incident reporting & classification module 30 - Brunei Shell ...

Revision
4.1
Brunei Shell Petroleum Company Sendirian Berhad
I NCIDENT R EPORTING &
C LASSIFICATION
( INCL. ‘OMNIS AFE’ )
M ODULE 30
T HIS DOCUMENT IS A LEVEL 3
PROCEDURE GUIDING AN ACTIVITY
RELATED TO THE HSE
M ANAGEMENT S YSTEM
Document no. : BSP-02.01.05-Procedure-1621
Document Owner:
Document Author:
Lee, Wai-Chee, HSE
Hairulanuar, HSE/42

Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
Revision Record
REV REVISION DESCRIPTION DATE
1.0 First issue September 1996
2.1 Updated to inc. reporting of potentially significant incidents November 2000
2.2 Updated to reflect “transition to asset units”, include OmniSafe amendments and
revised investigation & reporting changes
April 2002
3.0 Approved May 2002
3.1 Updated to reflect revised early notification of significant incidents + reference to
latest group guideline
June 2002
4.0 Definitions updated. Appendix G deleted. Environmental examples added. January 2003
Appendices H and I updated for Occupational Illness - Need for involvement of
LGL for actual consequence rated 3 and above included.
4.1 Corrections made for Actual consequences and potential risk June 2003
Distribution Control
Distribution of this document is via the LIVELINK document management system.
Notice and Warning
Copyright © 2002, Brunei Shell Petroleum Company Sendirian Berhad
This document is the property of Brunei Shell Petroleum Sendirian Berhad (BSP), KB3534, Negara Brunei
Darussalam. Circulation is restricted to BSP and its designated associates, contractors and consultants. It
must not be copied or used for any other purpose other than which it is supplied, without the expressed
written authority of BSP.
Except where provided for purposes of contractual requirements, BSP disclaims any responsibility or liability
for any use or misuse of the document by any person and makes no warranty as to the accuracy or suitability
of the information to any third party. Any misuse of the document is redressable by BSP.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
T ABLE OF C ONTENTS
1 INTRODUCTION 4
2 INCIDENT REPORTING PROCEDURE 9
3 SYSTEM TRAINING & COMPLIANCE MONITORING 13
APPENDIX A - OWNERSHIP OF INCIDENTS & STATISTICS 14
APPENDIX B- EXAMPLES OF ACTUAL RISK ASSESSMENT 15
APPENDIX C – EXAMPLES OF INCIDENT POTENTIAL 16
APPENDIX D – EXAMPLES OF ‘WORK RELATED’ INCIDENTS 18
APPENDIX E – EXAMPLES OF EXPOSURE HOURS 20
APPENDIX F - ENVIRONMENTAL INCIDENTS 21
APPENDIX G - COMPLAINTS FROM THE PUBLIC 23
APPENDIX H - OCCUPATIONAL ILLNESS REPORTING 24
APPENDIX I – OCCUPATIONAL ILLNESS CLASSIFICATION AND EXAMPLES 27
APPENDIX J - MEDICAL TREATMENT AND FIRST AID CASES 28
APPENDIX K – SEVERITY (OR CONSEQUENCE) RATING 29
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
1 INTRODUCTION
1.1 Purpose
The BSP HSE Management System requires that company and contractor staff report ALL HSE incidents and
near misses related to our activities. This is required so that we can:
- take prompt action to mitigate any residual risks or reduce further exposure;
- communicate the information to others (internally and externally), who may need to take action to
prevent such an incident happening
- meet our obligation to notify either government or shareholders about significant incidents or injuries
- investigate what happened swiftly and determine appropriate follow up actions to prevent recurrence
1.2 Scope
This procedure applies to ALL company and contractor staff. ALL HSE incidents or near misses shall be
reported, classified, and recorded in the corporate HSE Information System, OmniSafe, using this procedure.
The procedure covers:
- initial incident reporting
- incident evaluation, which involves actual consequence & potential risk assessment (severity &
likelihood)
- injury classification
- incident ownership & HSE ‘statistic’ ownership
- determining whether incidents are ‘work related’ and ‘reportable’
- what constitutes ‘exposure hours’
and explains how OmniSafe is used throughout the process to capture and store ALL relevant information
about each incident.
This procedure explicitly excludes the incident investigation process, which is addressed separately.
� Module 31 - Incident Investigation & Follow-Up
This procedure applies principally to BSP, but may also be used by BLNG, BST & BSM.
1.3 References
This document is supported by the Group yellow guide, Incident Classification, Investigation & Reporting (see
below)
� http://sww.shell.com/shell-online/group/hse/hse_publications/publications.htm
1.4 Roles and Responsibilities
1.4.1 Incident Reporter
ALL company employees and contractors MUST report ‘work related’ HSE incidents and
near misses within 24hrs.
Incidents MUST be reported in OmniSafe, which is available to ALL company web-users. In the event that the
web is unavailable, physically, or temporarily due to break-down or maintenance, then a paper copy of the
incident report shall be completed and submitted to the company line supervisor or company contract holder,
which must be entered into OmniSafe as soon as possible.
The company encourages everyone to report any incident or near miss, even if it is not considered to be ‘work
related’ - there is learning from every incident.
If there is any doubt whether or not the incident is work related, REPORT it. The recordability will be resolved
as part of the investigation and follow up.
The incident reporter must complete ALL the incident report fields, as accurately as possible, including their
own name and reference indicator, or contractor company.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
1.4.2 Incident Owner
Once an incident is reported in OmniSafe the reporter must select an ‘owner’, from a drop down menu in
OmniSafe to direct the report to. This person is called the ‘incident owner’. Invariably, this will be the most
appropriate asset owner representative (e.g. SOS, AOS, Terminal Superintendent, Drilling Supervisor, etc., or
the company contract holder (see Appendix A - Ownership of Incidents & Statistics).
The incident owner is responsible for firstly ‘accepting’ the incident (i.e. it is an incident related to his/her
asset, or contract, and they are the most appropriate ‘owner’), and secondly ‘evaluating’ the incident, which
includes confirming that
• the details of the incident are correct
• the actual consequence and potential risk assessments are appropriate, and
• in the case of an injury, the injury classification has been recorded.
The incident owner is also responsible for ensuring an investigation team leader is appointed appropriate to
the potential risk evaluation. On completion of the incident investigation the ‘owner’ is responsible for verifying
that the actions derived from the investigation are closed out properly by the assigned action parties and
approved.
Where medical treatment has been given by anyone other than HML staff, the incident owner must draw this
to the attention of HML, and provide them with all the necessary details for any required follow up.
ALL nominated incident owners are recorded in the OmniSafe database, and drop down menu, and given
OmniSafe “CLIENT SERVER” access.
1.4.3 Incident Sponsor
The incident sponsor is a department head, a manager, or a director, who is most directly associated with the
line incident owner. The seniority of the sponsor depends on the potential risk evaluation of the incident or
near miss, as follows
- LOW (department head)
- MEDIUM (manager)
- HIGH (director)
The incident sponsor is responsible for ensuring that the incident is investigated properly with the appropriate
level of seniority and independence and verifying that actions have been fully completed. The sponsor is the
only person able to close an incident in OmniSafe, having satisfied him/herself that the incident has been
properly followed up.
1.4.4 HSE Adviser
The HSE adviser will provide advice and support to the Incident Owner and Sponsor in clarifying and applying
this procedure. In addition, where required the HSE Advisor will assist in determining, in consultation with
the Medic/Doctor, the injury classification, especially regarding the differentiation between a lost workday case
and a restricted workday case. The HSE Adviser will interpret the guidelines and definitions to ensure that
consistency is applied throughout.
1.4.5 Medic/Doctor (HML)
When a company or contractor employee is injured, or reports sick, the medic or doctor MUST record the
treatment. The treating HML staff, if necessary in consultation with HSE Advisers, determine and recommend
the injury ‘classification ’. HML will also ascertain whether the treated illness is occupational (refer to
Appendix H - Occupational Illness Reporting).
