United Gulf Energy Resources LLC (UGER Oilfield Rentals) HEALTH SAFETY & ENVIRONMENTAL QUALITY MANAGEMENT SYSTEM AND HSE MANUAL

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1 United Gulf Energy Resources LLC (UGER Oilfield Rentals) HEALTH SAFETY & ENVIRONMENTAL QUALITY MANAGEMENT SYSTEM AND HSE MANUAL

2 TABLE OF CONTENTS Topic Page PREAMBLE 4 OUTLINE CHART HSE MANAGEMENT SYSTEM 7 HSE MANUAL INDEX 8 RECORD OF AMENDMENT LEADERSHIP & COMMITMENT 10 Objective 10 Procedure/Standard 10 Organising 10 Implementing 11 Monitoring and Feedback POLICY & OBJECTIVES 12 Objective 12 Procedure/Standard 12 Policy Statements 13 Organising 14 Implementing 14 Monitoring and Feedback ORGANISATION, RESOURCES & DOCUMENTATION ORGANIzING & RESPONSIBILITY: Objective 15 Procedure/Standard 15 Organising 15 Implementing 15 Monitoring and Feedback EMPLOYEE SELECTION, COMPETENCY & TRAINING: Objective 16 Procedure/Standard 16 Organising 17 Implementing 17 Monitoring and Feedback DOCUMENTATION: Objective 18 Procedure/Standard 18 Organising 18 Implementing 18 Monitoring and Feedback EVALUATION & HSE RISK MANAGEMENT 20 Objective 20 Procedure/Standard 20 Organising 20 Implementing 22 Monitoring and Feedback 22 Page: 2

3 5.0 PLANNING HSE Planning Objective 23 Procedure/Standard 23 Organising 23 Implementing 24 Monitoring and Feedback EMPLOYEE INVOLVEMENT Objective 25 Procedure/Standard 25 Organising 25 Implementing 25 Monitoring and Feedback CONTRACTOR SUPPORT SERVICES Objective 26 Procedure/Standard 26 Organizing 26 Implementing 26 Monitoring and Feedback SAFE OPERATING PROCEDURES Objective 27 Procedure/Standard 27 Organizing 27 Implementing 28 Monitoring and Feedback MANAGING CHANGE Objective 29 Procedure/Standard 29 Organizing 29 Implementing 29 Monitoring and Feedback HEALTH SYSTEM Objective 30 Procedure/Standard 30 Organizing 30 Implementing 31 Monitoring and Feedback EMERGENCY RESPONSE Objective 32 Procedure/Standard 32 Organizing 32 Implementing 34 Monitoring and Feedback IMPLEMENTATION & MONITORING MONITORING AND RECORDING Objective 35 Procedure/Standard 35 Organizing 36 Implementing 36 Monitoring and Feedback 36 Page: 3

4 6.2 INCIDENT REPORTING AND INVESTIGATION Objective 39 Procedure/Standard 39 Organizing 39 Implementing 40 Monitoring and Feedback MAINTENANCE TESTING, INSPECTION & MODIFICATION Objective 42 Procedure/Standard 42 Organizing 42 Implementing 43 Monitoring and Feedback AUDIT AND PERFORMANCE REVIEW 7.1 AUDIT 44 Objective 44 Procedure/Standard 44 Organizing 45 Implementing 45 Monitoring and Feedback PERFORMANCE REVIEW Objective 46 Procedure/Standard 46 Organizing 47 Implementing 47 Monitoring and Feedback 47 Page: 4

5 Preamble: The company has in place a comprehensive Health, Safety & Environmental Management System (HSE-MS). Over the years the system has evolved to meet the changing needs of the Company, Operators and Business Partners alike. A general review of Health Safety and Environmental Management Systems was undertaken in 2004 by the Executive Health, Safety & Environmental Committee (EHSEC) and it was agreed that, as an oilfield service provider and International Drilling Contractor, the company would be aligned with the International Association of Oil & Gas Producers (OGP) Guidelines for the Development and Application of Health, Safety and Environmental Management Systems (Report No 210 July 1994). This re-alignment also served to bring the HSE-MS in line with that of major Operators in Oman, including Petroleum Development Oman LLC (PDO) and Occidental of Oman, Inc (OXY). The following specific standards/guidelines relating to Health, Safety and the Environment were reviewed: - Guidelines for the Preparation and Submission of Safety Cases Tripartite National Safety Case Working Group DEPARTMENT OF Minerals and Industry, Western Australia, AS/NZS 4360: 1999 (Australian New Zealand Standard) Risk Management, and - AS/NZS 4804: 1997 (Australian/New Zealand Standard) Occupational health and safety management systems - General guidelines on principles, systems and supporting techniques, A chart outlining the components of the HSEMS is at Attachment 1. The revised Health Safety and Environmental Manual is divided into seven sections: Leadership and Commitment Policy & Objectives Organisation Resources and Documentation Evaluation & Risk Management Planning Implementing and Monitoring Audit and Review Page: 5

6 The seven sections are then expanded into sixteen specific HSE components: Organising & Responsibility Employee Selection, Competency & Training Documentation Risk Assessment / Risk Management HSE Planning Employee Involvement Contractor Support Services Safe Operating Procedures Managing Change Health System Emergency Response Monitoring & Recording Incident Reporting & Investigation Maintenance Testing, Inspection & Modification Audit Review Performance Review Each of the specific components addresses: The Objective of the particular component, i.e., the section s contribution to the HSE Management System Procedure/Standards What we want to apply and formalise in relation to Health Safety & the Environment Organizing Who is responsible for implementation. Monitoring & Feedback Monitoring of the specific components and feedback as to where improvements are to be made. To support the practical implementation of the HSE-MS the following "Guides" have been developed: Policy & Development Organisational Structure & Position Descriptions Training & Development Employee Information Booklet Documentation Change Risk Assessment Personal Protective Equipment Page: 6

