MPcp HSSE Guidelines

(1)

HSSE guidelines

(2)

These guidelines for HSSE have been developed as a supplement to MPcp.

They provide the structure for ‘how we do HSSE’ in projects, supported by

tools and examples from BP projects around the world.

The facilities that we operate in the future are determined by the projects that

we create today. The HSSE guidelines provide guidance on how we select,

design, build, and start-up facilities that are safe, meet our environmental

expectations and are healthy for our workers and surrounding communities.

Through the consistent application of these guidelines, developed from SPU

best practice, we will ensure that our HSSE goals are delivered.

Neil Shaw

technology vice president - projects & engineering

MPcp guidelines – overview 7

1 HSSE – summary 13

2 HSSE leadership 19

2.1 Introduction 19

2.2 Strategy and Goals 20

2. Roles & Responsibilities, Resources & Organization 21

2.4 Stakeholder Alignment 21

2.5 Performance Review 21

HSSE leadership roadmap 22

 HSSE management 27

.1 Introduction 27

.2 Project HSSE Management Plan 28

. Project Planning 30

.4 Risk Management 30

.5 Competency and Training 33

.6 Incident Reporting and Investigation 33

.7 Crisis Management and Emergency Response 33

.8 Regulatory and Compliance 34

.9 Document Management 35

.10 Action Tracking 35

.11 Management of Change (MoC) 36

.12 Knowledge Management 36

.1 Monitoring, Assurance and Verification 36

HSSE management roadmap 40

4 Health 47

4.2 Scope 47

4. Health Resources 48

4.4 Health Impact Assessment (HIA) – Outside the Boundary Fence 49

4.5 Workplace Health Risk Assessment 49

(3)

4.7 Crisis Management and Emergency Response 50

4.8 Contracts and Procurement Strategy 51

4.9 Human Factors (HF) and Ergonomics 51

health roadmap 52

5 Design safety 59

5.2 Scope 59

5. Roles and Responsibilities 61 5.4 Design Hazard Management (DHM) Overview 61 5.4.1 Design Hazard Management (DHM) Process 62 5.4.2 Inherently Safer Design (ISD) 62 5.4. Safety Critical Design Measures (SCDM) and Performance Standards 63 5.4.4 Study Programme and Action Management 63 5.4.5 Case for Safety (CfS) in Design and Operations 64 5.5 Integrity Management 64

design safety roadmap 66 6 Security 73 6.1 Introduction 73 6.2 Risk Assessments 73 6. Roles, Responsibilities, Resources, Training and Organization 74

6.4 Philosophy and Plan to Mitigate Assessed Risk 74 6.5 Technical Security Design and Response 75

6.6 Voluntary Principles on Security and Human Rights 75

security roadmap 78 7 Environmental and social 89 7.1 Introduction 89 7.2 Scope 90

7. Social Guidelines 90 7.4 Environmental Impact Management Process (EIMP) 90 7.5 Environmental Performance Requirements 91 environmental roadmap 92 8 construction contractor HSSE management 95

8.1 Overview 95 8.2 Planning 95 8. Pre-qualification 96 8.4 Selection 97 8.5 Pre-mobilization 97 8.6 Mobilization 98 8.7 Execution 99 8.8 Demobilization 99

8.9 Final Evaluation and Close-out 100

construction contractor HSSE management roadmap 104

9 resources 111

9.1 Projects Cyber Librarian 111

9.2 HSSE training 111

9. Tools and examples 111

(4)

Our goal is to generate business value by delivering projects, which are efficient in both capital investment and long-term operation. We will do this by consistently creating distinctive projects and delivering them with world class execution. The Major Projects common process (MPcp) is a key part of the overall project system which is designed to support Performance Units in pursuit of this goal. This system includes our people and processes, supported by networks and functional authorities, guidelines, tools and good examples.

The MPcp document lists expectations, for each of the ten elements of Projects Excellence, which shall be met before proceeding to the next stage of the project. Associated with each expectation are a number of attributes which describe and support the achievement of that expectation. These attributes are intended to guide project teams in developing their action plans for the stage and to drive consistent good project performance.

The MPcp document also describes the governance process, including functional attestation, required to meet the Group Investment Assurance and Approvals Process (GIAAP).

Guidelines have been written, for each of the main project disciplines, to provide more detailed support to project teams in the achievement of MPcp expectations. These Guidelines describe the framework and processes which discipline practitioners are expected to follow. They have been compiled from the wisdom and experience which exists in the company. They represent the current view of discipline requirements and good practice, which we want to be applied consistently across our range of projects. They have been entitled Guidelines deliberately because we want people to think about their application and not just follow them by rote.

Over time we expect people to identify improvements in the practices described in these Guidelines but we want such improvements to be introduced in a planned and systematic way. For this reason each of the Guidelines has clear ownership by the leader of the relevant project network. A project team should adhere to the Guidelines unless it perceives significant material benefit from departing from them. Where it does perceive such a benefit it should review the proposed departure with the relevant Network Leader beforehand, both to obtain challenge to its view but also to ensure that the experience is visible and can be readily captured for the benefit of others if the departure does lead to improved practice.

(5)

The responsibility for implementing the Guidelines lies with Team leaders within Performance Units. It is their further responsibility to ensure that proposed departures from the Guidelines and improvements to them are raised promptly with the relevant Network Leaders.

figure 1 MPcp and related guidelines

Health, Safety, Security and Environmental (HSSE) excellence is recognized as a key component of our strategy to become the #1 Projects Operator by creating distinctive projects with world class execution. The HSSE Guidelines are the ‘BP way’ of how we do projects that codifies HSSE best practice and enables knowledge to be shared to achieve best-in-class HSSE performance – we will use them everywhere.

Project Principles

App Sel Def Exe Ope Dashboards

MPcp Elements

• HSSE

• Subsurface Resource Characterization • Technology, Engineering &

Technical Definition • Project Management & Execution • Procurement & Supply Chain

Management • Project Services • Organizational Capability • Commissioning & Operational

Readiness

• Performance & Risk Management • Knowledge Management MPcp Guidelines • HSSE • Appraisal & Pre-development • Engineering & Quality Mgt. • Project Management & Execution • Procurement & Supply Chain Mgt. • Project Services

• Organizational Design

• Commissioning & Operational Readiness • Risk Management

• Knowledge Management

Resources • Tools • Templates • Examples

The HSSE Guidelines are structured around four levels (figure 2):

figure 2 structure of the HSSE Guidelines

Level 1 – The HSSE Strategic Knowledge Areas

Sections 2 - 8 of the guidelines are organized around the seven HSSE strategic knowledge areas (SKAs). Each section provides an overview of the knowledge area aligned with a roadmap and lists the MPcp HSSE expectations that must be met before proceeding to the next stage of the Project.