The medic/doctor will report the injury in the ‘Health Reporting’ module of the OmniSafe system and crossreference
the treatment report with the corresponding incident report (seeking HSE advice and help where
required). Following injury treatment, the doctor/medic must ensure that the relevant line supervision is
notified about the injury treatment promptly.
In the case of lost time injuries, the doctor/medic will also notify HSE (or the duty HSE Adviser), the relevant
line manager, or the emergency co-ordinator (EC) immediately.
Note: ALL patient treatment reports are confidential. Consequently, access to the Health Reporting
module is restricted to the Chief Medical Officer (CMO), and those to whom the CMO expressly grants
access.
In the case of occupational illness, the medic/doctor will ONLY record the instance of a case by
classification, type, and the asset/service unit location in OmniSafe. Detailed treatment data will be withheld
from the OmniSafe database, on separate file. This is to protect patient confidentiality. Follow up
investigation, and findings are determined by the CMO, but records of these investigations retained for later
scrutiny or audit purposes.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
In the event that a company or contractor employee obtained treatment from a 3 rd party medical centre or
practitioner, HML will, where required follow up with that party, to understand the nature of the injury/illness
and treatment to help in advising on injury/illness classification, or request for referral of the patient to
Panaga Clinic.
Process
Notification
Evaluation
Investigation
Approval
Close-Out
1.5 Definitions
Term Definition
Responsibility
Raise an incident report
Determine investigation level
Establish injury class
Produce investigation report
Create SMART action item
Input action item
Approve investigation report
Complete action item
Approve action item
Close-Out incident report
Roles
Reporter
Owner
HML/HSE
Team
Leader
Owner
Owner
Action Party
Owner
Sponsor
Table 1-1: Overview of Roles & Responsibilities
Time
Within 24 hours
Within 2
days
Within 20
working days
Within 1 month
As per target
date
Accident The term is normally used to describe an unplanned event, or chain of events, which has
caused fatalities. In all other cases of injury or illness, the term ‘incident’ is preferred – see
later.
Asset
Custodian
A person appointed by the Asset Holder to be the custodian of an asset and to have
management responsibilities for all activities carried out on that asset.
Asset Holder The position that is accorded single point accountability by the Managing Director for all
aspects of the management, including budgetary control, of a clearly defined asset or group
of assets, over part or all of its lifecycle, in order to achieve corporate objectives.
The postholder identified in the BSP Asset Holder list as being responsible for a particular
item or area of BSP property.
Contractor All parties working for the Brunei Shell Companies either as a direct Contractor or as a subcontractor.
Exposure
Hours
The total number of hours of employment including paid overtime and training but
excluding leave, sickness and unpaid overtime hours. The exposure hours should be
calculated separately for Company and Contractor personnel. Time off duty, even if this
time is spent on Company premises, is not included in the calculation of exposure hours,
but incidents during this time are included in the statistics if they are the result of failure or
absence of management controls.
Fatality (FAT) A death resulting from a ‘work related’ injury or occupational illness, regardless of the time
intervening between the incident causing the injury or exposure or causing illness and
death.
First Aid
Case (FAC)
Any single treatment and subsequent observation of minor scratches, cuts, burns, splinters
etc. that do not normally require medical care by a physician. Such treatment and
observation are considered First Aid even if provided by a physician or registered
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
HSE
Management
Control of
Contractors
professional person. Examples are found in Appendix J - Medical Treatment and First Aid
Cases
HSE Management controls (e.g. contracts, standards) verified by the Contract Holder to
ensure effective HSE Management by the Contractor.
Incident An unplanned event or chain of events, that has, or could have, resulted in injury or illness
or damage to assets the environment or company reputation.
Injury Any injury such as a cut, fracture, sprain, amputation etc., that results from a single
instantaneous exposure.
Lost Time
Injuries (LTI)
Lost Time
Injury
Frequency
(LTIF)
Lost Workday
Case (LWC)
Medical
Treatment
Case (MTC)
Near Miss
(NM)
Occupational
Illness
Permanent
Total
Disability
(PTD)
Reporting
Period
Restricted
Work Case
(RWC)
Road Traffic
Incident
Total
Reportable
Case
Frequency
(TRCF)
Loosely used expression to describe an injury which results in lost work – but more
precisely is the sum of injuries resulting in fatalities, permanent total disabilities and lost
workday cases, but excluding restricted work cases and medical treatment cases. This
parameter is used to generate the lost time injury frequency indicator (LTIF)
A safety performance indicator that gives the frequency of lost time injuries per million
exposure man hours. It is calculated by dividing the total number of lost time injuries (see
above) by the number of exposure hours in millions.
Any work-related injury, which renders the injured person temporarily unable to perform
their normal work or restricted work on any day after the day on which the injury occurred.
Any day includes rest day, weekend day, scheduled holiday, public holiday or subsequent
day after ceasing employment.
This definition deviates from OSHA guidance, which considers restricted work as a lost
workday case.
A single incident can give rise to several lost workday cases, depending on the number of
people injured as a result of that incident.
Any work-related injury that involves neither lost workdays nor restricted workdays but
which requires treatment by a physician or other medical specialist.
Medical Treatment does not include first aid even if a physician or registered professional
person provides this.
Examples are to be found in Appendix J - Medical Treatment and First Aid Cases
An Incident that could have caused illness, injury or damage to assets, the environment or
company reputation, or consequential business loss but did not.
Any work-related abnormal condition or disorder, other than one resulting from an injury
that is caused by or mainly caused by exposures at work. (50% or more probability that the
illness was caused by exposures at work) Occupational illnesses include acute and chronic
illness or diseases that may be caused by inhalation, adsorption, ingestion or direct contact.
The procedure to determine whether an illness is occupational can be found in Appendix H -
Occupational Illness Reporting
Any work-related Injury that permanently incapacitates an employee and results in
termination of employment.
The period of time covered by the report. Within BSP the LTIF and TRCF statistics are
always presented on a ‘rolling 12 month’ reporting period, e.g. all relevant incidents and/or
all relevant man hours within the 12 months immediately prior to the report date are
included.
Any work-related injury which renders the injured person temporarily unable to perform all,
but still some, of their normal work on any day after the day on which the injury occurred.
An incident involving a vehicle driven by a company or contractor employee, whether on or
off road, that has resulted in injury, illness or damage to assets, the environment or the
Company’s reputation, irrespective of the cost of repair or responsibility for cause.
A safety performance indicator giving the frequency of reportable injuries per million
exposure man hours.
It is calculated by dividing the sum of reportable injury cases by the number of millions of
exposure man hours over a given period (normally 12 months).
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
Third Parties Persons or organisations, which are not employed by, or contracted to, the Company or
contractor.
Work Related Those activities for which management controls are in place, or should have been in place.
Incidents occurring during such activities must be reported and will be included in
performance statistics.
For consistency in the reporting practices of Group Companies, the following activities are
considered to be work related, as they are susceptible to incidents with significant impact,
for which company controls should be in place:
• All work by company personnel,
• All work by contractor personnel on company premises, and
• All work by contractor personnel on non-Company premises for which it is concluded
on the basis of risk considerations that company and contractor management controls are
required
For Company personnel, work includes overtime, attending courses, conferences and
Company organised events, business travel, field visits, or any other activity where the
employee’s presence is expected by the employer.
Where it is impossible or inappropriate for the Company to seek to impose management
control on a contractor, exceptions may be justifiable. Examples may be found in areas
where contractor services are not dedicated to the company e.g.
• Manufacturing of components in a factory together with the manufacture of components
for other customers;
• Construction at a contractor’s fabrication site shared by other customers
• Delivery of goods or products to company locations by a contractor who is also employed
to deliver goods or products to other companies during the same journey.
• customer collection of company products, where the vehicle and drivers are under the
control of the customer.
