be capable of containing accumulated material until it is promptly

removed

7.2.1 Corrosion Protection

When metal tanks are in contact with soil or water they can corrode and leak. To prevent leaks

from corroded tanks there is requirement that tanks made wholly or partly of metal to be designed

and installed with adequate corrosion protection. To ensure that a tank is properly protected, an

owner and operator should develop a written design plan. The design should take into account

information specific to the site, such as soil moisture and acidity that can affect the corrosion rate

of the tank.

The unit should have corrosion protection methods consistent or equivalent to the following

measures:

o Construction materials that are corrosion ñresistant (e.g. fiberglass)

o Corrosion-resistant coating in combination with cathodic protection (cathodic protection

prevents tanks from corroding by reversing the naturally occurring electric current in the

ground that can degrade tank walls)

o Electrical isolation devices

o Other suitable means of corrosion detection/protection methods

It may not be practicable for existing tanks to meet these requirements because of the high cost of

installing corrosion protection on tanks that are already in the ground. In this case, owners and

operators of existing tanks may wish to more regularly assess the structural integrity of the tanks

to ensure that they are designed and maintained to contain the wastes stored or treated within

them without failing, collapsing, or rupturing. Such assessments should be independently certified

by a qualified, registered, professional engineer.

Tanks should also be integrity tested before use.

7.3

Operational requirements

Storage tanks should be utilized in a manner that minimizes or eliminates releases to the

environment.

• The compatibility of waste streams with construction and seal materials should be

assessed.

• Chemicals that may cause any part of the tankís system to fail may not be used.

• Overfilling of tanks has the potential for spills or releases of waste into the environment

such spills or overflows from the tank system should also be prevented by using, at a

minimum:

o Spill prevention controls, such as suitable and sufficient operational procedures or

valves designed to prevent the backflow of waste during fill-up a tank, or

o Overfill prevention controls, such as alarms that sound when the waste level in the

tank gets too high, and valve systems that automatically close to prevent overfill;

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o Sufficient room within an uncovered tank between the surface of the waste and the

top of the tank (minimum freeboard).

7.4

Inspections

• Owners and operators should inspect their tanks regularly. Inspections should thoroughly

identify leaks, deterioration, corrosion, or structural fatigue in any portion of the tank or

the system components.

• Regular inspections should be documented. Any remedial actions should be included in

the inspection notes along with planned completion dates.

7.5

Leak detection

In addition to visual inspection, owners and operators should also take into account any data

received from leak detection monitors and other tests. Waste tanks should be equipped with

either an active or a passive leak detection system. The leak detection system should be able to

detect failure in either the main tank or secondary containment system generally within 24 hours.

Thermal conductivity sensors, electrical resistivity sensors, and vapor detectors are commonly

used active leak detection devices. Boreholes and wells are examples of passive systems. Daily

visual inspections may also be used where tanks and tank components are physically accessible.

7.6

Release Prevention and Response Plan

In order to eliminate or mitigate the potential impact of any leak, facilities are required to

develop a Release Prevention and Response Plan, which outline the short and long term actions to

be taken to prevent and to mitigate a leak.

The release response may include leak detection system to detect leaks, and secondary

containment devices to contain any leaks that might occur from the tank or ancillary equipment.

All new hazardous waste tank systems should have leak detection and secondary containment

before being placed in service. Existing systems should be equipped with secondary containment.

7.7

Secondary Containment for Tanks

Owners and operators should meet requirements for secondary containment for tanks by using

one of the following secondary containments devices:

o An external liner that completely surrounds the unit with an impermeable material

o A vault (the tank rests in an underground chamber usually constructed with concrete

floors and walls and an impermeable cover)

o A double-walled tank (the tanks is completely enclosed inside another tank with a leak

detection monitoring system installed between the two)

o A government approved alternative design

In addition to the tank itself, ancillary equipment (e.g., pipes, valves, trenches connected to the

tank or tank system) should have full secondary containment. Examples of secondary

containment for ancillary equipment include lined trenches and jacketed or double walled piping.

When inspected daily, however, the following equipment is exempt from this requirement:

o Aboveground piping (not including flanges, joints, valves, and connections)

o Welded flanges welded joints, and welded connection

o Seal-less or magnetic coupling pumps

o Aboveground pressurized piping systems with automatic shut-off devices

Despite these precautions, occasionally leak system or secondary containment will leak or spill

waste. When this happens, the owner / operator should immediately take the tank out of operation

and determine the cause of the release. To prevent the spill moving away from the tank, the tank

owner and operator should also remove and properly dispose of any contaminated soil, ground

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water, or surface water. In addition, the owner / operator should notify the relevant authorities

within the required timeframe. The tank should then either be repaired or replaced.

8.0

LANDFARMING/BIOREMEDIATION TREATMENT PROCESSES

8.1

Definition

Land treatment involves the application of waste on the soil surface, or the incorporation of waste

into the upper layers of the soil in order to degrade transform or immobilize hazardous

constitutions present in hazardous waste.

Land farming is a bioremediation process, which involves the controlled application of waste to

soil and the incorporation of these wastes into the upper soil zone by tilling

Bioremediation involves stimulating naturally occurring bacteria to degrade organic wastes in

soils and groundwater.

8.2

Design standards

Land treatment units facilities should be equipped with controls for minimizing dust and run-off

of leachate to prevent contamination of air, soil, and water.

8.3

Operational requirements

Maintenance of suitable soil pH, careful management of waste application rate and control of

surface water run-off are all keys to the operation of a land treatment unit. The operation

requirements include:

o Controls on the rate and method of waste application (e.g. oily drill cuttings, oil

contaminated soil)

o Measures to control soil acidity.

o Measures to enhance microbial and chemical reactions

o Measures to control the moisture content of the area where wastes are treated.

o Treatment program and demonstration

In order to guarantee that these waste treatment practices should be conducted to properly degrade

the waste, the owners of land treatment units should provide trial data that demonstrates the

efficiency of the technique.

8.4

Monitoring & Inspection

The owner / operator should regularly inspect the treatment area to ensure that the facility is in

compliance with the operating criteria. In addition, owner and operator should establish a soil-

monitoring program (pH, H2O, of bacteria). If there is significant evidence that wastes in the unit

are not responding to treatment, the treatment program should be modified.

A reuse option or a final grave for the bioremediated materials should be identified and should be

achievable.

8.5

Groundwater monitoring

See 12.6

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9.0 SURFACE IMPOUNDMENTS

9.1

Definition

For the purposes of this document this is either a topographic depression, or man made

excavation, that is used to treat, store or dispose of waste. Examples: lined holding ponds, storage

pits, settling lagoons, clay quarry.

9.2

Design Standards

To minimize the potential for leachate to leak from a surface impoundment there are the

following requirements:

• Lining System

• Leachate collection and removal system where appropriate

• Leak detection system where appropriate

• Dikes, berms, and freeboard

• Construction quality assurance

9.3

Monitoring & Inspections

To ensure that the liners and leachate collection and removal system are working properly,

owners and operators of hazardous waste surface impoundment should:

• Inspect liners and dikes or berms for any problems after construction or installation and

continue regular inspections

• Regularly monitor leachate collection and removal system sumps to measure the amount

of liquid in the sump and determine whether the upper liner might be leaking

9.4 Groundwater monitoring

See section 12.6

10.0 INCINERATORS

10.1

Definition

Incinerator is an enclosed device that uses controlled flame combustion. Wastes may be

combusted for various purposes, namely volume and hazard reduction. In recent years wastes are

also increasingly being incinerated to recover energy eg use in specifically designed waste to

energy plants or as a replacement for fuel or raw materials in other industrial processes such as

co-incineration in cement kilns, coke oven, smelting, melting and refining furnace etc. This has

in turn governed the redesign of incinerators to include automatic feed, inline continuous

monitoring systems and secondary burners.

10.2 Permitting

The permit granted by the competent authority for an incineration or co-incineration plant should,

in addition to complying with any applicable requirements as relevant:

• List explicitly the categories & types of waste, which may be treated.

• Contain information on the quantity of waste, where appropriate;

• List the quantities of the different categories of waste which may be treated;

• Include the total waste incinerating or co-incinerating capacity of the plant;

• Specify the sampling and measurement procedures used to satisfy the obligations

imposed for periodic measurements of each air and water pollutants.

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• Specify the minimum and maximum mass flows of those wastes, their lowest and

maximum calorific values and their maximum contents of pollutants, e.g. PCB, PCP,

chlorine, fluorine, sulphur, heavy metals.

• Specify the operating conditions emission limits and risk control measures.

• Describe measures to recover heat generated during incineration as far as practicable e.g.

through combined heat and power, the generating process steam or district heating (where

applicable)

10.2

Operational controls

Incinerators should be designed, equipped and operated in a manner that environmental pollution

prevention in the form of emission limits and management controls are safely met.

• Incineration plants should be operated in order to achieve the maximum level of

incineration possible (fully controlled burning of the waste as per the design

specification)

• Incinerator operators should receive a comprehensive description of any waste before

they can accept it, such as information on the generating processes, information on the

physical and chemical composition of waste and information on hazardous characteristics

of waste.

• The company should regularly monitor certain critical parameters that will ensure

compliance with the performance standards.

These parameters, or operating

requirements, may include:

o Waste feed rates, gas temperatures and residence times, such as 850ºC / 2 seconds

and 1100ºC / 2 seconds for hazardous wastes with greater than 1% homogenate

organic substances (expressed as chlorine), combustion gas velocity, concentration of

oxygen, pressure, water vapour content of the exhaust gas

o Emission limit values for a range of parameters to air such as: NOx, CO, total dust,

TOC, HCl, SO2, heavy metals, dioxin and furans

o Operational control parameters for waste-water at least for pH, temperature, flow,

total suspended solid, dioxin and furan

o Limits on variation of system design and operating procedures

10.3 Monitoring & Inspections

The combustion process and equipment should be monitored and inspected to avoid potential

accidents or incomplete combustion.

Inspections and monitoring requirements include:

• Monitoring the combustion temperature and waste feed rate

• Sampling and analysing the waste and exhaust emissions to verify that the performance

standards established in the permit achieve the operating capability.

