Kuwait Energy
EL-12-211107
The list of activities presented would be adequate to demonstrate that relevant HSSE
activities were being undertaken in line with policies and in accordance with procedure
but there was no documentary evidence to back the assertion that these were being
undertaken on a systematic basis. Further, there were conflicts between this list of
activities and those described by some site personnel, for example, item 7 of the list
states that external audits are undertaken on an annual basis whereas the site
superintendent at Area A stated that external audits are undertaken at six-monthly
intervals.
Both sites (BEA and Area A) operated under the KE corporate HSSE Integrated
Management System, dated 23
rd
April, 2012, which KE stated complied with
ISO4001:2004 and OHSAS 18001:2007. During the visit, an HSSE organization chart
was presented to GCA which showed a direct link to the CEO of KE but did not feature
the President of KEE. Subsequent to the site visit, satisfactory organization charts were
provided illustrating that the HSSE manager in KEE had a second line of reporting directly
to the President of KEE, who did have a role in HSSE matters. Copies (i.e. not originals)
of certificates of registration were seen for KEE. Subsequent to the site visit, copies of
KE’s HSSE policies and procedures, covering its worldwide operations, were provided
and these appear to be up to the expected standard.
KEE’s representative further stated that its Egyptian operations met the local
requirements of Egyptian Law 4, covering all environmental aspects, which is monitored
by the Egyptian Environmental Affairs Agency (EEAA). The National Institute of
Occupational Safety and Health monitors safety and health matters in the workplace and
KEE stated that its operations were inspected/monitored on an annual basis.
Subsequent to the site visit, documents in Arabic were presented ostensibly to indicate
that the EEAA had made inspections every six months, and copies of some internal
audits, minutes of safety meetings and safety tour reports were also provided, but these
revealed a significant number of problems to be addressed.