Examples Tools HSS E Guidelines book HS S E Guidelines CD Knowledge Areas HSSE Leadership HSSE Management Health Design Safety Security Environmental and Social Construction Contractor Management

Level 1: The knowledge areas covered in the

HSSE Guidelines

Level 2: The Roadmaps - Activities to be

completed for each Knowledge Area and key stages of Project development

Level 3: Tools to assist in completing the

activities for each of the key stages

Level 4: Examples from projects

(6)

Level 2 – The Roadmaps

A roadmap is included at the end of sections 2 - 8 of the guidelines. The roadmap for each knowledge area is organized around the four key stages of project development (Appraise, Select, Define and Execute). They describe activities that should be considered before proceeding to the next stage of the project. The actions covered are extensive and some may not be relevant to every project. However, all actions should be considered prior to rejection. Addressing the respective activities for each stage will support the achievement of the stage objectives as well as provide an excellent foundation for the work of the subsequent stage.

Level – Tools

Tools to assist HSSE professionals, engineers and managers in completing the activities outlined in the roadmaps are located on the companion CD to the HSSE Guidelines and are also available at the ETP & Projects Library located at

http://pelib.bpweb.bp.com. Level 4 – Examples

HSSE examples from BP Major Projects are also located on the companion CD and at the ETP & Projects Library.

The tools and examples are intended to guide the project teams in completing the activities, driving consistency, and incorporating best practices and lessons learned. The HSSE Guidelines provide the structure for ‘how we do HSSE’ in projects, supported by tools and examples that will be invaluable for not only HSSE professionals, but also managers, engineers and other project personnel.

(7)

©2007 BP International Limited MPcp HSSE Guidelines 1 The HSSE Guidelines are aligned with the Projects & Engineering strategy, the BP Group 5 Year Plan and the Safety & Operations agenda. They seek to:

• Provide a common language and process to guide HSSE in projects. • Define HSSE excellence in terms of activities and good practice. • Incorporate lessons learned from previous projects.

• Provide HSSE professionals, engineers and project managers with tools and examples to assist in delivery of HSSE excellence.

Full implementation of these guidelines will result in enhanced project performance, protection of our reputation and improvement of our liability profile.

HSSE Leadership

‘HSSE leadership starts at the top, or it does not start at all.’

Management’s strong, visible and demonstrated commitment and leadership is a critical component of HSSE excellence in projects. Management is accountable for implementing these guidelines.

During the CVP Appraise and Select stages, management clearly defines and communicates to all project team members (BP and contractor) the HSSE strategy that defines the overall project HSSE philosophy, principles and goals. The HSSE strategy is fully considered when confirming the fundamental viability of the project, selecting the development concept, engineering the facility and during commissioning and start-up. Inherently safe design should be a critical factor in concept selection and can result in a simple to execute and operate design; or, if we get it wrong, a contrived design that is inherently difficult to operate safely.

HSSE must be led and managed like all other aspects of the business, and by the same people who manage these aspects – project management and members of the line organization. HSSE success is determined by what management does – not what they say – and managers and supervisors are held accountable for HSSE performance. HSSE is integrated into everything.

(8)

HSSE Management

HSSE Management describes the organization, plans and systems that should be developed and implemented to achieve the HSSE goals defined by project leadership. A key component of HSSE management is risk management. Effective management of HSSE risk is recognized across all BP segments as a key component for the delivery of world class projects.

Key HSSE management activities include the development of an HSSE risk management strategy (as part of the overall project risk strategy), and the development of a Project HSSE Management Plan. The HSSE Management Plan describes the key management systems that the project will use to manage the risks.

Getting HSE right (gHSEr) is the BP HSE Management System Framework which

supports the HSE Expectations to be adopted by all BP managers. Managers are accountable for putting in place appropriate documented systems and processes for each Expectation, for ensuring continuing progress towards Project HSSE goals and targets, and for confirming that these processes are effective via the HSSE Assurance process.

gHSEr is still the current framework for managing HSSE and should continue to be used until it is replaced by an Operating Management System (OMS). When the OMS is developed, the content of gHSEr will be fully incorporated.

Project HSSE Reviews (PHSSERs) are a mandatory element of a project’s assurance strategy and are specifically mandated by the Integrity Management Group Standard. PHSSERs heighten the awareness of HSSE risks and help make HSSE an integral part of the gated decision and approval process for projects within CVP.

Health

Health Risk Assessment (HRA) and health risk management are essential to ensure that personal, occupational, and environmental health risks in projects and operations are managed properly. The Health section of the Guidelines is focused on identifying and managing health risks and driving compliance with local laws and BP standards. Appraise and Select stage activities are focused on identifying and confirming key health risks and developing a health plan for the project. Key health risks in both the project and operational phase are identified through a review of regional health

risks and completion of a Health Impact Assessment (HIA). Potential health impacts should be considered during concept selection, especially when deciding where to locate facilities.

During the Define and Execute stages, a health organization is put into place and the Health Management Plan is updated to include planning for Execute stage activities (e.g. construction). A detailed Health Risk Assessment (HRA) is conducted to identify potential health impacts on workers and health considerations are incorporated into the design of the facility. Execute stage activities are focused on implementing the Health Management Plan and planning for the Operate stage.

Design Safety

Excellence in design safety is an engineering responsibility and is best achieved through Design Hazard Management. This process involves major hazard identification, evaluation and continuous risk reduction through design safety measures. Design Hazard Management is underpinned by four engineering activities:

Inherently Safer Design

Safety Critical Design Measures and Performance Standards

Safety Study Programme

Case for Safety

Managing hazards in design involves eliminating or minimizing major accident hazards at the source, and preventing those that remain from becoming major accidents. It also involves the provision of sufficient design integrity to control the consequences of a major accident to reduce severity and potential escalation, while providing mitigation and protection for personnel and key facilities from the effects (e.g. heat, smoke, gas, toxic fumes, etc.).

Security

The Group Security Policy underpins and establishes the basis for how BP manages global security. Our fundamental mission is to provide a safe and secure work environment by protecting ourselves, our assets and our operations against risk of injury and loss, or damage from criminal, hostile or malicious acts.