• Conducting visual inspections of the combustion unit and its associated equipment

• Testing the emergency feed cut-off system and any associated alarms

• Placing monitoring and inspection data in the operating log

Residues from the combustion of hazardous waste are also potentially hazardous waste (e.g.

heavy metals). The owner/operators should determine if the ash exhibits any hazardous waste

characteristics and classify the waste accordingly.

Ash that exhibits a hazardous

characteristic should be managed as hazardous waste. Depending upon the classification, the

ash residue may be stabilized and reused for an appropriate and approved use. Failing that,

the waste should be disposed of to appropriate landfill.

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11.0 LANDFILL SITES

11.1

Definitions

A landfill is a disposal (ultimate grave) facility where solid hazardous or non hazardous waste is

placed in (landfill) or on the land (landraise).

Leachate is the waste liquid, which comes from the waste. This includes any rain or surface

water, which comes into contact with the waste and is thereby contaminated. Leachate is

potentially hazardous and its characteristics will depend upon the components of the waste.

Landfill gas is gas that is generated by decomposition of organic material at landfill disposal

sites. Landfill gas is approximately 50 percent methane.

11.2 Permitting

The permit granted by the competent authority for a landfill should indicate the following:

• The identity of the applicant and, in some cases, of the operator

• A description of the types and total quantity of waste to be deposited

• The capacity of the disposal site

• A description of the site

• Waste acceptance criteria -WAC

• The proposed methods for pollution prevention and abatement

• The proposed operation, monitoring and control plan

• The future plan for restoration of the site.

11.3 Design Standards

To prevent or reduce the adverse effects of landfilling of waste on the environment, in particular

on surface water, groundwater, soil, air and human health, there are design standards:

• An engineered lining system for the base, side and capping of the landfill to include either

/ and a combination of natural eg clay and manmade eg. plastic (HDPE) materials

• Leachate and gas collection and removal systems where appropriate

• Leak detection systems as appropriate

• Construction quality assurance by experienced personnel

• Monitoring systems for gas and leachates eg a system of monitoring boreholes

• Run-on, run-off, controls

• Litter, dust, pest and vermin controls

11.4 Operational Controls

• Waste should be treated before being landfilled

• Hazardous waste that is landfilled should be disposed only at a hazardous waste landfill

• Liquid waste; flammable waste; explosive or oxidising waste; hospital and other clinical

waste which is infectious; used tyres, with certain exceptions should not be landfilled.

• Regularly (eg monthly) monitor & measure the amount and quality of leachate from

predetermined locations of the landfill

• Appropriate measures should be taken in order to control the accumulation and migration

of landfill gas (if produced)

• Potential for dust measurement if located near to dwellings

• Daily covering of wastes to reduce odor & vector issues

11.5 Inspections & Monitoring

To ensure that the liner and leachate collection and removal systems are working properly landfill

owners and operators should:

• Provide detailed independent QA throughout liner installation

• Continue regular monitoring for evidence of deterioration or damage throughout the life

and aftercare of the facility

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11.6 Groundwater monitoring

The treatment, storage, or disposal of waste directly on the land has the potential to generate

leachate that can carry hazardous contaminants into the environment. Such contaminants can pose

a serious threat to ground water resources and in-situ geology. This makes groundwater

monitoring an important component of the ongoing monitoring regime for waste facilities.

• Land based treatment storage or disposal facilities (land treatment areas, landfills, surface

storage areas and waste piles) should perform baseline monitoring and ongoing

operational monitoring of the groundwater under the facilities to ensure that the waste

management activities are not causing contamination of the groundwater.

• Land based facilities should install monitoring wells to detect contamination in the

perched aquifers and the primary underlying groundwater resource. In order to ensure that

the information received from the monitoring is accurate, facilities should develop a

ground water monitoring program in consideration of the following points:

• Enough wells installed in the right places to accurately represent the ground water activity

and characteristics under the facility

• Properly installed monitoring wells, i.e. cased, for long term use

o Consistent regular sampling and analysis procedures eg quarterly sampling and

analyses of groundwater

o Accurate records of information collected and data analyses

12.

OTHER FACILITY SITES

Other types of waste facility may exist that is different to those previously described. In these

cases, the facility should comply with the general principles for all facilities (where relevant) as a

minimum. Further information can also be obtained from the BP Central HSE Environmental

Team.

Best Practice Guidance For Waste Management for Waste Transportation, Storage, Treatment and Disposal

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Attachment 2 Waste Identification Label

WASTE IDENTIFICATION LABEL

TULLANTININ TƏSVIRI ETIKETI

Do you want to have someplace here where they need to indicate if waste is hazardous or not?

Waste type

Tullantinin Nˆv¸

Waste Category

Tullantının kateqoriyası

Waste amount (by wt or vol)

Tullantilarin miqdari (Áəki və ya həcm)

Known hazards (use msds)

Məlum təhl¸kələr

(materialin təhl¸kəsizlik pasportundan istifadə

olunmalidir)

Point of origin of waste

Tullantilarin yarandiği yer

Date received

Qəbul edilmə tarixi

Contact name and tel no.

Əlaqə saxlanmali şəxsin adi və telefon nˆmrəsi

LABEL TO BE FULLY COMPLETED AND AFFIXED TO OUTSIDE OF INDIVIDUAL

WASTE CONTAINER IF NOT IN ORIGINAL PACKING

ILK BAĞLAMADA TULLANTI HAQQINDA MƏLUMAT OLMADIĞI HALDA ETIKET TAM

ŞƏKILDƏ YAZILIB DOLDURULMALI VƏ HƏR BIR KONTEYNERIN BAYIR TƏRƏFINƏ

YAPIŞDIRILMALIDIR

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Attachment 4 Waste Transfer Note

WASTE TRANSFER NOTE

TULLANTILARIN TƏHVIL VERILMƏSI HAQQINDA QƏBZ

Skip number:

Reference No:

Badyanın nˆmrəsi:

Qeydiyyat nˆmrəsi:

1.WASTE DESCRIPTION. Describe fully the nature and quantity of each type of waste.

Attach additional sheets if necessary. Specify the containers used to hold the waste during

transportation.

1.TULLANTILARIN TƏSVİRİ. Hər bir tullantının nˆv¸n¸ və miqdarını tam şəkildə təsvir

edin. Ehtiyac olduğu halda əlavə vərəq qoşun. Daşınma prosesində tullantıların saxlanılması

¸Á¸n istifadə olunan konteynerin nˆv¸n¸ gˆstərin.

2.GENERATORíS DETAILS

2.TULLANTILARIN YARANMA MƏNBƏYI HAQQINDA

MƏLUMAT

Department (Production/Drilling/Pipeline, etc)

Şˆbə (Hasilat/Qazma/Boru kəməri və s.)

Facility/Site Location

Obyektin/sahənin yeri

Name and signature of responsible person

Məsul şəxsin adı və imzası

Contact number

Əlaqə telefon nˆmrəsi

TRANSPORTERíS DETAILS

DAŞIYAN HAQQINDA MƏLUMAT

Destination of shipment

«atdırılmalı məntəqə

Date of shipment

Daşınma tarixi

Name and signature of Transporter

Daşıyanın adı və imzası

Contact number

Əlaqə telefon nˆmrəsi

RECEIVERíS DETAILS

Qəbul edən haqqında məlumat

Name of facility

Obyektin adı

Date received

Qəbul edildiyi tarix

Name and signature of waste recipient

Tullantıları qəbul edənin adı və imzası

Contact number

Əlaqə telefon nˆmrəsi

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One transfer note is required to accompany each consignment of waste

Tullantilarin hər bir partiyasi ¸Á¸n təhvilverilmə haqqinda qəbzin bir n¸sxəsi tələb olunur

White copy to be completed and retained by the generator of the waste

Pink copy to be completed and retained by the transporters of the waste

Qəbzin Áəhrayı rəngli surəti doldurularaq tullantıları daşıyan şəxsdə saxlanılır

Qəbzin ağ rəngli surəti doldurularaq tullantını yaradan şəxsdə saxlanılır

Green copy to be completed and retained by the receiver of the waste

Qəbzin yaşıl rəngli surəti doldurularaq tullantıları qəbul edən şəxsdə saxlanılır.

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Attachment 5 Summary of Current Azeri Waste Management Legislation

Type

Legisl

Reference

ation

Subject

No.

Date

PDF

Presidential Laws

June 30,

Law

Industrial and Domestic Wastes

514-IQ

1998

Accesion of the Azerbaijan

Republic to the Basel Convension

of the United Nations

Organisation on the Control of

Transboundaty Movements of

Hazardous Wastes

Law

and Their Disposal

80-IIQ

Resolutions of the Cabinet of Ministers

Rules of issue of passports for

Resolut

hazardous

Resolution March 31,

ion

wastes

041

2003

..\..\Info &

Refs\Legislation\Aze

Types of Enterprises, Which Are

ri Legislation\ReCab

Resolut

Not Allowed to

Resolution

July 31,122-July 31-

ion

Drain (Discharge) Industrial Wastes

122

..\..\Info &

Refs\Legislation\Aze

Resolut

On Approval of the Rules of Road

Resolution January 27,

ri Legislation\ReCab

ion

Carriage of Dangerous Cargoes

010

On approval of Rules

..\..\Info &

of Issue of Special Permission

Refs\Legislation\Aze

(License) for Production and

ri Legislation\ReCab

Resolut

Allocation of Industrial

ResolutionDecember 6,217-Dec 06-

ion

Wastes

217

On approval of Rules of Issue

of Special Permission (License) for

Production, Industrial Use,

..\..\Info &

Storage, Re-circulation and

Refs\Legislation\Aze

Neutralisation of Ozone Depleting

ri Legislation\ReCab

Resolut

Substances and Products

ResolutionDecember 6,218-Dec 06-

ion

Containing Such Substances

218

"Legislation

Subject

Dir No.

