Document Responsibility: Environmental Standards Committee SAEP-64 Issue Date: 2 February 2017 Next Planned Update: 2 February 2020 Comprehensive Environmental Health Assessment
1 Overview
The Comprehensive Environmental Health Assessment (CEHA) program is a systematic
assessment of facilities and associated practices against Government requirements and GI-0151.006, ‘Implementing the Saudi Aramco Environmental Health Code’.
The objectives of the CEHA program are to:
Assess the compliance of Saudi Aramco facilities with the Government requirements and GI-0151.006; Identify and evaluate environmental health hazards, including chemical, physical and biological agents that may cause sickness, impaired health and significant environmental health noncompliance issues. Further, monitor food and water supplies to determine or detect impaired quality; Ensure that areas of non-compliance reported in previous CEHAs have been properly resolved, and Provide a comprehensive report to the proponent department on conditions related to environmental health at its facilities including recommendations for minimizing risks associated with public health and provide guidance for adequate health hazard control measures.
2 Scope
This document describes the procedures for the administration and implementation of the Comprehensive Environmental Health Assessment (CEHA) program.
3 Applicable Documents
All CEHA surveys shall evaluate compliance with the applicable documents below.
3.1 Saudi Aramco Document
General Instruction GI-0151.006 Implementing the Saudi Aramco Environmental Health Code (SAEHC)
3.2 Industry Standards
Saudi Arabian Standards Organization (SASO)
Industrial Safety and Health Regulations in the Kingdom of Saudi Arabia
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3.3 Other Requirements
General Regulations on the Environment, Kingdom of Saudi Arabia Royal
Decree No. M/34, October 15, 2001
Kingdom of Saudi Arabia, Labor and Workmen’s Law, Articles 128-144
Environmental Protection Standards, Document No. 1409-01, Saudi Arabian
Presidency of Meteorology and Environment (PME), August, 20, 1982
4 Definitions
Comprehensive Environmental Health Assessment (CEHA): A systematic
examination to identify and evaluate facility conditions and worker practices that potentially compromise the health of employees and users.
Major Finding: Deviations from standards that could result in a direct impact on human health, incur significant expense (BI-19) or are widespread.
Minor Findings: Findings which are isolated or do not have a high element of risk on human health.
Environmental Health Sampling Program: A program implemented by WED in line
with GI-0151.006, to ensure safe food and water supplies as well as hygienic conditions are maintained throughout Company facilities to protect the health and welling of Saudi Aramco employees and other users from chemical, physical and microbiological contaminants.
SAP EH&S Notification (CEHA Report): A mechanism employed by EPD to deliver
CEHA reports to proponents and track findings and recommendations until fully resolved. SAP EH&S notification is created by using EHS:EPD:RECOM_CO_ORGNATOR:0000 role through QM01 transaction.
Risk Matrix: A system intended to focus resources where health risks are apparent and present an exposure risk to the Saudi Aramco workforce and dependent population. Five risk factors are applied in a risk matrix to generate a rating score that is used to determine assessment frequencies.
Risk Factors: Include population affected; classification of premises (offices,
maintenance, operation and producing or services); control/ownership of business and potential environmental health issues.
Areas of Noncompliance: Major or minor deviations from standards that could adversely impact public health therefore decreasing productivity and increasing medical care costs.
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Control Measures: Permanent or interim solutions introduced by proponents to
mitigate environmental health hazards associated with major or minor findings.
5 Implementation Steps
5.1 Facility Selection
The Environmental Protection Department (EPD) selects facilities to be assessed
during the upcoming calendar year. A risk matrix is used to identify facilities presenting potential public health hazards following CEHA risk rating guidelines. The score produced from this exercise indicates the overall risk severity and determines CEHA frequency which can vary from annually to once every 3 years.
5.2 CEHA Team Selection
EPD determines the membership of each survey team and the type of expertise needed for each CEHA, based on the type and complexity of the facility. The Environmental Coordinator from the proponent department should be included as a team member.
5.3 Team Preparation
The team members familiarize themselves with the facility organization and functions. Previous CEHA reports should be reviewed, as well as documentation regarding past environmental health problems and incidents. The Team Leader may ask the proponent to submit facility information that will help prepare the team for their visit in the form of a pre-assessment questionnaire.
5.4 Opening Meeting
The opening meeting is normally held on the first day of the site visit. Communication with the proponent may however start a week or more in advance of the site visit to clarify any logistical or procedural issues, e.g. access to online but restricted laboratory data or Operating Instruction Manuals. In attendance are the survey team, the EC and appropriate facility supervisors. The purpose of the opening meeting is to: Introduce the survey team; Give an overview of the CEHA process; Determine the scope of the CEHA as it applies to the proponent department functions, and Clarify any areas of uncertainty and discuss site details and logistics.
