Technical SessionOffshore Self Regulation Implementation in Malaysia Upstream22 November 2018
Abdullah bin Abdul GhaniAsset Assurance, Asset Integrity & Assurance Management Production & Operations Management Malaysia Petroleum ManagementPETRONAS 1Open
Presentation Outline• Introduction• Regulatory requirement under DOSH• FMA Sections Exemption to PETRONAS• Certificated Machineries Integrity Assurance Process• Way Forward
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Introduction• Offshore Self Regulation (OSR) officially launched in 2013 where
Malaysia Government granted PETRONAS an exemption to Section 19,36 and the FMA (Notification, Certificate of Fitness and Inspection)Regulation 1970 [P.U.(A) 43/1970] of the FMA 1967 with eight (8)conditions.
• One of the Order exemption conditions is related to determination andcertification of the eligible inspector to examine the integrity and provideassurance of the certificated machinery.
• OSR allows PAC to plan, and carry out inspection and maintenanceactivities internally.
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Agency responsible for ensuring the safety, health and welfare of people at work as well as protecting the public from the safety and health hazards arising from the business activities.
Agency vested with the entire ownership in obtaining petroleum lying onshore or offshore of Malaysia and is responsible for stewardship and management of the overall exploration and production activities in Malaysia.
Provisions for securing the safety, health and welfare of persons at work and for protecting others against risks to safety and health in connection with the activities of persons at work, to established the NCOSH, and for matters connected therewith.
Occupational Safety and Health Act 1994 (OSHA)
Provision for the control of factories on matters relating to the safety, health and welfare of persons, and the registration & inspection of machinery and for matters connected therewith.
Factory & Machinery Act 1967
To consolidate laws relating to safety in transportation,storage and utilisation of petroleum and to provide for matters relating thereto.
Petroleum (Safety Measures) Act 1984
Provision exploration and exploitation of petroleum resources in Malaysia
Petroleum Development Act 1974
PETRONAS Malaysia Petroleum Management (MPM) takes role as a single reference point for all upstream exploration andproduction activities in ensuring energy security for Malaysia and sustainable development of the domestic oil & gas industryas the provision in Section 3 PDA 1974.
Regulatory requirement under DOSH
(DOSH)
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28 March 2013:Exemption granted officially by Human Resources Minister. The Order titled “Factory and Machinery (Exemption to PETROLIAM NASIONAL BERHAD) Order 2013”. The conditions of exemption are highlighted in the paragraph 3. of the Order)
FMA Sections Exemption to PETRONAS
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Exempted Sections and Conditions
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No. Direct Exemption Action Party1 Section 19 – Certificate of fitness PETRONAS & PAC2 Section 36 – Installation of machinery PETRONAS & PAC3 Factories & Machinery (Notification, Certificate of Fitness and Inspection)
Regulations 1970PETRONAS & PAC
No. Exemption Conditions1 PETRONAS shall involve DOSH in its annual work plan relating to occupational safety and health matters2 PETRONAS shall submit its annual work plan including the determination of OSH indicator to DOSH each year for
monitoring purposes3 PETRONAS shall involve DOSH in every verification activity at the highest level of management for the implementation of
the OSH management system4 One Joint Committee which members are from DOSH and PETRONAS shall be established for the purpose of
communication, discussion and decision making on any matters relating to OSH, and maintenance of the offshore machinery.
5 PETRONAS shall give DOSH the right to determine and certify the eligible inspector to examine the integrity of the machinery.
6 PETRONAS shall allow DOSH to conduct an audit or examination on any premises at any time in the interest of OSH. 7 PETRONAS shall involve DOSH in every plan and execution of shut down and reconditioning activities of the offshore
machinery.8 PETRONAS shall cooperate with DOSH for any purpose in relation to Offshore OSH.
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NOTE:*Essential documents for EIAC issuance:- Manufacturing Data Record (MDR)- HT Certificate- GA Drawing’**To include hard stamping practice within the guideline
Design Fabrication Installation & Commissioning
Cons
ultan
t/ Fa
brica
tor/
Contr
actor
PAC
OSR I
nspe
ctor
PETR
ONAS
TA: Technical Authority, SME: Subject Matter Expert, FAT: Factory Acceptance Test, HT: Hydrostatic Test, EIAC: Equipment Integrity Assessment Certificate
Submit equipment datasheet & specification
New PV/Boiler
Review/ approved by TA/SMENo
Submit equipment drawing & calculation
Authorized 3rd Party to appraise
Yes Review/ approved by TA/SME
Fabrication
Authorized 3rd Party to witness and approve HT/ FAT
Review & approve HT/LT/FAT
Installation & commissioning
Witness & approve test. Call up OSR inspector during site initial inspection
Witness & approve test. Issue *EIAC
No
Yes
NoImportedLocal
Yes
No
Yes`
Initiate Request NoHandover to Operation & update equipment register
Cont. to part 2 of 2
NoNo
Yes
Yes
Witness & approve HT/LT/FAT.No
Acknowledged & register the equipment
Notify PETRONAS for registration
Verify & approve docs.
OSR Process Workflow For Pressure Vessel, Boilers and Lifting Equipment…1/2
Certificated Machineries Integrity Assurance Process
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Operation Decommissioning
PAC
OSR I
nspe
ctor
PETR
ONAS
Regular inspection *Repair/Rerating
Review/ Endorse by TA/SMEAccept
Fail
Isolate (Mothball) Replace Notification of Decom. & update equipment register
Witness & Verify
NOTES:*Repair shall be performed by repairer approved by PETRONAS*PAC shall submit quarterly update to PETRONAS on each Pressure Vessel under OSR implementation (to be included in OSR MS)
OSR Process Workflow For Pressure Vessel, Boilers and Lifting Equipment..2/2
Cont. from part 1 of 2
Start to operate
•Verify and/or witness tests•Asses the inspection result
Initiate Request
EIAC RenewalAccept
Fail
Accept
Fail
Accept
Fail Witness & Verify Verify & Update record
Acknowledge
TA: Technical Authority, FAT: Factory Acceptance Test, HT: Hydrostatic Test, EIAC: Equipment Integrity Assessment Certificate
To notify PETRONAS End
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Way forwardPAC shall comply with the OSR Process Work Flow for Certificated Machineries (Pressure Vessel, Boilers and Lifting Equipment) integrity assurance requirements
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Thank you
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