Advice should be sought from the Contract Holder if the reportability of a particular
contractor is in doubt.
Please refer to Appendix D – Examples of ‘Work related’ Incidents
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
2 INCIDENT R EPORTING P ROCEDURE
2.1 Overview of the Process
Table 2-1 illustrates the whole incident reporting process, starting with initial notification, by the reporter,
through to closeout by the sponsor.
NOTIFICATION
Reporter
2.2 Internal Notification
2.2.1 Initiating an Incident Report.
Table 2-1
The reporter needs to complete the Incident Report Form, which is available in the OmniSafe Incident
Reporting System, http://swwbond.bsp.shell.bn/cgi-bin/omniweb.exe/index
Contractors, who do not have access to the company Intra-Web, must use the paper based incident report
form, and send it to their Contract Holder. The contract holder must then upload the information into
OmniSafe.
The initial report must capture:
• Where and When the incident happened;
• For any injury related incident, the number of people injured;
• What happened, i.e. brief description of the incident;
• Severity of the incident - Actual Consequence & Potential Risk;
• When the incident was reported and by whom (for reference purposes only)
2.2.2 Alerting Others in the Company
Incident Reporting Process
EVALUATION
Owner
HEALTH REPORT
HML MEDIC OR DOCTOR
INVESTIGATION
Investigation
Team Leader
Creating
Owner
APPROVAL
Owner
ACTION ITEM
Completion
Action Party
All incidents must be reported within 24 hours
CLOSE-OUT
Approval
Owner
‘Investigation’ is addressed in Module 31
Sponsor
Once reported in OmniSafe, the system automatically assigns an Incident Owner, based primarily on the
location, or the contract, and will generate an automatic ‘e-mail’ notifying him/her. All HSE advisors are
notified, and line staff appropriate to the incident owner.
In the case of a fatality, lost workday case (LWC), or serious incident with damage, or harm to the
environment, the incident owner must prepare a ‘newsflash’ indicating:
- Brief description (with an illustrative photograph if possible) of the incident, incl.
severity of the injury/damage
- Where the incident happened
- Whether the injured person is a contractor or company employee, and how the person
is recovering
- Immediate actions taken, if applicable
- Immediate causes, and any early lessons to be shared
This “newsflash” should be reviewed by an HSE Advisor, and submitted to the company MD for signature.
Then published via HSE/0 in English and Bahasa Melayu, in hard copy, and on the “bulletins” page of the
intraweb.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
An emerging issue has been identified concerning the potential legal implications for BSP and our contractors
as a result of incidents involving BSP activities. In particular, any findings attributing causes of incidents to
certain implicit shortcomings or negligence of one party can potentially be used in legal court against a
unsuspecting employer ( BSP or contractors)
What precaution should we/contractors be taking in developing, reporting and releasing incident reports?
In the light of this, all staff need to be cautioned that any communication of an incident outside of BSP or in a
wider forum must be done with care (see below note 1). A responsible and acceptable approach is to include
involving contractor or sub contractor key representatives to participate in the investigation into any incidents
that are associated with BSP activities. The final investigation report must be jointly signed off by the involving
contractor to confirm their acceptance of the findings and the subsequent recommendations. A positive spinoff
from this is the opportunity for learning from each other between BSP & our contractors.
NOTE 1:
For an incident with an ‘actual’ consequence of 3 or above, the incident owner must inform LGL
within 48 hours of the incident. LGL will assess the need for special precautions related to the
investigation (e.g. document control etc.) and advice the incident owner accordingly.
NOTE 2:
For an incident with an ‘actual’ consequence 4 or 5, HSE must submit a notification to SIEP-EPA
within 24 hours (see ’Incident, Classification, Investigation and Reporting Feb 2002’ Yellow guide).
For incidents with 'potential' consequence 4 or 5, HSE must submit a similar notification format, BUT
it is NOT required to do so within 24hrs, this is to allow for proper determination of the incident
potential.
2.3 Evaluation (Incident Owner)
The incident evaluation must be completed by the Incident Owner within 24hrs
after receiving the incident report.
2.3.1 Confirming the Accuracy of the Initial Incident Report
The incident owner must confirm the accuracy of the information given in the initial notification, checking
when, where, what, and who was involved. Where a person is hurt, the injury classification is determined by
HML, and the incident owner must confirm this with the medical department, if the data has not been posted
in OmniSafe.
2.3.2 Evaluate Potential Risk
It is imperative that the incident owner assesses the incident potential risk carefully as this determines the
seniority of the subsequent incident investigation.
The incident owner must use the Risk Assessment Matrix, available in OmniSafe, and determine FIRST the
potential consequence of the incident, THEN the realistic likelihood of this consequence, based on historical
knowledge (refer to examples in Appendix B- Examples of .) These two combine to reveal the potential risk. If
required, the incident owner may involve his HSE Advisor in assisting with this review.
The incident owner must:
• edit the report only after careful review
• THEN ‘accept’ the incident report in OmniSafe.
The incident owner must report all lost workday cases (LWC’s), and incidents, including near misses, with a
potential consequence of 3, or higher, to the Line Manager within the 24 hours of the incident.
The Line Manager should report all incidents with actual consequences rated 4 or 5, to the Company
Managing Director & HSE within 24 hours of the incident occurring.
Once the report is accepted, it will be published in the public OmniSafe web server.
Incident investigation leadership is driven by the potential ‘risk’ (refer to Appendix C – Examples of Incident
Potential). A typical level of investigation leader, and sponsor are shown in Table 2-2.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
Investigation Level Investigation Team Composition Team Leader Sponsor
Low First line of supervision Sec / Div Head Div / Dept Head
Medium Dept Head + other line staff as required +
HSE advisor
High Manager + Dept Head + HSE Advisor +
Independent person or specialist required.
Table 2-2
2.4 Injury Classification (Medic/Doctor & HSE)
In the event of an ‘incident with injury’ report, HML will automatically be informed.
Dept Head Manager
Manager Director
Following a medical examination, and treatment, the treating HML representative must complete a medical
treatment report, and recommend in consultation, where necessary, with an HSE Adviser the injury
classification (fatality, lost workday case, restricted workday case, medical treatment case, or first aid case),
(refer to Appendix J - Medical Treatment and First Aid Cases).
The treating doctor/medic will confer with the
• relevant Asset/Service Unit HSE Adviser during normal working hours, and
• the duty HSE Adviser outside normal working hours
The medical treatment report will subsequently be recorded in the Health Reporting module of OmniSafe.
This ‘Health Reporting’ module report carries a ‘field’ requiring the corresponding incident reference number to
be inserted. This ties together the treatment, with the incident, and the injury classification.
The OmniSafe Health Reporting module report can only be raised by the location medic(s), or other staff
appointed by the CMO. Where direct access to OmniSafe is not available or possible, the medic/doctor must
complete a paper hard copy treatment report and send it to HML/3 for uploading into the OmniSafe Health
Reporting Module.
Contractors or sub-contractors must submit their medical treatment report to their Company contract holder
who in turn will advise HML/3.
For any treatment of a work related injury or an occupational illness carried out in a private clinic or
Government hospital, the incident owner must inform the HML duty doctor, who will follow up with the
external medical practitioner.
2.5 Incident Investigation
For details of incident investigation please refer to BSP-02-procedure-1620 (Module 31 - Incident Investigation)
An investigation report must be submitted for review to the incident owner and sponsor
within 20 working days from the date of incident notification
The final electronic version of incident report must be archived in the OmniSafe system. The Incident Owner
must hold a hard copy.
NOTE: ALL lost workday cases require a ‘formal’ investigation
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
2.6 Incident Report ‘Approval’
Once an incident report has been fully investigated, the investigation report approved, and the follow up
actions defined and recorded in OmniSafe, the incident can be “approved” as either, ‘work related’ or ‘nonwork
related’.
Note: after “approval” the OmniSafe System Administrator can no longer edit the report, WITHOUT
intervention.