(9)

One of the key expectations of BP’s Group Security Policy is that security will be taken into consideration during the appraisal, selection, definition and execution of all new capital projects. As the project moves forward, project requirements will change. These adjustments should not prevent security analysis from taking place early, ideally at the Appraise stage. Security risks and plans will inevitably change; indeed early planning will reveal important areas for reconsideration. Project Managers should consider security as early as possible in the process. Bolting security onto a project rather than building it in can be, at best, expensive and, at worst, fatal.

Environmental and Social

The OMS Practice, Environmental Requirements for New Projects, is the basis for the Environmental and Social section of the guidelines. It is a full life-cycle process based on four fundamental principles:

We will identify and understand our impacts.

We will consult with others.

We will design to avoid adverse impacts and minimise use of natural resources.

We will reduce the adverse residual impacts of our wastes, emissions and discharges.

The early screening of environmental risk brings clarity and transparency to our decision making process and the Environmental Performance Requirements set consistent standards for delivery across the businesses. The Environment and Social section describes the processes to ensure that BP exhibits performance-driven management and that BP is consistent and transparent wherever the company operates.

Construction Contractor HSSE Management

Construction Contractor HSSE Management describes an eight-phase process for contractor management consistent with the OMS Practice for Working with

Contractors. Risk identification is a key part of the process and is a key factor in

determining contracting strategy. Active participation by BP and the contractor(s) are essential to achieve excellent HSSE performance.

During construction, there are four main tasks that leadership must implement—by doing, not saying—if the project is to achieve best in class HSSE performance:

Define and clearly communicate the HSSE expectations to each contractor and sub-contractor bidding on the job.

Consider HSSE as a critical factor in the evaluation of bids and selection of contractor(s).

Reinforce the contract HSSE requirements with the successful bidder(s) to ensure that those accountable for managing the project understand the expectations.

Manage performance of construction activities through site visits, proactive involvement in HSSE practices, enforcement of the HSSE requirements of the contract, and close out the construction phase with a post-contract joint evaluation of the contractor’s and BP’s HSSE performance.

(10)

2.1 Introduction

‘Everybody who works for BP, anywhere, is responsible for getting HSSE right. Good HSSE performance is critical to the success of our business.’

Lord Browne, January 1999

Strong, visible and demonstrated management commitment and leadership is a critical component of HSSE excellence in projects. The HSSE Guidelines are the ‘BP way’ of how we do projects – we use them everywhere. Management is accountable for ensuring that these guidelines are implemented.

The attitude of managers and supervisors towards HSSE plays a vital role in achieving excellent HSSE performance. Examples of HSSE Leadership behaviours that promote great HSSE performance are:

Set high standards

Regularly explain HSSE expectations and verify understanding and compliance.

Focus on sustainable performance improvements in HSSE and measure progress via leading and lagging indicators.

Continually emphasize that schedule will never compromise HSSE.

Consistently recognize good HSSE behaviour and performance. Tackle poor performance.

Communicate openly

Talk face-to-face with staff about HSSE performance and concerns.

Regularly vary communication methods to get the HSSE message across.

Keep the HSSE message simple and direct.

Provide prompt, honest feedback on concerns raised by the workforce. Show concern for people

Ensure effective mechanisms exist for people to raise HSSE and welfare concerns.

Be approachable for informal discussions about HSSE concerns.

Be personally involved in incident investigation to understand root causes and communicate learning.

Proactively involve others

Ensure adequate HSSE resources and training are available; allocate sufficient time and priority for HSSE initiatives.

Take personal action to improve HSSE performance by showing enthusiasm, decisiveness and support.

(11)

Regularly visit worksites and conduct ASAs

Confirm that BP’s HSSE expectations are communicated to the workers.

Ensure that the BP Control of Work (CoW) Standard is fully implemented on BP premises and that effective CoW programmes are implemented on contractor sites.

Confirm adequate BP presence and contractor supervision onsite to support and monitor work.

Review pre-job risk assessments to ensure that they are task specific; available in the language(s) of the workers performing the work and that the workers are aware of the hazards.

Although management is ultimately accountable for HSSE performance, BP people at all levels in the project organization are responsible for leading and engaging the workforce in meeting our health, safety, security, technical integrity and environmental goals and objectives. HSSE is integrated as part of everything we do.

The foundation for HSSE excellence in operations begins with creating distinctive projects – choosing the right projects to build during the Appraise and Select stages. During Define and Execute, we design the facility for inherently safe and environmentally sound operations, then build, commission and start-up the facility safely.

MPcp Expectation

(Appraise – Execute) Management commitment to HSSE is strong, visible and demonstrated.

2.2 Strategy and Goals

During the CVP Appraise and Select stages, management clearly defines and communicates to all project team members (BP and contractor) the HSSE strategy that defines the overall project HSSE philosophy, principles and goals. The HSSE strategy is fully considered when confirming the fundamental viability of the project, selecting the development concept, engineering the facility, and during construction, commissioning and start-up.

2. Roles & Responsibilities, Resources & Organization

Management establishes clear HSSE roles and responsibilities for all project team members and allocates competent HSSE resources, and where necessary, provides specialist expertise to support the line. Recruitment, selection and placement processes ensure that personnel are qualified and competent to perform their tasks. Sufficient thought should be given early in the project to the composition of the HSSE team and the timing when the team members should be committed to the project. There is a strong bias that the Project HSSE Manager is BP staff.

2.4 Stakeholder Alignment

Open and proactive communications are established and maintained with employees, contractors, regulatory agencies, public organizations, communities and JV partners regarding the HSSE aspects of the project. We value the importance of community awareness and will actively engage in dialogue with various stakeholders to maintain public confidence in the integrity of our projects and our commitment to HSSE performance.

2.5 Performance Review

HSSE performance metrics (both inputs and outputs) are established, communicated and understood throughout the project organization. Project management regularly reviews the HSSE performance metrics to determine progress against objectives and targets and what management system changes are necessary.

The Integrity Management Standard requires that the Performance Management System for all projects shall require formal reviews of health, safety, integrity, security and environmental impacts carried out at key stages. For major projects, GP 48-1

(12)

The actions covered are extensive and some may not be relevant to every project; however, all actions should be considered prior to rejection.

Set HSSE expectations for project team membersfor the Appraise and Select stages.