7 Environmental Dangerous Goods Transport HSE Plan Meetings / Communications Permit to Work / Tag Out Health Injury Management / Rehabilitation Emergency Planning Inspection Check Lists Incident Reporting & Investigation Audit Further guides will be developed and existing guides reviewed on an on-going basis. The Guides are designed to assist all employees apply the requirements as detailed in the HSE Manual. Reference to the Guides, is made in the Manual and easily identified, by use of the following symbol eg; Injury & Rehabilitation Guide or Personal Protective Equipment Guide This also allows you to automatically link to the relevant guide. Other references are made within the Manual and highlighted. Examples are shown below- Preventative Maintenance Manual Human Relations Policy and & Procedures Manual Job Hazard Manual Material Safety Data Sheet Register These are for information and do not have link facilities to the relevant documents. A summary box of Guides and related documents, where applicable, is shown at the end of each section of the HSE Manual eg; Resource Documents: - Human Resources Policy & Procedures Manual - Guide: Training and Development. Attachment 1: Outline Chart of the HSE Management System. Page: 7

8 Index: 1.0 Leadership & Commitment 2.0 Policy & Objectives 3.0 Organisation, Resources and Documentation 3.1 Organising & Responsibility 3.2 Employee Selection, Competency & Training 3.3 Documentation 4.0 Evaluation & HSE Risk Management 4.1 Risk Assessment & HSE Risk Management 5.0 Planning 5.1 HSE Planning 5.2 Employee Involvement 5.3 Contractor Support Services 5.4 Safe Operating Procedures 5.5 Managing Change 5.6 Health System 5.7 Emergency Response 6.0 Implementation & Monitoring 6.1 Monitoring & Recording 6.2 Incident Reporting & Investigation 6.3 Maintenance Testing, Inspection and Modification 7.0 Audit & Performance Review 7.1 Audit 7.2 Performance Review Page: 8

9 Amendments: 4.0 Leadership & Commitment 5.0 Policy & Objectives 01/06/04: Revision 0 01/06/04: Revision Organisation, Resources and Documentation 3.1 Organizing & Responsibility 3.2 Employee Selection, Competency & Training 3.3 Documentation 01/06/04: Revision Evaluation & HSE Risk Management 4.1 Risk Assessment & HSE Risk Management 5.0 Planning 5.1 HSE Planning 5.2 Employee Involvement 5.3 Contractor Support Services 5.4 Safe Operating Procedures 5.5 Managing Change 5.6 Health System 5.7 Emergency Response 01/06/04: Revision 0 01/06/04: Revision Implementation & Monitoring 6.1 Monitoring & Recording 6.2 Incident Reporting & Investigation 6.3 Maintenance Testing, Inspection and Modification 7.0 Audit & Performance Review 7.1 Audit 7.2 Performance Review 01/06/04: Revision 0 01/06/04: Revision 0 Page: 9

10 1.0 Leadership & Commitment 1. Objective 1.1 To provide and demonstrate strong visible leadership and commitment through involvement and the provision of the necessary resources to develop, operate and manage the Heath Safety and Environmental Management System (HSE- MS). In doing so attain the Policy and Strategic Objectives. 2. Procedure/Standard 2.1 Directors and Senior Management at all times set a high personal example in regard to Health Safety and the Environment (HSE). 2.2 HSE is a fixed Agenda Item at Board Meetings and all Operational Meetings. 2.3 Senior Management actively participates in HSE activities and reviews. 2.4 A detailed Group Health Safety & Environmental plan will be developed on an annual basis. 2.5 During the HSE plan development process, allocation of resources to implement the HSE initiatives and strategies are provided for in both Operational and Capital Expenditure Budgets. Budgets are developed and finalised in consultation with the HSE Manager. 2.6 Senior Management participates in internal and external HSE initiatives, activities and reviews at both local and remote sites. 3. Organizing 3.1 The Health Safety and Environmental Manager will identify and recommend resource requirements from a Group perspective. 3.2 Managers and Drilling Superintendents will identify resource requirements for their respective areas through discussions with their personnel. 3.3 The Operations Manager will consolidate HSE resource requirements into the Operating Budget. 3.4 The CEO will overview the process to ensure that appropriate and timely resource levels are allocated during the development of the Annual HSE Plan and Operating Budget. Page: 10

11 4. Implementing 4.1 Senior Managers will actively participate in HSE activities and initiatives detailed in the HSE plan. 4.2 All Managers required to provide input to the HSE Plan and Operating Budget will take into account completion time frames to ensure that budgets are completed in a timely manner. 5. Monitoring and Feedback 5.1 The HSE Plan will be distributed to Managers once approved. 5.2 Managers monitor HSE Plan implementation including expenditure of the approved budget on an ongoing basis. 5.3 Supervisors and Toolpushers will provide a monthly summary to the HSE Manager of HSE activities undertaken in their location. 5.4 The HSE Manager will report to the CEO on the status of HSE activities and initiatives in formal Monthly Performance Review Reports. 5.5 The EHSEC will review HSE Plan progress at all meetings. 5.6 The CEO will provide feedback to the Chairman, Shareholders and Directors in formal weekly and monthly review reports. 5.7 HSE Plan action items for rigs will be entered into the respective Safety Action Item List (SAIL) and the status of SAIL will be updated and reported monthly. Page: 11