2.7 Incident Report ‘Close-Out’
The OmniSafe system automatically notifies the incident sponsor via e-mail when all action items in the
incident report have been closed.
The Incident Sponsor can only close the approved incident report, when ALL the action items recommended out
of the incident investigation have been closed. The incident sponsor must verify that actions have been done
fully (this will probably be on a selective sampling basis), and then he/she can close the incident.
The sponsor must select the incident report in OmniSafe, then change the status from ‘Approved (Recordable
or Non-Recordable)’ to ‘Closed’.
2.8 Third Party Notification
2.8.1 Government
For all work related incidents involving staff earning B$750 per month or less as described below
Category 1 - fatalities.
Category 2 - injuries or occupational illness where the injured person is totally disabled from earning full
wages at the work at which he/or she was employed for more than 3 consecutive days. This
includes all Lost Workday Cases (LWC) or Restricted Work Cases (RWC) where the injury or
illness occurred as a result.
the incident owner must report it within 10 days of the incident to the Employment Commissioner of the
Brunei Government using the ‘Laws of Brunei - Worker’s Compensation Act 1957 - Schedule Form A’
Any oil spill of more than 5m 3 at sea must be reported to the Government Marine Department as per the Oil
Spill Emergency Response Procedure � BSP-02-Procedure-0660
2.8.2 Police
In all cases of a death whether or not work related occurring on Company premises, the incident owner must
notify the Royal Brunei Police immediately (this may be done in consultation with HRS).
In the event of a motor vehicle, or aircraft, incident or accident, which involves injuries to any person or
animal, or damage to any vehicle, aircraft, or property, whether or not these are owned by the Company, or a
third party, it must be reported by the driver to the nearest police station within 24 hours.
� HSE Standard Module 17 – Land Transport BSP-02-standard-1651 and TMS0439 Land Transport Manual
BSP-14.02-standard-003
2.8.3 Department of Civil Aviation (DCA)
All accidents involving aircraft must be reported by BSP SAV Dept. (Aviation Service Department) to the DCA,
with further notification to
• Advisory service for Shell Aircraft in London,
• Safety Design Dept. for Aircraft Manufacturer - Relevant information only at Company discretion.
2.8.4 Petroleum Unit
The Company is not obliged to report safety incidents to the PU, but will provide information if requested.
The incident owner is obliged to report an excursion on produced water effluent quality > 100-mg/l oil in
water, by sending a signed copy of the ‘Variance Control’ via HSE/5.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
3 SYSTEM T RAINING & COMPLIANCE M ONITORING
3.1 OmniSafe Training
Basic OmniSafe Training is provided for:
• Incident Reporters (i.e. every company employee)
• Action Parties
• Incident Sponsors
Advanced OmniSafe training is provided for:
• Incident Owners
• HSE focal points
• HSE Advisors
3.2 Monitoring Compliance with Reporting Procedure
Incident reporting procedure compliance is monitored through ‘OmniSafe’ performance indicators as follows:
• Late reporting
The incident is reported more than 1 working day after the date of incident.
• Overdue ‘evaluation’
Incident report is accepted more than 2 working days after the report is raised.
• Overdue ‘approval’
Incident report is approved more than 1 month after the incident date.
• Overdue follow up action items
Action items still open after the target date.
The System Custodian (HSE/41) extracts statistics related to compliance with the reporting procedure from
OmniSafe. The OmniSafe Performance Indicators are used in the Functional/Dept HSE Meeting.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX A - OWNERSHIP OF I NCIDENTS & STATISTICS
Incident Ownership
The “ownership” of incidents rests predominantly with the Asset Owner of the facility on which the incident
occurred, or, where the incident occurs outside of Company premises, with the Contract Holder.
The role of the incident owner is to ensure that there is the proper level of follow up as judged by the incident
evaluation, and that the investigation identifies underlying causes and remedial actions.
Example1: A contractor employee working for SCO is carrying out a task under cover of a PTW on CP-7
complex and hurts himself. The ‘incident owner’ would be the asset owner for CP-7 (EOP/1), and is
responsible for making sure the incident is evaluated, and an appropriate investigation is established.
Example 2: In the above example, the same contractor employee working for SCO is carrying out a task on
the workboat, anchored adjacent to Ampa-9, and injures himself. In this case the ‘incident owner’ is the
Contract Holder, who holds influence over the workboat itself.
Example 3: A contractor employee is working in a workshop belonging to the contractor and injures himself.
The ‘incident owner’ is the Contract Holder.
HSE Statistic Ownership
The Company party who is adjudged to have the “most” direct HSE management influence or control over the
outcome of the incident owns the statistic. In most cases this will be the same as the ‘incident owner’. In
some cases it may be another party who has a relation with the incident owner but who has more direct HSE
management control and influence.
Example 1: An STL pool car is involved in an accident and is being driven by another user department. The
vehicle is in technically good condition. STL does not have the “most” direct HSE management control over
the driver. The respective user department takes statistic ownership.
Example 2: A visitor to an offshore facility falls and injures himself. The facility owner will be the incident
owner, and will determine the underlying causes and sponsor the investigation. The investigation will
determine whether the facility or the visitor’s line department had the most direct control or influence over
the incident.
Example 3: A contractor employee injures himself in his workshop. The workshop belongs to the contractor
and is used to do work on behalf of the Company under contract. The activity was part of the contract scope.
The Company Contract Holder will own this and the statistic will be assigned to the contract holder’s
department.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX B- EXAMPLES OF ACTUAL CONSEQUENCES
The assessment of an incident is divided into two elements:
1. What actually happened and the actual consequences. (If this is level 4 or 5 reporting to SIEP is required)
and
2. The potential risk. This requires the assessment od what the potential consequences might have been
and the likelihood of these consequences based on historical data. Together the potential consequence
and likelihood give the potential risk.
Example 1
As part of a HSE Management System development for a Terminal, the following scenario was identified. All
the tanks in a terminal are within bunds. One of the tanks is receiving gasoline from a tanker. The operation
is started at night. The storage tank is overfilled and a large vapour cloud is formed by vaporising gasoline. A
passing vehicle ignites the vapour cloud. A major explosion and fire develop which destroy 10 of the 15 tanks
at the terminal, cause extensive damage, and result in multiple fatalities. Such an accident has occurred
previously in this business sector, and has caused international impact.
The following actual consequence levels were identified: P5, A5, E3, R5
Example 2
The following scenario actually occurs in an operation. All staff of a 24-hour operation use the site/facility
canteen for meals. Poor food hygiene practices leads to contamination of food. Limitations in the
temperature control both in the preparation and storage pending serving fail to kill harmful bacteria and lead
to their multiplication. Significant proportions of staff on all shifts suffer food poisoning and are unable to
carry out their duties causing extensive loss of production.
The following actual consequence classification is proposed: P2, A5 due to lost production R4 national
reputation damage due to food poisoning in other business sectors.
Example 3
The following scenario actually occurs in an operation. A manufacturing facility discharges an effluent
containing a harmful substance, which is moderately toxic, very persistent and has a moderate potential to
bioaccumulate. To avoid damage, a concentration of 15 mg/l should not be exceeded in the effluent to the
local environment. Due to increased production levels, the concentration of the substance in the effluent
increases to about 200 mg/l for extended periods of time. As a result the maximum allowable concentration
of the substance in the receiving aquatic environment is exceeded. During routine investigations by the
authorities, the substance is detected in low concentrations in tissues of commercial fish. The fish are
deemed unsuitable for consumption. An investigation points to the effluent from the facility.
As the discharge occurs for extended time periods, it is deemed to have resulted in continual environmental
damage. Massive damage claims and international reputation damage due to similar environmental impacts
have previously occurred in similar companies in our business sector. The following consequence
classification is proposed: A5, E4, R5.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX C – EXAMPLES OF I NCIDENT P OTENTIAL
Example 1: During a weekly off loading operation from a supply vessel, a roof section of a container became
detached and fell into the sea striking the vessel on the portside. Containers containing chemicals are
delivered once a month. The potential consequence to people from this incident is a single fatality. This
corresponds to a consequence level of 4. A similar incident with fatal consequences occurred 3 years ago.
