Health And Safety Policies And Procedures Manual

Diverse2

Health And Safety Policies And Procedures Manual

Byadmin ianuarie 1, 2024

SECTION 1 ……………………………….. GENERAL

SUBSECTION 1 INTRODUCTION

SUBSECTION 2 ORGANIZATION, ROLES AND RESPONSIBILITIES

SUBSECTION 3 DOCUMENT ORGANIZATION AND DESCRIPTION

SUBSECTION 4 MANAGEMENT OF CHANGE

SECTION 2 …………………………………. RELATED DOCUMENTATION AND INFORMATION

SUBSECTION 1 MANUAL STRUCTURE

SUBSECTION 2 QHSE STEERING COMMITTEES SUBSECTION 3 HSE MENTORING

SUBSECTION 4 ISM CODE

SECTION 3 …………………… HEALTH POLICIES, PROCEDURES AND DOCUMENTATION

SUBSECTION 1 RISK MANAGEMENT

1 MEDICAL PREPAREDNESS OF OVERSEAS ASSIGNMENT

2 PATHOGENS

SUBSECTION 2 IMPLEMENTING AND MONITORING

1 INSTALLATION CLINICS, MEDICAL DOCUMENTATION AND WORLDWIDE ONSHORE CARE

2 POTABLE WATER

SUBSECTION 3 EVALUATING AND IMPROVING

1 SANITATION, HYGIENE AND SMOKING LIMITATIONS

SECTION 4……………………. SAFETY POLICIES, PROCEDURES AND DOCUMENTATION

SUBSECTION 1 ORIENTATION AND TRAINING

1 HSE ORIENTATION

2 DRUGS, ALCOHOL AND WEAPONS IN THE WORKPLACE

3 TRAINING

SUBSECTION 2 RISK MANAGEMENT

THINK PLANNING PROCES

PERMIT TO WORK

CLIENT AND SUBCONTRACTOR PERSONNEL AND EQUIPMENT

DRESS REQUIREMENTS AND PERSONAL PROTECTIVE EQUIPMENT

SUBSECTION 3 PLANNING

1 HYDROGEN SULFIDE

2 EMERGENCY RESPONSE

SUBSECTION 4 COMMUNICATION

1 HSE INFORMATION

2 HSE MEETINGS

SUBSECTION 5 IMPLEMENTING AND MONITORING

1 START PROCESS

2 TRAVEL

3 GENERAL SAFE WORK PRACTICES

4 ENERGY SOURCES AND ISOLATION

5 FALL PROTECTION

6 MECHANICAL LIFTING

7 HAZARDOUS MATERIALS

8 PERSONAL IMPAIRMENT

9 ELECTRICAL SAFETY

SUBSECTION 6 EVALUATING AND IMPROVING

1 HSE RECOGNITION

2 FOCUS IMPROVEMENT PROCESS

3 INCIDENT REPORTING

The Health and Safety Management System described in this manual was compiled to improve HSE performance while attempting to capture the hard-learned lessons experienced in the past.

The policies and procedures in this manual are intended to address the hazards associated with our operations. The system is designed to enable individuals and teams to carry out a suitable and sufficient risk assessment for each task performed and maintain control to prevent incidents.

To achieve our safety vision of an incident-free workplace, it is vital that we know our people and enable them to contribute to their maximum potential while respecting the diversity of cultures and personality traits of individuals.

Mentoring is important at all levels within the organization to ensure that the wealth of knowledge of more experienced people is shared with less experienced people, to help them achieve their full potential.

It is not through rules alone that we will achieve our vision of an incident-free work place. It is through people actively caring and participating in our processes and by proactively taking responsibility for the well being of themselves and their co-workers.

It is important that all personnel understand their obligation to interrupt the operation if they observe an act or situation that could cause an incident.

The key tools within the system are the THINK Planning Process and the START Observation and Monitoring Process. Proper planning is the first step to implementing an incident-free operation. The THINK process reminds personnel to think about everything they do before actually doing it. The START process of monitoring the operation and reinforcing safe behavior, while correcting any unsafe acts or conditions, is vital to ensure that the necessary controls remain in place during implementation.

Personnel must be responsible and held accountable for their actions if an incident-free workplace is to be achieved.

This manual is a living document and depends on input from the end user to ensure it is modified or updated as necessary. Please do not hesitate to provide any feedback you have to Corporate HSE Department.

Health and safety area (S.S.O.) represents a specific operations assembly transformed into a complex management tool, intending to control the factors that act on occupational health and safety levels, as a result of occupational accident and disease factors identification, diagnosis and minimization, providing working conditions and medical assistance to work process attendees. S.S.O. activity objective, conferred by law, aims to remove or minimize the occupational accident and/or disease risk factors, existing in the work process, specific to any of its components (doer-work task-means of production-work environment), employees and their representatives in the area information, consulting and attendance.

S.S.O. represents a main component of general management and meets the company identified hazards features and levels, the applicable legal regulations and other regulations the company complies with.

This policy materialization is accomplished by the continuous design, implementation, maintenance and improvement of S.S.O. management system, to make possible the following basic targets:

compliance with all legal requirements, regulations and other S.S.O. relevant requirements;

Implementation, maintenance and improvement of a system to identify the hazards, and evaluate and control the risks associated to our activities;

Acquirement and use of safe technical equipment’s, raw materials, individual safety materials and equipment;

Accomplishment of preventive programs to ensure the permanent maintenance of work systems elements in a condition that meet the occupational safety and health assumed targets;

The employment of labor force able to accomplish the workplace tasks, under occupational safety and health conditions;

Employees training and improvement under occupational safety and health requirements, so that to accomplish an adequate managerial culture;

Company relationship modeling with central and local administration agencies, qualified to guide and control the occupational safety area activity;

Each employee required training, acknowledging and competence provision, in order to understand his role and responsibilities regarding S.S.O. efficiency improvement.

The personnel to have assigned specific responsibilities and to be motivated for company S.S.O. area policy implementation, in order to satisfy the interested parties expectations, and to continuously improve the S.S.O. management system efficiency;

Our philosophy in the corporative social responsibility area shall be to carry out projects and promote actions in education and sport areas, and to support the employees and local communities.

The Rig Oilfield Services S.S.O. management system complies with SR OHSAS 18001:2008 requirements, and in the capacity of General Manager, I take the responsibility to provide the material and human resources for S.S.O management system continuous implementation, maintenance and improvement, accordingly to the reference standard requirements of the occupational health and safety management system.

In the capacity of Rig Oilfield Services General Manager having authority and responsibilities regarding S.S.O. management system continuous design, implementation, maintenance and improvement coordination.

In order to meet the targets, any Rig Oilfield Services employee shall be fully aware of the own responsibility for workplace hazard level minimization, for the assurance of S.S.O. management system running and improvement continuity, in the whole company and its operations. All the employees’ service obligation is to acquire and apply without any exception the occupational health and safety management system documentation provisions.

GENERAL ORGANIZATION, ROLES AND RESPONSIBILITIES

1 ROLES AND RESPONSIBILITIES

HSE management is a line management responsibility. Visible management commitment and involvement at all levels is essential for successful HSE performance.

The purpose of this section is to provide an overview of the responsibilities of key positions within the Company organization with regard to achieving the Company Safety Vision:

“Our operations will be conducted in an incident-free workplace – all the time, everywhere.”

All Company personnel at all levels of the organization have the responsibility to comply with policy and procedures and participate in the achievement of annual HSE goals. Participation fosters positive, proactive attitudes and behavior to help meet HSE goals.

1.1 CHIEF EXECUTIVE OFFICER:

The Chief Executive Officer is ultimately responsible for the health, safety and welfare of all personnel working at Company installations, facilities and offices. Specific responsibilities include:

• Establishing and supporting the Company Safety Vision: “Our operations will be conducted in an incident-free workplace – all the time, everywhere.”

• Reviewing and giving approval of the Company Quality, Health and Safety, and Environmental Policy Statements applicable to worldwide operations.

• Give final approval of the necessary resources to maintain and improve the

HSE performance throughout Company operations.

• Attends Corporate QHSE Steering Commeetings and participates in regular reviews of overall HSE Performance to ensure effective HSE plans are in place to achieve the Company Safety Vision.

• Ensure that the value placed on HSE is never compromised and safety is placed on at least an equal footing to operations performance.

1.2 CHIEF OPERATING OFFICER:

The Chief Operating Officer is responsible for the day-to-day operations of the

Company.

• Review critical incidents with line management to ensure appropriate lessons are learned and adequate action plans are implemented.

• Review HSE indicators to ensure preventive actions implemented are providing adequate results.

• Be responsible for safe and efficient operation in worldwide operations.

• Ensure that adequate resources are dedicated to effectively support line management with regard to HSE issues in worldwide operations.

• Review and give approval of the Company Quality and HSE Policy

Statements applicable to worldwide operations.

• Participate in the annual review of HSE performance to identify gaps and any needed modification of HSE plans to achieve the Company Safety Vision.

• Issue guidelines to HSE plans and give final approval of those plans.

• Ensure implementation of Company HSE policies and procedures in worldwide operations.

1.3 QHSE Representative:

• Ensure adequate resources are available to support Business Unit Vice

Presidents on HSE issues that are applicable worldwide.

• Participate in the annual review of HSE performance to identify gaps and any needed modification of HSE plans to achieve the Company Safety Vision.

• Review and give approval of Company QHSE policies applicable to worldwide operations.

• Review and give approval of the Company Quality, Health and Safety, and

Environmental Policy Statements applicable to worldwide operations.

• Be responsible for the activities of QHSE Department to achieve global QHSE

objectives.

1.4 OIM OR MASTER:

• Develop installation HSE plans to achieve the Company Safety Vision.

• Monitor execution of installation HSE plans and provide a consistent approach to achieving the Company Safety Vision.

• Lead by positive example.

• Implement HSE policies and procedures on their assigned installation.

• Develop installation-specific procedures.

• Ensure installation class and statutory documentation is current.

• Assist with incident analysis as required.

• Authorize specific personnel for various circumstances (for example, responsible person for work permits, authorization for specific equipment operation, and so on).

1.5 SUPERVISORS:

• Participate in the development of installation HSE plans to achieve the

Company Safety Vision.

• Implement HSE policies and procedures within their departments.

• Ensure crewmembers are properly trained and fully understand plans for upcoming tasks and their responsibilities within those plans.

• Provide advice and guidance to crewmembers, act as a positive role model.

• Take a leading, participating role in the Performance Monitoring Audit and

Assessment.

• Conduct and facilitate effective HSE meetings.

• Treat people as THEY NEED to be treated, know your people

1.6 ALL COMPANY PERSONNEL:

• Visibly conduct themselves in line with the FIRST core values.

• Be responsible and accountable for their behavior and for their own safety.

• Have the obligation and the responsibility not to participate in an unsafe act and also the obligation and responsibility to interrupt any operation to prevent an unsafe act or unsafe condition from causing an incident. Each individual also has the obligation and responsibility to take action to correct any unsafe behavior or condition.

• Provide support by removing barriers that prevent achieving the Company Safety Vision: “Our operations will be conducted in an incident-free workplace, all the time. Everywhere.”

• Become familiar with and implement all applicable HSE policies and procedures.

• Actively support and practice the Company THINK, START and FOCUS processes in order to effectively plan, monitor and improve the HSE aspects of the operation.

• Immediately report all incidents to a Company supervisor.

• Actively participate in the various Company plans to improve HSE aspects of the operation (HSE Meetings, QHSE Steering Committees, Emergency Drills, HSE plan development and implementation, etc.).

• Actively mentor co-workers to help them improve their HSE performance.

• Be aware and understand their responsibilities and authority levels as documented in their job description and HSE Manual.

• Treat people as THEY NEED to be treated.

• Walk the talk.

2 ORGANIZATION

The C.E.O. is ultimately responsible for the safe and efficient operation of the Company. The Chief Operating Officer is responsible for the day to day operations of the Company. The Vice President QHSE is responsible for the activities of QHSE Department to achieve global QHSE management objectives. The Director of QHSE is responsible for the overall planning, maintenance and implementation of the HSE Management System in order to achieve QHSE objectives. Figure A illustrates line management at the executive level.

3 HSE FUNCTION

The HSE Department is independent of line management and provides support and advice on all matters related to HSE.

The role of the HSE Department includes three main areas: development and communication of appropriate HSE Policies and Procedures, global HSE strategy and support to operations, and development and deployment of Corporate Operations Safety Advisors.

HSE Policies and Procedures

• Communicate clear HSE expectations through the Corporate HSE Policies and Procedures.

• Review and act upon HSE related feedback to ensure effective understanding of expectations and capture lessons learned.

• Participate in, evaluate and align with regulatory, client and industry best practices for continuous improvement when applicable.

HSE Support for Global Operations

• Monitor global HSE performance.

• Assign high caliber line staff to HSE support positions.

• Facilitate and manage ISM and ISPS aspects at the corporate level.

• Facilitate and coordinate the follow up of critical incident analysis as requested.

• Communicate critical safety issues through HSE Alerts and various safety related reports.

• Communicate appropriate lessons learned across the Company.

• Oversee the operation of the Med-Track Program in conjunction with Human

Resources and Risk Departments.

• Directly support Medical Emergency Response Plans and oversee management of Medical Topside Support in the Business Units and Divisions.

• Develop HSE related training in conjunction with the Training Department and specifically deliver Safety Leadership Training (SLT) to key Company personnel.

• Monitor worldwide health, safety and security risks and, where appropriate, communicate to affected personnel.

• Monitor environmental legislation and communicate to affected personnel.

• Work with Supply Chain Management to review and evaluate potential HSE

RELATED DOCUMENTATION AND INFORMATION

HSE MENTORING

1 RECOGNITION AND APPRECIATION

The Company clearly recognizes the benefits associated with providing a working environment in which people, at all levels of the Company, feel "connected" to the Company and are given the opportunity to develop to their full potential. The FIRST core values of the Company are an integral part of our daily lives. Improving human behavior in all areas of our operation is fundamental to the success of individuals, groups of individuals and the Company as a whole. One of the key elements in the successful development of people is a network of mentors, within which people are offered constructive feedback, advice, guidance and suggestions towards personal and career development. People are respected and rewarded for helping each other succeed.

2 WHAT IS A MENTOR?

The dictionary defines mentor as "a friend entrusted with education; a trusted counselor, coach or guide." In modern terms, a mentor is someone who is a friend and a role model; an able advisor; a person who lends his support in many different ways to one pursuing specific goals.

3 WHO IS A MENTOR?

Many people have the potential to be a mentor, and may emerge from any level within the organization. Generally speaking, supervisors should be the most appropriate people to act as role models and mentors, simply because they have more experience of life and work to communicate with less experienced people. In very broad terms, a mentor is someone who has the positive personal attributes, valuable knowledge, and the experience in their personal and working lives, which can only be gained over a period of time. A great number of people are already mentoring as individuals, husbands, wives, parents, friends, sports team members and co-workers.

Mentors can be many things to many people; however, they all have similar clearly recognizable characteristics:

• They often do not realize they are seen as mentors; they are "naturals."

• They enjoy mentoring and provide an atmosphere for learning.

• They don’t hesitate to ask other team members for advice or help when needed, focusing on what is right, not who is right.

• They make a conscious effort to develop a sense of responsibility and accountability within the team.

• They consider the other person's point of view, treat people as they need to be treated and come to agreements.

• They keep their mentees informed.

• They naturally strive to develop and motivate people.

4 WHY DO WE NEED MENTORS?

It is vital that we as a Company seek and take every opportunity to develop and motivate people within the organization. People with valuable personal qualities and talent are in positions around the world, and we understand the value of communicating their life and work experiences to those less experienced. Our intent is to provide a forum and structure so people are continually encouraged, motivated and developed.

5 WHEN DOES MENTORING TAKE PLACE?

There is no set time or place for mentoring to take place. The important thing is that it is provided regularly, and that it is honest and understood. Remember that feedback, both supportive and constructive, is best given as soon as possible after the event requiring it and is best given face to face and one-on-one, but does not have to be. People can be mentored with a look, a letter, a gift, a conversation or phone call. The mentor knows what is appropriate.

6 HOW CAN MENTORING BE ESTABLISHED AND EFFECTIVE?

Some mentors are "naturals" in the art of mentoring and others need some advice and guidance to improve their mentoring skills.

It must be important to establish a relationship between the people involved, discover each other's colors and understand the characteristics of each color. A huge motivating factor in any relationship is giving recognition. Make sure people know their contribution is important to the team's overall success. The recognition must be genuine; deserved encouragement brings out the best in people. Although a close mentoring relationship needs to develop, there needs to be just enough distance so that the mentor remains objective.

When trying to help each other, both people in the relationship must know if the other has any concerns or worries. Ask broad, open-ended questions that give people the latitude and permission to speak honestly and without risk. Do not pry; you are a mentor not an inquisitor. Remember that when you ask a question it is vital to listen to the answer. Be responsive to people's fears and concerns.

Communication is the glue that holds all relationships together and communication must always be open and honest. A mentor should never apologize for providing corrective feedback.

Mentors know that setbacks sometimes occur at work. Finding solutions for problems is one of the strengths of a mentor. When searching for solutions, the mentor always looks beyond personal interest to the "Big Picture."

Above all, mentors should understand that personal and team success is not a single event but a continuous ongoing process. Mentors must find ways to stay motivated towards success in endeavors.

As with many things, ACTION makes the difference, and the following steps are the required actions for an effective mentoring network:

• In its simplest form, mentoring is a "buddy" system providing someone new to a place of work or in a new position, with a "buddy". The buddy must be an experienced co-worker and show what is expected, what to do and what not to do, and provide experienced information and guidance. Remember that very inexperienced people often do not even know the right questions to ask.

• Once established in a place of work or in a position, a person can be reasonably expected to have learned the "basics" and mentors can then plan long-term objectives. This is required to allow people to more fully develop and start teaching the philosophy of the Company. As previously stated, there is no standard format to follow, mentoring begins with communication.

• The long-term goal of mentoring is for the original mentor to phase out, allowing the person being mentored to become a mentor, which is a natural progression of success. In the early stages of the mentoring process, the mentor takes the lead – teaching, coaching and explaining. The person being mentored seeks to profit from the knowledge and skills exemplified by the mentor's achievements. A gradual transition takes place where the person being mentored becomes someone else's mentor. This needs to be carefully transitioned though, and the original mentor should regularly check in with the person being mentored so they do not feel deserted.

Treat people as THEY NEED to be treated.

HEALTH POLICIES, PROCEDURES AND DOCUMENTATION

RISK MANAGEMENT

1 POLICY

The Company must make available to employees information regarding known health hazards and recommended precautions prior to their commencing an overseas visit or assignment.

2 PURPOSE

The purpose of this policy is to:

• Minimize the risk of exposure to health hazards associated with countries identified as medium-risk and high-risk.

• Reduce the risk, through use of available vaccines, of Company employees and their dependents contracting diseases associated with the country of intended visit or posting.

• Reduce the risk of Company employees and their dependents contracting malaria, using preventive measures, and identify the symptoms in the event of exposure.

3 SCOPE

This policy covers all Company employees and their accompanying dependents.

4 PROCEDURE

The receiving Unit management is responsible for ensuring implementation. Personnel must be briefed on potential health hazards, advised of and encouraged

to receive the required immunizations, and informed of the necessary precautions

against malaria in endemic areas.

4.1 MEDICAL BRIEFING

Certain countries pose a higher medical risk to personnel, beyond the Company's control. A listing of specific higher risk countries can be accessed on the Corporate QHSE website.

The Corporate Medical Advisor is responsible for the content of the Overseas

Medical Briefing.

Prior to traveling, the Overseas Medical Briefing must be provided to personnel visiting or assigned to specific higher risk countries. If personnel are installation based, this briefing must be recorded in their installation Personal Medical Record upon arrival.

Personnel with known, serious, existing health conditions, which may be difficult to adequately treat in local medical facilities, must be pre-screened and their assignment re-assessed.

4.2 IMMUNIZATION

Prior to traveling, personnel must be made aware of the required and recommended immunizations for the area to which they are assigned.

Consideration must be given to administer immunizations during the following medical opportunities:

• Pre-employment medical examination

• Periodic medical examinations

• Special arrangement

All Company personnel present on a Company installation outside their home country for more than 24 hours must be in possession of their international certificate of vaccination.

The installation Personal Medical Record must be marked to indicate the immunization status.

4.3 MALARIA AWARENESS

The Corporate Medical Advisor is responsible for the content of the Malaria Briefing. The briefing must include both preventive measures and information on procedures

to follow if symptoms develop after returning from a malaria-endemic area.

Division management must ensure that personnel who have been assigned to a malaria-endemic area are provided with the Malaria Briefing before traveling. If personnel are installation based, receipt of this briefing must be recorded in their installation Personal Medical Record upon arrival.

The procedure for malaria prevention and prevention medications is available to employees at installations, facilities and offices. Personnel are encouraged to use malaria preventive medications.

4.4 MEDTRACK

Internationally assigned and employees who travel internationally for business must follow the periodic Medtrack medical examination program.

• A Company authorized physician must conduct all Medtrack examinations.

• On completion of the medical examination, the authorized physician must issue a temporary certificate indicating the employee's fitness to work.

• The Medtrack Medical Director will liaise as necessary with the Corporate Medical Advisor to make final determination on employee fitness to work. The final fitness certificate will be available on the Medtrack website after approximately 15 working days.

• All Company employees present on a Company installation or facility outside of their home country for more than 24 hours must be in possession of a fitness certificate indicating the employee is fit for work.

5 RESPONSIBILITY

5.1 ALL COMPANY PERSONNEL:

• Must comply with the requirements of the Medtrack Program if traveling internationally for business, or

• If present on a Company installation or facility outside their home country for more than 24 hours must be in possession of their international certificate of vaccination and fitness certificate.

• Mark their installation Personal Medical Record to indicate their immunization status.

• Make a proactive effort to be aware of recommended/required immunizations and medical briefing for the area(s) they are about to visit.

5.2 RIG MANAGER:

• Ensure employees are in compliance with the requirements of the Medtrack

Program.

5.3 HUMAN RESOURCES MANAGER:

• Ensure Company approved Medtrack providers are available to employees within their Unit.

5.4 RECEIVING BUSINESS UNIT MANAGEMENT:

• Ensure implementation of this procedure.

• Ensure the Malaria Briefing, immunizations and medical briefing are available for personnel to review prior to traveling. Receipt of these must be confirmed upon arrival.

• Ensure the Malaria Briefing, immunizations and medical briefing are provided to assigned personnel prior to traveling.

• For installation based personnel, ensure the Malaria Briefing is noted in their installation Personal Medical Record.

• Ensure personnel are made aware of required immunizations for that area.

• Ensure personnel transferred internationally into their Unit are compliant with the requirements of Medtrack.

• Receive confirmation that international employees within their Unit are fit to work in the area assigned. Confirmation must be received prior to the employee arriving in the Unit for assignment.

5.5 CORPORATE MEDICAL ADVISOR:

• Maintain the content of the Overseas Medical and Malaria Briefings.

• Oversee the Medtrack Program to ensure required information is forwarded to

Business Unit management.

6 DOCUMENTATION

Country-specific Medical Briefing information, immunization requirements and the

Malaria Briefing are available on the Corporate QHSE website

HEALTH POLICIES, PROCEDURES AND DOCUMENTATION

IMPLEMENTING AND MONITORING

1 POLICY

All installations must maintain a dedicated clinic, adequately equipped and staffed by a qualified Medical Person to effectively attend to all trauma and medical cases.

Systems must be in place whereby both personal medical information and information surrounding all treatment provided is accurately recorded, maintained and confidential.

Company authorized physicians and onshore clinics must be contracted for topside support in each Unit of operation.

2 PURPOSE

The purpose of this policy is to ensure:

• A qualified Medical Person, with suitable equipment, in appropriate surroundings, effectively attends to all trauma and medical cases.

• Adequate and relevant information is readily available when medical attention has been provided or is required.

• All trauma and medical incidents receive the appropriate medical attention and follow up once initial treatment has been provided on board the installation or at a facility. Verification will take place by Medical Audits.

3 SCOPE

This policy covers all Company personnel and installations and all Units, Divisions, Sectors and Branches.

4 PROCEDURE

4.1 INSTALLATION TRANSIT AND RE-LOCATION

Prior to an installation commencing a major change in geographical location or initiating an ocean going voyage:

• The Corporate Medical Advisor must be consulted to determine the necessity for additional medical equipment or personnel.

• The receiving Division/Sector QHSE Manager must ensure that a valid

Medical Emergency Response Plan is communicated to the installation.

