Tullow Oil is one of the leading oil and gas exploration and production companies. The company is headquartered in London and has over 120 operating licenses in 22 countries (Tullow Oil Plc 2016). The company is listed on three stock exchanges in London, Irish, and Ghana. The operation in the industry requires strict observation of health, safety, and environmental management practices to reduce the underlying risks and enhance the sustainability of the activities (Cruz-Cunha, Moreira & Varajao 2014). The company has in recent years acquired contracts and licenses to explore and production in various countries in Africa. In Kenya, in particular, the company has made discoveries, and the production process may start soon. The operations in the new sites require the company to use an effective Health, Safety, and Environmental (HSE) Model. This report reviews the company’s environmental, health and safety policy, as well as a proposed model.
The Policy
Tullow Oil expects every stakeholder in its operations to think of their role in HSE. Everyone connected to the operations is required to respect other stakeholders, reflect on lessons learned, and the protection of the environment (Tullow Oil Plc n/d). Observing these principles is a significant step upon which HSE risk management becomes an integral part of the operations at the sites.
In realizing the objectives of the HSE policy, the company is always committed in various ways. The first initiative is to undertake a proactive approach in managing HSE risks. The aim of the approach is to ensure that the risks are identified in advance, and the necessary actions are undertaken to mitigate their occurrences. The second step is to observe the HSE laws and regulation as set in the country of operations and the international regulatory body in the industry. Complying with the law assists in avoiding legal issues and conflict with the authorities (Bret-Rouzaut & Babusiaux 2011). Other steps upheld by the company, in this respect, include the prevention of pollution, maintaining the safe working environment, and evaluating performance with the strong and best practices in HSE in the industry.
The HSE Model
The proposed HSE Model is significantly important in assisting the stakeholders in Tullow Oil to remain dedicated to ensuring that the health, environmental and safety measures are at the preferred levels (Saeed, Khan & Ahmad 2013). The model is broken down into seven key elements with each having underlying objectives and components.
Policy and Objectives
The management team operating at the sites should take up the responsibility of defining the relevant HSE policy and objectives. The formulation of the policy at the operating level assist in the incorporation of the local circumstances and hence makes the guidelines issued to be relevant (Wilson et al. 2011). However, the guiding principles at the local levels should be in line with the corporate policy. The policy objective is to put in place arrangements to enhance compliance with HSE goals and expectations. The management at the new sites will be required to publish HSE initiatives to make clear the targets, objectives, and programs annually. The publication, in this case, assists in the definition of the efforts put in place for the coming year and the basis for performance evaluation for the past year.
Evaluation and Risk Management
The operation in the oil and gas industry is likely to be full of hazards that are likely to arise from the activities and materials used. The hazards in all the activities should be identified and their magnitude predicted to determine the mitigation strategies to apply (Perdicoulis, Durning & Palframan 2012). The consideration of incidents and potential emergencies arising from the processes and activities are necessary steps.
The evaluation of the potential risk can be undertaken through the consideration of various categories including the general, health and safety, and environmental assessments (Sutton 2010). General evaluation puts into consideration the potential risks and effects, taking into account the possibility of the occurrence and severity of the people, the environment, and the company assets. The risks are evaluated through the application of technical assessment, expertise judgment, the company, and industrial standards. Health and safety evaluations usually put into consideration the aspects such as fire explosion, collisions, exposure to chronic chemical and reagents, as well as the ergonomic issues (Cruz-Cunha, Moreira & Varajao 2014; Mannan 2014). Concerning the environmental evaluation, environmental matters arising from the operating activities of the organization are put into consideration. The assessment considers four key areas, including controlled and uncontrolled emission, disposal of solids, resultant noise, odor, and dust, and the effect on archeological and heritage sites.
Leadership, Commitment, and Accountability
HSE is a critical part of the business operation management. The role of leadership in ensuring the realization of the objectives is of great fundamental. The leadership in Tullow Oil will lead by demonstrating how important HSE is part of the sustainable operations. The leadership will exhibit the commitment in two ways. First, the necessary resources should be made available to ensure that required activities and systems in HSE are developed and maintained. Secondly, the management should come up with strong strategic approaches to ensure that effective HSE management is always maintained (Tullow Oil Plc n/d). Additionally, the responsibility areas in the HSE management should be made clear and individuals responsible identified. Attaching responsibilities to particular individuals entice a sense of accountability because it would be easy to measure HSE performance in specific areas and associate the outcome with the main actors.