Several times per year local damage occurs as a result of loose items falling during off loading. The Incident
Potentials determined are:
C4(P) - fatality if a person was below falling roof.
D3(A) - equipment damage causes partial shutdown.
C1(E) - slight environmental effect
Example 2: Bus carrying contract cleaning staff fails to stop at security check and hits the security gate.
There were no injuries. There have been previous occasions in company when sudden stops from hitting
obstacles resulted in fractures or bruises. The following classifications re appropriate:
D3(P) - injuries from sudden stop: D2(A) - damage to vehicle or obstacles.
Example 3: Mechanical digger severed a live 415 Volt underground cable to a laboratory while excavating to
lay water pipes. There were no injuries.
B4(P) - possible electrocution of driver (one person): C2(A) - loss of ongoing experiment and equipment.
Example 4: Radioactive contamination is found on workbench during routine monitoring. The incident
would be classified:
B4(P) - internal contamination can lead to cancer, cases are known in industry
E3(E) - repeated breach of statutory rules
Example 5: While trying to jump start a car (12V) with a crane battery (24V) the car battery exploded,
spraying acid on operator. Actual consequences: damage to clothing and car – level 1.
C4(P) –possible permanent eye injury: C2(A) – damage to the car
Example 6: Filing cabinet drawers are opened adjacent to a busy access route in an office. The cabinet
overbalances and falls over, nobody is hurt but people could have been passing.
It has occurred once before in the Operating Unit that someone was seriously hurt by such an accident.
C3(P) - major injury to person passing
Example 7: During 'start-up' an exchanger joint fails releasing an estimated 5-tonne cloud of propane. The
operator jumped away and sprained his ankle.
B5(P) - possible multiple fatalities if the gas cloud had been ignited: B3(A) - damage in case of gas cloud
explosion.
Example 8: During the loading of diesel from a tank, the ship’s hose sprung a leak and the river was
contaminated. The contamination was noted within minutes by an outsider who warned the loading master.
The damage could have been much worse if it had not been spotted so quickly. Small leaks have occurred
earlier in the company, but not a major one.
B3(E) or D2(E) - spills with minor effects have occurred, more serious local effect has not occurred previously
in this company.
D2(R) - local population gets worried about frequent minor spills.
Demonstration of Risk Management: Management of this risk should be demonstrated in a HSE Case.
Example 9
A manufacturing site built pre-1970 contains significant quantities of brown and blue asbestos as fire
retardant and pipe insulation material. No survey has been carried out to identify and label all sources of
asbestos. The insulation may need to be disturbed for maintenance purposes and it is not uncommon for
minor work to be carried out by company maintenance staff without adequate precautions to prevent the
release of dust.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
Chronic exposure to asbestos fibres may result in mesothelioma, asbestosis or lung cancer. Cases known in
industry, and may also have occurred in our company (uncertain). Lacking other information, frequency is
classed as C rather than B.
The following risk classification is proposed: C4(P) C4(A) due to monetary liabilities to meet claims and
insurance premiums C4(R) resulting from potential negative publicity.
Risk Management: Appropriate risk reduction measures should be incorporated to reduce the risk to ALARP.
Demonstration of Risk Management: Management of this risk should be demonstrated in the HSE Management
System or in a HSE Case.
Example 10
It is decided to drill a number of oil wells in a remote and rather arid area and some 200 employees and
contractors move in and set up a camp. The local population uses ground water for various purposes e.g.
drinking water consumption, watering cattle and small irrigation projects. The company plans to extract
water for drinking water and for various drilling related purposes. The capacity of the aquifer is unknown but
it is possible that demand for ground water might exceed the capacity of the aquifer to recharge and water
levels may decrease below the level to support the usage by the local population. The population have
already voiced their concerns about potential loss of cattle and diminished crop yields to the local mayor. If
the concerns materialise it would result in a major environmental effect (reflecting social impact
considerations), significant reputation damage and moderate compensation claims. This has happened in
our industry sector, although not in this company.
The following risk classification is proposed: B4(E) C4(R) B3(A).
Risk Management - Appropriate risk reduction measures should be incorporated to reduce the risk to ALARP
(e.g. aquifer testing, control of water usage).
Demonstration of Risk Management: - Management of this risk should be demonstrated in a HSE Case or in the
HSE Management System, which should include controls identified from a Social Impact Assessment.
Severity
People
0 No health
effect/injury
1 Slight health
effect/injury
2 Minor health
effect/injury
3 Major health
effect/injury
4 PTD or 1 to 3
fatalities
5 Multiple
fatalities
CONSEQUENCES INCREASING LIKELIHOOD
A B C D E
Never Heard of Incident Happens Happens
heard of in has several several
in industry occurred times per times per
industry
in our year in year in a
Company our
Company
location
Assets
Environment
Reputation
No damage No effect No impact
Slight
damage
Minor
damage
Localised
damage
Major
damage
Extensive
damage
Slight effect Slight impact
Minor effect Limited
impact
Localised
effect
Considerable
impact
Major effect National
impact
Massive
effect
International
impact
Rev. 4.1 - June 2003 Page 17 of 30
A
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX D – EXAMPLES OF ‘WORK RELATED’ INCIDENTS
Transportation of Personnel
Work-Related
- Personnel travelling exclusively on Company business using public or private transport from their normal
place of residence or regular place of work to a temporary place of work.
- Personnel travelling in Company-owned or arranged transport.
- Personnel travelling from temporary accommodation e.g. base camp, hotel, guesthouse etc. to a place of
work.
Non Work-Related
- Company and Contractor personnel commuting between home and normal work place on other than
arranged transport.
- Non business-related travel in vehicles which are allocated to employees or Contractor personnel for their
unrestricted personal use.
- Company and Contractor personnel travelling (even at irregular hours) from their home to a regular
assembly point where they are collected in transport specially furnished by their employer.
- Personnel deviating from a business trip for personal reasons provided this does not breach Company
procedures.
Example 1: An employee has a Company vehicle for which he/she has unrestricted personal use. The
employee is due to attend a business meeting at Bandar Seri Begawan on a Tuesday morning. The employee
decides to leave on the Monday evening and break his journey by visiting friends. An incident occurs at that
time. It is not work-related.
Example 2: Another employee has to use a pool car for a similar business meeting but persuades the pool
supervisor to breach Company procedures and release the car on the Monday so he/she can visit friends. If
an incident occurs at that time it is work-related.
Notes
Where an incident occurs during travel in non-Company arranged transport, but the subsequent
investigation shows that Company transport should have been provided (because, for example incidents
during this activity could create a negative impact on the Company) then the incident should be considered
work-related.
Example 3: A ship’s crew member is travelling ashore by launch for an authorised recreational trip. The
employer is expected to arrange safe transport. Therefore, if an incident occurs, e.g. from a collision of the
launch with another vessel, any injuries sustained by the crew member would be considered
work-related.
Transportation of goods and equipment
Work-Related
- Transportation of goods and equipment within Company managed locations.
- Transportation of goods and equipment on Company owned or contracted transport (e.g. trailers, boats,
etc.)
- Transportation of goods and equipment readily identifiable as related to the Company operations. (E.g.
seismic vehicles, land drilling rigs etc.)
Non Work-Related
- Those transport activities which are not primarily dedicated to the supply of goods and equipment for the
Company or its Contractors and which are not readily identifiable as related to Company or its
Contractors and do not present a high risk to the Company (e.g. delivery of mail, use of road, air and sea
freight, Contractors engaged on multi deliveries.)
Transportation of Product
Work-Related
- All incidents, which occur to Company employees, and to, Contractors on Company premises or working
under the Company’s management control.