4.2 INSTALLATION CLINIC STANDARD REQUIREMENTS

4.2.1 MEDICINE AND EQUIPMENT STANDARDS

Business Unit management must ensure a standard is determined for the type and quantity of clinic equipment, medications and disposable items utilized within the Unit.

If Business Unit management elects to allow use of medicines other than those detailed on the Company approved list, the following must occur:

• Each Division is responsible to forward the list of medications utilized in that

Division/Sector to the Corporate Medical Advisor (CMA).

• The CMA, with support from Corporate HSE Services, must review and approve the list then advise Business Unit and Division management which medications are considered prescription (Rx) or over the counter (OTC) within the Company, and identify duplication of medications within the list.

• The CMA must communicate the classification of the Division approved medicines as either prescription (Rx) or over the counter (OTC) to Topside Support in each Division.

If a medicine considered prescription by the Company is substituted for a local equivalent, the local equivalent will be considered prescription by the Company regardless of whether the local purchase requires a prescription or not.

The determination whether medicines are prescription or over the counter will be based on the United States Food and Drug Administration (FDA). For Company purposes any medicine, or dosage of medicine, identified as prescription by the FDA is considered a prescription medication in every area of operation.

Controlled drugs must be stored and locked in a specific locker at all times. The OIM must ensure that a system is in place for the issuance of these controlled drugs. The OIM must countersign the controlled drugs register at each crew change of the Installation Medical Person (IMP), and after each administration of a controlled drug.

The OIM must ensure there is an effective system in place for the disposal of out of date controlled and prescription drugs.

4 .2.2 CLINIC REQUIREMENTS

Clinic furnishings must be constructed of non-porous materials.

The clinic must be equipped with a “hands-free” system, which allows the IMP to speak directly to Topside Support.

The clinic must not be used for accommodation purposes other than during circumstances when the IMP needs to monitor or attend to a patient.

4.3 INSTALLATION MEDICAL PERSON

The Installation Medical Person (IMP) must be a qualified medical professional

(paramedic, registered nurse, MD, etc.), holding current certification or license.

The IMP must attend periodic theoretical and practical refresher training as per the

Company training matrix.

The IMP must maintain a current certification or license in Advanced Cardiac Life Support (including CPR and use of a manual Defibrillator) or equivalent course approved by the CMA.

At each crew change of the IMP, the oncoming must function test all major clinic equipment as per manufacturer's recommendation. This includes, but is not limited to, all cardiac equipment (AEDs/manual defibrillators, laryngoscopes, resuscitators, oxygen levels, and so on). Any malfunctioning equipment must be immediately reported to the OIM.

The IMP must inventory all medicines and disposable items on a monthly basis. All deficiencies must be immediately reported to the OIM.

The IMP must obtain authorization from Topside Support prior to the administration of any controlled or prescription drug, including non-prescription drugs at prescription strength, unless managing an emergency situation and following Company approved medical protocol.

4.3 INSTALLATION MEDICAL PERSON

The Installation Medical Person (IMP) must be a qualified medical professional

(paramedic, registered nurse, MD, etc.), holding current certification or license.

The IMP must attend periodic theoretical and practical refresher training as per the

Company training matrix.

The IMP must maintain a current certification or license in Advanced Cardiac Life Support (including CPR and use of a manual Defibrillator) or equivalent course approved by the CMA.

At each crew change of the IMP, the oncoming must function test all major clinic equipment as per manufacturer's recommendation. This includes, but is not limited to, all cardiac equipment (AEDs/manual defibrillators, laryngoscopes, resuscitators, oxygen levels, and so on). Any malfunctioning equipment must be immediately reported to the OIM.

The IMP must inventory all medicines and disposable items on a monthly basis. All deficiencies must be immediately reported to the OIM.

The IMP must obtain authorization from Topside Support prior to the administration of any controlled or prescription drug, including non-prescription drugs at prescription strength, unless managing an emergency situation and following Company approved medical protocol.

The IMP must follow medical protocols for emergency situations where authorization is not timely or possible. The Medical Protocols followed must be the Company approved unless local (Unit/Division) medical protocols have been adopted and approved by Business Unit management as well as the Corporate Medical Advisor

4.4 MEDICAL DOCUMENTATION

4.4.1 MEDICAL ACTIVITY LOG

General information relating to all treatment provided must be recorded using the

Medical Activity Log.

At each crew change of the IMP, the oncoming IMP must create a new Medical

Activity Log for the duration of that hitch.

The Medical Activity Log is "public domain" and may be distributed as such.

Copies of the Medical Activity Log must be reviewed at least quarterly by the OIM

and initialed for confirmation.

4.4.2 PATIENT CONTACT REPORT (PCR)

The Patient Contact Report is a "privileged document" and must be treated as such. Only authorized Company personnel may view Patient Contact Reports.

A copy of the Patient Contact Report generated must be included in the individual's personal medical record each time medical attention is rendered to that individual.

4.4.3 INDIVIDUAL PERSONAL MEDICAL RECORDS

Individual Personal Medical Records must be updated upon arrival on the installation and as necessary thereafter to indicate the following personal and pertinent past medical information:

• Name and address

• Blood type (if known)

• Any known allergies

• Significant past medical history (example; major surgery, any hospital treatment)

• Long term prescribed medication

• Emergency contact name (first and last names) and telephone number(s)

• Signed permission for accepting or declining blood transfusions in life threatening situations administered at clinics within the assigned Unit

• Signature affirming receipt of Malaria and Medical briefings (if appropriate)

The personnel of Company subcontractors, Clients and Client subcontractors must complete/update the Personal Medical Record with the following exceptions:

• Confirmation of Malaria briefing

• Confirmation of country specific medical briefing

• Immunization status

The Personal Medical Record is a "privileged document" and must be treated as such. Only authorized Company personnel may view Personal Medical Records.

4.5 TOPSIDE SUPPORT AND LOCAL MEDICAL PROVIDER

4.5.1 TOPSIDE SUPPORT

Topside Support is required in each Unit of operation. It is the responsibility of Business Unit management to retain a Topside Support provider and may elect to retain Topside Support locally. This may be done provided the infrastructure and local medical ability are capable of fulfilling the responsibilities defined for Topside Support. The selection of Topside Support by Business Unit management must be assessed and evaluated by the Corporate Medical Advisor prior to implementing.

The Corporate Medical Advisor will evaluate key aspects of the chosen Topside Support provider to ensure the most appropriate and effective medical care possible can be provided. The key aspects evaluated are, as a minimum:

• Medical competency of personnel

• Capabilities of the medical infrastructure

• Effective proximity of the medical support to the operation

4.5.2 LOCAL MEDICAL PROVIDER (LMP)

Local medical provider(s) must be identified in all areas of operation. The selection of a Local Medical provider by Unit or Division management must be assessed and evaluated by the Corporate Medical Advisor prior to implementing.

The LMP should advise and provide support to management on health related matters, including health promotion campaigns (when applicable).

The LMP may be required to organize pre-employment and periodic medical examinations of local personnel (when applicable).

The Corporate Medical Advisor will evaluate key aspects of the Local Medical Provider to ensure the most appropriate and effective medical care possible can be provided. The key aspects evaluated are, as a minimum:

• Medical competency of personnel

• Capabilities of the medical infrastructure

• Effective proximity of the medical support to the operation

• Access to and level of client’s medical facilities

The Local Medical Provider is responsible for providing local medical treatment onshore. The local medical provider may, at the request of Topside Support or local management, provide logistical coordination and support of local medical care.

Where local medical infrastructure and resources are readily available, Topside Support and Local Medical Provider responsibilities may be combined as a single provider.

4.6 MEDICAL AUDITS

A system of area/country medical risk ranking must be maintained to establish the frequency of audits.

Medical audits must be used to evaluate the physical condition of installation clinics and treatment facilities as well as the physical condition of Company retained, or potentially retained, onshore hospitals, clinics and treatment facilities.

Medical audits must be used to evaluate the professional abilities of installation based and Company retained, or potentially retained, onshore medical staff.

Medical audits must be conducted using the Company standard medical audit. Medical audits must include audit of compliance with the Sanitation and Hygiene

policy and procedure. (See Section 3 Subsection 3.1)

Medical audits must be conducted by Company approved physicians authorized as auditors or specific authorized Company personnel.

Audit reports must be documented and distributed to the following personnel:

• OIM (installation medical audits only)

• Rig Manager (installation medical audits only)

• Division and Sector or Branch Manager

• HSE Representative

• Chief Executive Officer

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

• Ensure Individual Personal Medical Records are updated upon arrival on the installation (and as necessary thereafter) to indicate personal and pertinent past medical information.

5.2 INSTALLATION MEDICAL PERSON:

• Be thoroughly knowledgeable with, and follow, Medical Protocols approved for use on the installation.

• Ensure controlled drugs are stored and secured in a specific locker.

• Attend periodic theoretical and practical refresher training as per the

Company training matrix.

• At each crew change, the oncoming must function test all major clinic equipment as per manufacturer's recommendation and immediately report any deficiencies to the OIM.

• Inventory all medicines and disposable items on a monthly basis and immediately report any deficiencies to the OIM.

• Obtain authorization from a Company authorized physician prior to the administration of any controlled or prescription drug, or non-prescription drug at prescription strength.

• Receive authorization for specific medical treatment as specified in the

Medical Protocols

• Discuss potential injury/illness based upon mechanism or index of suspicion even if the patient does not present with significant clinical signs or symptoms.

• Consult with Topside Support prior to disembarking of personnel for medical reasons.

• Maintain the overall cleanliness and housekeeping within the clinic.

• Maintain the appropriate level of confidentiality of medical documentation.

• Ensure patients sign the PCR form (when possible).

5.3 OIM:

• Ensure that a system is in place for the issuance of controlled drugs.

• Countersign the controlled drugs register at each crew change of the

Installation Medical Person and after each administration of a controlled drug.

• Ensure that there is an effective system is in place for the disposal of out of date controlled and prescription drugs.

• Review and initial copies of the Medical Activity Log at least quarterly

5.4 DIVISION MANAGER:

• Ensure emergency response plans and procedures for relevant site-specific and area or location (installations, facilities and offices) emergencies are developed within their area of responsibility.

• Select onshore physicians and clinics based upon review of credentials.

• Ensure a list of authorized physicians and clinics, relevant to the area of operation, is available on the Division/Sector QHSE website.

• Submit Medical Protocols to be used in the Division or Sector to the Business

Unit Vice President and Corporate Medical Advisor for approval.

• Ensure Medical Protocols are available for use on installations.

• Ensure a system is in place for Division management to monitor the effectiveness of Topside Support and establish clear communications with Topside Support (for example, monthly meetings).

• Ensure all installations in the Division have updated Medical Emergency

Response Plans readily available.

• Ensure the Medical Emergency Response Plan is communicated to and available on the installation prior to that installation arriving in that Division.

5.5 HSE Manager:

• Ensure the system of area/country medical risk ranking establishing the frequency of medical audits is available on the Corporate QHSE website.

• Consult with the Corporate Medical Advisor and approve personnel as authorized medical auditors

5.6 CORPORATE MEDICAL ADVISOR:

• Approve the standards for the type and quantity of clinic equipment, medications and disposable items set forth by Business Unit Management.

• Review medications list in use for each area of operation to determine which medications are classified as prescription only.

• Advise Business Unit management which medications must be classified as prescription only based on the U.S. FDA.

• Approve the selection of physicians and clinics proposed by Business Unit

Management.

• Approve Medical Protocols proposed by Business Unit management for use on installations.

• Maintain a system of area/country medical risk ranking to establish the frequency of medical audits.

5.8 MEDICAL AUDITORS:

• Use medical audits to evaluate the physical condition of installation clinics and treatment facilities as well as the physical condition of Company retained, or potentially retained, onshore hospitals, clinics and treatment facilities.

• Use medical audits to evaluate the professional abilities of installation based and Company retained, or potentially retained, onshore medical staff.

• Conduct medical audits using the Company standard medical audit.

• Distribute audit reports to required personnel.

6 DOCUMENTATION

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President.

• The Function Check-list of Major Equipment (Figure A)

(Must be retained in the installation files for not less than one year)

• Monthly Inventory (of Drugs, Consumables and Perishables) (Figure B) (Must be retained in the installation files for not less than one year)

• Controlled Drugs Register (Figure C)

(Must be retained in the installation files for not less than one year)

• Individual Personal Medical Record (Figure D)

(Must be kept in the individual's confidential personal medical file)

• Medical Activity Log (Figure E)

(Copies must be retained in the installation files for not less than 3 years)

• Patient Contact Report (Figures F1 – F4)

(One copy must be retained in the installation clinic files for at least 3 years) (One copy must be maintained in the person's Personal Medical Record)

.

IMPLEMENTING AND MONITORING

Potable Water

POLICY

Potable water produced and/or stored onboard installations must be suitable for human consumption.

PURPOSE

The purpose of this policy is to ensure that all water intended for human use (for example, drinking, showering, cooking, and so on.) is free from bacteria and other harmful impurities.

SCOPE

This policy covers all Company installations.

PROCEDURE

4.1 SAMPLING AREAS

Water samples must be taken from various locations, including:

Water maker

Bulk loading station

Galley

Shower rooms

Drinking fountains

4.2 POTABLE WATER QUALITY/TESTING

Potable water must be tested weekly for:

Coliform presence/absence

pH

Nitrates

Taste, odor and turbidity

Residual bromine (if brominated installed)

**This test is not mandatory if a silver ionizing system is in place in lieu of a brominator.

Potable water testing equipment must be available onboard the installation.

An annual test must be conducted to establish if any heavy metal or other contamination is present. The table below lists the minimum tests to be conducted and the maximum acceptable parameters.

**When silver salts are used for disinfecting The results of all weekly and annual potable water tests must be entered into the planned maintenance system. A copy of the results must also be stored in the files of the installation clinic.

Dedicated hoses used for transferring potable water from supply vessels to the installation must be suitable for potable water and clearly identifiable at both ends of the hose.

All potable water from supply vessels must be tested for residual chlorine, pH, taste, odor and turbidity before transferring to onboard holding tanks. (Allowable parameters for residual chlorine are: 0.2 – 0.4 mg/L or 0.2 – 0.4 ppm.) Water that does not meet the requirements must not be taken onboard.

Maintenance of the potable water systems must include cleaning of the potable water tanks at least every three years to remove bio-films and sediment.

All potable water must pass through a brominator or silver ionizer followed by an ultraviolet system to ensure microorganisms are eliminated. An ultraviolet system alone does not provide residual effect after treatment. Use of a brominator or a silver ionizer system provides the residual effect after treatment.

The use of a brominator or silver ionizer in conjunction with an ultraviolet system represents primary and secondary treatment for water sterilization. Both primary and secondary water sterilization are required.

Use of Calcium Hypochlorite (70% active Chlorine) or Sodium Hypochlorite (15% active Chlorine) for potable water treatment or sterilization is not permitted.

All drinking fountains and ice machines must be equipped with a filtering device to further purify water before being ingested. The filtering device must be cleaned and/or replaced in accordance with the manufacturer's instructions.

All drinking fountains, ice machines and coffee/tea makers that have fixed fill lines must be entered into the planned maintenance system.

RESPONSIBILITY

INSTALLATION MEDICAL PERSON:

Test potable water in accordance with this procedure.

Maintain a file of potable water test results in the installation clinic.

OIM:

Ensure testing of potable water in accordance with this procedure.

RIG MANAGER

Ensure annual heavy metals test is conducted and testing facility is capable of performing required tests.

DOCUMENTATION

There is currently no documentation associated with this policy or procedure.

EVALUATING AND IMPROVING

Sanitation, Hygiene and Smoking Limitations

1 POLICY

Accommodation, food preparation and services areas must be maintained to high standards of sanitation and hygiene.

Smoking is permitted in designated areas only.

2 PURPOSE

The purpose of this policy is to ensure that all personnel are adequately protected from the harmful effects of unsuitable sanitation/hygiene practices and second hand smoke.

3 SCOPE

This policy covers all Company personnel, installations and facilities.

This policy also covers any Client, subcontractor or outside agency that work at any

Company installation or facility.

4 PROCEDURE

4.1 INSPECTIONS

The accommodation, offices, galley, mess hall, food storage and recreation areas must be inspected weekly.

The following personnel must conduct the weekly inspection:

• OIM or designee

• Installation Medical Person

• Camp Boss

4.2 TRAINING

Prior to arrival on an installation, all catering personnel must have documentation to confirm they have received instruction in the following:

• Transmission of communicable diseases

• Personal hygiene

• First aid for choking

Prior to arrival on an installation, all food handlers must have documentation to confirm they have received instruction in the prevention of food-borne illness.

It is the responsibility of the catering contractor to provide the training required for catering personnel prior to arrival on the installation.

In exceptional circumstances training requirements for catering personnel may be met on the installation, provided the IMP is qualified to carry out this training and has the approval of the Rig Manager.

Prior to commencing work at any installation or facility, all catering personnel must be instructed, and refreshed annually, in the following:

• Emergency drills and duties

• Fire fighting, fire prevention and fire fighting equipment associated with the galley, mess hall, accommodation and laundry areas

For further information on training see Section 4 Subsection 1.3.

FOOD SELECTION

Each catering services provider must offer a “heart healthy” diet option at meal times.

Fresh fruits and vegetables must be offered at snack times and as an alternative side dish during meal times.

FOOD TRANSPORTATION

The OIM or designee must periodically inspect the containers used for the transportation of food products from onshore to Installations paying specific attention to the general physical condition of doors, seals and closing devices. The principal objective is to ensure the overall cleanliness and to establish the container's ability to maintain temperatures within the required limits.

The Installation Medical Person must be present during all food deliveries and must inspect all food items to ensure food quality. Questionable food items which appear to be contaminated or spoiled must be discarded. Meats that are partially thawed must be discarded. Results from this inspection must be documented with the weekly inspection and the catering company must be informed of the inspection findings.

FOOD STORAGE

When removed from the original container, all food, whether raw or prepared, must be stored in a clean covered container to protect against possible contamination.

All food must be given an arrival date and rotated so that foods are used on a first-in, first-out basis. The “use by” date takes precedence over the arrival date.

All refrigerators and freezers must have a functioning thermometer.

All “walk-in” refrigerators and freezers must have a functioning lock-in alarm system to sound in a permanently manned area. The alarm system must be included in the planned maintenance system.

A calibrated, portable thermometer must be available to confirm the temperature of food arriving onboard and the core temperatures of hot food.

All foods stored in refrigerators must either be in a suitable food storage container or covered by disposable wraps, such as foil, wax paper, plastic wrap, and so forth. Cloth towels may not be used to cover food.

Frozen food must be wrapped in freezer paper or left in its original container to prevent freezer burns.

Foods must be stored on racks and not placed directly on the floor. Use of wood pallets for floor racks is not permitted.

Cooked and uncooked foods must be stored separately to prevent any cross- contamination.

Foods and food dressings must be kept refrigerated and left out only during meal times.

Dry goods stores must be located in climate-controlled spaces.

FOOD PREPARATION

Meats, poultry and seafood must be thawed in a refrigerator or defroster if available. Poultry, meats and stuffing containing meat products must be cooked until all parts

of the food are heated to a temperature of 75 degrees Centigrade/167 degrees Fahrenheit.

Pork must be cooked until "well done" and no pink meat is visible.

All vegetables and fruits intended to be consumed raw must be thoroughly washed. Physical contact with food must be kept to an absolute minimum. Personal hygiene

must be strictly maintained during food preparation and service to eliminate contamination.

Only personnel trained and designated as food handlers may prepare and serve foods (Cooks, Cook's Helpers and Bakers).

Cutting gloves must be worn by personnel performing food preparation or serving activities requiring the use of a knife.

Foods must be prepared on clean, non-porous work surfaces. Wooden cutting boards are not allowed.

A system should be in place for identification and designation of cutting boards to help prevent cross contamination of food types (For example, separate cutting boards designated for beef, chicken, vegetables, and so on).

FOOD PROTECTION

Raw eggs with cracked shells must not be used.

Packaged foods marked with a manufacturer's expiration date must be discarded when date is passed.

Packaged foods marked with a "sell by" or "use by" date, must be discarded when date is passed.

Seafood that is discolored (pinkish), soft to the touch, or has a foul odor must be disposed of immediately.

Red meats and poultry that are discolored (greenish) or produce a foul odor must be disposed of.

Leaking or 'bulging' canned products must be considered contaminated and must be disposed of immediately.

FOOD LEFTOVERS

Food retained as leftovers must be:

Protected against contamination and maintained at the correct temperature at all times, especially during serving.

Removed from the serving line immediately after first serving is completed (For example, not left on the serving line between initial meal service and second service).

Foods retained as leftovers must not be:

Frozen.

Retained for longer than 48 hours.

Served as a leftover more than once

Leftovers served hot must be served at temperatures of at least 63 °C or 145 °F. Leftovers, such as chicken and seafood, must not be placed in the break rooms for

consumption.

Processed meats may be used for snacks provided they are not left out longer than 90 minutes.

Foods that are highly perishable (such as minced/ground meats, gravies, dressings, egg salad and tuna salad) may not be retained or reused.

CLEANING AND SANITIZING UTENSILS/EQUIPMENT

Food preparation tables must be washed and sanitized after each use.

Food preparation areas must have one sink equipped for washing hands with hot and cold running water, filled soap dispenser and material for drying hands using a sanitary technique. (For example, air dryer or disposable towels).

All kitchenware, food contact surfaces, equipment and utensils must be thoroughly washed and sanitized after each use. Special attention must be given to meat slicing machines, food mixers, can openers, grinders and cutting boards.

Where a dishwasher is used, the temperature of the wash and rinse water must be as per the manufacturer's instructions.

When a dishwasher is unavailable, dishes and eating utensils must be washed and rinsed in an approved solution and must be air-dried.

Dishes or eating utensils must not be wiped with towels or rags.

Deep fat fryers must be drained and strained daily and covered with a lid made of a non-absorbent material.

Grills, stovetops and drip pans must be cleaned at least once per shift, If foil is used as inserts in the drip pans, it must be changed daily.

Ovens must be cleaned at least weekly.

Soft ice cream machines must be cleaned once every 24 hours. Cold drink dispensers must be cleaned once every 24 hours.

Milk dispensing machines must be defrosted and cleaned weekly. Exhaust vents and filters must be cleaned weekly.

All "reach in" refrigerators must be emptied of their contents and cleaned weekly.

The grating in the walk-in refrigerator must be removed and the floor cleaned weekly.

The grating in the walk-in freezer must be removed and the floor cleaned monthly. Cups and glasses must be stored inverted.

Eating utensils must be stored with the handles up. Pots and pans must be stored inverted or by hanging.

Each installation must have a procedure in place for disinfecting all utensils, equipment and food contact surfaces. This procedure must include, as a minimum, the use of 20% bleach solution.

GENERAL ACCOMMODATIONS

Dirty work clothes must be laundered after each working shift. Personal clothing must be laundered on a regular basis.

Dirty work clothing, shoes or boots are not allowed within the accommodation. Maintenance staff must give full consideration to hygiene when performing maintenance within the accommodation.

MESS HALL

All personnel using the mess hall must comply with the following:

Wash hands, forearms and face (when needed) prior to using the mess hall.

Wear reasonable footwear (footwear that provides suitable protection in the event of an emergency), trousers/short pants and at least a 'T' shirt.

Sleeveless vests/shirts may not be worn.

ROOMS

All beds must be made daily.

All rooms must be swept and mopped daily. Grease and oil marks must be removed. Hallways must be swept and mopped at least daily and as often as needed to

maintain a high standard of cleanliness.

Trashcans must be emptied daily and washed when needed.

Washbasins, toilets, urinals, and shower stalls must be used as designed and cleaned and disinfected daily.

The hallway air vent louvers must be cleaned weekly.

Grease and finger marks must be removed from doors and walls daily. All beds must be changed (fresh linen) at least every seven days.

Beds must be changed immediately after notification by the OIM, or designee, that the occupant has departed the installation.

CHANGE/BREAK ROOMS

Change/break rooms must be cleaned twice daily or more frequently as needed. Each individual who uses the break/change room must be responsible to maintain

the room in a clean and orderly condition.

The OIM must ensure that personnel who use these rooms maintain them in a clean and orderly condition.

RECREATION AREAS

Movie rooms, cinemas, recreation rooms, reading rooms, gymnasiums and any designated leisure area must be cleaned daily or more frequently as needed.

OFFICE SPACES

All spaces inside the living accommodation used to conduct business and meetings must be cleaned at least daily. Cleaning must include:

Floors swept and mopped

Trash cans emptied

Window ledges and furniture dusted

Grease and finger marks removed from doors, walls and furniture

PERSONAL HYGIENE

All personnel must seek early treatment for superficial skin infections and inflammations.