12 2.0 Policy & Objectives 1.0 Objective 1.1 To demonstrate to all employees, clients and sub-contractors that the company has a high level of commitment to effective Risk and Safety Management consistent with and at least equal to other business aims. 2.0 Procedure/Standard 2.1 Group HSE Policy and supporting policies will: Commit the organization to reduce risk and hazards to health, safety and the environment arising from its activities, products and services, to levels that are as low as reasonably practicable (ALARP); Provide the setting for HSE objectives that commit the organisation to continuous efforts to improve HSE performance; Commit the organization to meet or exceed all regulatory and legislative requirements; Apply standards of its own where laws and regulations do not exist; Be relevant to its activities, products and services and their effects on HSE; Have equal importance with the organization s other policies and objectives; Be implemented and maintained at organisational level; Be publicly available. 2.2 Current HSE Policies (see next page). Page: 12

13 2.2 CORPORATE POLICY STATEMENTS: Mission Statement Corporate Health Safety & Environmental Safety Quality Rehabilitation Hours Of Operation Environment Manual Handling Hearing Conservation Waste Management Drug & Alcohol Exposure to Ultra Violet Radiation Smoking Eye Protection Compensation Claims Management Grievance Personal Protective Equipment (PPE) & Clothing Jewellery & Long Hair Food Hygiene Transport Training HSE Risk Management Policy Development Guide Page: 13

14 3. Organizing 3.1 The Health Safety and Environmental Manager will co-ordinate reviews of existing/new HSE Policies and the release of the updated Policy & Objectives Guide. 3.2 The Executive Health Safety and Environmental Committee will review on an annual basis, existing HSE policies. 3.3 The Executive Health Safety and Environmental Committee will review, endorse and seek approval from the Managing Director for the confirmation and implementation of new policies. 3.4 The CEO will sign off on all new HSE Policies. 3.5 The CEO will annually, on the confirmation of the Group HSE Plan, sign off on all existing policies. 3.6 The CEO will maintain a feedback loop to the Chairman, Shareholders and Directors. Policy Development Guide 4. Implementing 4.1 Employees are encouraged through the Policies and Objectives Guide to become involved in the review of existing and the development of new policies. Policy Development Guide 4.2 New employees are advised of their responsibilities and obligations at the time of engagement. Training and Development Guide 4.3 Visitors are advised of their responsibilities and obligations on arrival at any company controlled location or worksite. 4.4 All personnel are advised of the risks associated with the workplace. 5. Monitoring and Feedback 5.1 An annual review of policies and objectives will be undertaken in conjunction with the development of the Annual HSE Plan to ensure that they reflect the needs of the organization, clients and sub-contractors. Resource Documents: - Guide: Policy and Objectives - Guide: Training & Development Page: 14

15 3.0 Organization, Resources & Documentation 3.1 Organizing & Responsibility 1. Objective 1.1 To define, document and communicate the roles and responsibilities, authorities, accountabilities and interrelations necessary, (through the use of organisation charts) to implement the HSEMS. 2. Procedure/Standard 2.1 Safety is a line management responsibility. 2.2 Organisation Charts are developed to identify the reporting relationship between corporate, functional support groups and operations. Organisation & Responsibilities Guide 2.3 New and or transferring employees are inducted as to their roles and responsibilities relative to their position. Visitors and contractors are advised of their responsibilities, the hazards that they may encounter and the hazard control measures in place. 3. Organizing 3.1 The line manager is responsible for ensuring that every person under his control is adequately inducted regarding their HSE responsibilities, commensurate with the position they hold. 3.2 The CEO is responsible to review on a regular basis the reporting relationship and for the update of Organizational Charts. 4. Implementing 4.1 New and/or transferring employees are inducted as to their roles and responsibilities relative to their position. 5. Monitoring and Feedback 5.1 Position descriptions are reviewed as a minimum, on an annual basis during annual performance reviews to ensure they reflect the current position and Changing technologies. Page: 15

16 3.0 Organization, Resources & Documentation 3.2 Employee Selection, Competency & Training 1. Objective 1.1 To ensure that employees are competent to undertake activities that could impact upon the Health, Safety and the Environment of company activities. 2. Procedure/Standard 2.1 Employees are selected in accordance with the Employee Recruitment Procedures. (NDSC Human Resources, Policy & Procedures Manual) 2.2 Position descriptions identify the minimum skill level for each position and contain the necessary HSE requirements per position. 2.3 Where tasks require a specific competence, standards are developed and included in the job descriptions and take account of regulatory requirements. 2.4 Employees who do not have the required level of training will be progressively trained to meet the current minimum standard of training. Training & Development Guide 2.5 The Executive HSE Committee will review and issue a revised minimum standard for training on an annual basis. 2.6 The minimum standards review will take into account safety management systems, policy, plans, procedures, performance standards and regulatory requirements. 2.7 The HSE Manager will maintain and distribute on a regular basis a Training & Development Resource Catalogue, outlining the Training and Development Resources, In-house Training Packages, preferred training providers. 2.8 The Rig Pass Induction Programme or equivalent is to be provided to all new employees. Training & Development Guide 2.9 The Green Hand System or equivalent program is to be used for all new employees. Training & Development Guide Page: 16

17 3. Organizing 3.1 Roles and responsibilities for the selection and recruitment of employees are contained within the Human Resources Policies and Procedures Manual. 3.2 The HSE Manager will ensure that suitable methods are in place to ensure competency requirements are measured against performance objectives. 4. Implementing 4.1 Staffing levels are maintained to ensure that operations are conducted so as to ensure that HSE is not compromised. 4.2 All training undertaken is to be documented and entered into the Training Data Base. 4.3 All employees will be issued with an individual Training Passport to record previous training and training undertaken whilst employed by the company. 5. Monitoring and Feedback 5.1 The Personnel Manager is responsible to ensure that a suitable method, criteria and annual review of Job Descriptions is undertaken. (Human Resources Policy & Procedures Manual) 5.2 The Personnel Manager is responsible to ensure that a suitable method, criteria and annual review of the Selection System is undertaken. (Human Resources Policy & Procedures Manual) 5.3 Managers and Drilling Superintendents will establish a timeframe for the completion of minimum standards of training for those employees who do not meet the minimum standard at the time of engagement. 5.4 The Training and Development function will be audited annually to measure the competency and training system against performance standards. Resource Documents: - Human Resources Policy & Procedures Manual - Guide: Training & Development Page: 17