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Example: A road haulier is working under a long term contract to deliver a product on the Company’s
behalf. The haulier operates its own HSE-MS, has ISO 9000 and ISO 14001 accreditation and does not work
exclusively for the Company. An incident, which occurs during the time the haulier was delivering the
product for the Company, would normally be included in the Company statistics as would the exposure
hours.
- Transportation within Company-managed locations/by Company-managed pipelines.
- Transportation in Company branded road cars.
Non Work-Related
- Any incidents to Contractors not working under the Company’s management control.
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A PPENDIX E – EXAMPLES OF E XPOSURE H OURS
The following examples are intended to clarify the definition of Exposure Hours, and to give examples where
injuries are considered to be work related even though exposure hours are not being accumulated at the
time of the incident.
Example 1: A Company or Contractor employee being on board a manned platform, rig, standby boat,
supply vessel, construction or maintenance barge etc., but not on duty. The person is not engaged in work
tasks and the Company has no management controls in place other than housekeeping risks, hence, this
off-duty time is not counted as Exposure Hours. Nevertheless, an injury occurring during off-duty periods
would be considered a work-related injury if it is the result of failure of Company Controls.
Example 2: An employee sustains an injury in an offshore gymnasium in his off duty time. Management
controls had not been breached. The Injury is not work-related. If the controls had been breached, the
injury would be reportable but the Exposure Hours would not be accumulated.
Example 3: An office worker living in a suburban area who travels to work by public transport. This
person’s Exposure Hours would be the time spent at the office.
Example 4: An office worker living in a suburban area who travels to work in transport arranged by the
Company. This person’s Exposure Hours would be the time spent at the office. However, an injury occurring
to the employee in transport arranged by the Company would be considered a work-related injury.
Example 5: An employee is travelling on Company business but in the employee’s own time, i.e. outside the
employee’s normal working hours. This person’s Exposure Hours would be calculated on the basis of the
normal working week. Nevertheless, an injury occurring to the employee during such transportation would
be considered a work related injury.
Example 6: An employee working scheduled overtime. This person’s Exposure Hours would include all
overtime periods.
Example 7: An office employee working unscheduled extra hours. Whilst in theory such working time
should be treated as in Example 6, it is generally impracticable to keep records of such working time and,
hence, this person’s Exposure Hours should be calculated on the basis of the normal working week.
However, an injury occurring to the employee during such overtime working would be considered a workrelated
injury.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX F - ENVIRONMENTAL I NCIDENTS
The purpose of this section is to illustrate with examples types of Environmental Incidents, and in particular
to clarify what constitutes an environmental incident.
Definition and reporting of a spill
A spill has been defined as any unexpected loss to water or land of crude oil, condensate, feed stocks,
intermediates, products, or non-aqueous phase process materials irrespective of the amount recovered.
Definition does not include produced water spills.
Spills which are wholly contained by an impervious surface e.g. non-cracked concrete and good condition
bitumen bunds should be excluded. Clay and earth bunds are not considered impervious.
All spills irrespective of quantity should be reported to the line supervisor. Spills greater than 10 litres must
be reported in Omnisafe. Reporting of spills smaller than 10 litres in Omnisafe is discretionary and may be
limited to those where lessons can be learned from the incident. Spills less than 10 litres are typically
considered to have a minor effect on the environment. Spills of less than 10 litres are not at this time included
in the oil spill statistics.
Example 1: Crude oil spill during work on pipeline
A large diameter crude oil pipeline in the Terminal was being opened up for maintenance. Because the line
had not been adequately cleared beforehand, around 10m³ of crude oil spilled into the pipe track which was
impervious. The majority ran off into the site drains and was collected in the interceptor system and
recovered. None of the oil passed through the interceptor outfall to the stream or river.
As the spill had caused no environmental damage to the soil or water because it was effectively contained in
the imperbious pipe track and drains, it should still be investigated to prevent recurrence. However it would
not be considered as an environmental incident but must be captured in Omnisafe as an incident.
If the same spill had occurred under conditions of high rainfall and some of the oil had been discharged
through the outfall and recovered from the stream, the spill should then be counted as an environmental
incident.
Example 2: Diesel oil spill from ship
A vessel was berthed in port. Diesel oil was being transferred internally from shore to fuel settling tanks. The
settling tank overflowed spilling diesel onto the deck of the vessel and subsequently approximately 100 litters
went into the harbour. The Oil Spill Response Team was put into operation and the oil was dispersed within
an hour. The Authorities were notified.
This was clearly an environmental incident. The fact that the Authorities were involved, and the incident
attracted local media attention, means that it should also be considered as a reputation incident. To avoid
duplication, the incident should be classified and reported on basis of the highest rating.
Example 3: Waste paint tins
Three 5 litre tins of liquid paint all partly full were found in a general waste skip, which had been returned
from an offshore installation to a landfill site. The waste was detected by the landfill operator and constituted a
“waste non-compliance”. If it had gone into the landfill this would have breached statutory criteria and could
have led to further investigation.
Although it was spotted before it went in to the landfill, this incident should be considered as a minor breach
of statutory criteria, and therefore an environmental incident. As there had been previous non-compliances on
that landfill location which had come to the attention of the local press, the impact on reputation should also
be considered.
Example 4
A drum of chemicals is taken to a site ashore where drilling activities are being carried out. During the
process of moving this drum to a suitable storage place using a forklift, it is punctured and the chemicals leak
out into the ground.
In this incident the ground has been contaminated as a result of the loss of containment of the chemical and it
should therefore be considered an environmental incident.
Example 5.
During operations offshore a valve is inadvertently opened resulting in the unintentional release of
hydrocarbons to the atmosphere via the vent system.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
As it is now our policy not to vent this unintentional release should be considered an environmental incident.
Example 6.
A well is being drilled on land near a running stream. In order to manage the drilling mud a pit is correctly
constructed with a plastic lining and sandbags around the perimeter. However, during the night there is
extensive rain and the pit overflows into the stream.
This overflow of the pit into the stream must be considered an environmental incident as it has resulted in the
contamination of the stream.
Example 7.
During the removal of some redundant equipment and old batteries from an off shore facility the container
with its contents inadvertently falls into the sea.
This incident has two aspects, one is safety and the second is environmental. Both aspects should be
considered during the follow-up. From an environmental perspective consideration needs to be given to any
damage that may have been done to any underlying corals as well as the potential for any chemicals from the
batteries to harm the environment.
Example 8.
Land wells are provided with cellar to collect spills and grease contaminated liquid from the well assembly.
Liquid contained in the cellar is not an environmental incident as the cellar is designed for this purpose.
However, during heavy rainfall, well cellar can overflow to the surrounding area and could contaminate the
soil. This is a recordable environmental incident.
Example 9.
During the removal of a well cellar for de-commissioning and abandonment, the well cellar was backfilled with
ground water due to the high water table. The water was subsequently pumped out to the nearby river.
In this scenario if it is only groundwater that is being discharged to the nearby river then it does not constitute
an environmental incident. However, if there were any contamination of the groundwater from the cellar, then
the discharge of untested and contaminated water into the river would constitute an environmental incident
breaching our HSE Policy.
Example 10.
During the process of adding mercaptans to LPG some is vented into the atmosphere resulting in a pungent
odour being detected by a member of the public who phones in and complains about the smell. This should
be logged as an environmental incident as the emission of chemicals to the atmosphere that create a nuisance
to the public must be considered as ‘pollution’ of the environment.
Example 11.
Where a flare emits dark black smoke for an extended period (say 1 hour or more) this should be logged as an
environmental incident. Smoke is a pollutant and although a small puff may still be acceptable extended
periods of black smoke should not be accepted and should therefore be logged as an environmental incident.
Example 12.