All personnel must seek early treatment for transmittable diseases, such as colds and flu.

All community sink areas used by personnel to wash hands (For example, change rooms and community shower or toilet areas) must be equipped with a disposable paper towel dispenser or air dryer.

SMOKING LIMITATIONS

The Company is concerned with the health of all its employees. To allow both smokers and non-smokers to live and work in confining conditions with a minimum of health risks and inconvenience, the following must be adhered to:

Smoking may only be allowed in areas designated by the installation or facility QHSE Steering Committee and approved by the Division Manager.

Any area outside or inside the accommodations where smoking is permitted must be clearly marked.

Smoking must be prohibited in all other areas

Cigarette lighters are prohibited on Company installations. If a cigarette lighter is inadvertently brought to the Installation it must be turned over to a designated person for safekeeping until the owner departs.

Each installation must provide appropriate electric cigarette lighters and/or safety matches at each designated smoking area.

Smoking areas must be located in areas devoid of operating equipment and/or flammable substances (for example,, vapors, fuel storage, and so on) and where personnel are not forced to breathe second hand smoke.

Cabins, offices, control rooms, radio rooms, kitchens, dry stores, cold stores, lockers, freezers, food preparation areas and laundries may not be designated as smoking areas.

Designated smoking areas outside the accommodation must have a clearly visible means of warning personnel (for example, a flashing or rotating light) when smoking is not permitted for any reason, such as gas being detected.

All meetings must be non-smoking.

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Seek early treatment for superficial skin infections and inflammations.

Seek early treatment for transmittable diseases, such as colds and flu.

Do not wear dirty work clothing, shoes or boots within the accommodation.

Wash hands, forearms and face (when needed) prior to using the mess hall.

Wear reasonable footwear, trousers/short pants and at least a 'T' shirt while in the mess hall.

Do not wear sleeveless vests/shirts in the mess hall.

INSTALLATION MEDICAL PERSON:

Jointly conduct the weekly sanitation and hygiene inspection with the Camp Boss and OIM (or designee).

Be present during all food deliveries and inspect all food items to ensure food quality.

CAMP BOSS:

Jointly conduct the weekly sanitation and hygiene inspection with the Installation Medical Person and OIM (or designee).

Ensure all food handlers are instructed in the prevention of food-borne illness prior to handling food.

Ensure, prior to arrival on an installation, all catering personnel are instructed in the following:

Transmission of communicable diseases

Personal hygiene

First aid for choking

Ensure, prior to commencing work at any installation or facility, all catering personnel are instructed in the following:

Emergency drills and duties

Fire fighting, fire prevention and fire fighting equipment associated with the galley, mess hall, accommodation and laundry areas

Conduct and document required training for catering personnel and maintain the updated records aboard the installation, using appropriate personnel from the installation and resources from management of the catering contractor.

Ensure a system is in place to meet the requirements of the procedure regarding food handling and sanitation of the installation or facility.

Ensure beds are changed immediately after notification by the OIM, or designee, that an occupant has departed the installation.

OIM:

Jointly conduct, or appoint a designee to jointly conduct, the weekly sanitation and hygiene inspection with the Camp Boss and Installation Medical Person.

Conduct, or appoint a designee to conduct, a periodic inspection of the containers used for the transportation of food products from onshore to installations paying specific attention to the general physical condition of doors, seals and closing devices.

Ensure notification to the Camp Boss that an occupant has departed the installation.

Ensure that personnel who use Change/Break rooms maintain them in a clean and orderly condition

RIG MANAGER:

Approve requests, due to unusual circumstances, to complete catering training requirements aboard the installation.

6 DOCUMENTATION

The form indicated below is included in the manual and is intended to provide operations with a minimum list of areas to be inspected. It is expected that each installation must modify the form to add relevant areas.

Weekly Sanitation and Hygiene Checklist (Figure A)

(Copies must be retained in the Installation/facility files for a period of one year)

SECTION 4 …………………… SAFETY POLICIES, PROCEDURES AND DOCUMENTATION

SUBSECTION 1 ORIENTATION AND TRAINING

HSE ORIENTATION

DRUGS, ALCOHOL AND WEAPONS IN THE WORKPLACE

TRAINING

SUBSECTION 2 RISK MANAGEMENT

THINK PLANNING PROCESS

PERMIT TO WORK

CLIENT, SUBCONTRACTORS PERSONNEL AND EQUIPMENT

DRESS REQUIREMENTS AND PERSONAL PROTECTIVE EQUIPMENT

SUBSECTION 3 PLANNING

HYDROGEN SULFIDE

EMERGENCY RESPONSE

SUBSECTION 4 COMMUNICATION

HSE INFORMATION

HSE MEETINGS

SUBSECTION 5 IMPLEMENTING AND MONITORING

START PROCESS

TRAVEL

GENERAL SAFE WORK PRACTICES

ENERGY SOURCES AND ISOLATION

FALL PROTECTION

MECHANICAL LIFTING

HAZARDOUS MATERIALS

PERSONAL IMPAIRMENT

ELECTRICAL SAFETY

SUBSECTION 6 EVALUATING AND IMPROVING

HSE RECOGNITION

FOCUS IMPROVEMENT PROCESS

INCIDENT REPORTING

POLICY

All personnel must receive a HSE Orientation suitable for their work environment prior to commencing work or during a visit.

PURPOSE

The purpose of this policy is to ensure that all personnel receive critical safety information and understand site specific hazards prior to having access to the work site.

SCOPE

This policy covers all personnel who work at or visit any Company installation, facility or office.

PROCEDURE

SECURITY

Division management is responsible for site-specific security arrangements for new personnel and communicating it to those personnel prior to arriving in an area.

INSTALLATION HSE ORIENTATION

All installations must have a system in place to ensure all first-time arrivals are met by the OIM or designee.

All personnel arriving on an installation for the first time or any person who has not been on the installation within 6 months must attend an HSE Orientation and sign a form to verify their understanding.

Unless receiving a Short-Term Visitor Orientation, all personnel must receive:

An overview of the Core Values, Mission Statement and HSE Policy Statements to ensure understanding the importance of these documents and what they represent.

Information on current operations and the individual’s obligation to interrupt the operation or raise justifiable personal HSE concerns.

A written, installation-specific “Welcome Onboard Card.”

Information on emergency signals, muster stations and station bills, including roles and responsibilities.

Explanation of emergency preparedness, which must include reference to donning instructions for life jackets, personnel escape equipment, smoke hoods and PPE.

Explanation of the Colors process.

Information on HSE meetings – weekly, pre-tour, pre-task.

Explanation of how and where to receive QHSE and ISM information (Bulletin Boards, training material, SOLAS Training Manual).

Instruction on reporting of incidents – all injuries and incidents to be reported and who to report them to.

Explanation of the requirements to report any known allergies or current medication.

Explanation of the requirements to report possession of any mobile phones.

General HSE information, including designated smoking areas, high noise areas, housekeeping, jewelry and PTW.

Installation-specific safety information, procedures and hazards (H2S, asbestos, and so forth).

Information on hazards associated with, and the safe operation of, power- operated and/or remote-controlled equipment, such as watertight doors, hatches and winches.

Information on restricted or controlled access areas, such as columns, lower hulls and transformer rooms.

Explanation of drugs, alcohol and weapons policy. (They are not allowed.)

Explanation of the personal impairment policy.

Information on environmental awareness and waste management procedures.

Information on the safety representative (if applicable) and QHSE Steering Committee.

Explanation of current lifting gear color code.

Introduction to the OIM and review the organization chart for the installation.

The Company approved system must be in place to easily identify individuals who are visiting or new to the installation

Information on hazards associated with, and the safe operation of, power- operated and/or remote-controlled equipment such as watertight doors, hatches and winches.

Information on restricted or controlled access areas such as columns, lower hulls and transformer rooms.

Instruction on environmental awareness and waste management procedures.

Information about the safety representative (if applicable).

CREW CHANGE REVIEW BRIEFING

All returning crew members to the installation must undergo a HSE review briefing with the OIM or his designated representative within 6 hours of arriving on board. The following, but not limited to, must be included in the review:

Installation’s current HSE performance, inclusive of progress and status of Installation Specific HSE Plans.

All HSE incidents which have occurred on the installation since personnel last departed the installation on field break, inclusive of corrective actions.

Each returning individuals training compliance status, inclusive of planned schedule to achieve or maintain compliance.

JOB SPECIFIC ORIENTATION

All personnel must be introduced to their supervisor and are responsible to familiarize themselves with their work area, emergency equipment layout and emergency exits.

Key personnel with specific HSE duties (for example, Installation Medical Person, emergency response teams, and so on) must receive additional specific instruction on their duties.

BUDDY SYSTEM

All new Company personnel, Company personnel transferred between installations and newly promoted Company personnel must participate in the “buddy system” for a sufficient period of time to become familiar with specific aspects of the installation.

Company personnel in the “buddy system” must spend sufficient time together before, during or after tour to familiarize the newcomer with the installation, policy and procedure manuals; and instruction manuals specific to the position.

The OIM or designee must determine the content and the duration of the “buddy system” for personnel transferred between installations and newly promoted personnel, taking into account the individual’s knowledge and experience.

FACILITY HSE ORIENTATION.

All personnel arriving at a Company facility (for the purpose of performing work) for the first time or who have not been at the facility within 6 months must be given an HSE Orientation unique to that facility. This orientation must be given before personnel can begin to work. As a minimum, all personnel must receive the following:

An overview of the Core Values, Mission Statement and location of HSE Policy Statements to ensure understanding the importance of these documents and what they represent.

Information on tasks in progress and the individual’s obligation to interrupt the operation or raise justifiable personal HSE concerns.

A written facility specific HSE Information Card.

Explanation of emergency signals, muster stations, and roles and responsibilities.

Explanation of the Colors process.

Information on HSE meetings – weekly, pre-tour, pre-task.

Explanation of how and where to receive QHSE and ISM information (Bulletin Boards, training material).

Instruction on reporting of incidents – All injuries and incidents to be reported and who to report them to.

General HSE information, including designated smoking areas, high noise areas, housekeeping, jewelry, PTW and PPE.

Facility-specific safety information, procedures and hazards (asbestos, and so on).

Explanation of the drug, alcohol and weapons policy. (They are not allowed.)

Explanation of personal impairment policy.

Information on environmental awareness and waste management procedures.

Information about the safety representative (if applicable)

Explanation of the current lifting gear color code.

Introduced to the Facility/Base Manager and review the organizational chart for the Facility/Base.

All personnel must be introduced to their supervisor to ensure they understand their responsibilities and are familiarized with their work area, emergency equipment layout and emergency exits. Clients visiting or inspecting the facility must be escorted and supervised.

OFFICE HSE ORIENTATION

All personnel visiting any Company office must be verbally provided with alarm and emergency evacuation procedures.

All personnel working at a Company office must be provided with an HSE Orientation unique to that office. This orientation must be given as soon as possible after initial arrival at that office by the department head or designee. Additionally, any person who has not been at that office for the purpose of conducting work within six months must be given the HSE Orientation unique to that office. As a minimum, the orientation must contain the following:

Core Values, Mission Statement and location of HSE Policy Statement.

Obligation to interrupt the operation or raise justifiable personal HSE concerns.

Explanation of emergency signals, muster stations and roles and responsibilities.

Explanation of the Colors process

Explanation of how and where to receive QHSE and ISM information. (Bulletin Boards, training material).

Instruction on reporting of incidents – all injuries and incidents to be reported and who to report them to.

General HSE information, including designated smoking areas.

Explanation of the drug, alcohol and weapons policy. (They are not allowed).

Explanation of personal impairment policy.

Information on environmental awareness and waste management procedures.

All personnel must be introduced to their supervisor to ensure they understand their responsibilities and are familiarized with their work area, emergency equipment layout and emergency exits. Clients visiting or inspecting the office must be escorted and supervised.

RESPONSIBILITY

ALL PERSONNEL:

Familiarize themselves with their work area, emergency equipment layout and emergency exits.

Undergo orientation as required, dependent upon assignment.

OIM OR DESIGNEE AND FACILITY/BASE MANAGER:

Ensure all personnel receive an HSE Orientation prior to conducting any work.

Ensure a system is in place to meet all first time arrivals

Determine the content and the duration of the “buddy system” for personnel transferred between installations and newly promoted personnel.

Ensure the Company approved system is in place to easily identify, and determine the identification time frame for, individuals who are visiting or new to the installation.

DIVISION/SECTOR MANAGER:

Make site-specific security arrangements for new personnel and communicate them to the employee prior to arriving in an area.

OFFICE DEPARTMENT HEAD:

Ensure personnel newly assigned to the office receive an orientation specific to that office.

DOCUMENTATION

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President

Drugs, Alcohol and Weapons in the Workplace

POLICY

The unauthorized use, possession, sale, purchase, or distribution of weapons, alcohol, illegal drugs, or the improper/abusive use of legally prescribed drugs, or other intoxicating substances, or being under the influence, while working or while on Company premises, other working locations or while conducting Company business is strictly prohibited. The Company will utilize every reasonable measure to maintain a drug, alcohol and weapon free work environment and expects employees to abide by any and all applicable governmental regulations on this subject.

Those who refuse to participate in, cooperate with, or abide by the rules of this policy or the terms of this policy are subject to disciplinary action up to and including termination. In some cases of drug, alcohol and weapon possession, because of safety considerations an employee may be terminated immediately.

PURPOSE

The purpose of this policy is to advise all employees of the Company’s position on drugs, alcohol and weapons in the workplace.

SCOPE

This policy covers all persons employed by the Company on a full-time, part-time or temporary basis, and all installations and facilities. Lease or contract personnel performing work for the Company, on or off the premises, or other third parties on Company premises, are subject to this policy to the maximum extent practicable.

PROCEDURE

INVESTIGATIONS/SEARCHES

The Company reserves the right, to have authorized personnel conduct unannounced investigations which may include searches or inspections on Company property of employees and their personal effects for illegal or unauthorized items.

All personal items such as pockets, packages, bags, briefcases, lunchboxes, purses, toolboxes or other belongings or items including motor vehicles, being brought onto, on or being removed from Company premises are subject to inspection by the Company or its authorized agents at any time. Likewise, all Company-assigned

property such as, but not limited to, motor vehicles, lockers, desks, quarters of all employees and other personnel are subject to inspection.

Any Company employee who refuses to submit to a search or who is found in possession of any illegal or unauthorized items without an explanation satisfactory to the Company will be subject to disciplinary action up to and including immediate termination. Unauthorized items include, but are not limited to, firearms of any type. The Company or its authorized agents has the right to confiscate prohibited items and substances and, where appropriate, deliver such items to law enforcement authorities.

While on Company installations, prescription medication must be submitted to the person in charge of medical matters. The term valid prescription used in this policy includes, but is not limited to medications prescribed by a physician licensed to do so.

TESTING

All candidates for employment must complete a drug-screening test prior to employment with the Company with the outcome of a negative result. Prospective employees will be asked to read and sign a Drug and Narcotics Release Notice and a Drug Screening Release Form.

All employees are subject to clinically accepted tests (urinalysis, blood tests, hair, etc.) that may be deemed appropriate by the Company, to detect the use or presence of alcohol, illegal drugs, unreported medication or prescription drugs, or other prohibited substances.

The Company reserves the right to require clinically accepted tests (urinalysis, blood tests, breathalyzer, hair, etc.) of employee at any time for the following reasons:

Reasonable Cause – Where good cause or reasonable suspicion exists to believe that the employee’s job performance is or could be adversely affected as a result of being or having been under the influence of drugs or alcohol.

Random Testing – As part of an established program 100% of all employees are eligible. Employees tested at random may be subject to more than one test annually.

Post-Accident Testing – Immediately after a job-related accident, regardless of injury to person or damage to property or degree of involvement, to confirm or refute drug or alcohol use as a contributing cause.

Contractual Requirement – Clients may require the Company to demonstrate employees have received a negative drug and alcohol test result within 12 months preceding access to their premises and periodically thereafter as well.

CONFIRMATION TESTING

When deemed necessary by the Company, a second drug/alcohol confirmation test will be conducted on the initial sample with every “non-negative” test result prior to the testing laboratory formally notifying the Company of the positive test result. A Gas Chromatograph/Mass Spectrometry confirmation test is made of the same sample originally provided by the employee or candidate.

RELEASE OF INFORMATION

As a condition of employment with the Company, all employees must agree to have released to the Company the results of all substance screens and examinations, including all documents generated.

PROHIBITED ACTIVITIES

Any persons working for or employed by the Company are prohibited from:

Reporting to work or working while under the influence of or while impaired by alcohol or any other drug or substance (whether or not legally “intoxicated”).

Chemical dependence on alcohol or other drugs where job performance or safety of employees is adversely affected.

The use of illegal drugs. The term “illegal drugs” as used in this policy includes, but is not limited to marijuana, cocaine, heroin and similar drugs whose possession and use are prohibited by law, as well as prescription drugs unless validly prescribed to the employee by their physician.

The abuse of other substances whether available legally (such as cough syrup, over-the-counter medication or drugs for which an employee has a valid prescription) or never intended for human consumption (such as glue).

The unauthorized possession, use, transfer, or sale of alcohol, illegal drugs, narcotics and weapons on Company property or job sites whether located on Company property or not.

The use of legal drugs without a valid prescription, unauthorized possession, transfer, or sale of legal drugs on Company property or job sites whether located on Company property or not.

Adulterating or switching of any blood, urine or any other sample submitted for testing.

EMPLOYEES/CONTRACTORS

Company employees who, as a result of testing, are found to have positive levels of illegal or unreported drugs, alcohol or other prohibited substances in his/her system, regardless of when or where these substances entered his/her system, will be considered in violation of this policy and subject to disciplinary action up to and including termination.

Lease or contract personnel performing work for the Company, on or off the premises, found in violation of this policy will be subject to removal from the Company’s premises or other work sites. Furthermore, violation of this policy by outside contractor employees may cause the cancellation of the contract between the Company and the contractor.

NON-EMPLOYEES

Non-employees, including visitors, vendors, temporaries and/or candidates for employment, found to be in violation of this Company policy will be subject to removal from Company premises.

DISCIPLINARY ACTION

Disciplinary action for violation of this policy may include warning letters, periodic drug screening and suspension of employment or termination of employment.

Employees shall not be terminated without a review by the Human Resources Department, however, supervisors can remove an employee from the work site pending an investigation.

TREATMENT FOR DRUG/ALCOHOL ADDICTION

Employees who use illegal drugs or who believe they may have a substance abuse problem are encouraged to contact the Benefits Department. An employee, if not otherwise subject to disciplinary actions, will not be disciplined if he/she voluntarily asks for assistance before being requested to submit to testing. The Company may, at its sole discretion, limit the number of occasions that treatment will be offered. Any employee who has been permitted to return to work after obtaining treatment may be required to submit to additional testing at regular intervals as a condition of employment.

The Company intends, in appropriate circumstances, to help employees with problems associated with the abuse of drugs and alcohol and to encourage their rehabilitation. No part of this policy nor any of the related procedures is intended to

(a) affect the Company’s right to manage its workplace and discipline any of its employees or (b) to guarantee employment, continued employment, or terms or conditions of employment.

Employees undergoing rehabilitation or who have completed rehabilitation will be required to abide by all other Company rules and regulations including expected levels of job performance.

For information concerning the coverage under the Group Medical Plan Coverage for Substance Abuse Services contact the Benefits Department.

EXCLUSION

The use or possession of firearms or alcohol beverages may be allowed in special instances at land locations when approved in advance by management.

RESPONSIBILITY

EMPLOYEE (FULL-TIME, PART-TIME OR TEMPORARY BASIS):

Upon new hire or rehire the employee will be required to acknowledge the Company’s Drugs, Alcohol and Weapons in the Workplace policy by signing the Drugs and Narcotics Release Notice.

Upon offer of employment, a new hire or rehire the employee will be required to submit to a drug-screening test prior to employment with the outcome of a negative result.

When requested, all employees will submit to a clinically accepted test that may be deemed appropriate by the Company to detect the use or presence of alcohol, illegal drugs, unreported medication or prescription drugs, or other prohibited substances.

When requested, all employees will submit to a search of personal items that may be deemed appropriate by the Company to locate illegal or unauthorized items.

Employees who use illegal drugs or who believe they may have a substance abuse problem are encouraged to contact the Benefits Department to seek treatment for drug or alcohol addiction.

While on a Company installation, all prescription medication must be submitted to the person in charge of medical matters.

As a condition of employment with the Company, all employees must agree have released to the Company the results of all substance screens and examinations, including all documents generated.

COMPANY AUTHORIZED PERSONNEL:

Conduct random testing as part of an established program.

When necessary to locate illegal or unauthorized items, authorized personnel should conduct searches or inspections on Company property of employees and their personal effects.

While on a Company installation, collect and make note of prescription medication submitted by employees.

LEASE OR CONTRACT PERSONNEL AND THIRD PARTY:

Lease or Contract personnel and third party will be subject to this policy to the maximum extent practicable.

AUTHORIZED CLINICS:

Conduct clinically accepted testing as instructed by Company Authorized Personnel.

When deemed necessary, conduct second drug/alcohol confirmation test on the initial sample with every “non-negative” test result.

UNIT HUMAN RESOURCES DIRECTORS OR MANAGERS AND MANAGER OF HUMAN RESOURCES – HEADQUARTERS

Establish and maintain a program for random testing and a procedure to ensure the minimum criteria are being met.

Ensure the program implemented includes testing for cause, post incident and random.

Liaise with Global People Development and Legal to ensure facilities used for testing meet required regulatory requirements.

GLOBAL BENEFITS DEPARTMENT:

Provide assistance and information when requested by employee on the Company’s Substance Abuse Service.

DOCUMENTATION

Drugs and Narcotics Release Notice

Drug Screening Release

REFERENCES

All questions and feedback should be directed as such.

ORIENTATION AND TRAINING

Training

POLICY

Company personnel who perform work on installations or at facilities must be provided with HSE training in accordance with the worldwide training matrix.

PURPOSE

The purpose of this policy is to ensure all Company personnel are adequately trained to perform their duties in the safest manner possible and to prevent incidents or injuries.

SCOPE

This policy covers all personnel as defined by referenced Policies and Procedures and office-based personnel who travel to facilities and installations to conduct work.

PROCEDURE

TRAINING REQUIREMENTS

The HSE training requirements are detailed in the company's Worldwide and Business Unit Training Matrices.

Training, beyond the minimum required to assist personnel in complying with the specific HSE Policies and Procedures, is also detailed in the Company Training Matrix.

For the purposes of this manual, Company approved training includes Unit approved training, unless specifically stated otherwise.

TRAINING MATERIALS

Company approved training materials must be available to meet the requirements of the Health and Safety Manual

RESPONSIBILITY

ALL COMPANY PERSONNEL:

Complete HSE training as required by the Worldwide Training Matrix.

BUSINESS UNIT VICE PRESIDENT:

Ensure Company approved training materials are available to meet the requirements of the Health and Safety Manual.

RISK MANAGEMENT

THINK Planning Process

POLICY

A suitable plan with a risk assessment and appropriate controls must be confirmed in place, prior to all tasks.

PURPOSE

The purpose of this policy is to ensure that hazards are identified and risks are effectively managed and controlled at all times.

SCOPE

This policy covers all personnel that work at any Company installation or facility.

All Company personnel must incorporate the THINK Planning Process into all tasks performed, whether working individually or in teams.

PROCEDURE

The THINK Planning Process is utilized for Risk Management of all activities and tasks carried out throughout the Company.

The THINK Planning Process for Risk Management consists of the following steps:

Correctly identifying the hazards (What If?) and associated risks (consequences and likelihood) involved in an activity or task through risk assessment.

Utilizing knowledge and experience to demonstrate risks are as low as reasonably practicable (ALARP) by applying the appropriate level of risk assessment (THINK planning level).

Determining the controls (policies, procedures, standards and work practices) required to ensure the risk to people, the environment and property is as low as reasonably practicable throughout the task or activity:

Preventive controls – prevent an incident by reducing the likelihood an incident will occur.

Mitigating controls – reduce the consequences of an incident if preventive controls fail or are not effective.

Communicating the risks and controls to personnel who may be affected.

Anticipating possible deviations from the THINK plan by identifying changes, conditions and inactions (What If?).

It is essential for managers, supervisors and individuals to demonstrate risks are ALARP prior to performing activities or tasks. Verifying controls (preventive and mitigating) are in place and effective helps ensure identified risks are maintained as low as reasonably practicable.

Personnel must have the necessary knowledge, skills, and experience to perform the activities or tasks assigned to them, including any activities to control risks. This cannot be determined without a correctly developed THINK plan.