18 3.0 Organization, Resources & Documentation 3.3 Documentation 1. Objective To provide documented resources related to HSE that reflect the current needs of the organization and its people. Document Control Guide 2. Procedure/Standard 2.1 The Health Safety and Environmental Manager will establish a register of HSE related documents to include but not limited to : Document control; HSE Policy, objectives and plans; Key roles and responsibilities; HSE Management System elements and their interactions; Results of HSE evaluations and HSE Risk Management; Legislative and regulatory requirements; Procedures and work instructions and key activities and tasks; Emergency plans and responses to potential emergencies; Hazardous substances; Contractor arrangements; Training; HSE communications Incident Investigation; Relevant Omani and International Standards. 3. Organizing 3.1 Documentation will take into account the requirements of the company, functions and operations, contractors and partners. 4. Implementing 4.1 Requirements for HSE documentation will be determined by the HSE Manager, for approval by the Executive Health Safety & Environmental Committee, and if necessary, by the CEO. Page: 18

19 4.2 Documentation will be subject to periodic review and revision as necessary and authorisation prior to re-issue. A current list of HSE Resources and documents will be identified in the Document Change Guide. 4.3 Obsolete documents will be withdrawn from use. 5. Monitoring and Feedback 5.1 Recommendations for documentation upgrades will be coordinated by the HSE Manager in accordance with the documentation upgrade flowchart. Resource Documents: - Guide: Documentation Change Page: 19

20 4.0 Evaluation & HSE Risk Management HSE Risk Assessment & HSE Risk Management 1. Objective 1.1 To demonstrate that the company systematically manages all potential risks associated with its operations through identifying hazards, assessing the likelihood, analysing the causes and implementing control measures to ensure risks are reduced to as low as reasonably practicable (ALARP). 2. Procedure/Standard 2.1 A Manual containing Tasks and Hazards associated with company activities will be maintained and continue to be developed as a live resource- Job/Hazard Manual. 2.2 A Manual detailing Tasks associated with company activities will be maintained and continue to be developed as a live resource- Operating Procedures Manual. 2.3 A Register containing substances supplied by the company will be maintained and continue to be developed as a live resource - Material Safety Data Register. 2.4 A Register containing emergency plans will be maintained for all operations and maintained as a live resource - Emergency Response Plan Register. 2.5 A series of Guides will be developed and maintained to assist all employees with the various systems used by the company to manage its HSE Management System. 2.6 The Group Financial Controller will review, on an annual basis, insurance policies to ensure an appropriate level of insurance is provided for the risks undertaken by the organisation. 3. Organizing 3.1 Line Managers will assist in the ongoing development and use of the company Guides as a means of controlling and minimising loss through the identification, assessment and control of hazards. Page: 20

21 3.2 Health Safety and Environmental Personnel will assist Line Managers in the ongoing development and use of company Guides as a means of controlling and minimising loss through the identification, assessment and control of hazards. 3.3 Line Managers will at all times apply good oil field practice in the operation of company assets and comply with the Operations Procedures Manual at all times. (NDSC Operating Procedures Manual) 3.4 Line Managers will continue to monitor their areas of operation, to identify hazards and initiate steps to control them in accordance with the HSE Risk Assessment Guide. HSE Risk Management Guide 3.5 Line Managers are to promote and encourage the use of the STOP System. ODE Guide: Risk Assessment HSE Risk Management Guide 3.6 Where hazards are identified and it is determined that Personal Protective Equipment (PPE), is required, provision of PPE will be made with reference to the Guide on Personal Protective Equipment. Personal Protective Equipment Guide 3.7 Protection of the environment will be taken in accordance with the Environmental Guide. In addition the HSE Manager will undertake a Group Audit relating to the Environment every two (2) years unless there is an identified process or legislative change. Environmental Guide 3.8 Where an unfamiliar/new task is to be undertaken, the hazards and control mechanisms relating to the task are to be discussed with those personnel undertaking the task and with reference to the respective Job/Hazard Manual. Job Sheets are to be developed for tasks not already covered in the Job/Hazard Manual. Job/Hazard Sheets Manual 3.9 Tasks requiring the use of a formal Permit To Work will be identified within the Permit to Work Guide. Permit To Work/Tag Out Guide 3.10 Risks associated with Transport will be managed in accordance with the Job/Hazard Sheet Manual and Transport Guide. Transport Guide 3.11 Risks associated with Dangerous Goods will be managed in accordance with the Dangerous Goods, Transport, and Emergency Planning Guides. Dangerous Goods Guide Page: 21

22 3.12 Risks associated with Health will be managed in accordance with the Health Guide. Health Guide 3.13 Depending on where operations are undertaken and the local legislative requirements, there may be a requirement to develop site-specific Plans, Procedures, Manuals & Registers. The HSE Manager and Operations Manager will coordinate the development of procedures where a specific legislative requirement exists. 4. Implementing 4.1 Employees will be encouraged to participate in the identification of hazards through the use of systems and training programs developed from time to time. These systems include but are not limited to the 'STOP System, Permit To Work System and Job/Hazard Sheets. 4.2 Line Managers are to ensure that corrective action/follow-up is undertaken to effectively minimise loss and that such action is recorded and tracked in the Safety Action Item List (SAIL). 5. Monitoring and Feedback 5.1 Day to day operations will be monitored utilising a range of Inspection Checklists. (See Section 6 Implementing & Monitoring Monitoring & Recording). Inspection/Checklist Guide 5.2 The effectiveness of the components of the HSE Risk Management System will be audited in accordance with the Audit Guideline. Audit Guide Resource Documents: Corporate Guides: Documentation Change HSE Risk Assessment Personal Protective Equipment Environmental Permit To Work/Tag Out Documentation Change Inspection/Checklist Dangerous Goods Transport Health Audit - Job/Hazard Sheets Manual - Operating Procedures Manual - Material Data Sheet Register - Group Emergency Response Plan Page: 22

