Assessment and Improvement of a Safety Management System: A Case Study of a Diving Contractor in Vietnam

Offshore diving is reputed a dangerous and risky job because of its working conditions: high pressure and caisson disease, working alone in dark and deep water, using many types of equipment supporting from surface so safety requirements in diving operations are very high and strict.

In tendering for an offshore construction project, diving contractors are required to submit their safety management system to client to demonstrate that their businesses are managed efficiently and responsibly, and that they can provide a reliable service without excessive downtime caused by work-related accidents and incidents.

While offshore diving in some areas is heavily regulated, there are other areas where there may be little or no outside control of diving activities. In such areas the diving contractors themselves are left to establish their own internal controls by means of their company manuals and procedures. (IMCA D014)

To establish and implement or assess OHS MS of a diving contractor, beside applications international standards, national laws and regulations, and diving specific requirements should be considered and complied.

Mr. Dao Manh Tuong made a study which aim is to review requirements for safety management system of a diving organization, assess safety management system for diving services of PetroVietnam Manpower Training College (PVMTC) to identify non-conformances of the safety management system. From result of the assessment, some recommendations are suggested to improve the system. PVMTC is selected for his case study because they are the biggest diving contractor supplying diving services in oil and gas industry in Vietnam. To achieve the main objective, the sub-objectives are defined to: (1) review requirements for safety management system of a diving organization; (2) assess the existing safety management system of a Vietnamese diving contractor – PVMTC and identify the gap and non-conformances of the safety management system; (3) draw some recommendations for improving the current safety management system of the diving contractor.

Conclusions

OHS MS requirements of a diving organization

OHSAS 18001:2007 standard defines a model with elements of an effective OH&S management system for an organization and specifies requirements for the elements of the system. OHSAS 18001:2007 standard can be applied to any type and size of organizations (OHSAS 18001:2007).

The Regulations No. 41/1999/QD-TTg requires organizations operating in petroleum industry to have establish and develop effective safety management system but it does not specify a model of safety management system which organizations have to follow. In IMCA D014 – “IMCA International Code of Practice for Offshore Diving”, it does not require diving organizations to establish and maintain a safety management system for their organization. It requires diving organizations to establish a management system and prepare some documents to manage a specific diving project.

A comparison of requirements shows that there are correspondences between OHSAS 18001:2007, Regulations No. 41/1999/QD-TTg and IMCA D014. Documents of a safety management system comply with OHSAS 18001:2007 standard is also fulfilled requirements of Regulations No. 41/1999/QD-TTg. These documents could be reviewed and revised periodically or when necessary as defined by organizations. Documents required by IMCA are more detailed and extended for OHSAS requirements to control operations of a diving organization. Documents required by IMCA have to be reviewed and revised for each diving project.

Assessment of PVMTC’s OHS MS for diving services

The documentations of OHS MS in PVMTC are in general compliance with the Vietnam legal requirements. There are only two documents need to be prepared as required by regulations. Those are lists of relevant regulatory requirements and lists of specific requirements that fulfill the regulatory requirements in the area of safety and working environment.

The review of documentation and records of diving systems and of diving projects in Technical Services Department has shown that documentation; procedures and guidelines, and records for routine activities of diving system are prepared and performed very good and fulfill IMCA requirements. However, documentation required by IMCA to manage a diving project is not prepared adequately and regularly. They are prepared only when clients request. For example:
Diving project plan
Safety management system interface documents
Risk management process matrix
Risk assessment
Management of change procedure
Procedure for site-specific risk assessments
Procedures for control assessed hazards and risks

Recommendation to Improve the Existing OHS MS of PVMTC

From findings of the assessment some recommendations are suggested to improve the existing OHS MS of PVMTC to desired safety management system which complies with OHSAS 18001:2007 and fulfills specific requirements to which the organization subscribes.
1. Adapt the existing OHS MS to conform to OHSAS 18001:2007 and integrate with quality management system.
Improve organization structure focus on project management structure.

3. Identify and assess applicable legal requirements and other requirements.
4. Perform risk & hazard assessment for all activities of a diving project.
5. Standardize and document procedures for some routine activities and processes of a diving project.
6. Implement and maintain OHS programs and procedures

His thesis abstract is copied and posted.

ABSTRACT

Offshore diving is reputed a dangerous and risky job. Safety requirements in diving operations are very high and strict. A commercial diving contractor has to conform to various regulations, standards, codes and guidelines from local governments, the clients, and the insurers of the diving contractor or other outside organizations, societies, advisory committees and associations. To establish, implement or assess OHS MS of a diving contractor, beside applications international standards, national laws and regulations and diving specific requirements should be considered.

The aim of this thesis is to review requirements for safety management system of a diving organization, assess safety management system for diving services of PetroVietnam Manpower Training College (PVMTC) to identify non-conformances of the safety management system. From result of the assessment, some recommendations are suggested to improve the system.

The OSH MS assessment was conducted using checklists based on reviewing of requirements of OSHAS 18001:2007, Vietnamese applicable laws and regulations, and of diving specific requirements of IMCA. The assessment consisted of review of written documentation and performance of the existing OHS MS. No formal interviews or walk-through inspections of operations and work areas was done.
Finally, conclusions and recommendations for improving the existing system of PVMTC are drawn from findings of the assessment.