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Sama Global HSE Plan December 2023
5. HSE COMPLIANCE
5.1 Introduction
Sama Global has a commitment to HSE as one of its core values. This commitment is clearly outlined in our
Code of Business Conduct. These values guide us in our everyday business activities and provide direction
in how we want to conduct our business with our customers and suppliers. Our HSE Vision describes what
our goal is:
Creating an incident‐free environment
Conducting business with no adverse environmental impact
Integrating HSE into all of our business activities
Defining the value of HSE
Demonstrating industry HSE performance leadership
ﻤﯿـــــﺔSﺎﻟAﻟﻌMﺎ اAـــGﻤــLﺳOBAL
The practices described in this manual can help us achieve this Vision. It is the responsibility of every
employee to understand how to properly handle and manage our materials and wastes. Improper material
and waste management can result in regulatory issues, costs for clean‐up and remediation, exposure to our
employees and the surrounding environment and additional costs to address all of these items.
While the emphasis of this manual is US regulatory requirements for environmental practices many of the
procedures described can be used as best practices company‐wide (i.e., waste inventories, waste
determinations, container labeling, storage requirements and emergency procedures). Implementation of
proper procedures and providing training to affected employees are critical to an effective environmental
management process.
5.2 Regulatory Considerations
Most environmental regulations and permits refer to the “owner/operator” as bearing responsibility for
compliance. In many cases, Sama Global will be an operator of certain activities on our client’s sites. As
such, it is our responsibility to ensure that Sama Global operations and activities are in compliance with
applicable regulations, since every project has some environmental impact. The excuse that we did not
know about the environmental impact of our project work makes a weak and unacceptable defense to
regulatory agency inquiries.
This manual will discuss the personnel responsibilities as they relate to the environmental regulations.
While regulations are patterned after the programs, each regulation has unique concerns. HSE department
should be consulted concerning any communication with environmental regulatory. It is in the best interests
of the company and the client to have knowledgeable professionals talking to personnel about
environmental matters that may have significant impact on the project.
The Government of Iraq and local ministries have the power to enforce environmental regulations, and
violations can result in civil or criminal penalties. These penalties can be assessed against individuals directly
responsible for managing environmental concerns, officers of the corporation, or the corporation itself. The
environmental agencies can become aware of a violation in one of the following three ways:
1. Inspections – The agencies have fairly broad authority to inspect facilities and activities and to review
documents. The inspector may be looking for violations in specific areas, (e.g., hazardous waste) or in
several areas (e.g., wastewater, waste management).
2. Self‐Reporting and Notification Requirements – A number of statutes contain notice and reporting
requirements that require facilities to notify the EPA or other agencies regarding certain activities,
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