23 5.0 Planning 5.1 HSE Planning 1. Objective 1.1 To provide and demonstrate a systematic approach to the planning of Health Safety and Environmental activities with a focus on Hazard Identification, Assessment and Control within the organisation. 2. Procedure/Standard 2.1 The Annual HSE Plan will be developed in line with the HSE Plan Guide. 2.2 Plans are developed on an annual basis and will incorporate any specific requirement of Operators and Business Partners. HSE Plan Guide 2.3 A Draft Plan is developed by November each year by the Executive Health Safety and Environmental Committee. It requires approval by the CEO, prior to distribution. 2.4 The HSE Plan will be amended (if required), and the finalized Plan will be distributed in January. 3. Organizing 3.1 The Health Safety and Environmental Manager will ensure that the Annual HSE Plan is developed and distributed in accordance with the time frames as detailed in the HSE Plan Guide. HSE Plan Guide Page: 23

24 4. Implementing 4.1 The HSE Plan will be structured in the format of the Exploration & Petroleum Forum Guidelines: Leadership & Commitment; Policy and Objectives; Organization Resources and Documentation; Evaluation & HSE Risk Management; Planning; Implementation & Monitoring; Audit and Review. 4.2 The HSE Plan will provide for the attainment of HSE Policy, Objectives and Targets. The Plan will incorporate: Defined measurable outcomes; Regular identification, assessment and control of hazards; Legal requirements, associated with the workplace; Past experience (incidents, previous assessments); Compensation experience; Efficiency and effectiveness of existing resources; 4.3 The HSE Plan will be conveyed to employees through formal meetings and presentations in field locations. 5. Monitoring and Feedback 5.1 The status of the HSE Plan will be monitored and progress reported in Monthly Performance Review Reports. Resource Documents: - Company Guide: HSE Plan - Australian/New Zealand Standard AS/NZ4804: 1997 Occupational health and safety management systems- General guidelines on principles, systems and supporting techniques Page: 24

25 5.2 Employee Involvement 1. Objective 1.1 To have in place processes that allow for participation of the workforce in the development of HSE practices and the management of HSE. 2. Procedure/Standard 2.1 All employees have the right to be consulted on all work conditions and practices that may impact on their individual health and safety and all employees have the right and the obligation to Stop Work whenever they feel that an unsafe condition or practice exists. Policy & Development Guide 2.2 Where there is a legislative requirement, a consultative process/document will be developed. 3. Organizing Meetings & Communication Guide 3.1 Health, Safety and Environmental Management is a line management responsibility with ongoing HSE support provided by field and office based safety professionals. 4. Implementing 4.1 Safety Issues are communicated to employees utilising the following mediums: Executive Health Safety and Environmental Committee Meeting Minutes; Weekly Safety Meetings; Toolbox Meetings; Safety Alerts; STOP Items; Incident Reporting & Investigation; Job/Hazard Sheets; Inspections; Individual Training Status; Health Safety & Environmental Plan; Safety Training courses and Presentations Meetings & Communication Guide. 5. Monitoring and Feedback 5.1 A review of the communications processes and consultative arrangements in place will be undertaken on an annual basis, by the Health Safety & Environmental Manager. Resource Documents: - Guide: Policy & Development - Guide: Meetings & Communication Page: 25

26 5.3 Contractor Support Services 1. Objective 1.1 To ensure that corporate Health, Safety & Environmental Objectives are achieved by Contractors and Support Services. 2. Procedure/Standard 2.2 Where contractors and support services are used in company operations employees of contractors and support services will be involved in hazard identification and assessment processes of the tasks undertaken. 2.3 Where outside services are used, formal Project Execution Plans are developed. These outline the activities to be undertaken in all phases of design, construction and commissioning of new plant and equipment. 3. Organizing 3.1 Responsibility for Contractor/Support Services all times rests with line management through the Drilling Superintendent and Operations Manager. 4. Implementing 4.1 Integration of Health Safety and Environmental Safety Management Systems will occur to ensure the highest possible standard relating to the Health Safety and the Environment is achieved. 4.2 Where Contractor/Support Services are used the relevant Manager or Drilling Superintendent will ensure the competence of staff. 4.3 Contractor/Support Services employees are to receive training in aspects of the Heath Safety and Environmental Safety Management System applicable to the tasks being undertaken. 5. Monitoring and Feedback 5.1 Monitoring of compliance will be maintained through the provision of assessments including Pre-Evaluation and Inspections as detailed in Section 7.2 Performance and Audit Review. Page: 26

27 5.4 Safe Operating Procedures 1. Objective 1.1 To demonstrate the effective management of HSE Risk through the development of safe operational procedures commensurate with the risk involved in the procedure. 2. Procedure/Standard 2.1 A Job Safety Analysis (JSA) will be undertaken for all critical tasks. 2.2 Hazard Sheets will be developed to highlight hazards associated with each task as identified in A Manual of Job/Hazard Sheets will be maintained. 2.4 A Manual of Operating Procedures will be maintained. 2.5 A Permit To Work System will be used in association with Job Hazard Sheets. 3. Organizing 3.1 The Health Safety and Environmental Manager will be responsible for the issue of all new and or amended Job/Hazards Sheets once approved by the Executive Health Safety & Environmental Committee 3.2 The Job/Hazard Sheet Manual will be a controlled manual. 3.3 A Permit To Work System is to be used as described in The Permit To Work Guideline. 3.4 Existing Job/Hazard Sheets will be reviewed when there occurs: Permit To Work/Tag Out Guide A change to a process; A change in plant and equipment; The occurrence of a reportable incident. Page: 27