. Effective understanding of the process cannot be accomplished from employee-computer interface. Supervisors must utilize the information from the DVD to coach, mentor and monitor the effectiveness of their employees’ THINK plans. (See Section 4 Subsection 1.3)

DEMONSTRATING RISKS ARE ALARP

Company personnel reduce risks to as low as reasonably practicable by completing a qualitative risk assessment at the appropriate THINK planning level and applying appropriate controls available in the Company management system (policies procedures and standards), site specific work practices, and regulatory requirements.

All THINK plans include the requirement to reduce risks to as low as reasonably practicable. Reducing risks to as low as reasonably practicable requires personnel to consider the various additional risk reduction measures (additional controls) and determine if the effort and cost of those measures justify the additional amount of risk reduction obtained.

LEVELS OF RISK MANAGEMENT

Figure A visibly represents the levels of the THINK Planning Process available for identifying, assessing and controlling risk through effective planning:

THINK Planning Process – Individual

THINK Planning Process – Verbal

THINK Planning Process – Written

Task Specific THINK Procedure

Task Risk Assessment (TRA)

HAZOP / HAZID (Hazard Operability Study/Hazard Identification)

Major Accident Hazard Risk Assessment (MAHRA)

Safety Case

Operations Integrity Case (OIC)

The THINK Planning Process includes hazard identification and provides various levels of risk assessment to demonstrate risks are as low as reasonably practicable. The level of risk assessment applied is dependent upon the:

number of people involved in the assessment

knowledge, experience, and skill of the people participating in the assessment and developing the plan

criticality and complexity of the task or activity

potential negative consequences that may occur during the task or activity.

Higher levels of THINK planning used within the Company include Task Risk Assessments (TRAs), HAZOPs/HAZIDs, Major Accident Hazard Risk Assessments (MAHRAs), Safety Cases, and Operations Integrity Cases (OICs). These levels of THINK planning provide a higher level of detail to ensure risks are demonstrated to be as low as reasonably practicable. Demonstrating risks are as low as reasonably practicable for tasks, activities and hazardous operations is accomplished through risk assessment and effective application of controls represented by the Company Management system and site specific work practices.

THINK PLANNING PROCESS

The steps of the THINK Planning Process are:

PLAN What is the desired/required result? How will the

activity and task be performed, in what order and steps? Who has the necessary skills and experience

to safely perform the tasks and steps? When are the tasks and steps required to be performed?

INSPECT What tools, equipment or work areas require

inspection? Who will do the onsite inspection? What were the results of the onsite inspection?

IDENTIFY (What If?) What hazards are people, environment or

equipment exposed to? What are the potential causes and consequences related to these hazards? How likely are they to happen? What are the risks involved and are you able to clearly demonstrate they are as low as reasonably practicable?

COMMUNICATE What is required to be communicated regarding the

hazards identified? With whom do we need to communicate? Have the risks been communicated to the appropriate level of authority and supervision?

CONTROL What controls (procedures, work practices or

resources) are required to reduce the identified risks to as low as reasonably practicable? Have appropriate controls to reduce the likelihood of an incident occurring (Preventive) and reduce the consequences (Mitigating) of an incident occurring been effectively implemented? Have the appropriate controls from the Company Management System been clearly identified and applied? Are personnel involved constantly aware?

Creation of an effective THINK plans requires individuals or groups to be competent to perform the task and ask themselves:

Have I identified the changes, conditions, and inactions (What If?) that could lead to possible negative consequences?

Did I consider the likelihood that the negative consequences may occur?

Even though the risk in my plan is within my risk tolerance, have I demonstrated it to be as low as reasonably practicable?

Do I understand what I need to do to recognize and manage change?

The START observation card can be used at the work site as a prompt to assist in developing effective THINK plans.

RULES OF TASK PLANNING

When developing your THINK plan, you must follow the rules for task planning. By following the rules of task planning, you ensure that you and your team have the knowledge, personal experience, skill, and authority necessary to develop an effective THINK Plan, manage change, and successfully complete your task without incident and injury. You also determine which approach for managing change will be applied while carrying out the THINK Plan.

The rules of task planning are:

The plan, and all its steps, must comply with the Company’s Management System procedures. You must meet the expectations communicated by your supervisors and described in the procedures.

You must have the knowledge of the steps needed to perform the task safely and correctly. You must understand the steps needed to complete the task.

You must have the personal experience to anticipate what should happen next and what could go wrong.

You must have the skills to be able to perform the steps of the task safely and correctly.

You must have the approval authority to plan and perform the task before proceeding.

THINK PLANNING PROCESS – INDIVIDUAL

The THINK Planning Process will be most widely applied at the individual THINK plan level to assist individuals in planning what they are about to do. Individuals must use the THINK Planning Process to Plan, Inspect, Identify, Communicate and Control all tasks and associated hazards and risks. Individuals must apply START monitoring during execution of the planned task in order to recognize any deviation from the THINK plan, which may create new hazards and risks.

THINK PLANNING PROCESS – VERBAL

The verbal THINK Planning Process is used when more than one person is involved in a task. Joint participation in developing the THINK plan is required. Adequate communication between the personnel involved must ensure all aspects of the activities, tasks, risks and controls in the THINK plan are reviewed and understood.

When each person involved fully understands and agrees on the THINK plan and the necessary controls are implemented, the task may proceed.

THINK PLANNING PROCESS – WRITTEN

The written THINK plan is provided for supervisors to manage risk associated with tasks carried out by their crew using the Rules of Task Planning and by:

Creating experiences that provide learning opportunities.

Ensuring their people practice effective individual and verbal THINK planning skills on the job.

Reinforcing the practice of hazard identification (What If?) and assessment on the job.

Satisfying themselves people have learned and developed necessary skills to carry out their job in a safe and responsible manner.

Understanding and implementing available preventive and mitigating controls.

Identifying the hazards and assessing the risks (What If?).

Understanding what is needed to anticipate, recognize, and manage change,

The supervisor is responsible for the quality and completion of the written THINK

plan.

The THINK Process Checklist must be utilized and completed to ensure effective written THINK plans are created.

The START observation card can be used at the work site as an additional tool to prompt and assist in the development of written THINK plans.

If appropriate, the planning stage for development of a written THINK plan may take place in an area other than the work site. The work site must be visited for the Inspect, Identify, Communicate and Control stages. Visitation of the work site allows the personnel assessing the risks and developing the plan to:

Get a clear understanding of the environment including the layout of and safe and possible unsafe conditions in the area.

Identify hazards, actual and potential, and their consequences.

Inspect tools and equipment in the area and those that will be or may be required for the task.

Communicate with people directly and indirectly involved with the planned task who may be affected by the task.

Make an initial plan of control measures required to be implemented for the task, people and work area.

TASK SPECIFIC THINK PROCEDURE

Task Specific THINK Procedures are utilized to execute tasks that have been identified to have a higher level of criticality, complexity, or risk, based on the hazards identified for the tasks within the activity. Task Specific THINK Procedures document the safest and most effective way to perform a task, incorporating the experience of personnel involved.

The Task Specific THINK Procedure is comprised of task steps, critical task steps or both.

A critical task step is a task step that, if not performed correctly, can cause significant loss (severity rating of 15 or higher, see Section 4 Subsection 6.3) and a likelihood probability of Conceivable, Possible, or Likely. See Figure B, Risk Classification Matrix, for results marked with “†”.

Task Specific THINK Procedures represent Level 3 Installation Specific Procedures that are the basis for establishing effective and reliable preventive and mitigating controls for all task steps. The personnel at each installation or facility must determine the necessary controls (including ones in the Company Management System) for each task step in a Task Specific THINK Procedure. See Figure F for Task Specific THINK Procedure format options.

Task Specific THINK Procedures are required for all hazardous operations as determined by the installation’s Operation Integrity Case.

All crew members involved in or affected by the task must participate in the development of the Task Specific THINK Procedure. This assists them in identifying hazards and incorporating controls to reduce the risk of injury or incident.

Application of a Task Specific THINK Procedure requires individuals or groups to:

Review and discuss the Task Specific THINK Procedure prior to commencing the task.

Confirm the control measures for all task steps within the procedure.

Ensure personnel understand their responsibilities to carry out the task steps.

Understand the hazards and the consequences of those hazards.

Ensure the expected results are understood prior to commencing the activity.

Determine individual requirements through their own individual THINK plans after understanding the Task Specific THINK Procedure.

If it is determined at the installation/facility level that a Task Specific THINK Procedure needs to be developed or an existing one revised, a written THINK plan is required for the task to proceed until such time as the new or revised Task Specific THINK Procedure is approved.

Task Specific THINK Procedures require initial review and approval from the OIM and final approval of the Rig Manager. This approval process is required prior to the Task Specific THINK Procedures being included in the company management system at the installation level (Level 3 Installation Specific Procedures),

TASK RISK ASSESSMENT

The Task Risk Assessment provides a more detailed risk assessment to demonstrate that risks related to specific task steps are as low as reasonably practicable. The potential consequences for all critical task steps must be clearly identified in the assessment so existing control measures can be verified and/or new control measures implemented to reduce the identified risks to as low as reasonably practicable.

A Task Risk Assessment is required for all exemption requests and to assess critical task steps in Task Specific THINK Procedures. (See Section 1.5)

The Task Risk Assessment is available to provide a higher level risk assessment of the critical task steps listed in Task Specific THINK Procedures or written THINK plans.

Risk Matrix

NOTE: To rank Probabilities and Severities, assume existing controls/safeguards (policies, procedures, work practices, supervision) are in place and functioning effectively.

LOW RISK

Task may proceed and should be monitored. If possible, implement measures to reduce the risk even further

MEDIUM RISK – OIM must be notified.

Task may proceed but should be carefully monitored and re-assessed at

regular intervals to establish if additional measures or controls are required.

HIGH RISK

Task must not proceed. Implement and risk-assess alternative methods for

performing the task.

† TSTP Task steps with this risk require a Task Risk Assessment.

See Figure G in the documentation section of this procedure for an example of a completed Task Risk Assessment worksheet.

HAZARD IDENTIFICATION (HAZID)

A HAZID study is the structured, systematic risk assessment of an activity in order to identify the hazards associated with it. For example, the activity of drilling a high pressure/high temperature well would normally be split into a number of smaller tasks. Each task should be reviewed in turn, asking, "What could go wrong?" or "What if this happened?"

HAZARD AND OPERABILITY (HAZOP)

A HAZOP study is used to identify HSE hazards and operability issues for equipment or systems to reduce risks to ALARP. HAZOPs are primarily used during the design stage.

A HAZOP team should consist of personnel familiar with the equipment and systems and be lead by a facilitator trained and competent in the HAZOP process.

MAJOR AND OTHER WORKPLACE HAZARDS

Rig Oilfield has three processes to provide assurance that Major Hazards are effectively managed: the Major Accident Hazard Risk Assessment (MAHRA), the HSE (or Safety) Case, and the Operation Integrity Case (OIC).

A Major Accident Hazard Risk Assessment (MAHRA) shows that major hazards have been identified, the risk associated with those hazards has been qualitatively

assesses and that the preventive and mitigating controls necessary to reduce the risk to ALARP have been identified. The MAHRA identifies risks from three perspectives: by compartment, by system, and the installation as a whole. The MAHRA relies upon the knowledge and experience of the installation’s personnel.

A Safety Case is a document that contains a summary of the details of the installation, installation management and Company safety management system. Additionally, it shows the Company has identified, evaluated and analyzed all major accident hazards that may affect the installation and has in place appropriate means for controlling risks associated with those hazards including the procedures and in- place systems for evacuation, escape and rescue from the installation.

A Quantitative Risk Assessment may be used as part of the Safety Case risk assessment. Its use must be suitable and sufficient depending on the level of risk and local requirements.

The Safety Case is used to demonstrate major HSE risks are as low as reasonably practicable to meet regulatory requirements in the United Kingdom, Norway, Denmark, Netherlands and Australia.

The Operation Integrity Case provides assurance that major and other workplace hazards are identified, the risks associated with these hazards are assessed, and that the necessary controls are in place to reduce the risk to as low as reasonably practicable. Each identified control is assigned a responsible person. The OIC process is based upon (and referenced to) the Company Management System, so does not rely solely on the knowledge and experience of the personnel involved.

5 RESPONSIBILITY

5.1 ALL COMPANY PERSONNEL:

Participate and incorporate the THINK Planning Process into all tasks performed, whether working individually or in teams.

Participate in development and review of Task Specific THINK Procedures.

Ensure appropriate preventive and mitigating controls are in place to address the risks which are present in all tasks.

SUPERVISORS:

Ensure their crews are trained in the use of the THINK Planning Process. Be responsible for the quality and use of the THINK plans created by their crews.

Lead the THINK Planning Process daily.

Participate in the development and continuous review of Task Specific THINK

Procedures.

Participate in development and review of Task Risk Assessments (TRAs).

Ensure appropriate Company Management System Procedures are correctly implemented and applied (preventive and mitigating controls) in THINK plans.

OIM:

Review Task Specific THINK Procedures to identify critical tasks and determine if a Task Risk Assessment is required to demonstrate the risks are as low as reasonably practicable.

Review Task Specific THINK Procedures, offer initial approval and submit to Rig Manager for final approval.

Review and approve THINK Task Risk Assessments and those related to Exemption and forward to the Rig Manager for approval.

Monitor the participation and use of THINK planning on the installation.

Ensure appropriate Company Management System Procedures are correctly implemented and applied (preventive and mitigating controls) in THINK plans.

Ensure that a list detailing personnel responsible for HSE critical activities is documented, maintained and communicated.

RIG MANAGER:

Review Task Specific THINK Procedures to identify critical tasks and determine if a Task Risk Assessment is required to demonstrate the risks are ALARP.

Review specific Task Specific THINK Procedures and provide final approval.

Review and approve THINK Task Risk Assessments as required and those related to Exemption requests.

Ensure that an applicable MAHRA, OIC, or Safety Case has been completed.

Ensure that an approved procedure for the review of the installation’s MAHRA, OIC, or Safety Case is established.

Ensure adequate resources are provided so preventive and mitigating controls which have been identified on the installation can be put in place.

Ensure Company Management System Procedures are correctly applied as preventive and mitigating controls in THINK plans.

6 DOCUMENTATION

The forms indicated below are included in the manual and are not to be modified from their original format. These forms have been developed by Corporate HSE Services and are a requirement of this policy. These forms must be reproduced and made available to all installations/facilities by their Division/Unit offices. Forward any suggested improvements to these forms using the HSE Feedback form.

Written THINK Plan (Figure E1)

(Must be filed in the installation/facility files for at least 90 days.)

THINK Process Checklist (Figure E2)

(Must be filed in the installation/facility files for at least 90 days.)

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President.

Task Specific THINK Procedure (Figure F)

(Copies must be made available to personnel and retained until newer procedures or assessments supercede them.)

Task Risk Assessment Worksheet – Front (Figure G1)

(Copies must be made available to personnel and retained until newer procedures or assessments supercede them.)

Task Risk Assessment Worksheet – Back (Figure G2)

(Copies must be made available to personnel and retained until newer procedures or assessments supercede them.)

Permit to Work

POLICY

All installations and facilities must have a Permit to Work system in place that safely controls hazardous operations.

All personnel must be trained prior to using the Permit to Work system.

PURPOSE

The purpose of this policy is to ensure that authorized personnel, who are knowledgeable of the hazardous operation to be performed, have planned the work, inspected the work site, identified the hazards and communicated the suitable control measures to be taken to prevent the occurrence of an incident using the Permit to Work System.

SCOPE

This policy covers all personnel who work at any Company installation or facility.

PROCEDURE

A Permit to Work is not required for every job. Consider other forms of control measures, such as the THINK Planning Process, Energy Isolations, and so on before generating a permit.

GENERAL

Responsible persons have designated areas of the installation/facility and relevant equipment in their spheres of responsibility. A list of the responsible people (by position), their designated areas of responsibility and equipment must be posted at the administration site. They are responsible for ensuring all control measures and procedures are in place, prior to signing the Permit to Work.

OBJECTIVES AND FUNCTIONS OF THE PERMIT TO WORK SYSTEM

Ensure that proper authorization is given to carry out specific work at a certain time and place.

Ensure that personnel carrying out the work clearly understand the nature of the job, the hazards involved and the limitations on the work and time.

Specify the control measures to be taken before starting the work, during the work and after completing the work.

Ensure the OIM or designee is fully aware of and approves the work to be done.

Provide a record showing the type of work and indicate that a responsible person is assigned.

Provide a procedure for determining times when work must be suspended.

Provide procedures for other activities that may interact.

Provide a formal hand-over procedure if work overlaps a shift change.

Provide a formal hand-back procedure to ensure that any part of the installation affected by the work is returned to a safe condition and ready for reinstatement.

Provide a central display of open or suspended permits.

VALIDITY

The maximum validity of any Permit to Work is 24 hours. If the work is not complete within 24 hours, close the existing Permit to Work and initiate a new one following all steps listed in this procedure.

HAZARDOUS OPERATIONS

Hazardous operations that require a permit include, but are not limited to, the following situations:

HOT WORK

Hot work includes welding and oxygen/acetylene cutting, electrical work, grinding (fixed or portable), needle gunning and all work using other types of ignition sources.

With regards to hot work, hazardous operations that require a permit include but are not limited to:

Welding and oxygen/acetylene cutting anywhere on the installation except in the approved designated safe welding area.

All hot work in any designated hazardous area or in any area where an explosive gas mixture is likely to occur in normal operations.

Any time an electrical apparatus cannot be made dead (for any reason) and is considered hazardous to life.

All use of open flames such as burning garbage or use of an outdoor cooking grill.

As a minimum, the THINK planning process must be used for all other hot work to determine if a Permit to Work is required or what other controls need to be put in place.

Due to the risk of fires or explosions during hot work, ALL alternative methods of accomplishing the job must be considered prior to hot work being authorized.

Aspects that must be considered during any hot work include at least the following:

Well operations or situations, well testing, and simultaneous operations.

Back sides of walls, bulkheads, decks, floors, deck heads, and ceilings.

Areas adjacent to the work, such as fuel tanks or paint lockers.

Combustible materials stored in the area (must be removed or protected).

Vapors present or generated by the hot work.

A system must be in place so that all hot work is suspended and relevant ignition sources confirmed shut down when circumstances dictate.

Hot work must not be performed on any drum or other container that previously contained hazardous materials.

WELDING AND OXYGEN/ACETYLENE CUTTING

Only personnel authorized by the OIM are permitted to use welding or oxygen/acetylene cutting equipment.

Welding performed on structural members, high-pressure lines and lifting appliances must be performed only by an appropriately certified (coded) welder.

A designated safe welding area must be established by conducting a risk assessment. Whenever possible, welding and oxygen/acetylene cutting operations must be performed within the designated safe welding area. A Permit to Work may not be required in the designated safe welding area.

All designated safe welding areas must be approved by the Division Manager. Adequate ventilation must be provided for fumes and dust generated by welding and

cutting operations. If adequate ventilation cannot be accomplished, suitable respiratory protection must be worn.

When welding or cutting, the welder must wear appropriate clothing/PPE, including:

Welding shield and hardhat combined, or a hand-held shield and a hard hat with suitably shaded transparent eyepiece approved for welding.

Shaded eye protection when cutting.

Dry leather welding gloves.

Leather aprons (where appropriate).

A long sleeve garment approved by the manufacturer as suitable for welding.

Heat resistant, Kevlar or similar material Company approved full-body harness, when required. Shock absorbing lanyards must be protected from sparks and slag while in use during welding or cutting operations.

Clothing, particularly gloves, must be kept as dry as possible to assure some protection against an electric shock.

Screens or other effective means must be used to protect persons who may be exposed to harmful radiation or sparks from electric arc welding.

Welder's assistants and fire watchers must take adequate precautions to protect against welding flash.

All welding cables must be fully insulated and maintained.

All grounding connections must be secured to eliminate sparking. Welding machines must be switched off when not in use.

FIREWATCHER

A firewatcher must be assigned and clearly identifiable (for example wearing an orange vest) for any welding or cutting operation performed outside the designated safe welding area, and have no other duties while so assigned.

The firewatcher must wear long sleeves made of a flame-retardant material. The firewatcher is responsible for carrying out the following duties:

Assist the welder in inspecting and preparing the work site before beginning work.

Ensure that adequate fire-fighting equipment is readily available and familiarize themselves with its operation and what to do in the event of a fire.

Sign the Permit to Work before beginning the work.

Continually monitor the work site and adjacent areas for hazards that may affect the welder or that are created by the hot work.

Remain at the site for a suitable length of time after the welder has completed his assignment, watching for any indication of burning or smoldering.

Inspect and re-inspect the site where possible smoldering may occur for a minimum of 30 minutes after completion of any welding or cutting operation.

Notify the welder of intention to leave the work area so that a hand-over of responsibility to a suitable replacement can be carried out.

Take adequate precautions to protect against welding flash.

CONFINED SPACE ENTRY

Confined spaces are defined as a tank, mud pit, tunnel or similar spaces where there is a danger of explosion, lack of oxygen or the presence of toxic gases. All spaces that are not normally lit, not normally ventilated and not normally manned are also considered confined spaces.

All reasonable and practicable options to perform the task that do not require confined space entry must be ruled out and controls must be in place before proceeding.

A Permit to Work must be completed for any confined space or tank entry and a copy must be posted outside the area to be entered.

TRAINING

Any personnel entering confined spaces must be trained in the hazards of confined space entry and use of the equipment that must be utilized. This training (See Section 4 Subsection 1.3) and practical demonstration must be given in a formal manner and fully documented.

Responsible persons and the Emergency Response Teams must be trained and exercised in the proper use of the installation or facility specific confined space rescue and retrieval equipment. The training and drills must be documented. (See Section 4 Subsection 3.2)

EQUIPMENT

The following equipment must be available for confined space entries:

For work within confined space:

A portable gas detector capable of continuously monitoring the oxygen content, H2S content and Lower Explosive Limit (L.E.L.) complete with accessories to allow remote detection.

An explosion-proof air exhaust fan.

A minimum of two explosion-proof portable lights.

Explosion-proof radio communication set.

Appropriate warning signs and barricades.

For vertical confined space entry over 6 feet 7 inches (2 meters):

A portable tripod with a combined fall arrestor/retrieving winch or similar system.

One Company approved full body harness per person.

For rescue within confined space:

One 30-minute Self-Contained Breathing Apparatus (SCBA) per rescue team member.

A stretcher that allows rescue of an injured person.

VENTILATION OF CONFINED SPACE

Before completely removing the fastening devices on a confined space, the internal pressure must be checked and vented if necessary.

The atmosphere must be sampled for oxygen levels and combustible gas using a portable gas detector. If levels of toxic, inert, or combustible gases or oxygen are detected that present dangerous and hazardous conditions, the area must not be entered until measures have been taken that render the space safe.

All equipment used for testing purposes must be maintained and calibrated.

Persons who are competent should carry out testing. Those carrying out the testing should also be capable of interpreting the results and taking any necessary action. Testing must be conducted for each re-entry.

There are substantial risks if the concentration of oxygen in the atmosphere varies significantly from normal, 20.9%. For example, oxygen enrichment increases flammability of clothing and other combustible materials. Oxygen deficiency induces impairment to personnel.

Atmosphere below 19.5% or above 22% oxygen by volume must not be entered except for emergency rescue purposes and then only when personnel are equipped with positive pressure respirators.

CONFINED SPACE STAND-BY PERSON

A stand-by person must be assigned and clearly identified for any confined space entry. A stand-by person must have no other duties while so assigned.

Only personnel who have satisfactorily completed the Company's confined space awareness training can be authorized by the OIM to be assigned as a stand-by person. (See Section 4 Subsection 1.3)

The stand-by person is responsible for carrying out the following duties:

Assist the competent person to sample the atmosphere for oxygen and combustible gas levels.

Ensure adequate rescue equipment is readily available and familiarize themselves with its operation and what to do in the event of an emergency.

Sign the Permit to Work before beginning work.

Remain at the confined space entry site while any personnel are inside.

Continually monitor the confined space entrance and adjacent areas for hazards that may affect the personnel working in the confined space.

Prevent unauthorized entry.

Maintain contact with a manned control point (control room, radio room, and so on) and with the personnel in the confined space.

Maintain a tally of the persons inside the confined space.

Notify the person in charge of carrying out the work of their intention to leave the work area, so that a hand over of responsibility to a suitable replacement can be carried out.

Immediately raise the alarm if there are indications (through the agreed system of communication or otherwise) of the personnel within the confined space being negatively affected by the atmosphere. After raising the alarm, under no circumstances should the stand-by person stationed at the entrance attempt to enter the confined space before additional help has arrived.