Title

Web

PDF

Framework waste legislation

comm/environment/

Refs\Legislati

waste/legislation/a.h

on\EU

Waste Framework

75/442/EEC

Council Directive

Legislation\P

Refs\Legislati

on\EU

Hazardous waste

91/689/EEC

Council Directive

Legislation\P

Refs\Legislati

on\EU

List of wastes

2000/532/EC

Comission Decision

Legislation\P

Refs\Legislati

on\EU

Amendment to the list of wastes

2001/573/EEC

Council Decision

Legislation\P

Control of transboundary movements of hazardous wastes and their

disposal (Basel Convention)

93/98/EEC

Council Decision

European Union legislation on waste management operations

http://europa.eu.int/

..\..\Info &

comm/environment/

Refs\Legislati

Landfilling

1999/31/EC

Council Directive

waste/legislation/b.h

on\EU

..\..\Info &

Council and Parliament

Refs\Legislati

Incineration (of waste)

2000/76/EC

Directive

on\EU

..\..\Info &

Port-reception facilities for

Council and Parliament

Refs\Legislati

ship-generated waste and cargo residues

2000/59/EC

Directive

on\EU

European Union legislation on specific waste streams

http://europa.eu.int/

comm/environment/

Disposal of waste oils

75/439/EEC

Council Directive

waste/legislation/c.h

..\..\Info &

Refs\Legislati

Waste from the titanium dioxide industry

78/176/EEC

Council Directive

on\EU

..\..\Info &

Refs\Legislati

Batteries and accumulators containing dangerous substances

91/157/EEC

Council Directive

on\EU

..\..\Info &

Council and Parliament

Refs\Legislati

Packaging and packaging waste

94/62/EC

Directive

on\EU

Disposal of PCBs and PCTs

96/59/EC

Council Directive

Other in/directly related EU legislation

comm/environment/

Refs\Legislati

Approximation of the laws, regulations and administrative provisions of

waste/legislation/e.h

on\EU

the Member States

Legislation\P

relating to restrictions on the marketing and use of certain dangerous

DF files\CoDi

substances and preparations

76/769/EEC)

Council Directive

76-769-

eu.int/eur-

lex/en/consle

Protection of groundwater against pollution caused by certain

g/pdf/1980/e

dangerous

n_1980L0068

substances

80/68/EEC

Council Directive

Refs\Legislati

on\EU

Legislation\P

Assessment of the effects of certain public and private projects on the

DF files\CoDi

environment

85/337/EEC

Council Directive

85-337-

Refs\Legislati

on\EU

Legislation\P

DF files\CoDi

Urban waste-water treatment

91/271/EEC

Council Directive

91-271-

Refs\Legislati

on\EU

Legislation\P

DF files\CoDi

Integrated pollution prevention and control

96/61/EC

Council Directive

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Attachment 6 Summary of Current Georgian Waste Management Legislation

The Law On Protection Of The Environment (1996) is a framework law regulating legal

relationships between the state authorities and physical bodies and legal entities (irrespective

of ownership and organizational-legal forms) in the field of environmental protection and use

of natural resources. It also forms the basis for the review and development of environmental

legislation. It sets overall objectives for environmental protection and provides guiding

principles and instruments to achieve the set objectives. This law defines the rights and

obligations of the individual; delineates the competence of government agencies and sets out

criteria for delineation of the areas of competence between local and central authorities in the

protection of environment. The law obliges industrial facilities to undertake integrated control

and monitoring of environmental pollution.

One of the key requirements of the law applicable to industrial facilities is the development

and coordination of emergency response plans with relevant authorities. The law transfers

environmental commitments of the former owner of a facility to a new one. Another major

requirement set by this law is that any industrial or commercial activity should procure an

environmental permit from the relevant government agency and licences for utilisation of

natural resources such as: land, water, forest, flora, fauna and minerals.

The law defines guiding principles for all parties involved in planning and implementing

activities:

Risk Reduction: a developer / proponent of an activity is obligated to implement all relevant

measures to minimise or eliminate the risk of damage to human health or the environment

Sustainability: utilization of the environment and natural resources that does not pose any

threat to community development and ensures protection of the environment and natural

resources from irreversible quantitative and qualitative changes

Priority: an activity that affects the environment or human health should be replaced with a

lower risk option, even if it is more expensive. Preference should be given to the latter if its

cost is lower than that for compensation of damage inflicted to the environment by the lower-

cost option

User pays: users should pay for utilisation of natural resources (land, water, forest, flora,

fauna, mineral resources, etc.)

Polluter pays: polluters should bear the costs associated with the damage to the environment;

Preservation of biodiversity: activities should not lead to irreversible degradation of

biodiversity

Waste minimisation: priority is given to technologies that minimise waste generation

Recycling: priority is given to substances, materials and chemicals, which are biodegradable,

degrade without harm to environment or can be recycled

Reinstatement: any component of the environment degraded by an activity should be

reinstated to the condition as close as possible to that before the activity

Environmental Impact Assessment: a developer should take into consideration and assess

potential impacts associated with the proposed activity or development at the design or

planning stage in accordance with applicable legal requirements

Public participation in decision-making: public participation should be ensured in decision-

making related to important aspects of the planned activity

Access to information: environmental information should be accessible to the public.

The law sets out specific requirements in relation to waste disposal practices (Chapter 9), in

particular:

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The developer should ensure minimisation, treatment to acceptable standards, recycling /

recovery, disposal of industrial, domestic / household and other types of waste in accordance

with environmental, sanitary-hygiene and epidemiological standards and procedures

Disposal of household and industrial waste is permissible at specially defined places in

accordance with environmental, sanitary-hygiene and epidemiological standards and

procedures

Disposal of toxic, radioactive and other types of hazardous waste is permissible at specially

defined and engineered places in accordance with environmental, sanitary-hygiene and

epidemiological standards and procedures

No waste can be disposed in the sea or other water bodies.

The Law Of Georgia On Environmental Permit (1996) describes an environmental permit

application and acquisition process. It also provides classification of proposed activities into

four categories and defines different requirements by categories. This law classifies all

activities related to waste handling and disposal (in particular, disposal of household and

industrial waste, site selection and operation of non-hazardous landfills and incinerators;

disposal of toxic, hazardous and radioactive waste, its treatment and site selection and

operation of hazardous waste) as Category I, which requires a full scale EIA (Article 4).

A new edition of the Law Of Georgia On Transit And Import Of Waste In Georgia (1995)

was adopted in 1997. Article 2 of the law states that the following is banned on the entire

territory of Georgia:

Transit and import of hazardous (including toxic) and radioactive industrial, household and

other types of waste for further utilization, treatment, disposal or any other purpose (including

waste disposal operations listed in Appendix 4 of the Basel Convention)

Import of non-hazardous (including non-toxic) and non-radioactive industrial, household and

other types of waste for further treatment, disposal or any other purpose (including waste

disposal operations of group "F" listed in Appendix 4 of the Basel Convention).

Law Of Georgia On Obligation To Compensate For Harm Caused By Hazardous Substances

(1999) provides for obligatory compensation of damage inflicted by contamination with

hazardous substances. Compensation liability is assigned to a responsible entity, which is

defined as an entity polluting the environment with hazardous substance as a result of

production, treatment, storage, transportation, utilization or disposal of a hazardous substance

(separately or together with other substances); or as an entity that owns or controls a

hazardous substance; or as an entity, which produces, treats, stores, transports, uses or

disposes a hazardous substance on behalf of another entity.

A4.3 SNIP Standards

These Russian standards and rules (SNIP 2.01.28-85) are applicable to the design of facilities

for the neutralisation of hazardous waste and hazardous landfills. They do not apply to the

design of landfills for radioactive, solid domestic and non-toxic industrial wastes. The

standards were approved by Resolution No. 98, dated 26/06/1985, of the State Construction

Agency of USSR.

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Table A4.1: Applicable Waste Management Legislation

Applicable EU Waste Legislation

European Community (EC) Framework Directive on waste (91/156/EEC) Annex I

EC Directives 75/442/EEC and 91/156/EEC and other relevant EC standards for waste

management

EC Directive 1999/31/EEC Landfill

EC Directive 1991/689/EEC on hazardous waste

EC Directive 2000/76/EC on Waste Incineration

EC Directive 1986/278/EEC on Disposal of treated sewage on agricultural land

EC Directive 91/689/EEC Hazardous waste classification: Article 1(4)

Directive 75/439/EEC on Disposal of waste oil

EC Regulation 259/93 on Supervision and control of shipments of waste

World Bank Standards

(As default for wastewater treatment facilities, if no other standards specified)

United States Export Import Bank (US Ex-Im) standards

Project -specific standards for sewage, oily water treatment and wastewater discharges to

water

European standards for waste management

EC Directive 85/337/EEC

Georgian Legislation

Law of Georgia Regulation - "Instruction on Protection of Atmosphere During the Operation

of Landfill Sites", October 23, 2001

National Legislation - "Law on Transportation of Hazardous Wastes", 1998

National Legislation - "Law on Hazardous Chemicals and Law on Pesticides and

Agrochemicals", 1998

National Legislation - "On Compensation of Damage Caused from Hazardous Substances",

1999

Source: Legal register developed as part of the Georgian ESIA Draft for Disclosure

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A4.5 Guidelines and International Best Practice

The World Bank Pollution Prevention and Abatement Handbook (1998) contains detailed

guidelines regarding minimization of the use of resources as well as reduction of the quantity

of wastes requiring treatment and disposal. They are designed to protect human health, reduce

discharges of pollutants into the environment, use commercially proven and cost-effective

technologies, follow regulatory trends, and promote good industrial and environmental

management practices.

Other relevant guidelines include:

IFC Hazardous Materials Management Guidelines, December 2001

World Bank Guidelines for Oil & Gas Developments (Onshore)

ExIm Environmental Procedures and Guidelines, April 2001

E&P Forum Waste Management Guidelines, September 1993.

Best Available Technology (BAT) principles should apply.

AzSPU Chemical and Hazardous Materials Management Procedure

Page 2 of 24

1.0 Purpose / Scope

This procedure defines the Azerbaijan Strategic Performance Unit (AzSPU) requirements for

chemical and hazardous materials management and provides guidance to Operating

Areas/Facilities on the management of chemicals and hazardous materials to ensure that:

 Risks to personnel, public, environment and installations associated with selection,

procurement, transportation, storage and disposal of chemicals and hazardous

materials are comprehensively assessed in accordance with BP Corporate policies,

AzSPU guidelines and International Standards;

 A formal and consistent management system which documents all aspects of

chemical and hazardous material management is established and implemented across

the AzSPU.

This procedure takes account of the AzSPU commitments related to the management of

chemicals and hazardous materials as defined in the AzSPU Compliance Task Manager

(CTM) database.