28 3.5 New Job/Hazard Sheets will be developed if and when: New equipment (different from existing equipment) is procured; A new task is undertaken; A new hazard is identified. 4. Implementing 4.1 Employees will be trained in the use of Job /hazard Sheet review and the development of new Job/Hazard Sheets. 5. Monitoring and Feedback 5.1 Auditing of the Job/Hazard Sheet System will be undertaken as detailed in Section 7.2 Performance and Audit Review. Resource Documents: - Guide: Permit to Work/Tag Out - Job/Hazard Sheet Manual - Operating Procedures Manual Page: 28

29 5.5 Managing Change 1. Objective 1.1 To provide and demonstrate a systematic approach that ensures assessment prior to implementation of any proposed changes that may affect the health and safety of operations, and/or the environment in which it operates. 2. Procedure/Standard 2.1 Changes to the HSE-MS will be conveyed to employees via the use of established controlled resource publications/documents, as detailed in Section 3.2 of the HSE Manual and the Documentation Change Guide. Documentation Change Guide 3. Organizing 3.1 Responsibility for the change is contained within the various resources as listed in Section 3.2 of the Manual. 4. Implementing 4.1 Use will be made of existing system components, such as the Risk Management Guide, Job/Hazard Sheets Manual, Material Safety Data Sheet Register, and Emergency Response Plans to assist in the identification of HSE implications when changes are considered. 5. Monitoring and Feedback 5.1 An audit and review of the Management of Change process will be undertaken in line with Section 7.2 of the HSE Manual, Performance and Audit Review. Resource Documents: - HSE Manual: Section 3.3 Documentation - Guide: Documentation Change Page: 29

30 5.6 Health System 1. Objective 1.1 To ensure that the company has a Health System that ensures so far as reasonably practicable, that employees are not exposed to risks to their health. 2. Procedure/Standard 2.1 Ongoing monitoring, (where appropriate) and inspections of the workplace will be undertaken to identify health risks, and provide a mechanism for medical assessment if required. Health Guide 2.2 Pre-placement medical assessments and additional medical assessments as required, will be undertaken in accordance with the Health Guide. Health Guide 2.3 A First-Aid System will be developed for each location consistent with the Health Guide, and in conjunction with the Emergency Planning Guide. Health Guide 2.4 The Incident Reporting and Investigation System will be used to identify any health issues/trends to enable corrective action to be initiated. Incident Reporting and Investigation Guide 2.5 Rehabilitation of injured employees with be consistent as detailed in the Injury Management Rehabilitation Guide Injury Management and Rehabilitation Guide 3. Organizing 3.1 The Health Safety and Environmental Manager has overall responsibility for the co-ordination of Health related services. 3.2 Line Managers are responsible to ensure that Health aspects are consistent with the standards contained in this Section and supporting Guidelines. 4. Implementing 4.1 Standards and Guidelines in place, will at all times meet legislative requirements. Page: 30

31 5. Monitoring and Feedback 5.1 An audit and review of the Health System will be undertaken through the provision of audit processes as detailed in Section 7.2 of the HSE Manual Performance and Audit Review. Resource Documents: - Guide: Health - Guide: Injury Management and Rehabilitation - Guide: Emergency Planning - Guide: Incident Reporting and Investigation Page: 31

32 5.7 Emergency Response 1. Objective 1.1 To establish an Emergency Response System that sets out the procedures to be taken in an emergency. 2. Procedure/Standard 2.1 Each operating area including wellsites, and office/base locations is to establish an Emergency Response Plan to deal with but not limited to the following emergencies - Fire and or Explosion at the well site; Uncontrolled escape of hydrocarbon liquids or gas; Uncontrolled escape of formation water; Uncontrolled escape of toxic or corrosive gases; Discharge of hazardous or toxic chemicals; Major malfunction, structural or mechanical failure of equipment; Structural damage to buildings; Medical emergency due to personal injury; Personal medical condition and allergy; Storms, Cyclones; Aircraft Emergencies Any foreseeable event. 2.2 Each plan will be developed to be easily understood and to ensure all employees understand their role in an emergency situation. 2.3 Each plan will have a schedule of emergency drills. 3. Organizing 3.1 The Health Safety and Environmental Manager has overall responsibility for the co-ordination of Emergency Planning. 3.2 The Health Safety and Environmental Manager will maintain a central file of all Emergency Response plans. 3.3 Line Managers are responsible to ensure that appropriate Emergency Plans are in place and are consistent with the standards contained in this Section and supporting Guideline. Page: 32

33 In particular the plan will address - Competency of employees; The use of outside resources; Training of employees; Communications equipment and procedures; Support structure at head office. 4. Implementing 4.1 The Standards and Guidelines in place, will meet legislative and or good oilfield practice requirements. Emergency Planning Guide 5. Monitoring and Feedback 5.1 An audit and review of the Emergency Planning will be undertaken through the provision of audit processes as detailed in Section 7.2 of the HSE Manual Performance and Audit Review. Resource Documents: - Guide: Emergency Planning Page: 33