Emissions from flares if unburnt can have a pungent odour, often of H2S. As a result if the pilots of a flare are
left unlighted this should be considered as an incident. Initially it should be seen as a safety incident but if
there are any complaints regarding odours it should also be logged as an environmental incident.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX G - COMPLAINTS FROM THE P UBLIC
Example 1: Smoking flare stack
A call received from a member of the public had complained that a vent flare at the Refinery Plant was
exceptionally smoky over the weekend. The public living near the Plant has always taken an interest in HSE
issues at the Plant, and the incident was discussed at the local community meeting. If on investigation this
proved to be a justified complaint, it should be included as an environmental incident. Because of the local
interest it would certainly count as a Reputation incident.
Public complaints can be entered into OmniSafe, via the web, as a separate incident category.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX H - OCCUPATIONAL I LLNESS R EPORTING
The Shell Group and Brunei Shell want all cases of occupational illness to be reported. The reason for this is
to determine whether illnesses are occurring because of work, and if so, to take measures to try and prevent
them.
What is an occupational illness?
An occupational illness is defined as any abnormal condition or disorder, other than one resulting from an
injury, which is caused or mainly caused by work.
Illnesses and injuries can include the same conditions (e.g. back pain), however the nature of the causative
event or exposure is different. An injury results from a single instantaneous event or exposure, while an
illness results from repeated events or exposures or exposure over a period of time.
Occupational illness categories and examples are listed in Appendix I – Occupational Illness Classification and
ExamplesAppendix I – Occupational Illness Classification and Examples.
Why are we asking you to report possible occupational illnesses?
Health, like safety, is a line management responsibility. It is impossible to manage a problem unless we have
data that give us an idea of the extent of the problem, it’s relative importance, and the resources required to
manage it successfully. Reliable illness data will enable us to learn about health problems among our staff and
to manage them better.
Data from illness reports will not be used as a basis for comparing performance between departments or
companies, or to penalise them in any way. The data is intended to be used by managers to help improve
health performance over time.
In order to have meaningful data on which to base decision making we need to ensure that as many
occupational illnesses as possible that occur are recognised and reported. Employees, supervisors and
managers should all have a strong index of suspicion and not hesitate to refer if they feel that an illness may
be work related. They do not have to be sure that an illness is work related but simply have to have a
suspicion.
Who is responsible for deciding whether an illness is occupational?
The final decision on whether an illness is occupational is made by a Brunei Shell company doctor with
adequate training or experience in identifying occupational illness.
What is the reporting process?
The Minimum Health Management Standards require that Brunei Shell companies have a reliable system in
place for recognising and identifying occupational illness.
Usually, if an employee or their supervisor or manager suspect an occupational illness, they will arrange an
appointment with a company doctor or medic (offshore). If the doctor or medic feels that there is a likelihood
of occupational illness then they will fill out the reporting form, titled “Occupational Health Illness Report”
(which can be found on the HML/8 website) and forward this to the Chief Medical Officer (CMO) at HML.
Guidance on determining whether or not a condition is an occupational illness can be found in Appendix 4 of
the Shell Group document “Incident Classification, Investigation and Reporting, Issue 2.0, Feb 2002”. If there
is any doubt, however, doctors or medics should report the case to HML.
Company medics and doctors need to be vigilant when treating workers for the possibility that an illness may
be work related. If they feel that an occupational illness is likely then they should report it to HML.
Some workers will consult a non company doctor for treatment, such as in a private clinic or government
hospital. If the doctor feels that the illness is occupational then ideally they should report directly to HML
(local clinics have received copies of the reporting form). Many will not, however, and if the worker or their
supervisor or manager is aware that the illness may be work related then they should arrange a further
appointment with a company doctor to assess this.
On receiving the reporting form the CMO at HML will arrange for a review by a Brunei Shell company doctor
with adequate training or experience in identifying occupational illness to verify whether or not the illness is
indeed occupational. The reviewing doctor may request more information from the referring person and may
arrange to see the worker for a further examination, and occasionally investigations.
Do contractors need to report occupational illnesses?
Companies contracting to Brunei Shell companies should have a similar system in place to ensure that
occupational illnesses that occur in contracting workers while working for Brunei Shell companies are
reported to HML.
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Contracting companies may choose to use the Brunei Shell company medics and doctors or they may use their
own medical staff. It is important however that they remain vigilant and ensure that as many occupational
illnesses that occur as possible are captured and reported to HML.
What happens after occupational illnesses are confirmed by HML?
Confirmed occupational illnesses are added to the occupational illness database, commonly referred to as
Total Reportable Occupational Illness, or TROI. All occupational illnesses are reported as part of the HSE
reporting process. They are reported in the categories listed in Appendix I – Occupational Illness Classification
and ExamplesAppendix I – Occupational Illness Classification and Examples. The cases are reported in a nonidentifiable
way. The total occupational illness cases per million exposure hours (work hours) is reported as
the Total Reportable Occupational Illness Frequency, or TROIF. The data are used to identify problems and
plan the management of these.
Confirmed cases are only investigated if the worker with the occupational illness gives their consent. The level
and type of investigation depends on the details of the particular case. The worker’s management will be
informed and involved in the investigation, hence the need to obtain the worker’s consent prior to the
investigation. Significant illness cases (defined as those resulting in permanent total disability or death) will
be notified to the business director within 24 hours and the investigation will include a tripod analysis.
Non-accidental deaths.
Non-accidental deaths involving company or contractor employees while at work will be notified to the
business by the CMO within 24 hours and investigated. The same applies to non-accidental deaths outside
normal working hours where there is a reason to suspect a relationship between the death and events or
exposures at work.
Examples of non-accidental deaths that are work related include:
• Where an individual died as the result of exposure to toxic chemicals while at work.
• Where an individual with a major heart problem was not fit to perform the work he was doing,
resulting in his death.
• Where an individual committed suicide and his depression was found to be due to work related
stress factors.
The investigation will follow the guidance included in section 4.2 of the Shell Group guide “Incident
Classification, Investigation and Reporting, Issue 2.0, Feb 2002”. The investigation will aim to establish
whether the death was caused by work (in which case it will be recorded in the statistics as work related) and
whether there are any contributing factors which can be remedied.
Communication of lessons learned.
Where an investigation of an illness reveals a significant learning potential, the lessons should be
communicated within the business unit and where applicable to the business. “Significant learning
potential” is defined in section 3.7 of the Shell Group guide “Incident Classification, Investigation and
Reporting, Issue 2.0, Feb 2002”.
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Assessment of
contractor by
contracting company
doctor (if not using
Brunei Shell medic or
doctor)
SUMMARY OF REPORTING PROCESS
Case added to
occupational illness
database for
reporting
Worker/ supervisor/ manager suspects
occupational illness
and/or
Assessment by
Brunei Shell
company medic or
doctor
Medic or doctor feels
that occupational
illness likely
Reporting form
“Occupational Health Illness
Report” completed and
forwarded to CMO at HML
Occupational
illness confirmed
Case
investigated
Assessment by
non-company
doctor (e.g. govt.
hospital or private
clinic)
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX I – OCCUPATIONAL I LLNESS C LASSIFICATION AND
E XAMPLES
Note: The list of examples below is not all inclusive.
• Infectious and parasitic diseases:
Food poisoning, legionnaire’s disease, malaria, dengue fever, hepatitis.
• Skin diseases and disorders:
Dermatitis, chrome ulcers, oil acne.
• Respiratory conditions due to dust or toxic agents:
Asthma, rhinitis, bronchitis, asbestosis, silicosis, allergic alveolitis.
• Poisoning (systemic effects of toxic materials):
Poisoning by lead, mercury, arsenic, cadmium, carbon monoxide, hydrogen sulphide, solvents,
pesticides (and many others).
• Upper limb and neck disorders:
Tendonitis, bursitis, repetitive strain injury, raynaud’s phenomenon.
• Back problems and lower limb disorders:
Chronic back pain, sciatica, tendonitis, bursitis.
• Cancers and malignant blood diseases:
Lung cancer, mesothelioma, bladder cancer, leukaemia, lymphoma, skin cancers.