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5.5 Onsite Survey
a) The survey team shall assess the facility's environmental health performance by evaluating compliance with the documents listed in section 3 above. b) The survey shall, as a minimum, cover the following items: Previous CEHA survey reports Previous results from environmental health sampling program Field tests and samples to determine current conditions Certificates and training records as required Observations and assessments of the facility and the procedures c) The survey team shall inspect the facility including interviewing personnel, reviewing pertinent files, and assessing facility procedures. d) The survey team shall verify that any findings from previous CEHA surveys have been appropriately resolved. e) Minor findings which have remained outstanding between CEHA’s may be elevated into major findings due to continuous non-compliance. f) For a major finding, the CEHA Team Leader should ensure that a satisfactory interim measure is in place, pending permanent resolution, to mitigate any health effect caused by the condition to which the finding relates. Open major findings from a previous CEHA shall not be closed if the current CEHA assessment indicates that they have not been satisfactorily resolved. Furthermore, these findings will not be duplicated in the current CEHA notification.
5.6 Closing Meeting
a) After completing the onsite survey and comprehensive data evaluation, the team presents a summary of findings to the facility representative. That feedback provides an overview of the field work, assessment of documentation and professional assessment of current risks and necessary controls. b) Major findings are items that are in non-compliance with Government or Company environmental health requirements and pose a significant health risk or are widespread throughout the proponent facility or involve capital expense. The findings should be supported by referencing the specific mandatory requirement.
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Minor findings are all other items that should be addressed by the facility management and will be detailed in the final report. Safety issues will be reported directly to the facility Loss Prevention representative. c) The team discusses each of the findings, gives an overall assessment of environmental health performance, highlights areas that need immediate attention, and specifies items that require significant capital expenditure.
5.7 Final CEHA Report
a) Only major findings will be highlighted for action in the CEHA summary report. Minor items will be described in the report body. b) The CEHA Final Report is sent to the proponent manager as a SAP notification with a cover letter signed by the General Supervisor, Workplace Environment Division (WED), with copy sent to the proponent Environmental Coordinator. 5.8 Action Plan and Resolution of Findings a) After receiving and reviewing the Final Report, the proponent shall complete the action plan, which addresses resolution of the major and minor findings. For major findings requiring capital to resolve, the proponent shall develop an interim solution. The action plan, with estimated dates of completion, shall be submitted to EPD within four weeks of receipt of the Final CEHA Report. The action plan shall be reviewed by the CEHA Team Leader. b) The proponent shall resolve the major findings by the specified closure date. c) The closure of both major and minor findings will be verified on-site as deemed necessary by EPD.
5.9 Closure of Findings
a) System generated reminders are sent every six months to the originator, CEHA program coordinator and proponent manager until closure. b) Trigger for closure of a recommendation is a request for verification from the proponent organization concerned. c) Recommendations are closed in the system by the CEHA Program Coordinator following a verification of closure conducted by EPD employees.
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d) When all tasks (recommendations) are closed, the finding is automatically
closed in the SAP system. e) When all findings are closed, the overall notification is closed in the system. f) A finding involving a project action is not considered closed until the project has been completed and commissioned. g) EPD shall concur on the resolution and closure of all major findings where it is satisfied that the corrective action taken is systematic, sustainable and fully in accordance with code requirements.
6 Responsibilities
Title or Action or Task Organization Responsible for the administration, coordination, and execution of the CEHA program Shall finalize facility selection and the survey team composition by December of the preceding year. Shall send advance notification letters to subject proponent organizations. Environmental Protection Shall originate and approve a SAP EH&S notification for all findings and send the notification to the Proponent Manager. Department (EPD) Shall track the findings via SAP EH&S and work with the Proponent Department to ensure resolution. Shall prepare an Annual Report for submission to Corporate and Executive Management that summarizes all of the CEHA surveys conducted to date and the progress made by facilities in resolving major findings.
Shall provide a knowledgeable and experienced facilitator.
The facilitator must provide any requested pre-survey information. Shall provide access and logistical support to the survey team to inspect its facilities, interview its employees, and Proponent review its documents. Department Shall submit an Action Plan for the resolution of major and minor findings within four weeks of receipt of the Final CEHA Report Track the resolution of all findings and provide six (6) months periodic status for major open findings. Proper documentation shall be uploaded in SAP EH&S to support Saudi Aramco: Company General Use Page 7 of 8 Document Responsibility: Environmental Standards Committee SAEP-64 Issue Date: 2 February 2017 Next Planned Update: 2 February 2020 Comprehensive Environmental Health Assessment
Title or Action or Task Organization closure of resolved findings.
Team Leader directs the course of the survey, including
assigning tasks to team members Members participate fully during the onsite survey Finalizes findings by the end of the survey period Survey Team Presents findings in the Survey Report at the Closing Meeting Assists the Team Leader in preparing the Final CEHA Report
Revision Summary 2 February 2017 New Saudi Aramco Engineering Procedure. This document will formalize assessment procedures used within EPD, ensure consistency in CEHA administration and bring the CEHA program in line with the other main EPD assessment/audit programs (Environmental Performance Assessment) which is recognized under SAEP-32 and the Radiation Protection Assessment (SAEP-390).