CONFINED SPACE ENTRY

For all confined space entries, sounding must be done before entering. In case of a doubtful sounding or suspected presence of fluid that presents a drowning hazard, personnel must wear a floatation device.

An adequate system of communication must be agreed upon and tested by all involved to ensure that those entering the space can keep in touch with the stand-by person stationed at the entrance.

The time of opening or closing a confined space and entry or exit of personnel must be recorded at the manned control point (control room, radio room, and so on.).

The atmosphere must be continuously monitored with a portable gas detector to verify that the atmosphere remains gas free and that an acceptable oxygen level is maintained.

Air movers or blowers must be used for venting and to provide a continuous supply of fresh air while the work is in progress, unless sufficient airflow is obtained through a free flow process. Air movers or blowers must be installed in such a position that the fresh air intakes do not draw in fumes or vapors.

Provisions must be made for ready exits and entrances. Tanks, vessels or other confined spaces having openings or manholes in the side as well as in the top must be entered from the side when practicable. The use of a safety line to indicate the direct route to and from the work site must be considered.

Fuel tanks and crude oil tanks must not be entered without Rig Manager approval. No source of ignition may be introduced into a confined space where flammable

vapors or gases may be present.

When working in confined spaces, all pipelines discharging into that space must be closed with blind flanges, plugs or valves and energy isolation signs and tags posted. There must be at least two rescue team personnel in the confined space and one rescue team person outside the confined space equipped with approved respiratory equipment for all rescue situations in a confined space requiring respiratory equipment.

HOT WORK IN CONFINED SPACES

In addition to the above and the hot work procedures, (See 4.4.1) personnel must adhere to the following procedures.

If a high level of combustible gases or oxygen enriched atmosphere (above 20.9%) is detected, the area must be naturally aired or ventilated and a new test conducted. Repeat the airing/ventilation and testing procedure until the test indicates the area is safe for hot work.

If torch cutting or welding is carried out on pipelines passing through confined spaces, they must be isolated, purged if necessary, and energy isolation signs and tags posted prior to the hot work starting. (See Section 4 Subsection 5.4)

One of the highest risks from using gas within a confined space is the accumulation of gas due to leakage from the cylinders or hoses. To reduce this risk, gas cylinders should not be taken into confined spaces. Where it is necessary to take gas cylinders into confined spaces, periodic gas checks must be made in the vicinity of the cylinders and always prior to recommencing work after a break. The cylinders must be removed immediately on completion of the task.

When hoses are run into a confined space from gas cylinders outside the confined space, all hoses and fittings must be disconnected from the gas cylinders or removed from the confined space during extended breaks.

WORK ABOVE OPEN WATER

All work carried out over open water, outside the handrails and anywhere there is a danger of falling into the sea.

TRANSFERS TO/FROM SUPPLY AND CREW BOATS (SEE SECTION 4 SUBSECTION 5.2, BOAT OPERATIONS)

A Permit to Work is required whenever personnel are transferred to or from a supply or crew boat by a personnel transfer system, such as a personnel basket or Frog.

A Task Specific THINK Procedure must be developed and utilized when performing this task.

WORK ON SUPPLY BOATS

The Company strongly discourages allowing any Company personnel to work on supply or crew boats. If, in an exceptional circumstance, personnel work on supply or crew boats, only experienced and competent people (as determined by the OIM) are permitted to perform the task and controls must include the use of a written THINK plan.

WORK WITH EXPLOSIVES (SEE SECTION 4 SUBSECTION 5.7)

Any time explosives are removed from their certified shipping containers.

WORK WITH RADIOACTIVE MATERIALS (SEE SECTION 4 SUBSECTION

5.7)

Any time radioactive materials are removed from their certified shipping containers.

DIVING

All manned diving operations carried out from the installation or where there is an interface between manned diving operations and the installation.

ENERGY SOURCES (SEE SECTION 4 SUBSECTION 5.4)

The OIM or designee must determine if a Permit to Work is an additional requirement when an isolation certificate is issued for maintenance or repair of a system or component containing energy. In some cases, the work is only hazardous because of the energy. When effective isolation is achieved, the work may no longer be hazardous because the energy source (such as electrical energy, hydraulic pressure or air pressure) has been removed.

MAINTENANCE OF CRITICAL SAFETY SYSTEMS

Work that affects the state of readiness of the installation's critical safety systems

ASBESTOS WORK (SEE SECTION 4 SUBSECTION 5.7)

Work involving the cutting, drilling or other disturbance of material that contains asbestos.

SPECIAL STRAPS (WEBBING SLINGS) (SEE SECTION 4 SUBSECTION

5.6)

Work involving the use of slings made of synthetic fiber may be carried out in special cases (for example, lifting of chromium pipes, special drill pipe, engine cylinder heads, and so on).

DANGEROUS LIQUIDS (SEE SECTION 4 SUBSECTION 5.7)

All work involved in the mixing and/or pumping of concentrated acid and other such dangerous liquids.

MANRIDING (SEE SECTION 4 SUBSECTION 5.6, PARAGRAPH 4.4)

At the discretion of the OIM a Permit to Work may be required for certain complex operations.

PRESSURE TESTING (SEE SECTION 4 SUBSECTION 5.4)

Pressure testing or maintenance on equipment that contains or may contain residual pressure.

OVERBOARD DUMP VALVES

All work requiring the opening or potential opening of any overboard dump valve.

OTHER

Other work not covered by the previously mentioned situations where the OIM, a supervisor or any risk assessment identifies the requirement of a Permit to Work to control risks.

Any work where equipment that is not intrinsically safe is used in a hazardous area. For example: PDA, flash light, camera and so on.

DISPLAY OF PERMITS

A copy of the Permit to Work form must be displayed at the work site.

SUSPENSION OF PERMITS

A permit must be suspended for any of the following reasons:

Activation of the general alarm or instructions on the PA system. The permit administrator must be notified immediately of the cessation of work. As soon as it is safe and practicable, return all copies of suspended permits to the Permit System Administrator to keep until reactivation is allowed.

At any time when any person feels that the circumstances have or may change, such as when the control measures in place are not adequate or other activities going on could cause additional hazards.

If the control measures in place are not adequate.

REACTIVATION OF PERMITS

Reactivation of the work must take place only after the responsible person confirms that all the control measures are in place.

HANDOVER PROCESS

When a permit is to be carried over to another shift, both the responsible person and the person in charge of the work must ensure that the work is understood and the control measures are in place. The OIM and OIM Designee must ensure they are aware of all open permits at commencement of their daily tour.

If the responsible person or the person in charge of the work change, both must sign the permit confirming that the work is understood and the controls are in place.

5 RESPONSIBILITY

Two different signatures must always be on the Permit to Work. The same person must not sign as both the Responsible Person and the Person in Charge of the Work. This does not exclude the OIM or designee from acting as the Responsible Person.

1 PERSON IN CHARGE OF THE WORK (WORK DETAILED ON PERMIT TO WORK):

Request the Permit.

Ensure that specified control measures are complied with throughout the Permit to Work operation.

Provide onsite supervision or carry out the work personally.

Complete all relevant sections of the Permit to Work form.

Route completed form to those in the approval chain of responsibility.

Upon activation of the general alarm, immediately notify the permit administrator of the cessation of work and, as soon as safe and practicable, return the original copy of the Permit to Work to the permit administration site.

RESPONSIBLE PERSON (RESPONSIBLE PERSON AND PERSON IN CHARGE OF THE WORK MUST NOT BE THE SAME PERSON):

Ensure hazards associated with the proposed work have been identified.

Identify the necessary steps to ensure the safety of the site or installation.

Examine the work site with the person in charge of the work.

Ensure the person in charge of the work is made aware of the control measures to be taken, particular equipment to be used, and procedures to be followed during the Permit to Work period.

Ensure the control measures are implemented before work commences and that they remain effective while the Permit to Work is in force.

Ensure activities requiring a Permit to Work that may interact or affect one another are clearly cross-referenced.

Ensure the Permit to Work specifies actions to be taken if the work has to be suspended.

Ensure the work site is re-examined before work is restarted after having been suspended.

Examine the work site when the work is completed to ensure that the area is in a safe condition.

Ensure the hand-over procedures are properly followed if the work lasts more than one shift.

Authorize work and isolations in their area or system of authority. (The OIM must define these areas.)

CONFINED SPACE STAND-BY PERSON:

Complete the Company's confined space training.

Assist the competent person to sample the atmosphere for oxygen and combustible gas levels.

Ensure adequate rescue equipment is readily available and familiarize themselves with its operation and what to do in the event of an emergency.

Sign the Permit to Work before beginning work.

Remain at the confined space entry site while any personnel are inside.

Continually monitor the confined space entrance and adjacent areas for hazards that may affect the personnel working in the confined space.

Maintain contact with a manned control point (control room, radio room, etc.) and with the personnel in the confined space.

Maintain a tally of the persons inside the confined space.

Notify the person in charge of carrying out the work of their intention to leave the work area, so that a hand over of responsibility to a suitable replacement can be carried out.

Perform no other duties while assigned as Confined Space Stand-by person.

Immediately raise the alarm if there are indications (through the agreed system of communication or otherwise) of the personnel within the confined space being affected by the atmosphere. After raising the alarm, in no circumstances should the stand-by person stationed at the entrance attempt to enter the confined space before additional help has arrived.

FIREWATCHER:

Satisfactorily complete the Company fire watch training before being authorized by the OIM to be assigned as a firewatcher.

Perform no other duties while assigned as Firewatcher.

Wear long sleeves made of a flame retardant material.

Assist the welder in inspecting and preparing the work site before beginning work.

Ensure that adequate fire-fighting equipment is readily available and familiarize themselves with its operation and what to do in the event of a fire.

Sign the Permit to Work before beginning the work.

Continually monitor the work site and adjacent areas for hazards that may affect the welder or that are created by the hot work.

Remain at the site for a suitable length of time after the welder has completed his assignment, observing for any indication of burning or smoldering.

Inspect and re-inspect the site where possible smoldering may occur for a minimum of 30 minutes after completion of any welding or cutting operations.

Notify the welder of intention to leave the work area so that a hand-over of responsibility to a suitable replacement can be carried out.

Take adequate precautions to protect against welding flash.

PERMIT SYSTEM ADMINISTRATOR:

Keep copies of the permits in a central location (for example, a command or control center).

Ensure that all copies of active permits are returned to the administration site any time permits are suspended.

OIM:

Determine if a Permit to Work is an additional requirement when an isolation certificate is issued for maintenance or repair of a system or component containing energy.

Ensure all other reasonable and practicable options not requiring confined space entry, have been ruled out and controls which reduce the risks to as low as reasonably practicable are in place before signing the Permit to Work and approving the confined space entry.

Ensure all reasonable control measures have been or will be carried out before signing the Permit to Work and approving the work to be carried out.

Ensure permits for work activities that may interact or affect one another are clearly cross-referenced.

Ensure a copy of the permit is displayed at the work site until work has been completed.

Ensure a system is in place to monitor the effectiveness of this procedure by selected auditing, inspection and testing of in-force work permits.

Sign the permit to indicate satisfaction with the condition in which the operation was completed or not completed and confirming the permit is no longer in effect. The OIM must record on the permit the time and date the permit was closed out. NOTE: This responsibility may not be delegated to a designee.

Assign a permit system administrator and inform the work force who was selected.

Ensure personnel are trained prior to using the Permit to Work system.

Authorize personnel who have satisfactorily completed the Company's confined space training to be assigned as a stand-by person.

Authorize personnel who have satisfactorily completed the Company's fire watch training to be assigned as a firewatcher.

Authorize personnel to use welding or oxygen/acetylene cutting equipment.

Ensure all welding performed on structural members, high-pressure lines and lifting appliances is performed only by an appropriately certified (coded) welder.

RIG MANAGER:

Approve entry into fuel and crude oil tanks.

DIVISION MANAGER:

Approve designated safe welding areas.

6 DOCUMENTATION

The form (Figure A) is included in the manual as an example only and is intended to allow operations to take advantage of a preset form rather than having to create their own. Use of this form is not mandatory. However, if the example is not used exactly as it is included; the form used must include the key elements of the example and must be approved by the Business Unit Vice President.

Permit to Work form (Figure A)

Hot permit to work (Figure B)

(The original copy of all permits must be retained on the installation for at least 12 months.)

NOTE: Each Permit to Work system must have the ability to assign a unique number to each Permit to Work form for cross-referencing.

Mechanical Isolation Certificate ( Figure C)

Electrical Isolation Certificate ( Figure D)

Confined Space Entry Checklist (Figure E)

(Must be retained in installation/facility files for a period of one year.)

Gas test report (Figure F)

(Completed checklist must be retained in installation or facility files for 90 days.)

Figure A

Figure B

Figure C

Figure D

Figure E

Figure F

Figure G

Client and Subcontractor Personnel and Equipment

POLICY

Company subcontractor personnel must be assessed, monitored and recognized for working to a system equivalent to the HSE system of the Company.

Clients and their subcontractor personnel must be encouraged to participate in the Company's HSE system.

Only equipment authorized by the OIM or the OIM's designee may be installed or operated on the installation or facility.

PURPOSE

To ensure that the HSE interface of all Company operations involving clients, any subcontractor personnel and equipment are effectively managed to identify hazards and control risks.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees; HSE policies, standards and procedures; and equipment of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

Where possible, a proactive approach to assess suitability of client and subcontractor personnel and equipment is preferred to ensure an acceptable standard of personnel or equipment arrives at the installation. The OIM or facility manager must be notified before any client or subcontractor personnel or equipment is brought onboard an installation or to a facility.

SUBCONTRACTOR PERSONNEL

Any client, contractor or outside agency personnel that work at any Company installation or facility must be encouraged to take an active part in the Company THINK, START and FOCUS Processes.

All permanently assigned subcontractors (catering, cementer, mud engineer, and so on) must be introduced to the Colors process and encouraged to take an active part in the process.

Subcontractor personnel must perform a risk assessment appropriate to the task. Subcontractors performing specialized work on installations or at facilities must be

able to demonstrate completion of an industry recognized training applicable to the type of work to be performed. The OIM must approve these personnel to perform work.

Departmental supervisors must monitor subcontractor personnel working in their area of responsibility to ensure they are working to an HSE system equivalent to that of the Company and ensure subcontractor personnel perform appropriate risk assessments and adequate control measures are in place for all tasks.

SUBCONTRACTOR EQUIPMENT

The placement, installation and operation of any client or subcontractor equipment must have prior approval from the OIM or designee.

Prior to approval for the placement of subcontractor equipment it must be confirmed that the gross weight will not exceed the “Maximum Deck Loading” for where it is to be placed.

Issuance of the approval to install and operate client or subcontractor equipment does not preclude the application of the Permit to Work policy.

Qualified personnel must inspect the equipment and complete a checklist relevant for the equipment for the OIM’s or designee’s approval.

Any unsatisfactory items must be reported to the client or subcontractor representative.

Subcontractors must maintain their equipment to an acceptable standard prior to and while on board the installation.

Company onshore management must be informed of client or subcontractor equipment/personnel found to be unsatisfactory.

RESPONSIBILITY

SUBCONTRACTOR PERSONNEL:

Carry out their duties safely.

Ensure equipment is maintained, prior to and while onboard, to at least an equivalent Company standard as well as any applicable authority or regulatory requirement.

Perform a risk assessment appropriate to the task.

QUALIFIED PERSONNEL:

Inspect the equipment and complete a checklist relevant for the equipment for the OIM’s or designee’s approval.

DEPARTMENT SUPERVISORS

Monitor subcontractor personnel working in their area of responsibility to ensure they are working to an HSE system equivalent to that of the Company and ensure subcontractor personnel perform appropriate risk assessments and adequate control measures are in place for all tasks.

OIM:

Give prior approval to the placement, installation and operation of any client or subcontractor equipment.

Inform Company onshore management of client or subcontractor equipment/personnel found to be unsatisfactory.

Report any unsatisfactory items to the client or subcontractor representative.

Ensure any certification required for personnel or equipment is valid. (For example: Coded Welding, EX Equipment, Pressure Test, Equipment inspectors, hazardous materials handling, and so on).

DOCUMENTATION

The form indicated below is included in the manual as an example only and is intended to allow operations to take advantage of a preset form rather than having to create their own. Use of this form is not mandatory. However, if the example is not used exactly as it is included; the form used must include the key elements of the example and must be approved by the Business Unit Vice President.

Dress Requirements and Personal Protective Equipment

POLICY

The Company must provide Company personnel appropriate Personal Protective Equipment (PPE) and instruction in its use.

PURPOSE

The purpose of this policy is to ensure that all personnel are adequately protected from environmental elements and relevant workplace hazards where it is not practical to reduce relevant exposure to acceptable levels by using engineering control or practices.

SCOPE

This policy covers all personnel that work at Company installations and facilities.

PROCEDURE

Occupational health and safety is devoted to the anticipation, recognition, evaluation and control of those factors or stresses, arising in and from the workplace, which may cause illness, impaired health and physical injury. Any health or safety hazard has, by definition, the potential to cause harm in some way. Safety hazards (cause) can usually be linked to the harm (effect) directly. For example, a person is struck by a hand tool dropped from the derrick due to the hand tool not being tied off. In contrast, health hazards are not always obvious and potential adverse health effects may not be directly linkable to a single cause. As a result, controls to limit exposure to health hazards may be inadequate or overlooked. This is a key difference in identifying between health hazards and safety hazards, and in assessing and reducing the associated risks.

4.1 COMPANY APPROVED PERSONAL PROTECTIVE EQUIPMENT

All PPE worn by Company personnel must be Company approved. The maintenance of critical PPE must be performed by authorized, competent personnel. Effective protection is only possible when the selected PPE is:

Suitable for the task

Suited to the wearer and the environment

In good condition

Within the expiration date and worn correctly by someone who has been trained to use it

Of sufficient quantity to meet the needs of personnel

TRAINING

Business Unit management must ensure personnel are trained in the use of PPE. The training must cover both theory and practice on the PPE to be used. The training must be based on the recommendations and instructions supplied by the manufacturer. (See Section 4 Subsection 1.3)

HEAD PROTECTION

Hard hats must be worn by all personnel outside the accommodation at all times except in designated areas approved by the Division Manager. These areas must be clearly marked to indicate that a hard hat is not required.

Hard hats must be secured when working two meters or more above the deck, or as conditions dictate. Hard hats must be:

Fitted with a means of securing, such as chinstrap or hearing protectors.

Designed so as not to prevent wearing ear muffs and/or a face shield.

Made of non-conductive material and worn as recommended by the manufacturer.

Discarded if the shell of the hard hat is damaged.

Hard hat suspension must be adjusted to fit the wearer and not modified.

The company hard hat color designation to identify visitors and employees new to the installation is:

Bright orange or international orange – visitors and Short Service Employees

White – all other Company personnel

HEARING PROTECTION

The appropriate hearing protection must be worn in designated high noise areas, which exceed 83 dB. These areas must be clearly marked.

Hearing protection must be placed at the entrance of high noise areas to ensure that all persons who enter have hearing protection available.

EYE PROTECTION

All personnel must wear approved safety glasses, complete with approved side shields, when outside the accommodation, except in designated areas approved by the Division Manager. These areas must be clearly marked to indicate that safety glasses are not required.

Prescription safety glasses must have approved side shields securely fitted or permanently attached.

Safety goggles or a face shield with safety glasses must be worn:

During any activity, such as chipping, grinding, hammering, changing tong dies, high pressure wash down, and so on, which may result in a foreign body in the eye.

When handling corrosive or harmful products (solid or liquid) or when tasks deem it necessary.

Eye wash stations must be strategically positioned.

The wearing of contact lenses is permitted except as follows: in areas of dust and fumes; when wearing breathing apparatus; by people performing or assisting with welding operations.

All wearers of contact lenses must comply with the following:

Inform their supervisor that contact lenses are worn.

Keep available a pair of prescription safety glasses as a backup.

DRESS REQUIREMENT/CLOTHING

Appropriate clothing that ensures personal safety and protects an individual from the elements must be worn. All clothing must be Unit approved.

No jewelry may be worn while working. This includes finger rings, pierced or clasp earrings, studs and rings worn in face or body piercings, tongue piercings, metal watch straps, necklaces, chains, or medallions. The only exception is for non- conductive watches and non-conductive medical alert tags.

Certain operations, as determined by the THINK planning process, may require additional protective clothing. The following are examples of operations and required additional protective clothing:

Slicker suits must be worn when personnel might be exposed to hazards that coveralls do not give adequate protection from such as oil-based mud, completion fluids, heavy rain, and so on.

Sleeveless garments are not permitted in the galley or mess areas.

Loose clothing that can be caught in machinery must not be worn.

Safety and health risks associated with long hair must be controlled by use of hairnets and so on.

Aprons or protective suits must be worn when handling corrosive or harmful products.

Work vests or other floatation devices must be worn when working over water.

COVERALLS

Coveralls or two-piece work clothing must be made from cotton or flame-resistant fabric.

Reflective tape must be affixed to coveralls and two-piece work clothing to enhance visibility in low-light circumstances. Placement is usually across each shoulder, on the lower arms and on the lower part of the legs.

WORK VESTS

Must be adjusted to the wearer’s size and securely fastened. Must be returned to labeled stowage containers after use. Must be inspected weekly.

Work vests used in conjunction with full body harnesses must be compatible to ensure the “D” ring connection will not be fouled.

HAND PROTECTION

Gloves (cloth, rubber, leather, and so on) must be worn to protect the hands, dependent upon the exposure.

Asbestos-free, high-temperature gloves must be worn when handling hot pieces of equipment.

FOOT PROTECTION

All Company personnel must wear lace-up safety toe boots when outside the accommodation area, except in designated areas approved by the Division Manager. These areas must be clearly marked to indicate that safety toe boots are not required in this area.

All other personnel must wear safety toe boots or shoes when outside the accommodation area unless in designated areas approved by the Division Manager. For ankle protection, safety boots are preferred to shoes.

RESPIRATORY PROTECTION

Appropriate respiratory equipment, as specified on the Material Safety Data Sheet, must be worn for personal protection.

When there is risk of encountering an atmosphere immediately hazardous to health, or an atmosphere below 19.5% oxygen, a positive-pressure type Self Contained Breathing Apparatus (SCBA) or air line respirator equipped with an escape bottle must be worn.

NOTE: Normal oxygen content of air is 20.9% by volume at sea level.

All Company personnel with Emergency Response duties and those whose job requires the periodic use of a full-face SCBA mask or half mask respirator must take an annual fit test using the type of respirator to be worn, according to the manufacturer’s instructions, to ensure an adequate seal is achieved. This test must be documented.

SELF CONTAINED BREATHING APPARATUS

SCBAs and escape packs must be:

Located in appropriate areas and highly visible.

Stored to protect against dust, sunlight, heat, extreme conditions, excessive moisture or damaging chemicals.

Suitable for toxic and oxygen-deficient atmospheres.

Each installation must be equipped with:

12 30-minute SCBAs (positive-pressure type)

6 10-minute escape packs (positive-pressure type)

NOTE: This minimum requirement must be reviewed when working in known H2S areas (See Section 4 Subsection 3.1)

Only experienced persons will perform replacement or repairs of respirators, using parts designed for the respirator.

Replacement or repair of regulators is performed only by the regulator’s manufacturer or their authorized representatives.

Each SCBA bottle must be uniquely identified.

At least two of the Installation’s 30-minute SCBAs must have voice communication capability.

All Company personnel with Emergency Response duties and those who might use facial seal respirator for escape purposes in emergencies must maintain facial hair in such a way that allows a proper facial seal.

Employees are not permitted to wear contact lenses or glasses with temple pieces when using a pressurized full-face respirator.

A system must be in place to record the entry and expected time of exit of personnel using SCBAs in hazardous or oxygen deficient areas.

AIR-FED VISORS AND HOODS

Air used to supply visors, hoods, etc., must be tested prior to use to ensure compliance with Grade D air requirements.

Air used to supply visors, hoods, etc., must continuously meet the requirements of Grade D or higher.

BREATHING AIR COMPRESSORS

Grade D air, or higher, must be used for all breathing apparatus (for example, SCBAs, air line respirators, and so on). The air must be tested monthly and the results recorded in the planned maintenance system.

All breathing air compressors must be equipped with necessary safety devices and be able to be run by emergency power. Compressors must be constructed, designed and located to avoid entry of contaminated air into the system.

Suitable in-line air purifying absorbent beds and filters must be installed to ensure good breathing air quality.