This procedure applies to Operating Areas/Facilities within the AzSPU. The scope of the

procedure includes both onshore and offshore operational activities undertaken by BP and

contractors, including drilling.

Detailed guidance is provided with respect to the following processes:

 HSE assessment of products during selection;

 Product receipt, storage and handling requirements;

 Training requirements;

 Inspection and audit requirements;

 Record keeping.

Other aspects of chemical and hazardous material management, such as logistics, waste and

residual material disposal are not considered in detail in this document. General guidance and

specific procedures are referenced, as applicable.

For the purposes of this document, the terms "chemicals" and "hazardous materials" are not

mutually exclusive.

2.0 Definitions / Abbreviations

ALARP

As low as reasonably practicable

AzSPU

Azerbaijan Strategic Performance Unit

CAM

Contract Accountable Manager

Carcinogenic Substances and preparations which, if they are inhaled or ingested or if they

penetrate the skin, may induce cancer or increase its incidence

Chemicals

Any solids, liquids or gases which are used in the production process or in any

ancillary supporting activity, e.g. cleaning, transportation, etc

Control Tier:

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Corrosive

Substances and preparations which may destroy living tissue on contact

COSHH

Control of Substances Hazardous to Health

ERA

Environmental Risk Assessment

ESAP

Environmental and Social Action Plan

ESIA

Environmental and Social Impact Assessment

Explosive

Substances and preparations which may explode under the effect of flame, or

which are more sensitive to shocks or friction than dinitrobenzene

Flammable

Liquid substances and preparations having a flash point equal to or greater

than 21ºC and less than or equal to 55ºC

Harmful

Substances and preparations which, if they are inhaled or ingested or if they

penetrate the skin, may involve limited health risks

Hazardous

The definition of hazardous materials under EEC Directive 91/156/EEC is:

materials

“any substance which has the following potential properties: explosive,

oxidising, highly flammable or flammable, irritant, toxic, carcinogenic,

corrosive, infectious, teratogenic, mutagenic; substances which release toxic

or very toxic gases in contact with air, water or acid; substances which are

capable after disposal of producing another substance, and ecotoxic

substances”

HSE

Health, Safety and Environment

IMDG

International Maritime Dangerous Goods

MOC

Management of Change

Mutagenic

Agent capable of producing a mutation, i.e. permanent change in the genetic

material of cells

MSDS

Material Safety Data Sheet

OCNS

Offshore Chemical Notification Scheme

OGUK

Oil & Gas UK (previously UKOOA - United Kingdom Offshore Operations

Association)

OSHA

Occupational Safety and Health Act

OSPAR

Convention for Protection of Marine Environment of North-East Atlantic

PLONOR

OSPAR List of Substances / Preparations which are considered to pose little

or no risk to the environment

PPE

Personal protective equipment

CTM

Compliance Task Manager (database)

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PSA

Production Sharing Agreement

Performance Unit

SCM

Supply Chain Management

Teratogenic Substances and preparations which, if they are inhaled or ingested or if they

penetrate the skin, may induce non-hereditary congenital malformations or

increase their incidence

Toxic

Substances and preparations which, if they are inhaled or ingested or if they

penetrate the skin, may involve serious, acute or chronic health risks or even

death

Waste

Materials produced during operational activities, which are of no use, or value

to the process that generated it

3.0 Specific Requirements

Chemical and hazardous materials management shall be compliant with commitments made

in the Production Sharing Agreements (PSA), Host Government Agreements, Environmental

and Social Impact Assessments (ESIA), relevant Environmental and Social Action Plans

(ESAP), together with any subsequent commitments to, or agreements with, the lenders

and/or local governments. These are summarised in the AzSPU CTM database and shall be

taken into consideration when developing Operating Area/Facility specific procedures

instructions.

The following internationally recognized / adopted standards and legislation specific to

hazardous materials management shall apply as a minimum:

Health and safety assessment

 Control of Substances Hazardous to Health Regulations 2002 (COSHH);

 Occupational Safety and Health Act (OSHA), 29 U.S.C. 651 et seq. (1970);

 International Finance Corporation, Environmental, Health and Safety Guidelines,

“Hazardous Materials Management Guidelines”, Dec 2001.

Classification and labelling

 Globally Harmonized System for Hazard Classification and Labelling (GHS) Feb

2006;

 Proposal for the Chemicals

(Hazard Information and Packaging for Supply)

Regulations 2002: CHIP 3;

 International Maritime Dangerous Goods (IMDG) Code, May 2004;

 Guidelines to the Safe Packing and Handling of Cargo to and from Offshore

Locations (UKOOA/OGUK), Issue 2- Nov 2002;

 ISO 11014 - 1:1994. Safety Data Sheet for Chemical Products - Part 1: Content and

Order of Sections.

Chemical acceptability

 Stockholm Convention on Persistent Organic Pollutants (2003);

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 Vienna Convention on the Protection of the Ozone Layer (1985);

 For drilling, production and utility chemicals:

OSPAR PLONOR list (acceptable candidate chemicals);

OSPAR list I and II and chemicals subject to OSPAR decisions on phasing

out or prohibition (unacceptable candidate chemicals);

Chemicals which have passed the OSPAR pre-screening process

(e.g.

chemicals on the UK OCNS ranked list) (acceptable candidate chemicals).

Conventions, codes and regulations referenced above may change over time. AzSPU Safety

& Compliance Systems Manager shall ensure that a formal centralized process to track any

relevant changes is established, and that relevant Operating Area/Facility managers are

informed of the latest valid published versions. When a valid change is notified, all dependent

documentation must be reviewed and (where necessary) revised to ensure that it continues to

comply with the intent of the originating organisation.

National requirements may be no more stringent than the international standards adopted in

this Procedure. However, Operating Area/Facility HSE Managers shall be aware of the

possible need to conform to national legislation as well as to AzSPU procedures. If

compliance requirements are not clear, the AzSPU Safety & Compliance Systems Manager

shall be consulted for formal guidance.

4.0 Key Responsibilities

Offshore and Midstream HSE Managers

 Accountable for the effective implementation of this procedure within their respective

areas of responsibility.

 In collaboration with Operations Management to ensure that the necessary and

competent resources are deployed to effectively implement this procedure.

AzSPU Hazardous Materials TA

The AzSPU Hazardous Materials TA is the custodian of this document and shall ensure that:

 The requirements of this procedure are communicated and implemented within

AzSPU.

 This procedure is audited holistically on an annual basis.

 Regulatory requirements, both national and international, pertaining to chemical and

hazardous material management, as well as any changes to relevant legislation and

standards, are identified and communicated to Facilities/Operating Areas.

AzSPU Environment Manager

The AzSPU Environment Manager has overall responsibility for the AzSPU Environmental

Risk Assessment (ERA) Procedure (AzSPU-HSSE-DOC-00120-2) and shall ensure that:

 The requirements of the procedure are communicated and implemented within

AzSPU;

 The entire chain of the procedure is audited holistically on an annual basis.

 Ensuring that the AzSPU Environmental Risk Assessment (ERA) Procedure (AzSPU-

HSSE-DOC-00120-2) is in current revision and communicated to the AzSPU.

AzSPU Supply Chain Manager

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The AzSPU Supply Chain Manager shall ensure that:

 Material Safety Datasheet (MSDS) and other relevant requirements, as defined in this

procedure, are included in the Suppliers Contracts / Purchase Orders.

 Suppliers are contractually obliged to comply with the internationally recognized

standards and regulations for transportation, packaging and labeling.

 Technical support is obtained from Facility/Operating Area or AzSPU representatives

at the contract agreement stage.

Facility/Operating Area HSE Manager

Facility/Operating Area HSE Managers or delegates shall ensure that:

 The AzSPU Environmental Risk Assessment (ERA) Procedure (AzSPU-HSSE-DOC-

00120-2) is implemented on site.

 COSHH risk assessment and COSHHnet tool is implemented and operational within

the Operating Area/Facility (see Appendix 1).

 Site specific hazardous materials management procedures / instructions are developed

and are regularly reviewed and updated to ensure that they are consistent with each

other and the information contained in this procedure.

 Relevant training requirements are identified, and regular and timely training is

provided to Operating Area/Facility staff and contractors involved in the management

of chemicals and hazardous materials.

 Documented task-based risk assessments are undertaken.

 The introduction of new chemicals, or substitution of existing chemicals, on site are

approved.

 Inspections and audits of site based activities are scheduled and are carried out.

 Site specific inventory and relevant records are maintained.

AzSPU Health Team Industrial Hygienist

 Provides technical support, guidance and advice, as requested, on all aspects of

chemicals exposure assessment and control.

 Assists relevant site HSE personnel in completing IH technical tasks such as chemical

assessments and exposure monitoring.

 Monitors published occupation exposure limits, specifically those of the UK HSE and

US ACGIH.

 Communicates exposure limits to site HSE personnel.

 Administers the AzSPU MSDS Database (DOLPHIN).

 As part of the chemical MoC process, completes new chemical evaluations and

approves acceptable products.

 Advises on appropriate PPE for protection against chemical hazards.

 Provides advice to the Training Team regarding chemicals awareness/COSHH

training.

 Advises site H&S staff in identifying personnel for medical surveillance programs.

AzSPU HSE Compliance Advisor

 Manages identification and accurate interpretation of legal and other requirements (in

consultation with the legal department).

 Monitors changes to legal and other requirements.

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 Ensures communication of new, or changed, legal and other requirements to affected

parties involved in chemicals management or chemicals selection.

Persons Responsible for Selection

AzSPU HSE&TD (representatives from AzSPU central Health, Safety and Engineering

Teams and representatives from Supply Chin Management) shall be responsible for:

 The consideration of HSE implications during the selection of new drilling fluids and

process chemicals prior to use on BP-operated sites.

 Ensuring the distribution and availability of master copies of all MSDS Manuals for

mud, cementing and well service chemicals.

 Ensuring incorporation of all current MSDS into Dolphin electronic database.

All persons, including contractors, responsible for the selection of chemicals and hazardous

materials shall ensure that:

 HSE evaluation is undertaken during selection stage

(prior to purchasing) in

accordance with the requirements of this procedure;

 Operating Area/Facility HSE

/ or H&S Advisors are consulted on HSE risk

assessment issues and sign off final document for selection process.

Facility/Operating Area Operations Manager

Facility/Operating Area Operations Manager shall be responsible for ensuring that:

 Only approved chemicals are used on site.