• Disorders due to mental stress:
Depression, anxiety disorders, stress, recurrent tension headaches, irritable bowel syndrome.
• Noise induced hearing loss:
As defined in the SHC Noise Guide.
• Other illnesses and disorders:
Heatstroke, heat exhaustion, sunburn, hypothermia, seasickness, welding flash and other eye
conditions, vibration white finger, caisson disease, benign tumours, non-cancerous blood disorders.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX J - MEDICAL T REATMENT AND F IRST A ID C ASES
Medical Treatment Case (MTC)
The following examples are generally considered medical treatment:
• Treatment of infection
• Application of antiseptics during second or subsequent visit to medical personnel
• Treatment of second or third degree burns
• Application of sutures (stitches)
• Application of butterfly adhesive dressings or steri strips in lieu of sutures
• Removal of foreign bodies embedded in the eye
• Removal of foreign bodies from wounds, if the procedure is complicated because of depth of embedment,
size, or location
• Use of prescription medications, except a single dose administered on the first visit for minor injury or
discomfort.
• Use of hot or cold soaking therapy during the second or subsequent visit to medical personnel
• Application of hot or cold compresses during the second or subsequent visit to medical personnel
• Cutting away dead skin (surgical debridement)
• Application of heat therapy during the second or subsequent visit to medical personnel
• Use of whirlpool bath therapy during the second or subsequent visit to medical personnel
• Positive X-ray diagnosis of fractures, broken bones, etc.
• Admission to a hospital or equivalent medical facility for treatment or observation.
Loss of consciousness
If an employee loses consciousness as the result of a work-related injury, the case must be reported as least as
a MTC, no matter what type of treatment was provided. The rationale behind this is that loss of consciousness
is generally associated with the more serious injuries.
First Aid Cases (FAC)
The following examples are generally considered first aid treatment, i.e. one-off treatment and subsequent
observation of minor injuries:
• Application of antiseptics during the first visit to medical personnel
• Treatment of first degree burns
• Application of bandages during any visit to medical personnel
• Use of elastic bandages during the first visit to medical personnel
• Removal of foreign bodies not embedded in eye if only irrigation is required
• Removal of foreign bodies from wound; if the procedure is uncomplicated, and is, for example by tweezers
or other simple technique
• Use of non-prescription medications and administration of a single dose of prescription medication on the
first visit for a minor injury or discomfort
• Soaking therapy on the initial visit to medical personnel or removal of bandages by soaking
• Application of hot or cold compresses during the first visit to medical personnel
• Application of ointments to abrasions to prevent drying or cracking
• Application of heat therapy during the first visit to medical personnel
• Use of whirlpool bath therapy during the first visit to medical personnel
• Administration of tetanus shots or boosters. However, these shots are often given in conjunction with
more serious injuries. Consequently, injuries requiring these shots may be included in the statistics for
other reasons.
• Negative X-ray diagnosis or laboratory analysis, unless they lead to further treatment.
• Observation of injury during a visit to medical personnel
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
A PPENDIX K – SEVERITY (OR CONSEQUENCE) RATING
Severity rating for People
No Description
0 No injury or damage to health
1 Slight injury or health effects (including first aid case and medical treatment case) – Not
affecting work performance or causing disability.
2 Minor injury or health effects (Lost Time Injury) – Affecting work performance, such as
restriction to activities (Restricted Workday case) or a need to take a few days to fully recover
(Lost Workday case). Limited health effects which are reversible, e.g., skin irritation, and food
poisoning.
3 Major injury or health effects (including Permanent Partial Disability and Occupational
Illness) – Affecting work performance in the longer term, such as a prolonged absence from
work. Irreversible health damage without loss of life, e.g. noise induced hearing loss, chronic
back injuries, sensitisation, hand/arm vibration syndrome, repetitive strain injury.
4 Permanent Total Disability or one to three fatalities – From an accident or Occupational
Illness. Irreversible health damage with serious disability or death, e.g., corrosive burns, heat
stroke, cancer (small exposed population).
5 Multiple fatalities – From an accident or Occupational Illness e.g., chemical asphyxiation or
cancer (large exposed population).
Severity rating for Asset Damage
No Description
0 Zero Damage
1 Slight Damage – No disruption to operation (cost less than $10,000)
2 Minor Damage – Brief disruption (cost less than $100,000)
3 Local Damage – partial shutdown (can be restarted but cost up to $500,000)
4 Major Damage – Partial operation loss (2 weeks shutdown costs up to $10,000,000)
5 Extensive damage – Substantial or total loss of operation (cost in excess of $10,000,000)
The total cost (in US$) = consequential (downtime or deferment) cost + repair cost
Severity Rating for Impact on Reputation
No Description
1 Slight Impact – Public awareness may exist, but there is no public concern.
2 Limited Impact – Some local public concern. Some local media and/or local political attention
with potentially adverse aspects for company operations.
3 Considerable Impact – Regional public concern. Extensive adverse attention in local media.
Regional/national policies with political attention. Adverse stance of local government and/or
action groups.
4 National Impact – National public concern. Extensive adverse attention in the national media.
Regional/national policies with potentially restrictive measures and/or impact on grant of
licenses. Mobilisation of action groups.
5 International Impact – International public attention. Extensive adverse attention in
international media. National/International policies with potentially severe impact on access to
new areas, grants or licences and/or tax legislation.
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Module 30 - Incident Classification and Reporting BSP-02.01.05-procedure-1621
Severity Rating for Environment
It is important to stress that the size of environmental release is not always comparable with environmental
impact (e.g. 10 m3 of oil spilt in the ocean could have a different effect to 10m3 spilt in a small river). Also, the
significance of a release varies between local and global effects (e.g. an air emission incident might have
negligible environmental impact, but might be a clear breach of prescribed internal standards). A degree of
judgement is thus required.
If in doubt interpreting the severity of environmental consequence, please contact HSE/5 for advice.
No. Description Spills Prod
Water
0 Zero effect - No environmental damage. No
change in the environment. No financial
consequences.
1 Slight effect - Local environmental damage.
Within fence and within systems. Negligible
financial consequences. Compliant with
statutory limits or prescribed internal
standards.
2 Minor effect - Contamination. Damage
sufficiently large to attack the environment.
No permanent effect on the environment.
Minor breach of statutory limits or prescribed
internal standards.
3 Local effect - Limited loss of discharges of
known toxicity. Affecting neighbourhood.
Clear breach of statutory limits or prescribed
internal standards.
4 Major effect - Severe environmental
damage. The company is required to take
extensive measures to restore the
contaminated environment to its original
state. Extended breach of statutory limits or
prescribed internal standards.
5 Massive effect - Severe environmental
damage or severe nuisance extending over a
large area. In terms of commercial or
recreational use or nature conservancy, a
major economic loss for the company. Major
breach of statutory limits or prescribed
internal standards.
Venting / Flaring
Rev. 4.1 - June 2003 Page 30 of 30
-
Very small
spill
1 m 3
Moderate
spill
>10 m 3
Large spill
>100 m 3
Very large
spill
>1000 m 3
Oil in
water
> 40 ppm
Oil in
water
> 100 ppm
Oil in
water
> 1000 ppm
Uncontrolled
event
e.g. vent pipe leak,
maintenance
release
Smoky flare
Continuous for over
one (1) hour
Operational
excursion
without
permission/covered
by variation
Notes:
Guidance on quantification and fate of oil spill for offshore spill is given in
� BSP Emergency Oil Spill Procedure BSP-02-procedure-0660
Guidance on interpreting operational excursions for air emission incidents (e.g. compressor trips) is given in
� BSP Venting & Flaring Policy & Guidelines BSP-02-policy-1428
� BSP Venting & Flaring Guidelines (Operations) BSP-71-guidleine-02
Any excursions from operating guidance is a variation and must authorised by line supervision in accordance
with
� Variance Procedure BSP-71-procedure.01