Grade D air meets the following minimum acceptable quality standards as follows:

AIR LINE COUPLINGS

Breathing air line couplings must not be compatible with outlets for other gas systems, to prevent inadvertent attachment of air line respirators with harmful gases or oxygen.

DEDICATED PERSONAL PROTECTIVE EQUIPMENT

PPE must be readily available in required areas of installations and facilities, appropriate for that area and protected from the elements.

Areas requiring that PPE be available include but are not limited to:

Work shops

Chemical mixing areas

Machinery spaces

Moon pool

Rig floor

HAND-ARM VIBRATION (HAV)

HAV is vibration that reaches the hands when working with hand held power tools, hand guided machinery, or when holding materials being processed by machinery.

Regular exposure to HAV can cause a range of permanent injuries to hands and arms, known as hand-arm vibration syndrome (HAVS).

Risk factors contributing to HAVS are:

How high the vibration level is

Duration of exposure

How awkward the equipment is to use

How tight users must grip equipment

Environmental exposure during use (cold weather and rain)

When planning tasks that utilize equipment with potential to cause HAV, the hazards must be identified and the risk reduced. The factors that must be considered include:

Can the task be performed without the use of vibrating tools

Are there tools available with vibration control built in

Control length of exposure by rotating personnel during task

Amount of force exerted on the equipment to complete the task

Condition and maintenance of equipment used

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Dress in a manner that ensures personal safety on Company installations and facilities. This includes wearing and taking care of the appropriate personal protective equipment (PPE).

Inform their supervisor when contact lenses are worn and have a pair of prescription safety glasses available as a backup.

OIM:

Authorize competent personnel to maintain critical PPE.

Ensure all personnel with Emergency Response duties, and those whose job requires the periodic use of a full face SCBA mask or half mask respirator receive an annual fit test using the type of respirator to be worn.

Ensure a system is in place to record the entry and expected time of exit of personnel using SCBAs in hazardous or oxygen deficient areas.

Ensure PPE is available in a sufficient quantity to meet the needs of the personnel.

Ensure people are trained in the use of PPE

DIVISION MANAGER/BUSINESS UNIT OPERATIONS MANAGER:

Approve designated areas that do not require:

Hard hats

Safety glasses

Steel-toe boots or shoes

BUSINESS UNIT VICE PRESIDENT

Ensure adequate resources are made available for Region approved PPE.

Ensure training is available for people in the use of PPE

6 DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

PLANNING

Hydrogen Sulfide

POLICY

Precautions must be taken to ensure early detection of Hydrogen Sulfide gas (H2S) and to ensure contingency plans are in place to safeguard all personnel.

PURPOSE

The purpose of this policy is to protect all personnel on an installation from the potentially lethal effects of H2S gas.

SCOPE

This policy covers all personnel that work on Company installations.

PROCEDURE

H2S is a highly toxic, colorless (transparent) gas that can paralyze the respiratory system and kill within minutes. Being heavier than air, H2S tends to accumulate in lower areas. Mud pit areas are particularly hazardous. If H2S is heated sufficiently, it will rise. H2S has an odor of rotten eggs, but it quickly destroys the sense of smell, leading to a false sense of security. Disappearance of the smell after it has first been noticed may be due to an increase rather than a decrease in concentration.

CONTINGENCY PLAN WHEN H2S IS NOT ANTICIPATED

An H2S contingency plan must be in place and provide clear instructions as to what actions are to be taken in the event of an H2S emergency whether the installation is working at an open location or in close proximity to a fixed platform that may potentially release H2S. In the case of a fixed platform, a contingency plan that outlines the simultaneous operations and associated H2S risks should be developed between the client and the installation.

Adequate fixed H2S detection devices must be located in key areas on the installation, and set to alarm at 5-PPM low level and 10-PPM high level.

Each installation must be equipped with a minimum of two portable H2S gas detectors.

CONTINGENCY PLAN WHEN H2S IS ANTICIPATED IN THE WELL

A H2S contingency plan must be in place and provide clear instructions as to what actions are to be taken in the event of an H2S emergency whether the installation is working at an open location or in close proximity to a fixed platform that may potentially release H2S. In the case of a fixed platform, a contingency plan that outlines the simultaneous operations and associated H2S risks should be developed between the client and the installation.

Adequate fixed H2S detection devices must be located in key areas on the installation, and set to alarm at 5-ppm low level and 10-ppm high level.

Each installation must be equipped with a minimum of two portable H2S gas detectors.

Every person on the installation must be trained to know the dangers of H2S gas, and must be instructed on the use, function, and location of safety equipment before drilling into a zone suspected to contain H2S. (See Section 4 Subsection 1.3)

The client is to ensure, prior to drilling into a zone suspected to contain H2S, that H2S equipment is available onboard (installed and tested), and that all personnel are refresher-trained, know the site specific dangers of H2S related to the well and have been instructed in the proper use of required PPE.

The client must provide adequate resources (fixed and portable PPE, training on the use of PPE, appropriate stand-by vessels, and so on) are allocated and in place before drilling into a zone suspected to contain H2S.

All personnel must be fit tested with all H2S PPE onboard while drilling in a zone suspected to contain H2S.

A HSE Meeting must be held before drilling into a zone suspected to contain H2S. Emergency Response Team members must undergo practical refresher training with

specific focus on the treatment of H2S poisoning.

A sufficient quantity of self-contained breathing apparatuses (SCBAs) must be available for all personnel on board.

If the well plan includes the possibility of working in an H2S environment of 20-ppm or higher, a system capable of supplying sufficient breathing air for extended periods

must be supplied. This system must include provisions for disconnection and escape, such as a cascade system.

Self-contained breathing apparatus or a connection to the cascade system must be worn in concentrations exceeding 20-ppm.

Movement of personnel must be restricted in areas likely to have H2S contamination. Wind direction indicators must be strategically located around the installation.

All personnel must successfully complete a full-faced respirator fit test, according to the manufacturer’s instructions, to ensure an adequate seal is achieved. This test must be documented.

RESPONSIBILITY

ALL PERSONNEL:

Know the dangers of H2S gas and understand the use, function, and location of safety equipment.

Ensure facial hair is maintained in a way to allow a proper seal of the SCBA face mask.

EMERGENCY RESPONSE TEAM MEMBERS:

Have practical refresher training with specific focus on the treatment of H2S poisoning.

OIM:

Ensure an H2S contingency plan is in place and provides clear instructions as to what actions are to be taken in the event of an H2S emergency.

When H2S is anticipated in the well, ensure a sufficient quantity of self- contained breathing apparatuses (SCBAs) is available for all personnel on board.

Ensure inspection and approve client subcontractor equipment prior to installation. (See Section 4 Subsection 2.3)

Ensure emergency drills are conducted as required. (See Section 4 Subsection 3.2)

Assist the client by making accommodation for client subcontractor personnel to install equipment and conduct initial/refresher training on the installation.

RIG MANAGER

Liaise with the client to assist in selection of subcontractor personnel and equipment for use on the installation.

Ensure the plan to be used on the installation is sufficient to provide necessary and reliable protection for all personnel.

Ensure PPE (cascade systems and portable SCBAs) is placed in appropriate areas accessible to personnel and in sufficient quantity to protect the personnel likely to be working or muster there.

DIVISION MANAGER/UNIT OPERATIONS MANAGER

Review the H2S plan to be used on the installation for effectiveness.

DOCUMENTATION

Reference the installation specific Emergency Response Manual.

PLANNING

Emergency Response

POLICY

All installations, facilities and offices must have updated procedures, maintained equipment, and must conduct drills to ensure effective management of emergency response and security.

PURPOSE

The purpose of this policy is to reduce the impact of potential emergencies to human life, the environment, Company property and the Company reputation.

SCOPE

This policy covers Company installations, facilities and offices.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

EMERGENCY RESPONSE MANUALS

Each installation, facility and office must develop and maintain emergency response and recovery plans and procedures for relevant site-specific and area or location emergencies. Emergency Response Manuals must be reviewed annually and updated as required, or if an installation changes location, or geographical area.

NOTE: See HQS-HSE-PR-01 (Emergency Management Procedures Manual) for emergency response procedures and creation of onshore or offshore Emergency Response Manuals.

SECURITY

Each installation, facility, and office must develop and maintain prevention, contingency and security response plans for issues involving security. As a minimum, the Emergency Response manual must include procedures to prevent and mitigate security hazards associated with the following:

Environmental activists

Piracy

Airport reception / journey management

Labor Dispute

Bomb Threat

Extortion

Missing / kidnapped person

Civil disputes

Country evacuation

EMERGENCY RESPONSE DRILLS AND EXERCISES

The following emergency response drills must be conducted on installations at the specified intervals:

At least weekly:

− Fire and Abandon

− Pit Drill and Blowout Drill for each drill crew (recorded on IADC report)

− H2S Drill (if H2S is anticipated)

At least every 90 days:

− Man Overboard

− Environmental Spill

− Search, Rescue and Mock Injury Drill

− Helicopter Emergency Drill

− Ballast Control Drill (not applicable to jack-ups)

− H2S Drill (if H2S is not anticipated)

− Blackout Recovery

Additional drills to address specific risks (for example, shallow gas or well test) must be conducted before beginning the relevant operation.

All drills and exercises must be reviewed on completion to ensure Emergency Response and Recovery Plans are appropriate and updated as required.

The Onshore Emergency Response Team must hold a drill at least every 6 months with at least one installation to test the integration of the Onshore and an Offshore Emergency Response System.

PPE FOR DRILLS AND EXERCISES

All personnel must wear proper clothing for emergency response drills. At minimum, this must include:

long trousers

shirts (long-sleeved recommended)

substantial shoes

The OIM is responsible to ensure that hard hats, safety boots and safety glasses are worn where required to reduce the risk of injury to involved personnel.

NOTE: Shorts, vests (sleeveless shirts), and opened-toed sandals are not allowed.

PERSONNEL ON BOARD (POB)

All installations must have a system in place detailing personnel on board at all times. This system must be updated daily or as changes occur and include the following as a minimum:

arrivals and departures

a total count of all personnel on board

primary and secondary lifeboat assignments for all personnel

RESPONSIBILITY

ALL PERSONNEL:

Be aware of their role and the actions to follow in the event of an emergency.

Wear proper clothing for emergency response drills.

Actively participate during drills and in their review.

OIM:

Ensure effective emergency drills are held within the required time intervals.

Ensure hard hats, safety boots and safety glasses are worn where required during drill and exercise procedures to reduce the risk of injury to involved personnel.

Ensure a system is in place to detail personnel on board at all times.

RIG MANAGER:

Offer initial approval to the Installation Emergency Response Manual and any revision(s) and forward on to the Division Manager and/or Operations Manager for final approval.

ONSHORE EMERGENCY RESPONSE TEAM:

Hold a drill at least every 6 months with at least one installation to test the integration of the Onshore and an Offshore Emergency Response System.

DOCUMENTATION

The Company preferred method for documentation of Emergency Drills is located within the Global Reporting System (GRS). Use of this form within GRS provides an avenue for installation/facility management to review drill execution and track required exercises in a more expedient manner.

The form indicated below is included as an alternate in the event it is not possible to record Emergency Drills within GRS.

Emergency Drill Report (Figure A)

(When completed, retain in the installation or facility files for one year.)

The form indicated below is included in the manual as an example only and is intended to allow operations to take advantage of a preset form rather than having to create their own. Use of this form is not mandatory. However, if the example is not used exactly as included, the form used must include the key elements of the example and must be approved by the Business Unit Vice President.

Emergency Response Exercise Sheet (Figure B)

(When completed, retain in the installation or facility files for one year.)

COMMUNICATION

HSE Information

POLICY

Health, Safety and Environmental (HSE) information must be available to all personnel and appropriately communicated.

PURPOSE

The purpose of this policy is to ensure that all personnel are adequately informed of HSE issues, improving awareness and HSE performance.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

HSE information must be distributed to all installations and facilities and made available to all personnel. Relevant HSE information must be translated and printed in the predominant local language.

All relevant personnel must discuss HSE information at various departmental or installation and facility HSE meetings.

MONTHLY INCIDENT RATE CHART

Corporate HSE Services must provide a Monthly Incident Rate Chart to all Company installations and facilities.

The Monthly Incident Rate Chart provides a statistical comparison within the Company.

The incident rate will be a Year-to-Date and 12-month rolling recordable rate.

After receiving the Monthly Incident Rate Chart, crew supervisors must study and review the chart with their crew during their next Weekly Departmental HSE Meeting.

The Monthly Incident Rate Chart must be posted for personnel to review

SERIOUS INCIDENT BULLETINS

At the discretion of the Unit QHSE department, bulletins are issued to inform all personnel of serious incidents. All personnel should review the bulletins, which contain only factual information based on the related incident report. Incidents resulting in a potential severity of seven or greater should be considered for a bulletin. (See Section 4 Subsection 6.3 for assignment of severity value) Serious Incident Bulletins may be followed by an HSE Alert.

HSE ALERTS

HSE Alerts provide immediate notification of critical information and actions to address an incident or situation which represents a clear and present hazard to people, environment or property.

Corporate HSE Alerts are developed and issued to advise all personnel of an immediate danger. An alert must be immediately distributed to all installations and facilities and urgently acted upon.

HSE Alerts must be developed from facts gathered during the fact-finding of the incident.

All HSE Alerts issued by Unit management must be submitted to Corporate HSE Services for consideration for global application. Only Corporate HSE Services issues/distributes HSE Alerts globally.

Crewmembers must review the alert and discuss corrective and preventive actions that might be taken to prevent a similar situation from occurring on their installation or facility.

The OIM must use the FOCUS Improvement Process to confirm that appropriate action has been taken to cover the risk identified by the alert. The alert must be posted on the QHSE bulletin board and files a copy in a permanent reading file/binder for future reference and review.

HSE Alerts are “Non-Discretionary sources of opportunities” that the Company has identified as being important and/or critical to performance and require the use of the FOCUS Planning and Tracking Software to ensure action points which result from a corrective or improvement opportunity are effectively planned and tracked.

HSE BULLETINS

HSE Bulletins provide specific or general information related to a particular subject, situation or incident deemed of important value to inform and raise people’s awareness.

HSE ADVISORIES

HSE Advisories provide specific information to improve the understanding of an existing requirement or process through further explanation and clarification, or to communicate a new requirement deemed of critical value to be implemented and complied with.

HSE Bulletins and Advisories are “Discretionary sources of opportunity” that require managers and supervisors to decide if the FOCUS Planning and Tracking Software should be used to ensure action points which result from a corrective or improvement opportunity are effectively planned and tracked.

HSE SIGNS

All installations and facilities must use internationally recognized pictogram signs, according to the Company safety signs standard, to convey HSE critical information, such as PPE requirements, hazards, escape routes, emergency equipment, etc.

Where words are required to ensure understanding of a hazard/situation, they must be in both English and the predominant local language.

Temporary barriers for specific hazards must be erected when needed and clearly identified, then removed after the area is safe.

HAZARD MAPPING

Areas where restrictions on access or equipment apply must be mapped and the map must be available on all installations and facilities. Examples include high noise areas, ignition source zones (explosion-proof equipment only), lighting, authorized personnel only, and so on.

QHSE BULLETIN BOARD

All installations and facilities must have and maintain an up-to-date QHSE bulletin board that is accessible to all personnel.

ORGANIZATION CHART

All installations must have an organizational chart showing the OIM and the management/supervisory team. The chart must be accessible by all personnel.

DAILY COMMUNICATIONS

Each installation must have an effective system in place that ensures critical information is communicated in writing and understood throughout the working day. This must include reference to Operations Manual, Permit to Work, isolations, restricted areas, other work on the installation, and so on. These daily communications must include:

Standing Instructions for Drillers

Standing Instructions for Crane Operators

Formal shift hand-over report/logbook for all supervisors, issued at each shift change

FEEDBACK

Personnel are encouraged to provide effective feedback and corrective opportunities concerning any HSE aspects, using the QHSE Feedback form.

RESPONSIBILITY

ALL PERSONNEL:

Review Serious Incident Bulletins.

Review the HSE Alerts and discuss contributing factors and steps that might be taken to prevent a similar situation from occurring on their installation or facility.

SUPERVISORS:

Study and review the Monthly Incident Rate Chart with their crew during the next Weekly Departmental HSE Meeting.

OIM:

Ensure the Monthly Incident Rate Chart is posted for personnel to review.

Use the FOCUS Improvement Process to confirm that appropriate action has been taken to cover the risk identified by HSE Alerts.

Ensure relevant HSE Alerts are posted on the QHSE bulletin board and a copy filed in a permanent reading file/binder for future reference and review.

Ensure an effective system is in place that ensures critical information is communicated and understood throughout the working day.

Ensure an organizational chart showing the OIM and the management / supervisory team is accessible by all personnel.

DIVISION MANAGER:

Ensure HSE information is distributed to all installations and facilities, made available to all personnel translated and printed in the predominant local language.

BUSINESS UNIT QHSE MANAGER:

Issue Unit Serious Incident Bulletins.

Issue Unit HSE Alerts.

Ensure safety posters, HSE improvement campaigns, galley readers, videos, newsletters, and so on, are available to all installations and facilities on a periodic basis.

CORPORATE HSE DEPARTMENT:

Provide a Monthly Incident Rate Chart to all Company installations and facilities.

Review HSE Alerts drafted by Unit management for global consideration.

Issue Corporate HSE Alerts.

DOCUMENTATION

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President.

HSE Alert (Figure A1)

(Must be available to all personnel for their review.)

(A Template for Unit HSE Alerts is available from Corporate HSE Services.)

HSE Bulletin (Figure A2)

(Must be available to all personnel for their review.)

(A Template for Unit HSE Bulletins is available from Corporate HSE Services.)

HSE Advisory (Figure A3)

(Must be available to all personnel for their review.)

(A Template for Unit HSE Advisories is available from Corporate HSE Services.)

HSE Pictogram Signs (Figure B)

(Must be available to all personnel for their use.)

Standing Instructions to Drillers (Figure C) (File and retain completed forms for 90 days)

Standing Instructions to Crane Operators (Figure D) (File and retain completed forms for 90 days.)

Shift Hand-Over Report (Figure E)

(File and retain completed forms for 90 days.)

QHSE Feedback (Figure F)

(Must be available to all personnel for their use.)

COMMUNICATION

HSE Meetings

POLICY

Company personnel, client personnel and all subcontractor personnel must attend and participate in relevant HSE meetings as determined by the OIM.

PURPOSE

The purpose of holding effective HSE meetings is to:

Recognize proactive HSE performance.

Provide an opportunity for crews to discuss, understand and apply Company HSE processes and procedures for conducting tasks and identifying hazards and potential risks.

Increase awareness and motivate crewmembers by reviewing and learning from incidents and HSE information.

SCOPE

This policy covers all personnel that work at any Company installation or facility.

PROCEDURE

MEETINGS

Effective HSE meetings must be conducted in a positive manner to motivate proactive HSE performance among crewmembers.

Effective HSE meetings:

Follow a prepared agenda.

Are of sufficient duration.

Include clear and thorough discussion so attendees understand the issues.

Encourage active participation by attendees.

All HSE meetings must be documented and attendance sheets signed by all personnel attending. The OIM and Rig Manager must review and sign each meeting report and ensure appropriate action identified in the meeting is addressed using the FOCUS Improvement Process. Depending on the resources required to implement the improvement/corrective opportunity, utilization of the FOCUS tracking software may also be required.

The documented meeting report must be available for review by all personnel and a copy kept on file.

WEEKLY DEPARTMENTAL HSE MEETINGS

Crew supervisors are responsible for ensuring that effective HSE meetings are conducted.

Department heads are responsible to ensure that all personnel within their department attend at least one departmental HSE meeting per week. These meetings can be conducted with another department. It is both department heads’ responsibility to ensure that the joint meeting is effective for all attending personnel. Company subcontractors must attend and participate in relevant HSE meetings.

Client and all client subcontractor personnel must be strongly encouraged to participate in relevant HSE meetings.

The primary purpose of these meetings is to discuss the various planning, monitoring, corrective and improvement processes (THINK, START and FOCUS) used throughout the Company, how they apply, and are used. Additional topics include reviewing and discussing how other HSE information, internal or external, could apply to the department.

The list below suggests topics that should be discussed during meetings:

Welcoming new crewmembers.

Announcing individual HSE performance and recognition.

Teaching the THINK and START process (individually and together) (Management of Change) and FOCUS process as well as the complete HSE system in an organized manner.

Reviewing THINK plans, START observations and status of FOCUS

improvement and corrective opportunities.

Reviewing HSE Alerts and Advisories.

Demonstrating the correct use of tools and equipment.

Identifying hazards.

Discussing recent near hits and incidents.

Reviewing the Monthly Incident Rate Chart.

GENERAL HSE MEETINGS

The OIM must give full consideration to conducting a general HSE meeting on a periodic basis. General HSE meetings must be used for issues that apply to all personnel, such as HSE performance recognition, incident status (Unit, Division, Sector, Branch, installation or facility), and significant change to normal routines.

PRE-TOUR MEETINGS

Pre-tour meetings must be part of the hand-over process to ensure that all personnel starting work are aware of the current operation and their particular responsibilities.

PRE-TASK MEETINGS

Specific meetings must be held prior to certain tasks being conducted. The formality and content of the meetings depends on the exact nature of the task to be conducted. The person who has direct operational responsibility for the proposed operation must ensure that an effective pre-task meeting is conducted.

For more complex or non-routine operations (for example, spud, rig move or well test), a suitable meeting format must be adopted.

DAILY OPERATION MEETING

All department heads or their designees, together with the OIM, must attend a joint, daily operation meeting, to discuss each department’s plans for the next 24 hours.

Specific attention must be paid to the potential impact of interacting departments, with the intent of reducing any risk involved. Additional topics may include previous 24 hours START observations and action plans for corrective actions (FOCUS), any incidents in the previous 24 hours and an operational look ahead. The OIM is responsible for conducting this meeting.

QHSE STEERING COMMITTEE MEETINGS

Unit, Division, Sector, facility, and Corporate QHSE Steering Committee Meetings must be conducted at least twice a year. Installation QHSE Steering Committee Meetings must be conducted at specific times so that each crew has the opportunity to attend a meeting per year. Annual HSE goals must be reviewed during Corporate, Unit, Division, Sector, Branch installation and facility QHSE Steering Committee Meetings to determine HSE performance gaps and identify improvement/corrective opportunities (if any) to be addressed.

Current QHSE Steering Committee meeting minutes must be posted on the QHSE bulletin board.

All other aspects of QHSE Steering Committees are addressed in the Organization and Responsibility section. (See Section 2 Subsection 2)

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Attend and participate in relevant HSE meetings.

SUPERVISORS:

Ensure effective HSE meetings are conducted.

DEPARTMENT HEADS:

Ensure all personnel within their department attend at least one HSE meeting per week.

Attend a joint daily operation meeting with the OIM.

COMPANY SUBCONTRACTORS:

Attend and participate in relevant HSE meetings.

OIM:

Encourage Client and all client subcontractor personnel to participate in relevant HSE meetings.

Review and validate (within GRS) each meeting report and ensure appropriate action identified in the meeting is addressed using the FOCUS improvement process.

Give full consideration to conducting a general HSE meeting on a periodic basis.

Conduct the Daily Operation meeting.

Conduct QHSE Steering Committee Meetings at specified intervals

RIG MANAGER:

Review and validate (within GRS) each meeting report and ensure appropriate action identified in the meeting is addressed using the FOCUS improvement process.

DIVISION MANAGER:

Conduct QHSE Steering Committee Meetings at specified intervals.

BUSINESS UNIT VICE PRESIDENT:

Conduct QHSE Steering Committee Meetings at specified intervals.

CORPORATE QHSE DEPARTMENT:

Conduct QHSE Steering Committee Meetings at specified intervals.

6 DOCUMENTATION

The Company preferred method for documentation of HSE Meetings is located within the Global Reporting System (GRS). Use of this form within GRS provides an avenue for installation/facility management to review meeting content and offer feedback in a more expedient manner. HSE meetings must be forwarded to installation management for review and feedback.

The form indicated below is included as an alternate in the event it is not possible to record HSE Meetings within GRS.

HSE Meeting Report (Figure A)

(Must be retained in installation or facility files for a minimum of three years.)

IMPLEMENTING AND MONITORING

START Process

POLICY

The START Process must be used to observe and monitor work practices, plans and workplace conditions.

PURPOSE

The purpose of this policy is to:

Empower employees to observe tasks and work areas and look for safe and at-risk/unsafe behaviors and safe and unsafe conditions.

Empower employees to monitor themselves and others to ensure the safe execution of a plan by interrupting and correcting at-risk/unsafe behaviors, unsafe conditions and unplanned changes.