Communication and Information
The communication of the information on the corporate policy and standards should be highly upheld as a step in HSE management at Tullow Oil. The stakeholder, in particular, the employees, contractors, and partners will be informed of HSE policy and objectives, the identified hazards, and the importance of playing their roles. The management should ensure that the employees are consulted when changes affecting workplace health and safety are to be effected (Bendiksen & Young, 2015; Chandrasekaran 2016). The open door policy is considered as an avenue upon which the employees shall be encouraged to report on HSE issues in their responsibility areas.
The operating units should issue an official communication to the players in the organization, especially on relevant subjects on HSE. The first issue requiring communication and information sharing concerns HSE performance in the past year with the aim to inform the stakeholders on success and failure within the period in question (Cameron, 2012). Secondly, the management communicates HSE targets for the following year, the significant incidents, and expected initiatives to improve the performance (Urizar & El-Sayed Abdel 2015). Additionally, the issuance of audit and management review reports, communication on HSE challenges, and emergency response, are regarded as important steps in information sharing. Lastly, Tullow Safety Rules will always form an important part of the induction process. The new employees and those transferred to new operational areas will be briefed on HSE strategies and expectations in the new responsibility areas. The commitment, in this respect, ensures that all the employees are aware of HSE expectations.
Monitoring and Corrective Action
The element, in this case, is based on the realization that despite how strong the rule and regulation are, and the will of the stakeholder to support HSE programs, at times the target can be missed. Monitoring is to be undertaken in two perspectives, including the active and reactive monitoring. Active monitoring is used in checking the compliance with the objectives and whether the targets are met (Ratan 2010). The latter concern the incidences such as ill health and environmental damages, to form the basis for the prevention of the occurrences in the future.
Recording and reporting are key pillars of the monitoring and correctional elements of the model. All the operating units in Tullow Oil will maintain records of the compliance with the HSE policy and the effectiveness of its implementation. The records and their contents shall be accessible and controlled to keep their integrity at preferred levels (IAOGP2010). Individuals in various responsibility areas will report the performance indicators to their respective head of operating units, upon which annual reports from the units at the corporate level will take place (Lyons & Plisga 2005). The reports will assist in the identification of weak areas and non- compliance, forming the basis for corrective action.
Variance
Variance is considered an essential component of the HSE model at Tullow because of the need to incorporate changes and make the strategies flexible to the changing situations. In this case, the deviation from the set rules and regulations on safety is allowed. However, to avoid errors and an increase in the risk level, any deviation from the set rules should be formally documented after comprehensive assessment and justification (Workplace Law Group 2011). The approval from the regional business manager and endorsement from HSE Manager would be a prerequisite for the execution of the changes.
Self-Assessment, Auditing, and Management Review
The implementers at the operational units may at times fail to observe the set rules while at the same time the management may not offer the necessary support (Idowu 2016). The HSE management team should conduct a regular assessment to collect evidence on compliance/non- compliance. The evaluation shall use items such as documentation, interviews, and observations as the source of evidence.
HSE at Tullow will be subjected to a third party audit to review the compliance and the capability of the HSE policy and management independently. The third party/external auditor would be critical in determining whether the management approaches are effective, and identify areas requiring improvement, progression, and better HSE management (Elearn 2012). Apart from the third party audit, the head of the HSE will make arrangements on how internal experts from various operational units will conduct peer audit on a regular basis (Arter, Cianfrani & West 2012). The findings from the peer and external audits will be compelled to come up with a management review report.
As is evident from the above analysis, the seven–HSE element model would assist Tullow Oil to ensure that its operations in the Kenyan oil exploration and drilling sites comply with the health, safety, and environment expectations. The seven pillars will assist the management to ensure that the operations would be compliant with the law, sustainable, and supported by the community.