Integrated health, safety and environment impact assessment

Sophie Khomeriki, from MWH Global, examines the integrated health, safety and environmental impact assessment (HSEIA) process used by the Abu Dhabi National Oil Company and compares it to UK practice

The Abu Dhabi National Oil Company (ADNOC) is the de-facto regulatory body for health, safety and the environment for the oil and gas industry in Abu Dhabi.

The HSEIA process is defined within ADNOC codes of practice documents, which are guidelines and standards covering the entire range of health, safety and environment issues.

A staged process

The HSEIA process is undertaken by an independent consultant on behalf of the developer at four distinct stages of the project. At the end of each stage an HSEIA study report is prepared and submitted to ADNOC for their approval. The following four phases are defined for the project approval process:

• Phase 1: HSEIA report is prepared at the front-end engineering and design stage of the project and is approved prior to project moving to engineering, procurement and construction (EPC) stage.
• Phase 2: HSEIA report is prepared when EPC contractors are at the detailed design stage of the project. This report is approved prior to construction and assesses health, safety and environment impacts of the works.
• Phase 3: HSEIA report is prepared when the construction is underway and is approved prior to operation of the facility. It includes review of operational manuals, maintenance procedures to ensure safe operation.
• Phase 4: HSEIA report is prepared at the end of a project’s life and approved before the shutdown of the facility.

In addition, each operational facility prepares an HSEIA report every five years and submits it to ADNOC for approval. This ensures that facilities review and apply any changes to legal requirements.

Detailed reports

The content of the HSEIA reports is structured in a similar way, with the main difference being the level of detail available at each stage of the project.

The main components are discussed below and indicate that there are similarities to UK practices:

• Hazards and effects register – lists all health, safety and environment hazards and their effects with proposed mitigation measures and assigned risk scoring. The register is based on findings of HAZIDs (hazard identification studies), HAZOPs (hazard and operability studies), health risk assessments, and quantitative risk assessments. The phase 2 report includes hazards and effects of construction works.
• Environmental impact statement (EIS) – identifies, analyses and assesses potential environmental impacts of the projects to ensure environmentally sound development.

  UK practice: The environmental impact assessment process and EIS requirements of ADNOC are similar to those of the EIA Directive (85/337/EEC, as amended).

• Control of major accident hazards report (COMAH) – demonstrates that all necessary steps have been taken to identify and prevent major accident hazards and to limit their potential consequences to people, assets, environment or reputation. For phase 2 HSEIA, COMAH is prepared for construction activities.

  UK practice: The COMAH report is similar to those required by the Health and Safety Executive in the UK for chemical industries, storage activities, explosives, nuclear sites, and other industries where dangerous substances identified in the COMAH Regulations 1999 are kept or used.

• Occupational health risk assessment report (OHRA) – identifies workplace health hazards; prioritises implementation of control measures; and reviews the occupational health management system in place, and assess its adequacy for new projects. At phase 2 stage, the OHRA process evaluates the potential risk to construction workers’ health, and proposes activities to control their exposure to risks.

  UK practice: The issues dealt with in the OHRA are similar to those covered in international occupational health and safety management system standards such as OSHA and OHSAS 18001.

• Company health, safety and environment management system review – the developer’s existing health, safety and environmental management system is reviewed to identify how it provides equivalent management control of health, safety and environmental issues related to the project. For phase 2, contractor and subcontractor health, safety and environment plans are also reviewed.

  UK practice: In the UK, ISO 14001 and OHSAS 18001 are voluntary standards, which provide guidelines on how to control and improve organisation’s health and safety performance, support environmental protection and prevent pollution in conjunction with socioeconomic needs.

An integrated approach for an integrated regulator

As a body that regulates all environmental, health and safety aspects of oil and gas operations, an integrated HSEIA process provides ADNOC with a comprehensive evaluation of all project-related health, safety and environment aspects in a single document. Its staged approach also ensures that phase-specific issues are identified and adequately assessed.

In the UK, where separate regulatory bodies deal with environmental and health and safety aspects, an integrated HSEIA approach is thought to be less functional.

This article was written as a contribution to the EIA Quality Mark’s commitment to improving EIA practice.

Sophie Khomeriki is a principal environmental consultant at MWH Global