Increase personnel’s ability to recognize and respond to hazards.

Reinforce observed or monitored safe behavior through effective feedback.

Interrupt operations when unplanned change is recognized.

Promote accountability for maintaining a safe workplace.

Obtain commitment among co-workers to repeat safe behavior.

Provide supervisors with feedback on trends in safety behavior.

SCOPE

This policy covers all Company personnel, regardless of position.

Any client, subcontractor or client subcontractor that works at any Company installation, facility or office must be encouraged to take an active part in the process.

PROCEDURE

The START process must be actively led by all supervisors and supported by all Company personnel.

All Company personnel are responsible for their own safety and behavior. All Company personnel are obligated to interrupt any unsafe operation and correct any at-risk/unsafe behavior or unsafe condition.

Proper implementation of the START process by all personnel provides an effective method of preventing injuries, safeguarding equipment and avoiding operational exposures by all personnel.

GENERAL

START PROCESS

SEE with total focus and observe for safe and at-risk/unsafe behavior and conditions. Recognize safe behavior and reinforce it with effective feedback, treating each person on an individual basis. Correct at-risk/unsafe behavior and conditions immediately, in a constructive manner. Understand the colors of the person you are relating to and treat them as THEY NEED to be treated.

THINK about what you see. Think "what if?" to anticipate and recognize change. What can happen as a result of the change, condition or inaction you are observing? Think what to say. The success of your message is determined by how it is spoken.

ACT to monitor and observe safe and at-risk/unsafe behavior as well as unsafe conditions. Anticipate and recognize change and immediately interrupt the task to evaluate the change to either correct the condition/behavior or revise the plan. If a person is working in an at-risk/unsafe manner, immediately interrupt the task and correct the behavior. Failing to take action means that you condone the unsafe condition or at-risk/unsafe behavior.

REINFORCE safe behavior with specific effective feedback to encourage continued safe behavior and raise awareness of at-risk/unsafe behavior and unsafe conditions. Communicate corrective and improvement opportunities with effective feedback to encourage change. Remember, when giving feedback, be specific.

TRACK results of observations through active participation by all personnel. Tracking is sharing and communicating observations with people on a daily basis to reinforce a safe workplace and raise people’s awareness of where to focus their efforts and proactive measures.

THE START PROCESS IS USED TO PERFORM OBSERVATIONS AND FEEDBACK.

Observations can be performed on an individual (or individuals engaged in performing the same task) or conditions. Performing an observation on an individual does not necessarily require specific knowledge and responsibility of the task being performed. The individual performing the observation makes the commitment to

identify safe conditions and safe behavior and/or interrupt the operation to act on an unsafe condition or at-risk/unsafe behavior.

For people to provide effective feedback to one another requires they actively care about each other’s safety. Effective feedback requires that people recognize and re- enforce safe behavior at every opportunity and interrupt/correct at-risk/unsafe behavior immediately.

THE START PROCESS IS USED TO MONITOR THINK PLANS.

Monitoring a THINK plan is when an individual or group has knowledge and understanding of a plan, and makes the commitment to continually assess the plan in progress. The purpose of monitoring plans is to recognize any change or deviation from the plan. The resulting consequences of not recognizing a change or deviation from the plan can be one or more of the following:

An unsafe condition

An at-risk/unsafe behavior

A missed opportunity to interrupt

An incident (Near Hit, Serious Near Hit, Personnel Injury, Environmental Damage, Property Damage)

All personnel must continually monitor their THINK plans and work conditions using the START Process.

START OBSERVATION TRAINING

All Company personnel must be trained in the performance of START observations. Effective understanding of the process cannot be accomplished from employee-computer interface. Supervisors must utilize the information from the DVD to coach, mentor and monitor the effectiveness of their employees’ observation and monitoring techniques. (See Section 4 Subsection 1.3)

The quality of START observations is enhanced by performing them daily using the

START Card.

Supervisors should perform joint observations with non-supervisory personnel or subcontractor personnel to assist their development and understanding of the proper START observation and feedback techniques.

START CARD

Supervisors must ensure that they and their personnel perform START observations and record them on START Cards.

START OBSERVATION TRACKING

The OIM must ensure an effective system is in place to:

provide personal oversight of START participation by personnel,

track, communicate, trend START observations and,

act upon the results of observations as needed.

Effective START Observation tracking consists of the following:

Review and communication of observations by personnel, supervisors and onboard management. (Review in pre-tour, pre-task, departmental and morning meetings.)

Establish trends of observations for safe behavior, at-risk/unsafe behavior, and safe and unsafe conditions in the workplace (what, where, when).

The Management of Change process must be used for improvement or corrective opportunities created from trending results (see Section 1 Subsection 4). Refer to FOCUS Improvement Process (Section 4 Subsection 6.2) to determine if utilization of the FOCUS tracking software is necessary.

START MONITORING

START monitoring is an essential part of the execution of any THINK Plan. It must be continuously performed. START monitoring is performed by an individual on their Individual THINK Plan, or performed by a group of individuals on the group’s THINK plan. START monitoring the execution of a plan is another method of tracking.

Anticipation and recognition of change is accomplished by continuous START monitoring of the plan using personal experience and knowledge of the plan to evaluate what could potentially change or cause deviation from the plan.

START monitoring can only be performed by individuals that have a thorough understanding of the plan. To monitor effectively, continuous evaluation of a plan

must be performed to compare what is actually seen, heard and experienced versus what is planned to be seen, heard or experienced.

START monitoring provides the opportunity to recognize change or deviation from the plan that has occurred or could occur. Anticipation or recognition of a change provides the opportunity to interrupt the task and assess the change to control any new risks.

Effective START monitoring must be performed during the execution of a THINK

plan and includes continuously asking yourself:

Is the plan still good for the task at hand?

Are the tools and PPE still suitable for the task at hand?

Are the risks still the same as identified in the plan?

Are more or fewer people involved in the task?

Are all people involved or affected by the plan informed?

Do I know what will happen next?

START TOURS

Supervisors must perform periodic dedicated START observation tours. This is accomplished by making rounds for the specific purpose of conducting observations. START tours may also be conducted with non-supervisory personnel or subcontractor personnel for training purposes.

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Participate by personally performing START observations daily.

Are responsible to help achieve an incident-free workplace by interrupting any unsafe operation and correcting any unsafe behavior or conditions.

Immediately report any observed unsafe condition to a supervisor if it cannot be made safe.

Continually monitor THINK plans and work conditions using the START

Process.

Develop and improve observation skills through practice and participation.

SUPERVISORS:

Actively participate in START observations and monitoring.

Review trends to identify potential proactive efforts.

Ensure their personnel are trained to perform START observations and monitoring.

Review START Cards submitted by their personnel daily.

Conduct periodic dedicated START observation tours.

Participate with their people to ensure they are performing START

Observations correctly.

Make clear their expectations regarding safe behavior and safe conditions.

Not to tolerate repetitive at-risk/unsafe behaviors by people and always take the appropriate action to correct.

OIM:

Ensure an effective system is in place for tracking, communicating and trending START observations.

Review observation trends and ensure appropriate proactive measures are implemented if necessary.

Lead interdepartmental START observations.

Lead clients, subcontractors and client subcontractors to actively participate in START observations and monitoring.

Ensure systems are in place to review and communicate observations by personnel, supervisors and onboard management.

Hold supervisors accountable for their participation, and that of their people, in START observations and monitoring.

Actively recognize personnel’s proactive efforts in START observations and monitoring (quality cards, participation, consistency of observations).

Make clear their expectations regarding safe behavior and safe conditions.

Ensure that at risk/unsafe behavior by people is not tolerated and always take the appropriate action to correct.

RIG MANAGER

Ensure active participation in the START Process by all personnel.

Personally lead START observations.

Conduct dedicated START observations tours during installation visits.

Carry out START observations with supervisors during installation visits to evaluate the supervisor’s effectiveness in START observations and monitoring.

Review observation trends, ensure appropriate proactive measures are implemented, and suitable resources are provided.

BUSINESS UNIT VICE PRESIDENT AND OPERATIONS MANAGER

Personally lead START observations.

Conduct dedicated START observations tours during installation visits.

Carry out START observations with supervisors during installation visits to evaluate the supervisor’s effectiveness in START observations and monitoring.

Ensure suitable resources are provided to implement proactive measures.

6 DOCUMENTATION

The form indicated below is included in the manual and is not to be modified from its original format. The form has been developed by Corporate HSE Services and is a requirement of this policy. The form must be reproduced and made available to all installations/facilities by their Division/Business Unit offices. Forward any suggested improvements to the START Card using the HSE Feedback form.

START Card (Figure A)

(Must be retained until the information is entered into the tracking system.)

The START Card can be used to facilitate individual and verbal THINK Plan development at the worksite. The card can be used as a checklist for identifying potential hazards during the job planning stages.

The START Card provides a convenient method to capture the initial details of a Near Hit by using the categories on the card that are relevant to the event. These details are transferred to the Incident Report for formal reporting.

Figure A, START Card

IMPLEMENTING AND MONITORING

Travel

POLICY

Effective means for the safe transport of personnel to and from Company installations or facilities must be in place.

When traveling in Company vehicles, personnel are responsible for driving or riding safely.

PURPOSE

The purpose of this policy is to reduce the risk of injury to any person and prevent other incidents while traveling.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation.

PROCEDURE

4.1 TRAVEL SAFETY BRIEFING

All personnel should be given a travel safety briefing within 24 hours before traveling to any installation.

All personnel must be given a travel safety briefing within 24 hours prior to departing from any installation, covering all safety requirements specific to the mode of transportation.

A Company person designated by the OIM must coordinate the movement of personnel arriving or departing the installation.

Rules and instructions issued by the helicopter/boat contractor or operator must be followed.

HELICOPTER TRAVEL

During helicopter flights over water, life jackets must be worn unless specific circumstances dictate otherwise (for example, injury or local legislation).

During all helicopter flights, seat belts and hearing protection must be worn and smoking instructions adhered to. Passengers and helideck crew must wear hearing protection when approaching or departing helicopters if helicopter engines are running.

Passengers must exit the helicopter before refueling unless otherwise authorized by the pilot.

Lightweight or loose articles must be held firmly to prevent them from being sucked into engine intakes or rotor blades.

When transporting long items in the area of a helicopter, they must be carried horizontally to prevent contact with rotor blades.

HELICOPTER OPERATIONS

All Company personnel who travel to or from Company offshore installations by helicopter must be briefed before each flight. They must also view the Emergency Helicopter Abandonment Video. Business Unit management is responsible for determining the interval frequency for viewing the video based on local environmental and operational conditions. (See Section 4 Subsection 1.3)

A Helicopter Landing Officer (HLO) must be trained by a Company approved instructor and designated by the OIM.

All activities on the helicopter deck, including loading or unloading of passengers and baggage, must be directed by the HLO.

The HLO must ensure that a fireman dressed in full protective gear is positioned at a safe distance from the helideck but close enough to man firefighting equipment and perform entry rescue if necessary. The fireman must maintain a safe distance until the helicopter makes its landing.

The HLO must ensure the fireman has no other duties while so assigned

During helicopter operations, crane booms must be positioned so that there is no possibility of interference with the helicopter, and the crane operator must not be in the crane cab. If simultaneous crane and helicopter operations are planned, permission must be received from the helicopter pilot to allow the crane operations to continue.

The standby boat, if available, must be notified in advance of arrival or departure of a helicopter and must be in close attendance to the installation until the helicopter operation is complete.

In all cases, the helicopter company or client must inform the installation of the helicopter’s arrival with sufficient notice to allow mobilization and readiness of the standby boat and helideck crew.

The HLO must ensure the helideck is ready for helicopter operations prior to arrival, including the following minimum aspects:

Helideck equipment is verified as operational.

Helideck is cleared of all loose material.

Helideck crew wears suitable and secure PPE.

Personnel must only disembark or approach the helicopter under the direction of the HLO after clearance from the pilot.

Under no circumstance can personnel approach the tail rotor.

Only designated helideck crewmembers are permitted to load and unload baggage to and from the helicopter.

The installation radio operator and pilot must establish and maintain communication with the helicopter throughout the operation.

Helicopter manifests must contain the following information at minimum:

Number of passengers

Names of passengers

Weight of passengers, baggage and cargo

Helicopter identification number

During refueling, the helicopter must be grounded to the installation and fire-fighting equipment on the helideck manned.

BOAT OPERATIONS/USE OF PERSONNEL TRANSFER BASKET

Life jackets must be available for all Company personnel traveling by boat.

Transfer of personnel between installations and boats must be done only with an approved personnel transfer device (for example, personnel basket or Frog). The OIM or designee must approve transfers only after considering natural light conditions, the wind, sea condition, motion of the installation relative to the boat, available landing area on the boat deck, experience of the crane operator and crewmembers being transferred.

The number of personnel on the basket at any time must not exceed the manufacturer’s specified maximum.

Personnel must wear life jackets or other personal flotation devices during transfer. Landing areas at both ends of the transfer must be adequately sized and illuminated.

Radio communications must be established and maintained between the installation crane operator and the banksman on the boat or quayside.

A tag line must be used on the personnel basket.

Any person sick, suffering vertigo or injured must not be allowed to ride the basket, unless placed inside and escorted by an experienced crewmember.

No cargo except personal luggage may be transferred with the personnel basket. Luggage must be placed in the middle of the basket and cannot be held by personnel during transfer.

The basket must be kept over water as much as possible during the transfer.

One transfer basket must be available for use at all times. The basket must be regularly inspected, certified and recorded in the lifting gear register, in addition to being visually inspected immediately prior to each use.

The standby boat, if available, must be in close proximity to the installation until the transfer operation is complete.

Prior to boarding a personnel basket, personnel must receive instruction in the proper use of the basket from a person authorized by the OIM.

COMPANY VEHICLES

Company vehicles are described as those owned by the Company or on long-term lease (over one month) for use on public roads.

Company vehicles must only be driven by approved persons holding a valid driving license for the class of vehicle recognized by the local authority, and operated according to local traffic laws.

Driving Company vehicles while impaired by any means is prohibited. This includes driving a personal vehicle while on Company business, as well as a short-term lease (less than one month) or Company vehicle. For impairment see Section 4 Subsection 5.8. For drugs and alcohol see Section 4 Subsection 1.2.

Company vehicles must be inspected and properly maintained in a road-worthy condition. Any unsafe condition found during inspection must be rectified as soon as possible.

The driver and all occupants in Company vehicles must wear seat belts.

Each Division must make available defensive driver training appropriate for the local conditions. This should be supported with a “hands-on” driving assessment for all new drivers. (See Section 4 Subsection 1.3)

All personnel driving Company vehicles must receive defensive driver training appropriate for the local conditions.

The use of an in vehicle monitoring system or vehicle data recorder should be considered for all long-term contract or company owned multi-passenger vehicles used for the purpose of transporting company personnel. Consideration must be given to appropriate route, appropriate time of day to travel, and number of round trips required.

Company personnel, as well as Company contractor personnel, transporting Company personnel are responsible for safe driving practices. If passengers observe unsafe driving practices, they have the obligation to request the driver to stop the vehicle.

The use of cellular phones while driving any vehicle on Company business is prohibited unless the phone is used with a “hands free” device, providing this does not violate local law. Persons should pull over and park the vehicle safely before holding telephone conversations.

Company personnel must use the THINK planning process prior to driving in Company vehicles.

The following should be considered:

Is the trip necessary right now?

Is the journey too long to finish safely without stopping?

Is the driver suffering from fatigue?

Is public transportation a viable option?

Is weather a factor?

Is the vehicle equipped with area-appropriate emergency supplies?

Is car-pooling possible?

The number of passengers must not exceed the manufacturer’s design/specification for the vehicle.

All loads must be secure and not exceed the manufacturer’s design/specification for the vehicle.

The combination of passengers and load or cargo must be safe even if they do not exceed the manufacturer’s design/specifications for the vehicle.

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Receive instruction in the proper use of a personnel basket prior to utilizing it.

Manage all aspects of the transportation process within their control to identify hazards, reduce risk and eliminate unnecessary exposure.

Wear a seatbelt while in Company vehicles.

Receive driver training appropriate for local conditions prior to driving Company vehicles.

Report all unsafe acts of pilots/drivers/captain while transporting Company personnel.

Report poorly maintained, company, client or contractor supplied modes of transport.

Receive briefing appropriate to mode of travel prior to travel to/from Company installations.

View Helicopter Safety DVD-ROM at required intervals.

HLO:

Be certified as HLO by Company approved instructor prior to performing as HLO.

Direct all activities on the helicopter deck, including loading or unloading of passengers and baggage.

Ensure a fireman dressed in full protective gear is positioned safely near the helideck to man firefighting equipment or perform entry rescue if necessary.

Ensure fireman has no other duties while assigned to the helideck duties.

Ensure the helideck is ready for helicopter operations prior to arrival.

OIM:

Ensure Helicopter Safety DVD-ROM is watched at intervals determined by the Business Unit Vice President.

Designate a Helicopter Landing Officer (HLO) to coordinate the movement of personnel arriving or departing the installation.

Approve boat transfers of personnel only after considering the relevant safety factors described in the procedure.

Ensure all personnel are given a travel safety briefing within 24 hours prior to departing from any installation, covering all safety requirements specific to the mode of transportation.

Authorize personnel to give instruction in the proper use of the basket.

DIVISION/SECTOR HSE MANAGER

Approve content of Helicopter/Travel safety briefing.

Make available defensive driver training appropriate for the local conditions.

BUSINESS UNIT VICE PRESIDENT:

Determine the interval frequency for viewing Helicopter Safety DVD-ROM based on local environmental and operational conditions.

6 DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

IMPLEMENTING AND MONITORING

General Safe Work Practices

A system for designating areas of responsibility for housekeeping must be put in place for each installation and facility.

All work areas on the installation or at the facility must be maintained in a way that provides a safe and organized working environment.

Floors, steps, stairs and walkways must be kept clean and free from slippery substances, tripping hazards or other obstructions to the best extent possible.

Non-slip surfaces must be maintained in good condition and free of oil and mud to the best extent possible.

Adequate measures to prevent spills and leaks from becoming hazards must be put in place (for example, drip trays, splash guards, sight glass isolations, drain plugs, and so forth).

Special attention must be paid to drill-floor housekeeping during periods of high activity, such as tripping tubulars and casing operations.

Slips, protectors, tools, and so on should be promptly and properly stored and not allowed to accumulate around the work area.

Soiled cleaning materials, scrap and waste must be placed in designated containers for proper disposal.

LIGHTING

Lighting systems shall provide a sufficient level of illumination in all work areas. All light lenses must be kept clean and maintained.

All escape routes, embarkation areas and any emergency control panels shall have the ability to be supplied by an emergency power source in the event of loss of normal power.

DECK MANAGEMENT

Escape routes and access to safety equipment must be clearly identified and must not be restricted in any way, unless alternative plans are in place.

Cargo handling material such as slings, shackles, and so on must be stored in designated areas.

All deck cargo must be stored in a manner to prevent movement caused by adverse weather conditions and/or vessel motion.

All loose items of deck cargo must be located in areas where deck loading limitations are not exceeded.

“Lever” or “Breakover” style chain binders must not be used by Company personnel or used to secure Company owned equipment. If these type binders are used to secure subcontractor equipment they must be fitted or removed by a representative of the company that is responsible for the equipment. If it is not possible for a subcontractor representative to fit/remove the binder, a supervisor such as a Crane Operator or Deck Foreman must perform the task.

If a binding device is needed, ratchet style load binders, turnbuckles, or ratchet style tie down straps must be used by Company personnel to secure Company owned equipment.

SAFE BEHAVIOR

Horseplay is not permitted at any installation, facility, or office at any time. Recreational swimming and diving from installations is prohibited. Recreational fishing is not permitted from any installation or facility. Handrails must be used when ascending or descending stairs.

SAFE WORKING LIMITS

The manufacturer's stated safe working limit for any piece of equipment or system must not be exceeded. Safeguards or procedures must be present to prevent exceeding these limits. The equipment must be maintained in such a manner to allow operation up to the safe working limit. When exceptional circumstances

prevent equipment from being maintained in a manner that allows operation up to the safe working limit, temporary controls must be put in place, such as removing the equipment from service or reducing limit levels.

When continuous operation of equipment approaching the stated safe working limit is required, consideration must be given to additional safety measures to be taken in case of equipment failure. This could include guards, barriers or restrictions to personnel being put in place, or simply ensuring that all personnel are aware of the increased hazard of equipment approaching its operational limit.

SAFE TRIPPING OF TUBULARS

The derrick racking board and the rotary table must be visible to the driller either by direct line of sight or by remote camera.

The derrick racking board must be equipped with mechanical means to assist in moving tubulars.

Tubulars must be secured at the derrick racking board level immediately after being racked.

An effective procedure for drifting tubulars in the mast/derrick must be used to ensure that drifting operations are conducted safely.

Dumbbell type safety handles must be fitted on all manual tongs including extension jaws for casing and BHAs, as well as spares held onboard.

Industry recognized pinch points will be painted yellow and black, safe handholds will be painted green.

Web handles should be used to maneuver power tongs on and off tubulars. Personnel must stay clear of tong lines and chains while tension is being applied for

makeup or break out of tubulars.

BHA components must not be allowed to fall over after being removed from the drill string.

Formation accumulation and safety clamps must be removed from tool joints and/or BHA components before being hoisted into the mast/derrick.

Hands or feet must not be placed below the core barrel opening while recovering cores.

MANUAL TONG SNUB LINES

Snub lines must be:

Ordered for the specific application for which they are to be used (fit for purpose).

Marked with length of line and SWL.

Spares maintained in a secure environment to preserve condition with suitable controls in place for issuance, use, and re-ordering.

WIRELINE OPERATIONS

During wireline operations, the drill floor, wireline unit and any areas between the two where the wireline is in tension must be designated as restricted areas.

Prior to start of wireline operations, a THINK plan meeting must be held with relevant installation and subcontractor personnel.

Public address announcements must be made at the start, as necessary during and at the completion of wireline operations.

Fluid levels in the well bore must be monitored throughout the wireline operation. Communications must be established, tested, and maintained between the wireline

unit and the drill floor.

DROPPED OBJECTS

Derricks, masts, crane booms and any area where there is a potential of dropped objects must be inspected at regular intervals to ensure that objects are adequately secured with safety lines or that a secondary means of securing is in place to prevent any objects from falling. Surplus or redundant equipment must be removed.

Storage shelves must be designed to prevent objects from falling.

DROPPED OBJECTS PREVENTION SCHEME (DROPS)

The Company required dropped objects prevention program is “Dropped Objects Prevention Scheme” (DROPS). The Dropped Objects Prevention Scheme (DROPS) is available via the internet at http://www.dropsonline.org/

The Dropped Objects Prevention Scheme contains the following criteria:

Dropped objects awareness campaign

Dropped objects inventory register

Removal of redundant and non-essential equipment identified in the “Dropped Objects Inventory Register”

Risk Assessment of equipment in areas listed in “Dropped Objects Inventory Register”

Record of risk-reducing controls (preventive and mitigating)

Inspection routine

The inspection procedures and routine must be included in the installation’s planned maintenance system

The Dropped Objects Inventory Register must include but is not limited to the following areas and related equipment:

Derrick and Substructure

− Crown and water table

− Monkey board

− Traveling equipment

− Drill floor and mezzanine deck

− Lower substructure and BOP area

BOP and Tubular Handling Equipment

− Pipe racking system (PRS)

− Pipe handling system

− Top drive

− Pick Up/Lay down machines

− BOP Crane

− Drill floor hoists

− Iron roughneck

DROPS assessments must be completed every three years by an independent assessor. The medium and high priority action items identified by DROPS assessments must be entered into FOCUS.

Medium and high priority deficiencies from regular DROPS maintenance tasks must be entered into FOCUS.

WORKING WITH TOOLS AND EQUIPMENT AT HEIGHT

The following must be adhered to when working with tools at height:

During the THINK planning stage preventative and mitigating controls for dropped objects must be developed.

All tools and equipment used at height must be adequately secured to either the user or the workplace.

Tools must provide a lanyard attachment point that still enables the tool to be used effectively.

Sockets and extensions must be “locked-on” to ratchets.

Tools taken aloft must be secured in a tool bag or on tool belt with the bag or belt attached to the user and the tools attached to the bag or belt.

Items must not be loosely carried in pockets where there is the possibility of them falling out (for example; tally books, pens, keys, tape measures, and so on).

Where work at height is taking place, the area below shall be equipped with suitable barriers/warning signs to prevent unauthorized entry.