Define HSSE roles and responsi-bilitiesfor project team.

Roles and

Responsibilities

APPRAISE SELECT

Strategy and Goals

APPRAISE SELECT

Establish the HSSE strategy that defines the overall Project HSSE phi-losophy, culture, principles, drivers, and boundaries.

Define project HSSE high-level goals, objectives, and targets. Establish the protocol for project

leadership to visibly demonstrate and communicate the commit-ment to HSSE.

Update the HSSE strategy as con-cept options are evaluated and one is selected.

Define specific HSSE goals and ob-jectives for project and align with project activities and near term field work.

Set specific, measurable HSSE tar-gets for the project.

Review and update protocol for proj-ect leadership to align with Selproj-ect stage activities.

Resources and

Organization

APPRAISE SELECT

Develop a high level project HSSE organizational structure for the Select stage.

Develop project HSSE cost estimate

(inclusive of manpower).

Interface with project services team to effectively track costs.

Obtain JV approval (where applicable) for HSSE resource requirements.

Develop project HSSE resource and organization plan.

Identify project HSSE staffing, sup-port needs, and budget for Define and Execute stages.

Interface with project services team to integrate HSSE resource and or-ganization plan into overall project resource forecast and plans.

Review and update (if necessary) HSSE

roles and responsibilities. Update and communicate HSSE roles and responsibilities for Execute stage activities.

DEFINE EXECUTE

Update the HSSE strategy with focus on planning for Execute stage activi-ties (e.g. fabrication, integration and installation).

Confirm HSSE goals and objectives.

Assess performance of Define stage activities against HSSE targets.

Review and update protocol for proj-ect leadership to align with upcom-ing project activities.

Implement HSSE strategy.

Review and update project targets for Execute stage activities.

Assess performance of Execute stage activities against HSSE tar-gets.

Set specific targets for Leadership

(BP and contractor) visibility in the field.

Verify that HSSE expectations are understood and implemented at the workface by all contractors and sub-contractors.

DEFINE EXECUTE

Finalize the project HSSE resource and organization plan for Execute stage activity.

Hire the project Execute stage HSSE advisors necessary to assist in con-tractor audits and development of site- specific HSSE plans.

Refine HSSE-related budget/man-power estimates.

Implement HSSE resource and orga-nization plan.

Periodically review the effectiveness of the HSSE organization.

Develop operations HSSE staffing plan and consider appropriate timing to hire and assist in the development of HSSE procedures for the new fa-cility/operations.

Develop HSSE transition plan and de-manning strategy from project to operations.

(13)

Develop the project external stakehold-er engagement strategy in alignment with other project functions.

Implement the project external stake-holder engagement strategy and begin the process of active engagement.

Stakeholder

Alignment

APPRAISE SELECT

Performance

Review

APPRAISE SELECT

Establish an HSSE review process with project and BU leadership to regularly review HSSE performance.

Assess HSSE performance and use information to improve performance and processes.

DEFINE EXECUTE

Implement the project external

stake-holder engagement strategy. engagement strategy.Implement the external stakeholder

Openly communicate HSSE perfor-mance, achievements, milestones, and issues with external stakehold-ers. Implement the HSSE Monitor-ing, Assurance and Verification Plan.

DEFINE EXECUTE

Assess HSSE performance and use information to improve performance and processes.

Verify that HSSE expectations are understood and implemented at the workface by all contractors and sub-contractors.

Assess HSSE performance and use information to improve performance and processes.

(14)

.1 Introduction

HSSE Management describes the organization, plans and systems that should be developed and implemented to achieve the HSSE goals and targets defined by project leadership. A key component of HSSE management is risk management. Effective management of HSSE risk is recognized across all BP segments as a key component for the delivery of world class projects. Risk Management Guidelines for

Major Projects defines the project level risk management process to ensure that key

project risks are managed holistically.

Getting HSE right (gHSEr) is the BP HSE Management System Framework which

supports the HSE Expectations to be adopted by all BP managers. The Project HSSE Manager is accountable to the PGM for ensuring that the project has a comprehensive overall HSSE strategy and plan for delivering its HSSE goals and targets, is appropriately resourced, has the necessary management systems in place and is working in accordance with those management systems to deliver HSSE performance. Essential responsibilities include:

Confirm that all Health, Safety, Security and Environmental concerns and risks relating to the full lifecycle of the project, novel technology and nature of the location have been identified.

Develop a Project HSSE Management Plan that defines HSSE expectations, organizations, and systems to be used to manage HSSE throughout project development and execution.

Verify that all applicable regulations, BP standards, practices, requirements and expectations relative to HSSE have been identified and have been met, e.g. o Control of Work

o Driving Safety

o Integrity Management

o Environmental Requirements for New Projects

Confirm that HSSE Plans are in place and are being implemented that will assure HSSE performance during design, construction, commissioning and installation.

Develop a holistic Case for Safety (CfS).

Develop a Transition HSSE Plan that assures operational personnel have adequate HSSE training, emergency response arrangements and procedures have been established, and all notifications, and requirements for regulatory and HSSE contractual compliance have been completed and handed over to the site for ongoing compliance.

(15)

gHSEr is the current framework for managing HSE and should continue to be used until is replaced by an Operating Management System (OMS). When the OMS is developed, the content of gHSEr will be fully incorporated.

MPcp Expectation

(Appraise – Execute) A documented HSSE Management system is in place which meets BP’s expectations and requirements.

.2 Project HSSE Management Plan

The Project HSSE Management Plan describes the organization and HSSE management systems implemented to manage HSSE risks. All projects shall implement the following BP Group Standards and future standards as they are developed: Personal Safety o Control of Work o Driving Safety Integrity Management Marine Operations

The intent of the BP Group Standards is to ensure a formal approach to managing risk for BP employees and their contractors. The further intent is to promote adoption of the standards by companies working on behalf of BP on non- BP premises. Projects should endeavour to hire contractors with HSSE programmes that are as protective, or more protective, than BP Group Standards, and encourage those who do not have such programmes to adopt them.

The Golden Rules of Safety are minimum standards for safeguarding personal safety and key controls and procedures that must be followed in all places of work. These rules have been created to allow knowledge from past safety incidents to be shared widely across BP, and emphasize the basic rules that should be in place at all locations for managing safety during typical risk activities.

MPcp Expectations

Appraise An HSSE Management Plan has been developed and the Project Leadership Team has clearly defined and communicated to all project team members the HSSE strategy that defines the overall project HSSE philosophy, principles and goals.