 Chemicals and hazardous materials are stored and handled in accordance with the

requirements of this procedure.

 Discharge to the environment of effluent containing chemicals will not take place

without a) a comprehensive risk assessment and b) formal approval and consent from

the relevant regulatory authorities.

 Training requirements are correctly and formally defined, and that training is

provided by qualified and certified personnel.

AzSPU Contractor HSE Specialist

The AzSPU Contractor HSE Specialist shall

 Liaise with the HazMat TA and Health Team Industrial Hygienist and SCM Category

Managers to identify appropriate requirements for the safe management of HazMat,

as this relates to contractors and suppliers.

 Ensure that the requirements of this procedure are communicated to SCM Category

Managers for incorporation, as applicable, in Suppliers‟ Contracts/Purchase Orders.

 Schedule and oversee contractor audits that include verification of contractors‟

compliance with the applicable requirements of this procedure.

5.0 Procedure / Process

The procedures outlined below are the minimum requirements to be put in place to eliminate,

or minimize to as low as reasonably practicable (ALARP), any potential negative impacts

resulting from the use of chemicals and hazardous materials and to meet legal and other

requirements.

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The introduction of a new chemical, the replacement of an existing chemical, a change in

composition of an existing chemical, and a change in use of an existing chemical are all

required to go through the Chemical MoC process. This is described in detail in the AzSPU

Management of Change Procedure (AzSPU-GEN-PRC-001-007), which can be accessed

through the e-MoC system.

5.1 HSE Assessment during Materials Selection

During the selection process, the responsible persons shall ensure that all candidate materials

undergo HSE assessment. Such assessment will form the basis of:

 Final product selection.

 Definition and implementation of appropriate mitigation measures.

The materials can only be procured upon satisfactory completion of the HSE assessment, as

detailed below.

A common selection process shall operate across the AzSPU, applying to all Operating

Areas/Facilities and contractors, and covering:

 Production, drilling and utility chemicals.

 Laboratory, catering and cleaning chemicals.

 Emergency response chemicals (e.g. fire fighting, spill clean-up).

HSE assessment, as described in the sections below, shall be applied to all chemicals,

irrespective of their purpose or origin. If the full required data set required for the assessment

is not available for locally-available chemicals, Operating Areas/Facilities and Contractors are

required to consult the relevant HSE /or H&S Advisor before proceeding with procurement.

The selection and assessment procedures implemented by contractors shall be audited against

AzSPU requirements.

5.1.1 Generic Health and Safety Assessment

Generic health and safety assessment during the selection stage shall be based on the product

MSDS, available data on generic assessments undertaken in accordance with the

internationally recognized systems, e.g. COSHH, OSHA, as well as any information on

ecotoxicity and known environmental impacts of the product.

The assessment shall determine the following, as a minimum:

 That a carrier is identified with all necessary licences, permits and approvals for the

transportation of the relevant class of product from the country of origin to the

country of destination.

 That existing storage and containment facilities are adequate for the planned

quantities of product (or that storage and containment needs are identified and the

resources to create these are allocated) and that incompatible chemicals are

segregated.

 That personnel exposure risk, associated training needs and personnel protective

equipment (PPE) requirements are clearly identified and available.

 That spill contingency requirements and equipment are identified and available.

 That disposal routes are available for any unused product, waste or reacted product,

waste streams containing chemical or chemical residues.

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5.1.2 Environmental Risk Assessment

Chemicals that will be discharged into the environment as part of planned operations require

regulatory approval. Where the discharge of chemicals into the environment is planned and

unavoidable, persons responsible for the selection shall ensure that:

 Products least harmful to the environment are selected; and

 The choice is validated by means of comprehensive Environmental Risk Assessment

(ERA).

Detailed environmental risk assessment shall not normally be required for chemicals used in

processes that will not result in a discharge to the environment. However, such assessment

might be required when the risk of environmental damage is high due to potential spill

resulting from loss of containment, e.g. during transportation of large volumes of highly toxic

materials to offshore locations. Persons responsible for the selection of chemicals shall liaise

with the Operating Area/Facility Environmental Advisor for the advice on the need for an

ERA.

Detailed guidance on the Environmental Risk Assessment and the approval process is

provided in the AzSPU Environmental Risk Assessment (ERA) Procedure (AzSPU-HSSE-

DOC-00120-2).

5.2 Procurement

Specific to procurement of chemicals and hazardous materials, the supplier shall provide the

following information with the delivery of the materials:

 Full details of the Supplier/Manufacturer.

 Complete MSDS. Chemical products supplied from within the EU member states

should be provided with MSDS compliant with ISO 11014 requirements, as a

minimum.

 Information on chemical composition, ecotoxicity and known environmental impacts

of the product in addition to that included in MSDS. This information is mandatory

for any chemical for which environmental risk assessment is required. Where

necessary, BP and/or its contractors should offer the supplier a formal confidentiality

agreement in order to secure this information. Failure of disclosure may prevent

completion of the assessment and approval process.

The Suppliers shall ensure that the containers and packaging are labelled in accordance with

the recognized international standards and regulations, and are in good condition.

The AzSPU SCM Manager shall ensure that the requirements above shall be included in

suppliers contracts or purchase orders, as appropriate.

5.3 Task-Based Risk Assessment

Once the product is procured, a specific task-based risk assessment shall be conducted by

personnel/working group involved into the chemicals utilisation process (e.g. site controller,

maintenance, operations technicians, HSE advisors, etc.) prior to the delivery of the product

to the operational site.

A task-based risk assessment shall be undertaken for each separate use, or application of the

product. Internationally recognised systems, e.g. COSHH, or tools such as COSHHnet shall

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be used, as directed by AzSPU HSE&TD. All task-based risk assessments shall be

documented and authorized.

The HSE Advisor undertaking the task-based risk assessment shall be trained and qualified in

COSHH. Instructions to personnel on the implementation of the COSHH Regulations and the

COSHH Approved Code of Practice are provided in Appendix 1.

5.4 Transportation, Delivery and Receipt

Transportation of chemicals and hazardous materials to the operating sites shall be in

compliance with:

 National regulatory requirements including all relevant permits and approvals.

 Recognised international standards and regulations.

 Relevant BP requirements.

Upon the delivery of hazardous materials to the operating sites, and prior to offloading, cargo

documentation, i.e. delivery note and MSDS, shall be checked and visual inspection of the

cargo undertaken to ensure that:

 Containers / sacks / pallets are free from rust, dents and puncture marks that would

endanger integrity of the container;

 Containers are delivered in pallets and/or cages; and

 Containers / sacks / pallets are clearly labelled.

In the event of a non-compliance the site HSE Advisor shall make judgement on whether to

return the product to the supplier (e.g. unidentified container, lack of MSDS, etc), or to

quarantine the product for safe temporary storage (e.g. damaged container).

The placement of products in a quarantine area is an emergency provision, intended only to

minimise „unknown‟ risks while uncertainties are resolved. The resolution of uncertainties

should therefore be pursued with urgency, to minimise the risk that two or more „unknown‟

(and therefore potentially incompatible) materials might be placed concurrently in the same

quarantine area.

Quarantine areas should not be used for planned or deliberate part of any procurement

process. The use of quarantine areas should be monitored regularly, to ensure that

procurement processes are improved where necessary.

All deliveries and offloading of chemicals and hazardous materials shall be recorded and

supervised at all times. Delivery note records shall be kept on site.

5.5 Storage

Chemicals and hazardous materials shall be stored in purpose-built and specifically

designated locations. Such locations shall be shown on the site map. The key design

principles for storage locations are as follows:

 Segregation: care shall be taken to establish the compatibility of each chemical.

Incompatible chemicals must not be stored together and shall be separated by

sufficient distance and physical barriers as required by their characteristics

(see

compatibility chart in Appendix 2).

 Containment: each segregated storage area shall have an impermeable bund to ensure

secondary containment of 110% of the largest vessel volume. There must be no

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connection between bunded areas for incompatible categories of material. If due to

operational constraints the establishment of an impermeable bund is not possible,

then the storage area must be segregated and served by a drain system with no

discharge to the environment. Secondary containment of individual chemicals /

hazardous materials can also be provided by double skinned tanks, providing that the

outer skin can contain 110% of the tank contents.



All chemicals and materials shall be stored in containers of a compatible material and

construction.



All containers

/ sacks

/ pallets shall be labelled in accordance with recognised

international standards and regulations in English. An example of a label is shown in

Appendix 3. Container / sack / pallet condition, clarity and legibility of labels shall be

regularly checked and assured.



Appropriate spill response and clean-up equipment for all inventory materials shall be

maintained and available.



Containers

/ sacks

/ pallets shall be protected from excess temperature and

precipitation in accordance with the requirements of the chemical and container

suppliers defined in the MSDS or any other relevant documentation.



Storage areas shall be accessible only by vehicles directly engaged in handling the

materials present in the areas. Care shall be taken to minimise the risk of accidental

damage to containers / sacks / pallets by general traffic.



Access to storage areas shall be restricted to authorised personnel only.



Storage areas shall be signposted in English and local language. The signs shall be

clearly visible and have internationally recognised symbols describing the PPE

requirements for personnel entering the storage area and the nature of the hazardous

materials stored (e.g., flammable, corrosive).



If on-site space allows, facilities shall have a dedicated, segregated quarantine area

where non-compliant materials can be placed for safe temporary isolation. For sites

with more limited space (e.g. offshore) quarantine areas should be set up as required,

ensuring segregation from other on-site chemicals.

Materials, for which there is no current or anticipated use, shall not be kept in storage

indefinitely. Operating Area/Facility specific procedures / instructions shall establish the

maximum storage period for such products, depending on the site storage requirements. If no

use is made of a material within such period, the Operating Area/Facility HSE /or H&S

Advisor shall contact the designated users to establish whether the material is still required for

any current or imminent operation. If there is no confirmation of requirement, approval shall

be obtained from the designated users to seek an appropriate disposal route for the material.

Materials held in storage should be reviewed at 3-month intervals to determine:

 Whether there is a continuing use for the material.

 Whether the rate and pattern of use justifies storage for long periods of time (for

instance, where it is known that there is a permanent need for supplies of the material,

and where it is logistically and economically efficient to procure large quantities at

widely-spaced intervals of time).

