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HSE Regulatory Compliance Training
- 1. HSE Regulatory Compliance Verification Training Pack Module 2 for HSE Advisors & Line HSE Focal Points
- 2. Training Pack Module 2 As part of its Business Principles and Policies, SPDC is required to comply with all the relevant HSE Laws and Regulations enacted by the Federal, State and Local Governments of Nigeria. In addition to this, SPDC is required to comply with some international laws, conventions and protocols to which Nigeria is signatory; and all limits, criteria and other requirements subscribed to by SPDC, SIEP and the Shell Group, including international standards where applicable. Introduction:-
- 3. WHAT IS COMPLIANCE ? AN ACT OF YEILDING (PROCEDURES,POLICIES,STANDANDS ETC) SUBMISSION ( LAWS ,ACTS,DECREES ETC) AGREEMENT (PROTOCLOS,CONVENTIONS,TREATIES ETC)
- 4. DEFINITION Statute , ordinance , judicial decision , executive order , or a regulation having the force and effect of law , that determines the legal standing of a case or issue . Applicable legislation are Statutes/regulations that are relevant or peculiar to a particular operation .
- 27. Oil Producing Trade Sector (OPTS) Structure Executive Management Committee SPDC Rep : Basil Omiyi Environmental & Safety Committee SPDC Rep: Carol Macauley SNEPCo Rep: Justice Derefaka Gas Flare Down Working Group JV Rep: Abdul Yammama SPDC Rep: Catherine Osharode Production Water Disposal Study Working Group JV Rep: SPDC Rep: Carol Macauley Air Quality Study Working Group JV Rep: SPDC Rep: Abdul Yammama NESREA Working Group JV Rep: SPDC Rep: Carol Macauley Legal Committee EPG Rep: TBA External Stake Holder Committee EPG Rep: TBA Others
- 28. HSE Regulator Focal Points: No HSE Regulation Focal Point 1 MOSR All Members Of HSE Compliance Team 2 EGASPIN All Members Of HSE Compliance Team 3 FMEnv Remi NCAA Lucky 4 NNRA Abdul 5 NOSDRA Caroline 6 NCC Tele 7 NAMA Lucky 8 Oil and Gas Pipelines Regulations Tele 9 NMA Chituru 10 FML Caroline 11 Explosives Act Chituru
- 30. Steps involved in Conducting Reg. Compliance verification/ Audit. What is Reg. Compliance Verification:- Compliance Verification Exercise is a monitoring process as it seeks to assess how a team or facility is complying with the regulatory requirements guiding its operations at any point in time. Since new regulations will constantly be evolving, the steps set out here would be considered generic irrespective of which regulation is being monitored or verified for compliance. Planning The planning stage shall involve preparation of tracking matrices or such other simplified checklists for the Regulations to be verified and the publication of an agreed verification schedule.
- 37. Adequate commitments and human resources are critical factors in the success of the internal Regulatory Compliance verification process. It is therefore essential that the regulatory compliance verifiers/auditors/inspectors receive as a minimum, appropriate training, either as auditors/ internal auditors or through a programme of shadowed and observed auditing/inspection under a lead auditor in line with EP2005-0180 and associated Work Instructions. A satisfactory completion of a minimum of 3 of these verification audits would guarantee confirmation as a competent compliance inspector by the HSE Manager. Competence Requirement for compliance inspectors
- 38. Application of Skills and Personal Judgment Unlike other types of audits where the auditor could use his judgment and audit skills in grey areas, statutory compliance audit is specific and only subject to legal / regulatory control. As such, witnessed evidence shall either be compliant or non-compliant. Where there is a disagreement between the Auditee and Auditor, the understanding of the Regulators shall apply. Steps involved in Conducting Reg. Compliance verification/ Audit Cont.
- 44. Example of a tracking Matrix
- 45. Calculation for Percentage Compliance with Formula: % Compliance = number of complied requirements X 100 Total number of applicable requirements
Notes de l'éditeur
- Basically, procedures, policies and standards are internal frameworks that guide the way our business should be conducted.That is adhering to internal policies and procedures. Laws, Acts & Decrees are created by the government to inform us how well the government think we should run our business and as it affects our environment. We need to obey the laws in order to retain our LTO. Conventions & Treaties are agreement by organisations to adhere to certain policies as it affects a particular industry. Audits & Verifications are internal means by which Shell take stock of its operations to know their level of compliance to Laws, Standards , Conventions etc.
- Types : This means the type of operation that is being carried out by the asset team e.g drilling, production, Seismic e.t.c. Terrain : This is a very important aspect to consider in selecting the set of regulation that will be applicable to an operation. The limit for certain monitoring parameter in the land is quite different from that of swamp and off shore. When we talk about terrain we are considering where the operation is sited i.e land, swamp or offshore. State of Operation : The state that a facility is situated also determines the type of applicable legislation that will affect the facility. Each state has their own set of regulation. Therefore as a company, we have to comply with all regulation and standard as applicable to our operations