Select The Project HSSE Management Plan adequately addresses the HSSE risks identified and how they will be managed in future stages, including health, occupational and design safety, security, environment and social.

Define The HSSE Management Plan is updated to reflect Define activities and to identify the HSSE management issues associated with Execute.

Within-Execute The HSSE Management Plan is updated to reflect Execute activities, including construction, installation, hook-up and commissioning.

End-of-Execute The project and site are fully implementing robust HSSE Management Plans, processes and procedures to confirm preparedness and obtain approvals for start-up.

(16)

. Project Planning

The goal of the Project Appraisal Plan (PAP) is to enable an informed decision on project viability and concept selection. Significant HSSE issues that could affect the viability of the potential project should be identified and assessed. HSSE risks, including Major Accident Risks (MAR), are taken into account in the evaluation of project options.

The Project Execution Plan (PEP) is developed during the Select stage and defines key project strategies and plans necessary to complete the Define and Execute stages of the project. All HSSE concerns and risks relating to the characteristics of the full lifecycle of the project, novel technology, and the nature of the location shall be identified and managed. HSSE management is a critical component of the PEP.

.4 Risk Management

Effective management of risk is recognized across all BP segments as a key component of the delivery of world class projects. The Integrity Management (IM) Standard requires that formal procedures are in place to identify hazards associated with normal and abnormal operations, assess risks, formally document this information and communicate it to affected staff. New projects with the potential for a major incident shall assess their risks using the Group MAR Process (ETP No. GP

48-50 Major Accident Risk Process).

Risk Management Guidelines for Major Projects defines the project level risk

management process to ensure that key project risks are managed holistically. Key project HSSE risks are identified and assessed as part of this process and a Project Risk Register is maintained for documenting the results of the process.

The BP Group Standards (Driving Safety, Control of Work, Integrity Management and Marine Operations) ensure a formal approach to managing risk for BP employees and their contractors for these areas. In addition, detailed HSSE risks are managed at the discipline level (e.g. Health Risk Assessment and Human Rights Risk Assessment) and by site or job-specific risks assessment techniques (e.g. UXO Risk Assessment, job-safety analysis, and task risk assessment). The Diving HSSE Guidelines shall be used in conjunction with other BP Health, Safety, Security and Environment (HSSE) policies, practices and procedures to manage risks associated with diving operations.

RTC Task Risk Assessment (see figure 3.1) is one example of a risk assessment process that has been implemented to systematically identify and manage hazards associated with specific tasks at the worksite.

RTC

Task Risk Assessment

Risk assess it Talk it Check it

The RTC Assessment Process is a pre-task risk assessment led by the supervisor prior to the start of each shift, or as necessary throughout the shift.

The System

The risk assessment form is designed as an Aid Memoir with a systematic approach to identifying the following:

• Tasks Involved • Hazards Involved • Control Measures

RTC is carried out immediately following the regular toolbox talk at the start of the shift, or prior to commencing any new task outside the scope of the initial RTC assessment.

The Process

• The foreman completes the RTC form at the work site prior to commencing work.

• The foreman and team discuss task specific hazards and control measures. • Once everyone understands the tasks, risks and control measures, an RTC form

is signed.

• The foreman inspects the work site and signs the form.

• A ‘time-out’ is taken if the task changes, additional risks identified or anyone thinks it is not safe to proceed.

• At the end of the shift, the team signs off on a form confirming that the worksite is clean and safe.

See toolbox for details on how to implement RTC on your site.

(17)

Appraise An HSSE risk assessment has been conducted and all significant HSSE risks, along with all their response plans, are documented in the overall project Risk Register with named individuals responsible for managing them and providing input into regular progress reviews.

Select The HSSE risk assessment is updated to ensure that all risks relating to the characteristics of the full lifecycle of the project, novel technology and the nature of the location have been identified. All response plans are documented in the overall project Risk Register with named individuals responsible for managing them and providing input into regular progress reviews.

Define The HSSE risk assessment is updated to reflect all Define activities and to identify the risks associated with Execute. All response plans are documented in the overall project Risk Register with named individuals responsible for managing them and providing input into regular progress reviews.

Within-Execute The HSSE risk assessment is updated to reflect all Execute activities. All response plans are documented in the overall project Risk Register with named individuals responsible for managing them and providing input into regular progress reviews.

End-of-Execute The HSSE risk assessment is updated to ensure that all risks associated with handover and transition to Operations have been identified and are being managed. All response plans are documented in a Risk Register with named individuals responsible for managing them and providing input into regular progress reviews.

.5 Competency and Training

Recruitment, selection and placement processes should ensure that personnel are qualified, competent, and physically and mentally fit for their assigned tasks. BP and the contractors’ workforce should have the required skills and training to competently perform their tasks in a healthy, safe and environmentally sound manner. A plan should be in place to verify that the contractor demonstrate and document that their workforce (including subcontractors) are trained, competent and meet BP expectations.

The IM Standard requires that project, design, construction, operations, maintenance and contractor personnel shall be trained in the relevant operating and/or maintenance procedures, and in the potential hazards associated with their work. Understanding of the training received shall be verified, and competence assessed, at regular intervals.

.6 Incident Reporting and Investigation

All incidents should be reported and investigated to a level appropriate to their potential for harm. The Financial Control and Accounting (FC&A) Incident Reporting &

Investigation Procedure defines the requirements for doing this. The E&P Safety and Operations Reporting Decision Tree provides additional guidance to support SPUs

in reporting incidents. The IM Standard requires that all significant IM incidents are investigated using a recognized root cause analysis process to determine the possible cause(s) and identify and recommend actions to prevent a recurrence.

Group HSSE Reporting Requirements define BP’s mandatory reporting requirements. Traction is the Group web-based tool for reporting incidents and recording investigations

and is also used to input performance data such as hours worked. The IM Standard requires “The SPA IM shall also ensure that findings are promptly addressed and that resolutions covering both the technical and human factors leading to the incident are documented in Traction.”

.7 Crisis Management and Emergency Response

The IM Standard requires that all business segments and BP Operations shall develop and maintain Crisis Management and Emergency Response (CM&ER) plans, based on identified hazards and risks including those developed from the MAR process.