Unused material shall not be returned to storage unless it is in the original container / sack,

with the original label on it. Materials that do not meet these requirements must be placed in

quarantine, and must be appropriately re-packaged and labelled as rapidly as practicable.

Materials that are stored at work locations, due to operational requirements, shall be in

appropriate containers / sacks / pallets, placed on drip trays and located over an impermeable

surface (where practicable).

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All storage locations shall have current up-to-date MSDS information available for each

chemical / hazardous material stored. Such information can be presented either in the form of

the original MSDS, or in a form of a ChemTag (Appendix 4).

Waste material shall be disposed of in accordance with the AzSPU Waste Management

Strategy (AzSPU-HSSE-DOC-00068-2) requirements and relevant Operating Area/Facility

specific waste management procedures and site instructions.

All sites with storage facilities should maintain records of the following:

 Product delivery date.

 Quantities stored.

 Product removed from storage, including date, quantity and destination.

 Product returned to storage, including date and quantity.

 Product disposed as waste.

 Running totals of amounts used per month (bulk products only).

Such records shall be maintained by the Materials Controller or any other person responsible

for managing the site chemical storage areas.

5.6 Fire Extinguishers

Requirements for fire extinguishers (including placing, maintenance and testing) are included

within the CTM database.

5.7 MSDS Database

AzSPU HSE&TD together with site administrators shall maintain a MSDS database (Dolphin

or equivalent) and a register of generic risk assessments based on the internationally

recognised system of COSHH for all the products used within the AzSPU. This database shall

be reviewed and updated regularly.

5.8 Site Specific Chemical and Hazardous Materials Inventory

At the site level, each Operating Area/Facility shall maintain a Chemical and Hazardous

Materials Inventory. The Operating Area/Facility HSE or H&S Advisor shall ensure that the

Inventory is revised periodically to ensure that new information on chemicals and substances

in use is evaluated and changes made, as required.

The inventory shall specify, as a minimum:

 Product name.

 Supplier / Manufacturer name.

 MSDS.

 Chemicals storage location.

An example of a site inventory is provided in Appendix 5 of this procedure.

5.9 Handling

Handling of chemicals or hazardous materials shall be in compliance with the requirements

identified and documented during the task based risk assessment process.

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5.10 Waste and Residual Material Disposal

The options for the disposal of unused product, waste and residual material should be

assessed in the following order of priority:

 Return to vendor, taking into account:

Confirmation that vendor will accept.

Identification of a carrier qualified and prepared to arrange shipment.

Confirmation that waste, residual and reacted material has been fully

characterised, suitably packaged and labelled and that it can be shipped and

received under prevailing regulations in all countries through which it will

pass.

 Reuse or recycling of the product.

 Disposal to a dedicated treatment or landfill facility in accordance with the AzSPU

Waste Management Strategy (AzSPU-HSSE-DOC-00068-2);

 Long term storage in a dedicated, secure, BP-approved facility if no other option

consistent with BP‟s policy and relevant regulations is available.

Discharge directly to the environment shall not take place without authorisation and approval

in accordance with the requirements of the AzSPU Environmental Risk Assessment (ERA)

Procedure (AzSPU-HSSE-DOC-00120-2). These requirements include the need for formal

approval and consent by the relevant regulatory authorities. Each site shall maintain an up-to-

date register of the state and municipal organisations with regulatory authority in their areas

of operation.

5.11 Training

All staff engaged in chemical or hazardous materials selection, procurement, storage,

handling and transportation shall receive training in:

 Correct interpretation of MSDS documentation.

 Task-based risk assessment.

 The identification and use of appropriate PPE for each chemical type.

 Correct labelling and container / sack / pallet types for each class of chemical.

 Identification of incompatible chemical types, and appropriate container materials

and storage facilities.

 Identification of appropriate handling and transportation equipment and procedures.

 Appropriate spill and clean-up response for each chemical.

Operating Area/Facility shall maintain an up-to-date training record and training schedule for

each employee. The record will be reviewed at least annually, and will be updated whenever

additional training has been successfully completed.

As far as practicable, training related to safety should be provided by professional trainers,

should be undertaken to recognised international standards, and should result in the award of

a formal qualification or completion certificate. Where formal certification is awarded, a

specific training schedule should be implemented to ensure that all necessary refresher

courses are provided at the intervals prescribed by the guidelines or regulations under which

the training is defined and delivered. Formal training is mandatory for responsible managers.

5.12 Record Keeping

Site-specific records relating to hazardous materials management shall include the following,

as a minimum:

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 14 of 24

 Chemicals and Hazardous Materials Inventory.

 Product disposed as waste and associated waste transfer notes.

 Product returned to vendor.

 Running totals of amounts used per month.

 Task-based risk assessments.

 Copies of MSDS.

 Training register.

 Incident reports.

 Audit reports and any other audit related records.

5.13 Inspections and Audits

Documented regular inspections shall be undertaken at each Operating Facility using

the AzSPU Hazardous Materials Management Checklist

(AZSPU-HSSE-DOC-

00124-2).

An audit schedule shall be developed at AzSPU level to provide further assurance of

compliance with the requirements of this procedure.

6.0 Key Documents/Tools/References

AzSPU Waste Management Strategy (AzSPU-HSSE-DOC-00068-2)

AzSPU Environmental Risk Assessment (ERA) Procedure (AzSPU-HSSE-DOC-00120-2)

AzSPU Health Surveillance Management Programme (AzSPU-HSSE-DOC-00135-2)

AzSPU Respiratory Protection Management Programme (AzSPU-HSSE-DOC-00136-2)

AzSPU Management of Change Procedure (AzSPU-GEN-PRC-001-C7)

Sangachal Terminal Hazardous Materials Management Site Instruction Health & Safety

Commission - List of Approved Workplace Exposure Limits EH40/2005 (amended 2007)

(AzSPU-HSSE-PMT-01266-2).

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 15 of 24

Revision/Review Log

Revision Date

Authority

Custodian

Revision Details

Gunther

17.08.2006

Alan McNulty

First issue

Newcombe

26.10.2007

Alan McNulty

Hijran Jafarova

Periodic review

29.02.2008

Alan McNulty

Hijran Jafarova

Periodic review

Revised in line with May ISO 14001

11.09.2008

Alan McNulty

Hijran Jafarova

external audit findings / recommendations.

Authority position/name has changed to

05.12.2008

Yuliy Zaytsev

Hijran Jafarova

reflect org changes in HSE&TD as of

December 1st 2008

Team / position titles updated throughout.

Requirement for the storage capacity of

material storage areas to be identified

removed from procedure, in response to

November

2008 ISO

14001 audit

observation.

Requirement for sacks and pallets also to

be labelled in accordance with the

template in Appendix

3 added to

procedure, in response to November 2008

ISO 14001 audit observation.

Yuliy Zaytsev

Hijran Jafarova

Requirement

for

dedicated permanent

(AzSPU Safety

(AzSPU IH

quarantine area removed from procedure

28.04.2009

& Compliance

Technical

as not practical for sites with limited space

Systems

Authority)

(e.g. offshore).

Manager)

Instructions

personnel on the

implementation of COSHH regulations

added as Appendix 1 to procedure.

Reference to Chemical MoC

(accessed

through new e-MoC system) added to

procedure.

Reference to Dolphin MSDS database

added to procedure.

Key documents list reviewed and updated.

Yuliy Zaytsev

Hijran Jafarova

(AzSPU Safety

The next review date was extended due to

(AzSPU IH

6/04/2010

& Compliance

AzSPU reorganization and e-MoC

Technical

Systems

transition plan

Authority)

Manager)

Document ownership amended and

Yuliy Zaytsev

John Elliott

example checklist deleted. Minor updates

(AzSPU

to reflect organisational changes. The next

02/11/2010

Offshore HSE

Hazardous

review date was postponed to allow

Manager)

Materials TA)

further organisational changes to be

agreed.

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 16 of 24

APPENDIX 1 - INSTRUCTIONS TO PERSONNEL ON IMPLEMENTATION OF COSHH

The purpose of this section of the document is to give instruction to personnel on the

implementation of the Control of Substances Hazardous to Health (COSHH) Regulations and

the COSHH General Approved Code of Practice (ACoP).

Dispensation for Area

Covered by Term

Term

Use of Term Infers

(All dispensations are to be

recorded and retained)

Must

Legislative Requirement

No dispensation can be granted.

Head of CHSE via Unit

Group Standard/Practice or Golden

Authorisation above the level of

Rule

AzSPU Unit. Forward to Head of

HSSE / SPU EA for referral to

Group

Shall

Minimum requirement stipulated at

Approval of Head of HSSE / SPU

SPU/Az level

Should

SPU/Az Best Practice or

Approval of Site Manager / OIM

Recommended/Preferred option

The COSHH Regulations provide the legal framework to protect people against health risks

from hazardous substances used at work. This document is not a comprehensive general guide

to all aspects of the regulations, but should be read in conjunction with the COSHH (General

ACoP), Control of Carcinogens and Control of Biological Agents published by the Health and

Safety Commission.

NOTE: “AUDIT” in terms of COSHHnet means Review and Authorise

Roles and Responsibilities

Technical Authority/BU Administrator (Industrial Hygienist, Technical Authority for COSHH and

Business Unit COSHHNet custodian)



Provide advice, support, training and audit of COSHH management on site



Responsible for the development and any modifications to the system



Ensure that COSHH is fully implemented and integrated into local safe systems of work



Ensure that COSHH implications are considered as part of any new project or modification of

existing plant



Ensure that all COSHH Assessors and Coordinators have relevant access to COSHHnet



Act as Main Administrator of COSHHnet system, in terms of managing sites and users‟ access

to the system



Carry out and/or coordinate air monitoring as identified in COSHH Assessments

Site Management

Site Management shall be responsible for:

 Appointing competent persons with regard to the roles of COSHH Co-ordinator and

COSHH Assessors.

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 17 of 24

 Ensuring that provisions for hazardous substances are in place with third parties and

that performance and competence of such parties are suitably monitored.

 The maintenance of comprehensive, accurate and up-to-date records, where required

by legislation.

 Ensuring that COSHH implications are considered as part of any new project or

modification of existing plant.