34 6.0 Implementation & Monitoring 6.1 Monitoring and Recording 1. Objective 1.1 To ensure there are effective procedures for the monitoring and reporting on relevant aspects of the HSE Management System and for maintaining the records of the results. 2. Procedure/Standard 2.1 An Active Monitoring Process related to Health Safety and Environmental activities will consist of a series of inspections as detailed in the Inspection Checklist Guide. Inspection Checklist Guide 2.2 Monthly reviews of the HSE Plan will be undertaken by the Health Safety & Environmental Manager in association with the Executive Health Safety and Environmental Committee. A monthly Performance Review Report will be provided to Line Managers, the Chairman, Shareholders and Directors. (See section 7.0, Audit & Performance Review). 2.2 A Reactive Monitoring Process relating to known events including the reporting of incident/accident investigations will be maintained in accordance with Section 6.2 Incident Reporting and Investigation. Incident Reporting and Investigation Guide 2.3 All HSE records unless specifically indicated shall be retained for a period of 5 years. (Examples include Incident Investigation Reports, HSE Plans, Audits, Permits to Work). 2.4 Any reports associated with atmospheric monitoring and/or health surveillance shall be retained for 30 years. 2.5 Training records shall be held for an indefinite period. 2.6 Records relating to any plant shall be kept for a period of 5 years unless an approved code of practice specifies a different period. Page: 34

35 3. Organizing 3.1 Line Managers are responsible for ensuring that monitoring is undertaken as detailed in the respective sections of this manual. 4. Implementing 4.1 Employees will be encouraged to participate in all relevant active and reactive monitoring processes. 5. Monitoring and Feedback 5.1 An Audit on the use of active monitoring processes will be undertaken through the provision of audit processes as detailed in section 7.2 Performance Audit and Review. 5.2 A list of current Inspection Checklists and Documents used for monitoring Health Safety and Environmental activities is on the following page. Page: 35

36 Reporting Forms Weekly Safety Meeting Report Monthly Safety Meeting Report Monthly STOP Observation Analysis Green Hand System Rig Induction Base/Office Visitor Induction Journey Management Incident - First Report Form Incident Follow Up Report Form Safety Action Item List (SAIL) Monthly Performance Review report Monthly Safety Review Report (PRIDE) Monthly HSE Statistics Report (PDO) Monthly Key Performance Indicators (KPI) Monthly Emergency drills Weekly Kick Drill Document Reference Number [.. ] [.. ] [....] [..] [..] [..] [.. ] [.. ] [.. ] [.. ] [..] [.. ] [.. ] [.. ] [..] [..] Inspections/Checklist Rig Commissioning Inspection Checklist [. ] Rig Pre-Spud Inspection Checklist [. ] Rig Inspection Checklist Safety 2 [. ] Bi-monthly Rig Inspection Checklist Pt. 1 [. ] Bi-monthly Rig Inspection Checklist Pt. 2 [. ] Motor Vehicle Inspection [. ] Forklift Inspection [. ] Crane Inspection [. ] Fire Equipment Inspection [.] Electrical Inspection [.] Preventative Maintenance Inspection [ See PMS Manual Requirements ] Rig Mast Inspection [ ] Lifting Equipment Inspection [ ] Environment Hazard Inspection [ ] Permits Permit to Work Form Appointment Permit Signatories PTW Control Log Sheet Hazardous Work Checklist PTW Audit Checklist [ ] [ ] [ ] [ ] [ ] Page: 36

37 Document Reference Number Audits HSE-MS Audit Internal Monthly Operations Audit Weekly STOP Audit [.. ] [.. ] [.. ] Training Reporting Forms Training Course Attendance Report Employee Training Passport [. ] [. ] Personnel Reporting Forms Personnel Evaluation Report Employee Action Notice (EAN) [. ] [. ] Resource Documents: - Guide: Inspection Checklist - Guide: Incident Reporting and Investigation - Electrical Specification Manual - Preventative Maintenance Manual - HR Polices & Procedures Manual Page: 37

38 6.0 Implementation & Monitoring 6.2 Incident Reporting & Investigation 1. Objective 1.1 To demonstrate there is a systematic method of incident reporting, investigation and follow up to prevent a recurrence. 2. Procedure/Standard 2.1 Procedures for the reporting of all incidents affecting Health, Safety and the Environment are detailed in the Incident Reporting and Investigation Guide. 2.2 Specifically: Incident Reporting and Investigation Guide A First Report of any incident is required immediately an incident occurs and is to be forwarded to the HSE Manager, Operations Manager and respective Drilling Superintendent at Muscat Base Office. A more detailed investigation and Follow UP Report may be required and if so, the Report is to be forwarded to the HSE Manager normally within 48 hours of an incident occurring. Incident Reporting and Investigation Guide 3. Organizing 3.1 Responsibility for Incident Reporting and Investigation primarily rests with Line Management. External support if required will be coordinated by the HSE Manager in accordance with the Incident Reporting & Investigation Guide. 3.2 Employees, through their line managers, will be encouraged to become involved in the investigation of incidents. 3.3 A flow chart detailing the incident reporting and investigation process is detailed in the Incident Reporting & Investigation Guide. Page: 38

39 4 Implementing 4.1 Current Report forms are included in the Incident Reporting & Investigation Guide. It is essential that only current forms be used. 4.2 The Health Safety and Environmental Manager will be responsible for the timely reporting to the regulatory authorities, as required. 4.3 The Health Safety and Environmental Manager will be responsible for the compilation of statistics to government agencies, operators and other associations as directed by the CEO. 4.4 The Executive Health Safety & Environmental Committee (EHSEC) will review all Incident Investigation Reports and direct follow-up action as appropriate. Such action may include the distribution of Safety Alerts. 4.5 All corrective actions identified in Incident Investigation Reports will be entered in a Safety Action Item List (SAIL) and will be tracked to close-out. 5. Monitoring and Feedback 5.1 For all Recordable Incidents (Fatality, Lost Time, Medical Treatment, Restricted Work) and Significant Incidents (including environmental) the EHSEC will: Confirm and document the satisfactory close out of these incidents; Require a risk assessment (based on Australian/New Zealand Standard AZ/NZS 4360) to be undertaken by the Health Safety & Environmental Manager to identify if the corrective action has resulted in a reduction of the risk associated with the activity being undertaken at that time. 5.2 Corrective actions are selected based on the principle of risk minimisation and by the application of the following hierarchy of controls: Engineering Controls - including substitution, isolation, modification to design, machine guarding and mechanical ventilation. Administrative Controls - including job rotation, job re-design, roster changes and limiting exposure time. Personal Protective Equipment this is the last line of defence and is only considered after Engineering and Administrative Controls. PPE does nothing to control the existence of a hazard. Page: 39