(18)

These plans shall be consistent with the Group Crisis Management Framework. The Group Crisis Management Framework sets out a management system for CM&ER in BP, and the recommended good practice for each stage in the process. Across BP, the response priorities should always be:

• First – People

• Second – Environment • Third – Property • Fourth – Business

The fundamental philosophy of over-reaction, assessment, response and subsequent de-escalation should be adopted.

.8 Regulatory and Compliance

The Global HSSE Compliance Framework details the minimum requirements for HSSE compliance management processes used by BP businesses. It reflects the underlying premise that businesses must prioritize their HSSE compliance management activities based on risk. When effectively implemented, resourced and supported by leadership, HSSE compliance programmes that conform to this framework will enable projects to reduce their business risks associated with HSSE non-compliance and support a culture of integrity. (BP’s 5-Step Compliance Process is illustrated in figure 3.2.)

Implementation of this framework is mandatory for all BP businesses where BP is the operator. In all other cases, we should strive to influence our partners to adopt similar processes and procedures.

figure 3.2 bp’s 5-step compliance process

.9 Document Management

HSSE documents are developed and controlled in accordance with the project document management system. It is critical that all relevant HSSE documents are transferred to operations personnel prior to start-up.

.10 Action Tracking

HSSE is integrated into the overall project action tracking system. Traction should be used to document and ‘track to closure’ all actions resulting from HSSE incidents and

1. Risk assessment

and prioritisation 2 .Compliance planning

5. Management review and certification 3.Implementation and operation 4. Measurement, evaluation and corrective action

(19)

incident investigations. In addition, actions may result from discipline related activities (e.g. Health Risk Assessments, HAZOPS, ESIAs, Site Security Risk Assessments, etc.). Although a master HSSE action tracking system may not be practical, all action items should be documented with names of responsible managers, due dates and ‘track to closure’ data. HSSE actions should be rigorously reviewed by management on a regular basis to ensure that actions are closed on-time. .11 Management of Change (MoC)

The IM Standard requires that all BP Operations shall maintain a Management of Change (MoC) system to ensure continued integrity and safe operation in the event of temporary or permanent changes to technology, facilities, equipment, operations or organization. For Major Projects that are executed in or on behalf of the SPU/BU, there is a preference to use the SPU/BU MoC system in order to provide consistency and continuity at handover of the project to operations. The use of one MoC system will also provide the SPU/BU with the ability to easily review the project’s design and execution and understand where exceptions to site technical practices or waivers to industry standards were approved by project management.

.12 Knowledge Management

Well managed knowledge is essential to build on the BP way of doing HSSE in projects as described in these guidelines. The key processes, technology applications and supporting roles outlined in the MPcp Knowledge Management Guidelines should be implemented to ensure that we apply our best HSSE knowledge to our projects every time.

.1 Monitoring, Assurance and Verification

Key features of HSSE monitoring, assurance and verification are:

• Management’s accountability for establishing effective documented processes to deliver HSSE performance.

• Effective monitoring, review and verification processes involving audits, peer reviews, internal assessments and external assessments.

• Plans to improve HSSE performance and address areas requiring attention.

Project HSSE Reviews (PHSSERs) are an essential element of a project’s assurance strategy and are specifically mandated by the Integrity Management Group Standard. ETP GP 48-01 Guidance on Practice for HSSE Review of Projects defines the process and detailed procedures for the conduct of PHSSERs. The overall objective of the PHSSER process is to assure the client Business Unit that HSSE-sensitive areas have been identified and that the appropriate project, engineering and operational systems have been or will be developed to control the identified risks. Assurance is provided by reviewing proposals at various key stages in their development. (See figure 3.3). PHSSERs heighten the awareness of HSSE risks and help make HSSE an integral part of the gated decision and approval process for projects within CVP. PHSSER reports are an important element of the decision support packages required at each CVP stage gate.

Additional requirements of GP 48-01 include:

• Variances from this GP are expected to be rare and must be reviewed and approved by the SPU Engineering Authority, who will consult with the HOD Engineering on significant variances.

• Projects shall document completion of all HSSE recommendations (PHSSER, HAZOP, etc).

• Formal acceptance of the Pre-Start-up HSSE Review recommendations by the host site Business Unit Leader or his nominee and completion of priority actions should be a condition of start-up.

figure 3.3 the 7 PHSSERs

Appraise Select Define Execute Operate

The 7 PHSSERs

‘Creating Distinctive Projects’ ‘Delivering with World Class Execution’

Appraise Stage

PHSSER Select Stage PHSSER

Pre-Sanction Stage PHSSER Detailed Engineering Stage PHSSER Construction Stage PHSSER Pre-Startup Stage PHSSER Operate Stage PHSSER

(20)

Appraise A plan has been developed for application of GP 48-01 (Guidance on Practice for HSSE Review of Projects), the Appraise PHSSER has been completed, and a plan for the Select PHSSER is available for implementation.

Select The Select stage PHSSER has been completed and a plan for the Define PHSSER (Pre-Sanction) is available for implementation.

Define A Pre-Sanction PHSSER is completed and a plan is in place to conduct Detailed Engineering, Construction and Pre-Start-up PHSSERs.

Within-Execute Detailed Engineering and Construction PHSSERs have been conducted and there are plans for a Pre-Start-up PHSSER.

End-of-Execute A Process Safety and Start-up Review (PSSR) and Pre-Start-up PHSSER have been completed and actions required for start-up have been completed.

Tools and examples are available via the Projects Library at

http://pelib.bpweb.bp.com

and on the CD included with these guidelines

G

H

S

E

R

5 STAR

Safety PROGRAM

The Five Star Safety Program recognises and rewards positive safety behaviours and deters negative safety behaviours by encouraging all site personnel to contribute to site safety and by providing a simple incentive scheme.

How it works

After receiving the Site HSE Induction, each employee receives the red ‘Five Star’ stickers that are placed fully visible on the right side of the hard hat.

Employees will be rewarded a silver star for exceptional HSE actions or leadership.

Every third star earned will be a gold star.

Violation of one of the Golden Rules results in removal of a red star.

The 5 Star Safety Program is an example of a safety Recognition & Reward program. See the Five Star Program on the Tools and Example CD for additional details.

(21)

Develop a Project HSSE Manage-ment Plan (HSSE-MP) that address-es full cycle activitiaddress-es.

Align the Project Circles of Influ-ence with the scope of project ac-tivities and clearly articulate in the HSSE-MP.

Update the HSSE-MP to reflect Se-lect stage activities.