Local management shall identify an appropriate person to whom the duties of COSHH Co-

ordinator can be delegated. The Co-ordinator‟s role is outlined in this document. Management

must also ensure that COSHH is fully implemented and integrated into local safe systems of

work. Once such a COSHH Management System is in place, the Co-ordinator shall facilitate

and support line management in maintaining the system.

Management shall ensure that suitable arrangements are made with regard to duties on

maintenance, examination and test of control measures such as Local Exhaust Ventilation

(LEV) and Respiratory Protection Equipment (RPE).

COSHH Co-ordinator

The site health and safety function and Medics are primary COSHH co-ordinators (see the

role of COSHH coordinators) and advise line management on the adequate control measures

required for any task.

The COSHH Co-ordinator shall report to management on all aspects of the local COSHH

programme. The Co-ordinator shall be the principal custodian for COSHH-related records

onsite, further definition of this role is as follows:

 Co-ordinate inventory and ensure availability of health and safety information on all

hazardous substances.

 Ensure that a mechanism is in place for updating substance information, including the

screening of new substances.

 Assist primary assessors by participation in the assessment process and advising

where specialist support may be required.

 Monitor and review contractor assessments to ensure suitability.

 Act as local custodian of the BP COSHH Database System

 Ensure that all assessment recommendations are entered onto an action tracking

system and monitor progress.

 Propose nominations for assessor training.

 Audit COSHH assessments

 Ensure that provisions for programme review and audit are in place

COSHH Assessors

Operations supervisors shall be the primary COSHH Assessors. Assessor training is provided

by attendance at the BP COSHH Assessors Course, which enables them to recognise where

and how their knowledge and experience fits into the assessment process.

In most situations the person in charge of the work, eg team leader or supervisor, will be the

prime instigator of the assessment process. They shall also be responsible for the regular

review of tasks and substances under their control and for ensuring that risks and precaution

information is passed onto their teams.

Contractors

The simple guiding principle is that whoever is in control of an operation must ensure that

adequate arrangements are in place. Legal responsibility remains with the employer. Good co-

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 18 of 24

operation and co-ordination are critical and it should be decided, at as early stage as possible,

who has a duty under COSHH. In general, where a contractor/vendor provides a specialist

service, including the use or supply of hazardous substances, they have a primary duty of

assessment and they shall, with agreement of local management, utilise the BP COSHHnet

tool.

Contractors shall be responsible for:

 Agreement with BP that suitable arrangements are in place prior to commencing any

activities involving substances hazardous to health.

 Health surveillance arrangements, where appropriate, for their own employees.

Health Risk Assessment Process

The health risk assessment process under COSHH involves five key steps, which are:

(1)

Hazard and task identification.

(2)

Risk assessment.

(3)

Measures to prevent or control exposure.

(4)

Record keeping.

(5)

Review.

The COSHH Assessment System provides a proforma for assessing risks to health in a format

suitable for easy use, retrieval, sharing and storage. Forms should be completed by a

competent COSHH Assessor and then audited by the Site Co-ordinator.

Step 1: Hazard and Task Identification

All activities where there is a risk of exposure to substances hazardous to health must be

identified and a task-based assessment carried out. This should be integrated with other BP

safe systems of work, such as the Integrated Safe System of Work (ISSOW) and Task Risk

Assessment (TRA) processes.

All hazardous substances should be identified and information gathered on their hazards.

MSDS are usually the main source of such information. Where insufficient information is

provided to allow a health risk assessment, eg where substances may be evolved or created

onsite (welding fume, biological agents, oil mists etc), specialist advice should be sought

from the COSHH Co-ordinator, or the BP Industrial Hygienist.

Step 2: Risk Assessment

In all but the simplest cases, task-based risk assessments must be carried out by a competent

person; this is most likely to be line management, or those directly in control of the work who

have trained as COSHH Assessors. They will be assisted by the COSHH Co-ordinator and,

where necessary, specialist support.

Provision shall be made to assess all core activities and to identify and record all new tasks

which could arise from non-routine work, chemical trials etc. In addition, existing methods of

assessing risk, such as ISSOW and TRA, can also highlight activities that are required to be

assessed for the purposes of COSHH.

In all circumstances, both BP and its contractors must ensure that a safe system of work has

been established before commencing any activities involving hazardous substances.

As a tool for ensuring a logical and consistent approach, the BP COSHHnet tool is suitable

for use http://coshh.bpweb.bp.com/

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 19 of 24

Step 3: Measures to Prevent or Control Exposure

The COSHH Regulations require that the exposure of employees to substances hazardous to

health must be either prevented or, where this is not reasonably practicable, adequately

controlled. Where the assessment indicates a risk to health, it is important to specify steps to

achieve effective control.

A hierarchical approach should be taken when deciding upon control options, as follows:

 Elimination of substance or process.

 Substitution with a less hazardous substance and/or process.

 Engineering measures such as containment and ventilation.

 Procedural measures, eg segregation, limiting exposure time, good housekeeping,

standing instructions/procedures/permits, supervision, housekeeping, personal

hygiene, etc.

Personal Protective Equipment (PPE) should only be used as a last option.

This hierarchical approach is included as part of the COSHH Assessment tool.

Step 4: Record Keeping

A written record of the assessment should be retained as a „living‟ document. This document

should be revisited if circumstances change in order to explain the decisions regarding risk.

All risk assessments shall be stored in the current BP COSHHnet tool.

Records relating to examination, maintenance and testing of controls (Regulation 9), exposure

monitoring (Regulation 10), health surveillance (Regulation 11), information, instruction and

training (Regulation 12) are also required to be kept.

Step 5: Review

Assessments should be reviewed every 2 years unless there have been some significant

changes, for example:

 Changes to chemicals and/or their sources, process, work procedure or

exposure controls.

 New information on health effects of chemical agents Workplace Exposure Limits,

etc.

 Adverse results from exposure monitoring health surveillance, etc.

Maintenance, Examination and Testing

Operational procedures are to be developed to ensure that control measures are being used

correctly.

Control measures such as local exhaust ventilation systems (eg laboratory fume cabinets,

fabrication shop extraction etc) and non-disposable PPE are to be inspected weekly and a

system is to be put in place for maintenance, examination and testing on an annual basis, with

records kept for 5 years.

Monitoring

Where the assessment concludes that there could be serious risks to health if control measures

fail, exposure limits might be exceeded or control measures might not be effective, air

monitoring should be carried out. Monitoring should, whenever possible, use validated

techniques and be carried out by a Competent Person. The BP Industrial Hygienist can advise.

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 20 of 24

As stated in the AzSPU Record Control Procedure (AzSPU-HSSE-DOC-00041-2) emissions

monitoring records are to be retained for 6 years after the relevant PSA, HGA, IGA has

expired (under COSHH monitoring records must be kept for 5 years).

Health Surveillance

The COSHH Co-ordinator should identify from assessment where there could be a

requirement and then contact the BP Occupational Health Medical Officer for instruction and

guidance.

As stated in the AzSPU Record Control Procedure (AzSPU-HSSE-DOC-00041-2) health

assessment records are to be retained for 75 years (under COSHH records shall be kept for 40

years).

Detailed health surveillance instruction is provided in the AzSPU Fitness for Task and Health

Surveillance Management Programme (AZSPU-HSSE-DOC-00007-2).

The BP duty to provide health surveillance does not extend to non-employees, therefore

contractors and third parties shall be responsible for arrangements for their own employees.

Information, Instruction and Training

Information should be made readily available on risks to health, precautions, monitoring and

health surveillance. This should be supplemented by instruction on the purpose, use and

reporting defects of control measures and training on local safe systems of work, emergency

procedures and competency.

Competency levels are dependent upon duties delegated by management, eg:

 General awareness - 1 hour CBT COSHH Awareness

ID:_scorm12_bp_ep_at_sa_coshh_enus, Tool Box Talks

 COSHH Assessor - 1 day COSHH Assessor Course

 COSHH Co-ordinator

5 days International Hygiene Module on Control of

Hazardous Substances W503; or 5 days Fundamental Principles of Industrial Hygiene

(FPIH); or equivalent training

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 21 of 24

APPENDIX 2 - STORAGE COMPATIBILITY CHART

YES

may be stored together

should NOT be stored together

may be stored together subject to

EXTREMELY

HIGHLY

VERY

RADIO-

EXPLOSIVE

OXIDISING

FLAMMABLE

TOXIC

HARMFUL

CORROSIVE

IRRITANT

special precautions

FLAMMABLE

TOXIC

ACTIVE

EXPLOSIVE

YES

OXIDISING

YES

EXTREMELY

YES

FLAMMABLE

HIGHLY

YES

FLAMMABLE

YES

VERY

YES

TOXIC

YES

HARMFUL

YES

CORROSIVE

YES

IRRITANT

YES

RADIO-

YES

ACTIVE

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Chemical and Hazardous Materials Management Procedure

Page 24 of 24

APPENDIX 5 - EXAMPLE CHEMICAL AND HAZARDOUS MATERIALS SITE INVENTORY

Submitted date:

Facility

Name of person submitted the Spreadsheet:

Site Chemicals Inventory Spreadsheet

Discharge to environment

Product Information

Company

Product Name (Trade Name of

Material Safety Data

Task-Based Risk

Site Technical

Function

Bulletin -PIB

OCNS Category

Storage Location

Regulatory

ACC number

Name

the product only)

Sheet (MSDS)

Assessement

Point of

Contact Person

(if applicable)

approval

discharge

reference

Control Tier:

Revision Date: 02 Nov 2010

Document Number: AZSPU-HSSE-DOC-00078-2

Print Date: 2/1/2011

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AzSPU Compliance Task Verification Procedure

Page 1 of 12

AzSPU Compliance Task Verification

Procedure

AZSPU-HSE-DOC-00094-2

Authority:

Faig Askerov, AzSPU

Custodian:

Anar Naghiyev, AzSPU

Regulatory

HSE Compliance Team

Compliance and

Leader

Environment Manager

Scope:

AzSPU

Document

HSSE MS Document

Administrator:

Coordinator

Issue Date:

January 8, 2007

Issuing Dept:

Regulatory Compliance &

Environmental

Team,

HSE & Engineering

Revision Date:

August 6, 2010

Control Tier:

2- AzSPU

Next Review Date:

August 6, 2011

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

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AzSPU Compliance Task Verification Procedure

Page 2 of 12

1. Introduction

The HSE Compliance Task Manager (CTM) Tool provides a means of managing legal

compliance requirements across AzSPU. CTM can be accessed at the following site:

https://HSEcms.bpglobal.com. To log on to CTM users need to enter their BP NT ID and

NT password. Users who log on to CTM can view and manage specific tasks they are

responsible for.