40 5.3 An Audit on the use of reactive monitoring processes will be undertaken through the provision of audit processes as detailed in section 7.2 Performance Audit and Review, with a focus on corrective action implementation and follow up. Resource Documents - Guide: Incident Reporting and Investigation Page: 40

41 6.0 Implementation & Monitoring 6.3 Maintenance Testing, Inspection and Modification 1. Objective 1.1 To ensure there is an effective system of planned maintenance and inspection and testing and minor modification that will reduce risks to as low as reasonably practicable (ALARP) through the life of plant/equipment. 2. Procedure/Standard 2.1 A Preventative Maintenance System (PMS) will be used to monitor critical components of operating plant and equipment. 2.2 The PMS will list all major components of operational plant and equipment. 2.3 The PMS will identify all equipment to be subjected to NDT Magnetic Particle Inspection. 2.4 Where required the PMS will indicate API inspection procedures. 2.5 The PMS will include API inspection requirements for - Used drill pipe; Heavy weight drill pipe; Used drill collars and subs. 2.6 The PMS will identify the frequency of inspection (3, 6 and 12 months) 2.7 Electrical Inspections will be undertaken in accordance with the Electrical Test and Examination Schedule. (Rig & Camp Site Electrical Specification) 2.7 All modification to plant and equipment will be in accordance with established maintenance procedures. (Application For Modification Form). (Modification Procedures Manual). 3. Organizing 3.1 A Rig Specific PMS manual will be held for all operating Rigs. Page: 41

42 4. Implementing 4.1 The Preventative Maintenance Supervisor (PMS) will co-ordinate all activities associated with the PMS in association with Line Managers and field based trade personnel. 5. Monitoring and Feedback 5.1 The Operations Manager, Drilling Superintendents and PMS will monitor the use of the Preventative Maintenance System and modification to company assets, and will report on its effectiveness on a routine basis. Resource Document: Preventative Maintenance Manual Modification Procedures Manual Rig & Camp Site Electrical Specification Quality Assurance Procedures AS ISO 9002 Page: 42

43 7.0 Audit & Performance Review 7.1 Audit 1. Objective 1.1 To define, document and have in place an effective Audit process to ensure that Health Safety and Environmental Systems are implemented, maintained and provide for a safe workplace. 2. Procedure/Standard 2.1 The Health Safety & Environmental Management System will be internally audited annually. Components to be audited are: Leadership & Commitment; Policy & Objectives; Organisation, Resources, Documentation; Evaluation & Risk Management; Planning; Implementation and Monitoring; Audit & Review; 2.2 HSE Procedures will be selected in advance and audited on a monthly basis in accordance with an established schedule contained in the Annual HSE Plan. 2.3 External audits will be undertaken by the Clients in accordance with the schedule they establish. 2.4 Additional auditing may be undertaken where it is identified that: There is a change in Legislation; Changes occur in the products, processes, services or activities; Advances occur in science and technology including epidemiology; A significant Health Safety or Environmental incident has occurred; Significant non-conformance is identified within a scheduled Audit; The Executive Health Safety & Environmental Committee (EHSEC) deems it necessary. 2.5 Rig operations shall be externally audited at least each three years. Page: 43

44 3. Organizing 3.1 The HSE Manager is to ensure that a schedule of Health, Safety and Environmental Auditing is prepared for inclusion in the Health Safety and Environmental Plan. 3.2 The Executive Health, Safety and Environmental Committee will confirm the Audit schedule. 4. Implementing 4.1 The Health Safety and Environmental Manager will provide criteria for auditing each component of the Heath Safety and Environmental Management System. 4.2 The audit process will follow the procedures as detailed in the Audit Guide. Audit Guide 5. Monitoring and Feedback 5.1 An Audit on the use and application of the Audit Process as detailed in the Audit Guide will be scheduled as detailed in Section 2, Procedure/Standard. 5.2 The status of the audit schedule, outcomes, recommendations and corrective actions will be reported monthly in the Performance Review Report. 5.3 All findings of external Health Safety and Environmental audits will be reviewed by the Executive Health, Safety and Environmental Committee. Resource Documents: - Guide: Audit Page: 44

45 7.0 Audit & Performance Review 7.2 Performance Review 1. Objective 1.1 To enable the company to review and continually improve the Health, Safety and Environmental Management System to achieve overall Health Safety and Environmental performance. 2. Procedure/Standard 2.1 The Executive Health Safety and Environmental Committee (EHSEC) will review annually all policies associated with the Health, Safety & Environmental Management System as identified in Section 2.1 Policy & Objectives. 2.2 The Executive Health Safety and Environmental Committee will review on a monthly basis Heath Safety and Environmental objectives, targets and performance objectives. 2.3 The Executive Health Safety and Environmental Committee will evaluate the effectiveness of the Health Safety and Environmental Management System and the need for changes in light of: Changing Legislation; Changing expectations and requirements of interested parties; Changes in the products or activities of the organisation; Changes in the structure of the organisation; Employee numbers; Customer requirements; Cultural requirements; Advances in science and technology including epidemiology; Lessons learned from Health Safety and Environmental incidents; Market preferences; Reporting and communication; Feedback (particularly employees). Page: 45