SELECT

Project HSSE

Management Plan

APPRAISE

Project Planning

APPRAISE SELECT

Provide HSSE input into the Project Ap-praisal Plan.

Provide HSSE input into Appraise Stage DSP.

Update HSSE content of the Project Ap-praisal Plan.

Provide HSSE input into Select Stage DSP, the Define FM and the PEP.

APPRAISE Develop an HSSE risk management

strategy as part of overall Project Risk Management Strategy.

Conduct an HSSE risk assessment

and document all significant HSSE risks in a project risk register.

Develop HSSE risk management plans as an integrated part of overall Project Risk Management Plan.

Update HSSE risk profile as project risks evolve and update projectrisk register.

Risk Management

The actions covered are extensive and some may not be relevant to every project; however, all actions should be considered prior to rejection.

Competency and

Training

APPRAISE SELECT

Develop an HSSE competency and train-ing strategy for the project team, suppli-ers, agency personnel, and contractors.

Develop a HSSE competency and training matrix for the project team and agency personnel.

Integrate contractor HSSE training re-quirements into the contractor manage-ment process.

DEFINE EXECUTE

Provide HSSE input into Define Stage DSP.

Provide HSSE input into the Execute FM.

Monitor Execute stage activities to ensure HSSE conformance to the Project Execution Plan.

DEFINE EXECUTE

Update the HSSE-MP to reflect

De-fine stage HSSE activities. Update the HSSE-MP to reflect Ex-ecute stage HSSE activities.

Provide HSSE input into project pro-cess for handover to operations. (Go, No-Go, etc.)

DEFINE EXECUTE

Implement the risk management plan and monitor to ensure effectiveness.

Update HSSE risk profile as project risks evolve and update project risk register.

Implement the risk management plan and monitor to ensure effective-ness.

Update HSSE risk profile as project risks evolve and update project risk register.

EXECUTE DEFINE

Implement and monitor the HSSE com-petency and training delivery plan.

Ensure that contractor HSSE training re-quirements are included in the contrac-tor management process.

Implement the HSSE competency and training delivery plan.

(22)

Develop and communicate HSSE incident reporting and investiga-tion requirements consistent with the FC&A Incident Reporting & In-vestigation procedure and Group HSSE Reporting Requirements.

Update incident investigation and re-porting procedures in alignment with the Project Circles of Influence.

Train new project team members and contractors on incident reporting pro-cedures.

Crisis Management

and Emergency

Response

APPRAISE SELECT

Develop Crisis Management and Emer-gency Response (CM) plans aligned with identified HSSE hazards and risks, including health, security and those de-veloped from the MAR process.

Review and update CM plans at least annually.

Incident Reporting

and Investigation

APPRAISE SELECT

Regulatory and

Compliance

APPRAISE SELECT

Develop timeline for implementation of BP Global HSSE Compliance Framework for project.

Identify key regulatory requirements and milestones and incorporate within the Relationship Management Plan.

Develop a matrix of local, national and international regulatory requirements.

Develop a strategy and plan to ensure compliance with all regulatory require-ments and acquire the regulatory ap-provals required to operate.

Document

Management

APPRAISE SELECT

Develop and file HSSE documents consistent with the project document management procedure.

Develop and file HSSE documents consistent with the project document management procedure.

DEFINE EXECUTE

Update incident investigation and re-porting procedure in alignment with the Project Circles of Influence.

Train new project team members and contractors on incident reporting pro-cedures.

.

Update incident investigation and re-porting procedure in alignment with the Project Circles of Influence.

Train new project team members and contractors on incident reporting procedures.

DEFINE EXECUTE

Review and update CM plans at least an-nually and ensure readiness for Execute Stage activities.

Conduct training, drills and exercises for IMT members to ensure competency.

Review and update CM plans at least annually and ensure readiness for op-erations.

Conduct training, drills and exercises for IMT members to ensure compe-tency.

DEFINE EXECUTE

Implement the strategy and plan to ensure compliance with all regulatory requirements and acquire the regula-tory approvals required to operate.

Develop a plan to ensure site HSSE compliance requirements for Execute are understood and met.

Implement the strategy and plan to ensure compliance with all regulatory requirements and acquire the regula-tory approvals required to operate.

Implement plan to ensure site HSSE compliance requirements are met for Execute stage activities.

DEFINE EXECUTE

Develop and file HSSE documents con-sistent with the project document man-agement procedure.

Ensure a process for the transfer of HSSE documents to the Operations Team.

(23)

Action Tracking

APPRAISE SELECT

Integrate HSSE within the overall project action tracking strategy.

Utilize Traction for HSSE incident tracking.

Interface with project services to ensure integration of HSSE actions within the overall project action track-ing process.

Utilize Traction for HSSE incident track-ing.

Monitoring,

Assurance and

Verification

APPRAISE SELECT

Develop and implement an HSSE Moni-toring, Assurance and Verification Plan that clearly articulates the assur-ance activities to be conducted during the project.

Conduct Appraise Stage PHSSER.

Conduct Select Stage PHSSER.

Knowledge

Management

APPRAISE SELECT

Integrate HSSE into the project

Knowledge Management Plan.

Establish a process to incorporate

HSSE lessons learned from previ-ous projects.

Capture Appraise and Select HSSE les-sons at the end of Select.

Incorporate lessons learned from pre-vious projects.

Management of

Change (MoC)

APPRAISE SELECT

Integrate HSSE within the project MoC

system. manage HSSE risks associated with Implement the MoC procedure to changes.

DEFINE EXECUTE

Include HSSE actions within the overall project action tracking process.

Utilize Traction for HSSE incident track-ing.

Include HSSE actions within the overall project action tracking process.

Ensure a process for the transfer of open HSSE actions to Operations Team.

DEFINE EXECUTE

Conduct Pre-Sanction Stage PHSSER. Conduct Detailed Engineering, Con-struction and Pre-Startup PHSSERs.

Conduct Pre-Startup Safety Review (PSSR).

DEFINE EXECUTE

Incorporate lessons learned from

pre-vious projects. lessons at end of Execute.Capture Define and Execute HSSE

Ensure a process for the transfer of HSSE lessons learned to the Opera-tions Team.

DEFINE EXECUTE

Use the MoC procedure to manage HSSE risks associated with changes.

Periodically audit the MoC system and MoC register to ensure conformance with the MoC procedure.

Periodically audit the MoC system and MoC register to ensure confor-mance with the MoC procedure.