This work instruction accompanies the AzSPU HSE Legal And Regulatory Requirements

Procedure (Document AZSPU-HSE-DOC-00038-2) which describes the CTM Tool in

further detail.

This procedure describes the process for verifying tasks to ensure that they are SMART

i.e.:

 Specific - stand alone, clear and direct.

 Measurable - I can say it is done.

 Actionable - starts with an action orientated verb (i.e. collect, record, post,

survey, inspect).

 Reasonable - no wish list, stick to tasks the site is already performing, whenever

possible.

 Timely - set the right frequency, don‟t overdo it.

Compliance Tasks have been and will continue to be developed from the following

Source Documents:

 Contractual agreements (e.g. PSA, HGA)

 Host Government Agreements (HGA)

 Project-specific documents (ESIAs, Technical Notes)

 Applicable legislation & regulations

(National legislation & International

Agreements ratified by Host Countries)

All capitalized terms used in this procedure are defined in the following section.

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

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AzSPU Compliance Task Verification Procedure

Page 3 of 12

2. Definitions

Compliance Task (Task): A clearly defined action that is developed from the High

Level Requirement/Rule. The Compliance Task is contained in the Task Description

column in the Task Spreadsheet.

Compliance Task Manager (CTM): An electronic compliance matrix

(database)

enabling businesses to manage the relationship between applicable legal and other

requirements, compliance tasks, accountable BP employee positions, and operational

controls.

Consolidation: Combining similar tasks from multiple rows in the Task Spreadsheet into

a single row. This requires copying and pasting of the task language and citation

information into a single row in the Task Spreadsheet. The task language will normally

need to be amended to reflect all of the requirements added.

Continual Task: A Task that has no due date assigned, e.g. to comply with the HSE

policy.

High Level Requirement/Detailed Requirement: Title of the Source Document and

specific reference (e.g. section heading).

Due Date: Specific date when a task is to be completed.

Entity: The Facility where the Compliance Task is conducted, e.g. Sangachal Terminal,

Chirag-1 platform etc.

Evidence Document Description: Name of the document that provides evidence of Task

completion, e.g. CWAA Waste Register.

Evidence Document Location: Location of the evidence record (physical or electronic

filing location).

Frequency: The number of times a task occurs, e.g. One Time, Monthly etc.

High Level Requirement: A requirement contained in a Source Document. The

requirement is contained in the “Requirement Citation Text 1” column in the Task

Spreadsheet.

Operational Control: Procedure or site instruction that ensures the Task is completed

correctly.

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

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AzSPU Compliance Task Verification Procedure

Page 4 of 12

Operational Control Location: Location of the Operation Control (physical or

electronic filing location e.g. dK Documentum).

Owner: The full name of the person responsible for implementing a Task.

Position Title: The employee‟s formal job title, e.g. WA Control Room Technician,

Senior HSE Compliance Adviser, etc. Position Titles are included in the Position Title

List in the Task Spreadsheet.

Quality Assurance (QA): The process of checking compliance with the requirements of

this procedure.

Recurring Task: A Task that is repeated at a specific Frequency, e.g. monthly.

Requirement Citation Text: Actual language taken from the Source Document which

the Compliance Task is developed from.

Roll Up: Combining duplicate tasks from multiple rows in the Task Spreadsheet into a

single row. This requires copying and pasting the duplicated task information into a

single row in the Task Spreadsheet. There is no need to amend the task language as the

requirement(s) added are identical.

Source Document (Driver): Documents that are reviewed for the purposes of identifying

requirements and developing tasks. These documents include, but are not necessarily

limited to; PSAs, HGAs, ESIAs, technical notes and correspondence with the regulators.

State: The current state of the Task i.e. whether the Task is „Open‟ (to be completed

and/or recurring) or „Closed‟ (completed and non-recurring).

Supervisor: The full name of the person accountable for implementing a task, normally

the line manager (or more senior) of the task Owner.

Supervisor Team: The Position Title of the person accountable for completion of the

Task, normally the line manager of the Task Owner, e.g. DWG Platform Wells TL. Note

that this must be a BP position.

Task: See Compliance Task.

Task ID: A unique reference number for identifying tasks.

Task Activation: Uploading a Task to CTM and assigning its State as Open.

Task Owner: See Owner.

Task Spreadsheet: The excel spreadsheet containing tasks and related information (the

template to be used is AzSPU-HSE-DOC-00094-A2).

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

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AzSPU Compliance Task Verification Procedure

Page 5 of 12

Task Statement: Statement summarizing the Compliance Task requirement.

Task Verification: The process described in this procedure.

Task Verifier: The designated Operating Area /Asset Compliance Advisor (who may be

supported by a HSE Compliance Adviser).

Team: The Position Title of the person responsible for implementing the task, e.g. DWG

Staff Geophysicist.

3. Purpose

The purpose of this document is to describe:

 The actions to be undertaken by Operating Area /Asset HSE personnel in the Task

Verification process.

 The actions to be undertaken by AzSPU HSE Compliance Team personnel in

conducting Quality Assurance.

4. Roles & Responsibilities

4.1 Offshore & DC&I HSE Compliance Adviser; Exports Compliance Lead; ST

Compliance Adviser:

• SPA for respectful asset related task verification and quality assurance process and drive

the SPU Compliance agenda by:

Owning the process of verification of tasks in CTM system in cooperation with

Operations H, S & E Advisers

Communication with SMEs, Regular connectivity meetings with HSE

Compliance team, offshore site/assets personnel and Offshore environmental

advisors;

submit verified & QA tasks to HSE Compliance Team for further processing

within the agreed timeline

conduct task closure quality assurance reviews with objective to ensure the

requirements are followed and activities are compliant

Promoting compliance culture in asset operations by arranging CTM training

and compliance awareness sessions for a facility staff; ensure task owners / task

supervisors are aware of CTM User training pack / to keep the list of participants

updated arranging and conducting CTM user training to target people

Tracking and reporting of progress of compliance tasks and issues on regular

basis

Quality Assurance of verified tasks:

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu

AzSPU Compliance Task Verification Procedure

Page 6 of 12

1. Check that the format of the data entered is correct.

2. Check that the minimum required data has been included.

3. Provide email notification to the Operating Area/Asset Task Verifier listing tasks that are

ready for activation in CTM. Tasks will be activated in CTM as soon as practicable after

email notification, as agreed with the Operating Area/Asset Task Verifier.

4.2 Operating Area/Asset Level

Asset/Ops Area H&S & Environmental Advisers from the Operating Area/Asset HSE

function (whether Environmental, H&S), in coordination with Offshore & DC&I HSE

Compliance Adviser; Exports Compliance Lead; ST Compliance Adviser: are

responsible for verifying of respectful (H, S& E) tasks in the Task Spreadsheet in

accordance with Sections 5 & 6 of this procedure, including:

 Assigned tasks are understood by Task Owners or their line managers.

 Operating Area /Asset Advisers undertake Task Verification in accordance with

the requirements of this procedure.

 Reviewing and sense checking the applicability of assigned tasks and revising the

applicability as required.

 Facilitating the Task Owner or their line manager to review task language and

amend as required.

 Verifying that assigned tasks are understood by the Task Owner or their line

manager.

 Completing the Position Title List in the Task Spreadsheet.

 Checking that all information entered in the Task Spreadsheet is formatted in

accordance with this procedure.

4.3 HSE Compliance Team

HSE Compliance TL (or delegate)

Accountable for ensuring that:

 Compliance Advisers comply with the requirements of this procedure.

 Effective explanation and support is provided to Operating Area /Asset Advisers

in a timely manner.

 Verification processes are simplified where possible and focused on higher risk

areas.

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu

AzSPU Compliance Task Verification Procedure

Page 7 of 12

Compliance Adviser

Responsible for:

 Help coordinating Task Verification for their respective Operating Areas (i.e.

Offshore, Terminal and Midstream).

 Checking that information in the Task Spreadsheet is formatted in accordance

with this procedure.

 Providing explanation and support to Operating Area/Asset designated

compliance adviser in a timely manner.

 Final Quality Assurance of Tasks prior to upload into CTM.

 Advance notification (on Task Activation) to all personnel who are responsible &

accountable for implementation of compliance tasks

 Coordinating the delivery of training for CTM users.

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu

AzSPU Compliance Task Verification Procedure

Page 8 of 12

5. Key Operating Area requirements:

Tasks are issued in the Task Spreadsheet, the format of which must not be

changed. The content of the file should only be changed in accordance with this

procedure.

The column headings for the Task Spreadsheet you will be using are provided in

Appendix 1 - please read and understand Appendix 1 before working on the Task

Spreadsheet. Only those column headers shaded green must be completed, if

applicable.

Do not make any changes to the columns titled “DO NOT AMEND”.

If you have any questions please do not hesitate to contact your respective

Compliance Adviser in the HSE Compliance Team.

Every task must be verified with the Task Owner(s). Where the Task Verifier has

reviewed the task with the responsible party‟s line manager, unless otherwise

agreed, the line manager has responsibility for checking the Task Owner‟s

awareness and understanding of their assigned tasks. The Task Verifier must

ensure that the line manager is aware of this responsibility.

Please include your comments only in the “Comments (Operating Area /Asset)”

column.

Do not delete any rows in the spreadsheet. If you identify duplicate tasks please

indicate this in the “Comments (Operating Area /Asset)” column by referencing

the Task ID, e.g. “DELETE: DUPLICATES TASK ID 678”.

Control Tier:

2-AzSPU

Revision Date: August 6, 2010

Document Number: AZSPU-HSE-DOC-00094-2

Print Date: 2/1/20118/25/2010

PAPER COPIES ARE UNCONTROLLED. THIS COPY VALID ONLY AT THE TIME OF PRINTING. THE CONTROLLED

VERSION OF THIS DOCUMENT CAN BE FOUND AT http://docs.bpweb.bp.com/dkazspu

Military reference books and manuals (2009-2023, Volume 4) - page 14