Safety Manual. SEMS Program

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1 Page 1 of Purpose The purpose of this program is to ensure that all employees are adequately trained and prepared to work in an offshore environment by having the necessary skills and knowledge. The shall be a documented program and will be readily available to BSEE upon request. Ardent Management will ensure that the is maintained and kept up to date by means of periodic audits to ensure effective performance. An agreement with the operator regarding appropriate safety and environmental policies and practices must be in place prior to beginning work at operator facilities. All employees, both in offices and working on offshore facilities, will participate in the development and implementation of the and will have access to the sections of the plan that are relevant to their jobs. 2.0 Scope All company operations shall use this program both in business units and project operations. 3.0 Policy All employees being assigned to an offshore or SEMS regulated facility shall be trained in operating procedures, safe work practices, JSA s, and emergency response/control measures by a qualified instructor. Qualified trainers must have a recognized certification or equivalent to show their qualification. Assessors must have the qualifications necessary to accurately assess the skills and knowledge of an employee who has been trained. Training records shall be maintained either electronically or in hard copy format and available for inspection or audit. Job-specific training must be provided for new or transferred employees. All employees must be trained on the tasks they perform on a regular basis. Periodic refresher training for all employees will be conducted to maintain adherence to operating procedures. A job title list and roles has been developed and is available for review. Minimal qualifications required to perform each role including a combination of education and work experience has been established. Personnel will be assessed prior to assignment via written examinations and hands-on demonstrations to validate that they possess the required skills and

2 Page 2 of 5 knowledge to carry out their duties and responsibilities and to ensure they are competent to work alone if necessary. The training program and the materials used during training must be evaluated on a periodic basis to ensure that the training is effective and that employees are able to apply what they have learned in the classroom to their field work. Task-specific JSA s must be completed daily that includes all personnel involved in the job activity. The immediate supervisor of the crew performing the job onsite must conduct the JSA, sign the JSA, and ensure that all personnel participating in the job understand and sign the JSA. The JSA must identify, analyze, and record the steps involved in performing a specific job, the existing or potential safety, health, and environmental hazards associated with each step, and the recommended action(s) and/or procedure(s) that will eliminate or reduce these hazards, the risk of a workplace injury or illness, or environmental impacts. The individual in charge of the JSA must approve and sign all JSA s before personnel can begin work. Mechanical integrity and safe operation of all equipment used will be achieved through inspection, testing, and quality assurance. Management of Change The Management of Change (MOC) process addresses temporary and/or permanent changes to the organization, personnel, systems, procedures, equipment, products, materials, services, regulations, and applicable laws. MOC Procedures must be used when revising operating procedures, safe work practices, and training programs. All temporary and/or permanent changes will be evaluated and managed to ensure that risks arising from these changes remain at acceptable levels. The MOC process establishes minimum procedures necessary to identify and control potential hazards or impacts associated with change. The MOC ensures that any changes that could affect the health & safety of personnel or that may threaten the environment are properly recognized, reviewed, approved, communicated, and documented. Proposed changes and the consequences of the change must be communicated to the appropriate personnel.

3 Page 3 of 5 It is the responsibility of all personnel employed by and operating under the Company s control to be familiar with the content and procedures contained herein. No deviation (to the detriment of equipment, material, or personnel) shall be permitted from the intent of these procedures. It is the responsibility of the Company Operations Manager to ensure that the MOC process is fully complied with and documented. All approvals for MOC must be signed by the Operations Manager and if deemed necessary, by a member of Senior Management (i.e., President, Vice President, etc.). Any Company employee can make a request for change to the Company s Standard Operating Procedures (SOP). The request shall be documented on the Management of Change Request Form and sent to the Operations Manager for review. Upon receiving, the Operations Manager shall communicate and discuss the request with the Company s HSE Manager, Quality Manager, and other members of the Company s SEMS committee. Once the committee has approved the request, it will be implemented into the Company s SOP Manual and shall be distributed to all Managers, Field Supervisors and SEMS Committee Members. It shall then be the responsibility of the Company s Operations Manager and Safety Manager to inform and train all personnel whose job tasks are affected on permanent change(s) prior to its implementation or use. Emergency Response Each facility and Ardent crew shall have qualified persons who will be responsible for initiating the emergency response program. Appropriate designated individuals will be responsible for emergency reporting and response requirements as well as complying with all applicable governmental regulations. All employees must be aware of the facility emergency control center and must have access to the following information: o Emergency Action Plans o Oil Spill Contingency Plans o Safety and Environmental Information Emergency response training must be provided at designated intervals for all personnel.

4 Page 4 of 5 Emergency response drills based on realistic scenarios should be conducted to exercise elements contained in the facility or area emergency action plan. Each completed drill shall be evaluated and analyzed to identify and correct weaknesses and deficiencies as necessary. Incident Investigations All incidents with serious safety or environmental consequences and incidents that are determined to have possessed the potential for serious safety or environmental consequences will be investigated. Incident investigations must be initiated as promptly as possible, with due regard for the necessity of securing the incident scene and protecting people and the environment. Recordkeeping All agreements between Ardent and Ardent s operators regarding contractor safety and environmental policies and procedures must be documented. The following records are pertinent to the maintenance and sustainability of the SEMP and must be documented: o Information on applicable regulations o Complaint records o Training records o Process information o Product information o Inspection, calibration, and maintenance records o Pertinent contractor and supplier information o Incident reports o Emergency preparedness and response information o Significant environmental information All records and documentation must be retrievable and protected against loss. All safety policies and procedures will be made available to operator clients at any time upon request. All training, knowledge, and experience that is necessary for an employee to perform their job in a safe and environmentally sound manner will be recorded and documented and may be requested by operator clients and/or the Bureau of Ocean Energy Management, Regulation, and Enforcement at any time. Annual reviews of the SEMP will be conducted at designated intervals to determine if the program is suitable, adequate, and effective. The annual review will address the possible need for changes to the policy, objectives, and other program elements.

5 Page 5 of 5 The management review shall take into consideration program audit results, changing circumstances and continual improvement. Management review observations, findings, conclusions, recommendations, and action items will be documented. All SEMS records will be maintained for 6 years. Stop Work Authority All employees are empowered and expected to utilize their stop work authority to immediately stop work that is creating imminent risk or danger. Stop Work Authority is granted to all personnel without fear of reprisal, to stop work or decline to perform an assigned task when an imminent risk or danger exists. Stop Work Authority shall be included on all JSA s and communicated to all employees through training and safety meetings. All employees are authorized to report unsafe working conditions. Posters regarding instructions for reporting unsafe working conditions will be posted at each job location. Ultimate Work Authority A designated person will be identified as having Ultimate Work Authority. The person with Ultimate Work Authority will oversee specific operations or activities and must be identified on the JSA. If an emergency occurs that creates an imminent risk or danger to the health or safety of an individual, the public, or to the environment, the individual with the UWA is authorized to pursue the most effective action necessary in that individual's judgment for mitigating and abating the conditions or practices causing the emergency.