Develop a process to transfer HSSE MoCs to the Operations Team.

(24)

4.1 Introduction

The Group Health, Safety, Security & Environment (HSSE) policy underpins and establishes the basis for how BP manages health matters globally. It determines that our fundamental mission is to provide a safe, secure and healthy workforce and working environment by protecting ourselves, our assets, the local community and our operations, while ensuring ‘No Harm to People’.

One of the key expectations of BP’s getting HSE right (gHSEr) and getting Health right

(GHR) is that health will be taken into consideration during the proposal, planning and

implementation stages of all new capital projects. The aim of this section is to provide guidance to project management, project HSSE professionals and contractor groups, to ensure that effective measures are taken at all CVP stages to ensure a healthy workforce and working environment.

The benefits of a common process for health are:

• Avoidance, control and mitigation of health risks through early identification and planning

• Full alignment with business objectives and deliverables • Simplicity and Efficiency

o The use of common language across projects

o Reduced workload - no need to reinvent health management for each project

o Consistent health management throughout the life of the project • Better connectivity and access to timely technical support from the function • One ‘BP way’ of delivering Health

4.2 Scope

The following guidelines apply to all E&P Major Projects. For projects in existing assets (e.g. North Sea, GoM and Colombia), much of the health infrastructure and processes may already be in place and some actions may not be relevant. However, for projects in new areas or where assets do not currently exist, the actions may be relevant and required.

As the project moves forward, the health priorities will change. This should not prevent health analysis from taking place early, where possible at the onset of the Appraise stage. The health risks and required health protection programmes will also

(25)

inevitably change; indeed early planning will reveal important areas for reconsideration. Therefore, project managers are strongly advised to consider health matters as early as possible in the process.

4. Health Resources

A review of pre-Appraise health related activities should be conducted to confirm what health risks were identified and the health policies, procedures and organization implemented to manage them. Prior to the Access stage, a review of the location and the environment should have been conducted to identify the health risks and ensure that health policies and procedures were implemented to protect staff. At the Access stage, competent health resources should have been assigned to support the team.

For projects where medium or high health risks are present, a full time Health Manager should be appointed at the start of the Appraise stage. A project health team should be put in place whose composition, size and organizational structure meets the assessed health and industrial hygiene risks in the selected project option. Industrial hygiene and health support staff needs should be assessed, and resources should be defined and regularly reviewed as the project progresses.

figure 4.1 occupational health Occupational Health Disease/Illness Health surveillance Occupational Medicine Industrial Hygiene Occupational Health & Well Being Effective control Exposure Work Activities

4.4 Health Impact Assessment (HIA) – Outside the Boundary Fence

A Health Impact Assessment (HIA) is a combination of procedures, methods and tools by which a project may be judged as to its potential effects on the health of a population, and the distribution of those effects within the population. The HIA should be integrated with the Environmental and Social Impact Assessment (ESIA), and the communities’ opinions and needs affected by the project should form an integral part of the assessment. Based on the HIA, health policy and procedures are developed and implemented that mitigate the potential negative health impacts.

4.5 Workplace Health Risk Assessment (HRA)

Health Risk Assessment (HRA), in an occupational context, considers all the ways in which the work environment and the actual tasks to be done potentially impact on workers’ health. HRA may need to cover individual cases or may be generic for a group of people doing the same tasks in the same place. HRA should continue for the life of the project and must be appropriate for the degree and complexity of the activities being undertaken.

4.6 Health Management Plan

BP’s commitment to ‘No Harm to People’ clearly positions health and well-being as integral to the business process. Everyone has a responsibility and a role in ensuring that BP’s activities, products and emissions do not adversely affect the health and well being of employees, contractors, customers or the public.

Managers have the overall accountability for health, and therefore should establish suitable health programmes. This commitment and responsibility is about much more than maintaining basic health and safety standards or achieving the neutral point that ‘No Harm’ represents. It is about recognizing that health includes mental, physical, social and environmental well-being, and encompasses a spectrum from illness to optimum wellness. Truly effective health management includes creating an environment that provides the opportunities for individuals to optimize their own health and well-being, thereby improving both personal and business performance and fully realizing their potential.

(26)

figure 4.2 employees’ health and performance optimized 4.7 Crisis Management and Emergency Response

Clearly defined and well thought-out plans for medical and industrial hygiene are essential components of the project’s Crisis Management and Emergency Response (CM&ER) plan. The plan should describe the response to various medical emergencies utilizing available resources. Epidemiological information and accident and illness data can provide this.

Multiple casualty scenarios, unforeseen events, spillages and emissions, and emerging illnesses such as food poisoning and Avian Influenza, should also be considered. An assessment of local health and industrial hygiene facilities and services will be needed and should include consideration of their ability to manage the full range of serious medical conditions, especially in emergency situations. If necessary, arrangements should be made for access to international medical evacuation, repatriation and

EMPLOYEES HEALTH & PERFORMANCE OPTIMISED

ILL HEALTH

OPTIMUM WELLNESS OPTIMUM PERFORMANCE

NEUTRAL POINT Chronic Disability Illness Absence Non Attendance Presenteeism Acceptable Work & Productivity

High Quality Work & Productivity

PEAK CREATIVITY & PRODUCTIVITY

treatment services. Access to industrial hygiene services outside the local area may also be necessary.

Drills and exercises should be conducted that test the medical emergency response at all levels (first aid to fatality) and Industrial Hygiene procedures.

4.8 Contracts and Procurement Strategy

Health requirements should be incorporated into the contractor pre-qualification and selection process and the health performance of contractors should be tracked during Execute stage activities. Contractors play a major role in projects, and due diligence background checks should be performed for potential contractors. Health expectations should be included in the Invitation to Tender and processes should be implemented to ensure contractor groups understand the BP Health requirements and that they have suitable programmes, resources and competencies to meet them.

4.9 Human Factors (HF) and Ergonomics

Human Factors (HF) and Ergonomics considerations should be incorporated into the design, commissioning, and operation of equipment and facilities. Facilities that eliminate or minimize human failure should also be designed to mitigate the consequences of any human failures that do occur. Incorporation of human factors and ergonomics considerations into design is an iterative process. It requires good management and end user participation, the application of human factors and ergonomic design standards, and lessons learned from previous projects.

Tools and examples are available via the Projects Library at

http://pelib.bpweb.bp.com

and on the CD included with these guidelines