All tools, equipment and other loose items taken into the derrick must be entered into the Derrick Log Book (See Section 4 Subsection 5.5)

KNIVES

The use of knives is prohibited except for food preparation and dining. Alternative cutting tools must be used.

HAND TOOLS

Crewmembers must be made aware of safe working practices associated with hand tools, including but not limited to:

The proper tool for the job and its correct use

Inspection of tools prior to use to verify fit for purpose.

Proper securing of tools when working at heights.

Tracking of tools taken up the mast/derrick.

Requirement to not modify the design of a tool.

Procedures for cleaning and storing tools on completion of the task.

Hand tools must not be used beyond the manufacturer's operating limits or in ways not recommended/approved by the manufacturer, specifically (as a minimum):

Torque, air pressure and rated rpm

Explosion protection for use in designated hazardous areas

Shock proofing for use in wet conditions

Size of tools to be used with equipment (drills, discs, and so forth)

The OIM must ensure that necessary tools are provided onboard and that training is given to employees in their proper use. (See Section 4 Subsection 1.3)

No personal tools may be used to perform work on any installation or at any facility. Hand tools that are in an unsafe or questionable condition must be taken out of

service and repaired or replaced. To ensure tool integrity is not compromised, repairs to hand tools may only be effected by the manufacturer or by someone with the knowledge, skills and ability to safely complete the repair.

Only approved explosion protected extension cords may be used in areas defined as hazardous areas and where there may be potential gaseous conditions.

Non-explosion protected hand tools must never be connected to explosion protected cords in a hazardous area without the OIM's approval and a valid Permit to Work in effect.

PORTABLE LADDERS AND STEPS

Before using portable ladders or steps, Company personnel must be trained in their correct use and the procedures to be followed in order to identify and control the hazards associated with their use. (See Section 4 Subsection 1.3)

Portable ladders and steps may be used for work at a height only under circumstances in which the use of safer access equipment is not justified in view of the short duration of use and low level of risk.

Never overreach when working from a ladder or steps.

Portable ladders and steps must be positioned to ensure their stability during use. It is essential that they rest on a stable, strong, immobile and horizontal footing.

Portable ladders must be secured to prevent slipping before they are used. Ladders with several sections must be correctly used and secured to ensure that the sections are prevented from moving relative to each other.

Portable ladders and steps should be stored undercover with adequate ventilation. They should be kept away from excessive heat or dampness and not be left exposed to the weather.

All portable ladders and steps must be inspected before use. Portable ladders and steps found to be unsafe must be removed from service.

A ladder register and inspection routine must be included in the planned maintenance system.

POWERED (LOCAL OR REMOTE CONTROLLED) WATERTIGHT DOORS AND HATCHES

Before passing through any powered (local or remote controlled) watertight door or hatch opening, the door or hatch must be in the full open position and not in motion. Persons having access to remote control switches for powered doors or hatches must be assured the area is clear of personnel before activating remote control switches.

All powered (local- or remote controlled) watertight doors and hatches must have an audible and visual warning system at both sides of the door or hatch that warns personnel of the hazard of the door or hatch opening or closing.

All powered (local controlled) watertight doors must have signs posted adjacent to and on both sides of the door indicating: "Warning – Open Door Fully Before Passing Through."

All powered (remote controlled) watertight doors must have signs posted adjacent to and on both sides of the door indicating: "Warning – Open Door Fully Before Passing Through. This Door May Close Automatically."

REMOTE CONTROLLED MACHINERY

All remote controlled machinery with exposed moving parts (such as anchor winches, jacking gears, wireline units, hose reels, and so forth), must be clearly marked with warning signs stating "Warning – this machinery may be remotely operated at any time" or a similar statement.

RADIO COMMUNICATIONS

HANDS FREE COMMUNICATION

All installations must be equipped with fixed hands-free communication systems, (for example, talkback, clearcall, and so on) between the driller’s stations and the derrick racking board, as well as between the driller’s stations and the BOP working area.

PORTABLE COMMUNICATION

Installations should utilize radio communications (transmit and receive) equipment to provide an effective method of verbal communication during tasks for all personnel who are directly involved in:

Drilling operations,

Lifting operations, and

Other operations where the THINK Planning Process has determined that radio use will reduce the likelihood and/or consequences of an incident.

NON-METALLIC PIPES

Due to inherent conductivity, all non-metallic pipes must be grounded.

Use of non-metallic piping must be in accordance with IMO Resolution A.753(18) and installation classification society guidelines (ABS, DNV, and so on).

RESPONSIBILITY

ALL PERSONNEL:

Conduct themselves in a manner to protect themselves and others who may be affected by their actions, the environment and property.

Have the obligation to interrupt the operation if someone's safety is jeopardized or if damage to the environment or property is likely.

OIM:

Ensure that necessary tools and equipment associated with this policy and procedure are provided onboard and that training is given to employees in their proper use.

Approve the connection of non-explosion protected hand tools to explosion protected cords in a hazardous area and ensure a valid Permit to Work is in effect.

Ensure the installation is maintained with the highest regard for good housekeeping and deck management.

Ensure a system for designating areas of responsibility is put in place.

BUSINESS UNIT QHSE MANAGER:

Facilitate implementation of DROPS program.

DIVISION MANAGER:

Ensure implementation of DROPS program.

Provide adequate resources necessary to implement a DROPS program or equivalent.

Ensure that installations are provided with the necessary tools and equipment associated with this policy and procedure.

Ensure that training is available to employees in the proper use of tools and equipment associated with this policy and procedure.

BUSINES UNIT VICE PRESIDENT:

Approve type of portable radio equipment to be utilized in the Business Unit.

DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

IMPLEMENTING AND MONITORING

Energy Sources and Isolation

POLICY

Any energy-containing system or component must be effectively managed and controlled in normal operation, maintenance or during testing.

PURPOSE

The purpose of this policy is to heighten the awareness of personnel regarding energy sources and ensure that equipment is rendered safe by releasing any trapped energy from it and that the equipment cannot be energized at either local or remote locations.

SCOPE

This policy covers all personnel that work at Company installations and facilities.

PROCEDURE

Equipment or systems containing energy (including electrical, mechanical, hydraulic, pneumatic, thermal and kinetic) must be clearly marked to allow identification.

Energy isolation must be considered prior to maintaining or repairing any system or equipment containing energy.

Worm drive securing devices (jubilee clips, radiator hose clamps, and so on) must not be used on pressurized connections.

4.1 TRAINING

Training for compressed gases may be found in the Safety OJT Module. The OIM must:

Ensure only competent personnel perform maintenance or repairs to any system or component containing energy.

Authorize personnel as responsible for that system or component.

Ensure personnel who perform maintenance or repairs to systems or components that contain or may contain energy have been trained in the requirements of energy isolation. (See Section 4 Subsection 1.3).

Only personnel authorized by the OIM or designee may perform isolations. These personnel must be competent in their knowledge and understanding of hazards, the equipment to be worked on, and the procedures and skills necessary to effect and remove the following categories of isolations:

Electrical

Mechanical

Hydraulic

Pneumatic

Thermal

Kinetic

Chemical

Stored

ENERGY SOURCES

ELECTRICAL ENERGY

Aspects concerning the control of the hazards associated with electricity are detailed within the Electrical Safety policy. (See Section 4 Subsection 5.9)

MECHANICAL ENERGY

Appropriate guards or shields must be installed on all equipment to adequately protect personnel from moving parts (such as grinding wheels, belts, chains, and so on).

Grinding/abrasive wheels and their working RPM must match that of the grinder. Manufacturer’s recommended working pressure must not be exceeded on

pneumatic or hydraulic tools.

Lathes, drilling machines, pedestal drills and band saws must be fitted with an instantaneous shut down device (for example, DC injection braking). If instantaneous shutdown devices cannot be fitted, guards must be installed that enclose all moving parts and prevent the machine from operating when they are removed.

All shop appliances not fitted with instantaneous shutdown devices must be fitted with a “deadman” switch.

Power hand tools must not have the ability to be locked in the “On” position.

Attachments to power tools (for example, sockets to impact wrenches) must be properly secured.

The hazards of other forms of mechanical energy (including springs, levers, and equipment falling due to failed hydraulic systems) must be controlled.

PRESSURE ENERGY

Pressure is defined as any substance (air, hydraulic, water, well bore fluids, and so forth) under pressure, for test purposes or for normal use, that can cause severe injury to personnel or damage to property if a sudden rupture or burst occurs.

All connections on pressurized lines must be snubbed with adequate means to prevent them from swinging or kicking in case of sudden release of pressure or rupture of the line, and must be suitable for the pressure intended.

Pressurized lines and hoses must be adequately secured to prevent mechanical damage.

Pressure relief lines must be secured against movement when pressure is released. Isolation valves cannot be installed in pressure relief lines.

A Permit to Work must be completed before any testing or maintenance on equipment that contains or may contain residual pressure.

For maintenance isolations, there must be a positive means to confirm all pressure is relieved and system is made safe by proper lockouts of control valves. This may mean locking valves open or closed.

All personnel on board must be made aware of pressure testing and the area involved must be appropriately marked and/or barricaded.

A means must be provided to ensure that the intended maximum pressure is not exceeded. To avoid exceeding the intended maximum pressure, use test pressure only during testing operations. Safe working pressure must be adhered to for normal use.

Components under pressure must not be subjected to any form of shock loading, used as a lifting gear securing point, hammered on or used as support for other equipment.

All personnel involved in the operation must be made aware of the possibility of trapped pressure in any pressurized system. A means of safely bleeding off pressure must be an integral part of the system. Special precautions should be taken when troubleshooting any problem with pressurized systems.

All fixed-pressure vessels must have the maximum safe working pressure clearly indicated and a means of indicating current pressure. Pressure relief mechanisms must be installed to prevent exceeding the safe working pressure, and must be tested as per the Company Standard PM Task for EMPAC asset 00959 – Relief Valves.

A system must be in place to ensure that the downstream side of pressure relief mechanisms remains clear of obstructions.

Each accumulator bank will be fitted with an isolation valve and a vent valve, as well as a pressure gauge that is fitted with an isolation valve and a vent valve. There must be provision provided to lock these valves in the open or closed position.

The following procedure is included as one example of a means to isolate a pressurized energy source

Check that the pressure gauge is operational before proceeding with maintenance.

When any maintenance is to be performed on any accumulator bank, the accumulator isolation valve will be closed and the accumulator vent valve will be opened, the pressure gauge isolation valve will be in the open position and the gauge will be reading zero.

There will be provision provided to lock the accumulator isolation valve in the closed position and to lock the accumulator vent valve and the pressure gauge isolation valve in the open position.

These valves are to remain in the isolation and vent position until all maintenance work is completed.

Portable hoses and fittings must be suitable for the intended use (pressure, volume, contents, and so forth), inspected prior to use, properly installed and secured (for example: whip checks, “R” clips, etc.) in case of connection failure.

COMPRESSED GASES AND CYLINDERS

All gas cylinders must be checked for general condition, leaks and hydrostatic test date upon arrival at the Installation or facility. Cylinders must be marked with the date these checks were performed and indicate that they meet the preceding criteria.

Nitrogen cylinder contents must be checked with a gas detector (oxygen analyzer) to confirm whether the contents are inert or flammable. However, in developed areas where an established infrastructure provides reliable and consistent quality control supported by regulatory legislation, this check may be performed prior to delivery to the installation/facility. The cylinder must be accompanied with documentation to confirm the contents. The gas/cylinder provider should have a system in place to manage and track the inspection and filling of the gas cylinders.

In locations where an established infrastructure does not provide reliable and consistent quality control, cylinder contents must be verified at the installation/facility for inert or flammable gases, prior to use.

Cylinders must be stored in an upright position at all times. Caps must be removed only when the cylinders are in use. If cylinders are designed for caps, they must be secured on both full and empty cylinders while they are being moved or transported.

When cylinders are in transit, they must be secured, preferably in racks.

Cylinder trolleys should be used to transport cylinders from one place to another. Portable transfer racks for working sets of oxygen/acetylene bottles must be

constructed to ensure a steel plate separates the bottles, and bottles are adequately secured to protect gauges, regulators and valves.

Portable transfer racks and cylinder trolleys subject to being hoisted must be included in the lifting gear register.

Cylinders should not be subjected to temperatures above 54°C (129°F) and should be stored in a shaded area. Cylinders must also be protected from the radiant heat of flares.

The cylinders should be stored in a designated area.

Empty cylinders should be separated from full ones and must be marked accordingly.

Closed storage areas must be ventilated to atmosphere or cylinders must be stored in the open air.

Oxygen and acetylene cylinders must not be stored alongside one another. They must be separated by a distance of at least six meters or with a non-flammable barrier.

Cylinders must not be used as rollers or support even if they are believed to be empty.

Valves on all compressed gas cylinders must be closed when not in use.

An efficient backpressure valve (in-line check valve) and a flash/flame arrestor must be provided near the cylinder in the acetylene and oxygen supply lines.

The pressure of oxygen should always be high enough to prevent acetylene flowing back into the oxygen line.

Acetylene pressure should not exceed 1-bar (14.7psi) due to risk of explosion.

When oxygen or acetylene cylinders are coupled (banked), flame/flash arrestors should be used between the cylinders and the coupler block or between the coupler block and the regulator. Only oxygen or acetylene cylinders of approximately equal pressure should be coupled.

Manifold hose connections, including inlet and outlet connections, should be such that the hose cannot be interchanged between fuel gases and oxygen manifolds and headers.

Grease or oil must not be used on any oxygen/acetylene system threaded connections.

Only approved pressure gauges may be attached to oxygen and acetylene bottles. These gauges must be dry gauges and crossovers should not be used.

No liquid filled gauges may be used on any compressed gas bottles unless it is filled with Halocarbon liquid.

Only those hoses specifically designed for welding and cutting operations should be used to connect an oxygen/acetylene cutting torch to gas outlets.

Accumulators and pulsation dampeners must be pre-charged with only inert gases, such as nitrogen.

Oxygen must not be used in place of compressed air for tools, air starters, cleaning purposes or other uses.

COMPRESSED AIR

Compressed air must not be used as a means of removing dust, dirt, and so forth, from a person’s body or clothing.

Air used for cleaning or drying purposes must only be done using adequate tools, and the pressure must be limited to 30psi.

Compressed air must not be used for blowing a drift through tubulars.

Compressed air must not be used for clearing a blocked line or pipe, except during the routine operation of the bulk system.

The main rig air system or any rig air compressor must not be connected to the flare boom. Connection to the flare boom via portable air compressor(s) stored on an open deck is allowed.

Isolation valves cannot be installed in relief lines either before or after the pressure relief mechanism.

OTHER FORMS OF ENERGY

Other forms of potential energy must be considered during the hazard identification step of the THINK Planning Process, including:

Thermal Energy, such as heat or cold radiating from hot or cold surfaces; heat generated by friction or chemical reaction, steam lines, steam lances, and so forth; or cold generated by flowing gas, and so forth.

Kinetic energy, such as unsecured hanging items swinging due to vessel motion, movement due to sudden impact from another item, dropped objects, and so forth.

Chemical energy, which can be the result of a chemical reaction between two or more substances. Review the manufacturer's instructions and Material Safety Data Sheets before mixing chemical substances (for example, two-part paints, two-part resins, use of acid or alkaline batteries, and so forth).

Nuclear energy (which results in a radioactive hazard) and explosives are covered in the Hazardous Material Policy. (See Section 4 Subsection 5.7)

Stored energy (such as compressed springs and electrical capacitance) which may not be as obvious or as easily isolated.

ENERGY ISOLATION

PERSONS INVOLVED IN ISOLATIONS

RESPONSIBLE PERSON

The person who authorizes isolations within an area of operation or for a particular system. The OIM must authorize Responsible Persons for defined areas of operation and systems.

COMPETENT PERSON

The person who is deemed “Competent” to isolate a given piece of equipment or system. The OIM must authorize individuals as competent persons for each type of energy isolation.

PERSON IN CHARGE OF CARRYING OUT THE WORK

The person who is in charge of carrying out the work on the isolated equipment and is the person who requests permission for the isolation from the Responsible Person.

OIM

The OIM determines if a Permit to Work is an additional requirement when an isolation certificate is issued for maintenance or repair of a system or component containing energy. In some cases the work is only hazardous because of the energy. When effective isolation is achieved, the work may no longer be hazardous and hence the isolation process controls the risks associated with the energy.

OBJECTIVES OF THE ISOLATION SYSTEM

The overall objective is to always use the highest level of isolation that is reasonably practicable.

The adequacy of the isolation must reflect any reasonably foreseeable hazards and the consequences should those hazards be realized.

Isolations must be in place throughout the duration of the operation.

Isolations must be “tried” to prove effectiveness.

Isolated equipment and remote operating stations must be correctly and clearly identified with energy isolation tags.

Isolations must be recorded in the documentation system.

STANDARD ISOLATION PROCESS

A standard isolation is one that is in place for equipment or systems for work performed during a period less than 24 hours (see paragraph 4.3.5 for Long Term Isolation).

The following is the standard process for a person in charge of carrying out the work to request an electrical, mechanical, pneumatic, thermal and/or hydraulic isolation:

Contact the relevant departmental responsible person.

The responsible person authorizes the isolation and ensures the person in charge of carrying out the work fully understands all relevant isolations required.

The person in charge of carrying out the work contacts the competent person who then performs the isolation.

The competent person must ensure that all stored energy is discharged prior to performing the isolation.

The competent person isolates and tags the equipment or system with the required warning tags. Locks, hasps or other special arrangements to positively isolate the energy source may be required.

The competent person and person in charge of carrying out the work must physically conduct a test to ensure that the isolation is effective before work on the equipment or system begins. This can be achieved by either attempting to operate (if equipment) or (if a system) by other physical means (mechanical, electrical, bleed off of pressure, etc.) to confirm positive isolation.

The person in charge must periodically monitor the effectiveness of the isolation. Any work handed over must be entered on the isolation certificate.

When work is handed over, the person in charge must verify that the isolation of equipment or system and discharge of stored energy remains effective.

The competent person and person in charge of carrying out the work (who may be the same person) must enter the isolation details on the isolation certificate. One copy of the isolation certificate is retained at the isolation co-ordination point and the person in charge of carrying out the work retains a copy.

There must be a system in place for each person performing work on an isolated piece of equipment to maintain control (individually lock or secure) of the mechanism maintaining the isolation.

STANDARD DE-ISOLATION PROCESS

The following is the standard de-isolation process for the person in charge of carrying out the work to request an electrical, mechanical, pneumatic, thermal and/or hydraulic de-isolation:

When a job is complete, the person in charge of carrying out the work must complete the relevant section of the isolation certificate. When de-isolating from a long-term isolation, the isolation must also be closed out in the long- term isolation logbook and removed from the notification board.

The person in charge of carrying out the work requests the responsible person to confirm that the equipment is safe to be de-isolated.

The competent person ensures that it is safe to restore energy, removes all isolation tags (locks, etc., if used) and signs off on the isolation certificate.

The responsible person or designee can now test the equipment. They must be satisfied that the equipment is operating correctly and that the relevant people have been informed before the equipment is returned to service.

LONG-TERM ISOLATIONS

An isolation is considered long-term if it has been active for more than 24 hours and the equipment is no longer actually being worked on (for example, awaiting spare parts) but is not ready for de-isolation.

When a change of status from standard to long-term isolation is required, the person in charge of carrying out the work notifies the responsible person and all parties involved in the standard isolation.

During any long-term isolation, the following additional points must be addressed:

The OIM must be informed by responsible person.

The method of securing the long-term isolation (for example, locking of electrical isolators, locking of valve handles, removal of valve handles, use of blind flanges, and so forth) must be confirmed.

All copies of the isolation certificate must be marked “LONG-TERM ISOLATION.”

One copy of the isolation certificate must be retained at the isolation coordination point.

Long-term isolations must have a copy of the isolation certificate at the isolation points and may also have a copy on the equipment itself.

A long-term isolation logbook or notification board must be maintained at an appropriate central location.

When the work recommences on equipment covered by a long-term isolation, the responsible person informs the OIM or designee and ensures that:

The competent person and the person in charge of the work review the long- term isolation certificate. The person in charge of the work must sign the long- term isolation certificate.

Operation of the equipment is physically tried to confirm positive isolation before work on the system or equipment begins.

The work proceeds according to standard isolation procedure previously detailed.

LONG TERM DE-ISOLATION PROCESS

Proceeds according to standard de-isolation process.

5 RESPONSIBILITY

5.1 RESPONSIBLE PERSON:

Ensure the person in charge of carrying out the work fully understands all relevant isolations required.

Visit the work site and ensure THINK Plans and Isolations are appropriate.

Test the equipment and must be satisfied that the equipment is operating correctly and that the relevant people have been informed before the equipment is returned to service.

Notify the OIM when any standard isolation becomes long-term.

COMPETENT PERSON:

Isolate and tag the equipment or system with the required warning tags, locks, hasps and special equipment.

Enter the isolation details on the isolation certificate.

Physically try to operate the equipment to confirm positive isolation before work begins on the system or equipment.

Ensure it is safe to re-instate energy, remove all isolation tags (locks, and so forth, if used) and sign off on the isolation certificate.

PERSON IN CHARGE OF CARRYING OUT THE WORK:

Request permission for the isolation from the Responsible Person.

Contact the Competent Person who will perform the isolation.

Enter the isolation details on the isolation certificate.

Request the Responsible Person to confirm that the equipment is safe to be de-isolated.

Notify the Responsible Person and all parties involved in the standard isolation if the isolation becomes long-term.

Physically try to operate the equipment to confirm positive isolation before work begins on the system or equipment.

Personally ensure the isolation is individually secured and maintain control of the isolation for the entire time they are actively performing work on the equipment.

OIM:

Ensure a system is in place to meet the requirements outlined in this procedure.

Ensure all Company personnel who perform maintenance or repairs have been trained in the requirements of energy isolation (rendering equipment/system safe from an energy source or sources) as per Company training.

The OIM must determine if a Permit to Work is an additional requirement when an isolation certificate is issued for maintenance or repair of a system or component containing energy.

Define responsible person for areas of operation.

Authorize individuals as competent persons for each type of energy isolation.

6 DOCUMENTATION

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President.

Cylinder Status Tag (Figure A)

(Must remain on cylinders from the time they arrive to the time they depart the installation or facility.)

Energy Isolation Certificate

(Must be retained in the installation or facility files for a period of one year.)

An isolation logbook may be used at the discretion of the Business Unit Vice President. The purpose of the logbook is to provide an efficient method for tracking and auditing isolation certificates.

Figure A

IMPLEMENTING AND MONITORING

Fall Protection

POLICY

All installations and facilities must adequately protect personnel from the risk of falling from heights.

PURPOSE

The purpose of this policy is to ensure that the risk of falling is assessed and personnel are protected from falling and the injuries associated with falling.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

Fall protection is a system of support that prevents or arrests an individual's fall. A method of fall protection must be utilized when working at an elevated position that is more than 6 feet, 7 inches (2 meters) above normal working surfaces and where any fall hazard exists.

TRAINING

All employees must be trained to recognize the hazards of falling and the procedures to be followed in order to minimize any associated risk. (See Section 4 Subsection 1.3) The training must include a practical demonstration using equipment utilized on the installation. The training must be given in an organized manner and must be fully documented.

There must be one person trained as a Competent Person in fall protection by a Company approved instructor on the installation at all times. Each Business Unit is responsible for approving fall protection training providers. (See Section 4 Subsection 1.3)

There must be one person trained by a Company-approved instructor as a Competent Person in confined space rescue and rescue from heights on the installation at all times. Each Business Unit is responsible for approving the training provider(s). (See Section 4 Subsection 1.3)

METHODS OF FALL PROTECTION

The following methods of fall protection must be used, in order of preference:

Fall hazard elimination (for example, repositioning valves down to deck level).

Traditional fall protection (for example, handrails, guardrails).

A fall restraint system, such as restraint lines that prevent personnel from reaching the fall hazard (for example, derrickman's harness).

A fall arrest system, such as lanyards with personal shock absorbers, self- retracting lifelines (inertia reels), or ladder climbing systems that "catch" personnel when the possibility of a fall cannot be prevented.

Fall protection procedures (for example, personnel basket, man-riding operations) must be used only when it is clearly impractical to provide complete fall protection using any of the preceding methods. Personnel using such procedures must be trained to recognize the fall hazards involved and to fully understand their roles and responsibilities.

TRADITIONAL FALL PROTECTION

All stairways and permanently elevated walking and working areas must be equipped with handrails.

All deck openings must be covered or adequately guarded.

Handrails, including temporary and removable types, must be of sufficient strength. All handrails, barriers, stairways, gratings, elevated walkways and elevated working

areas must be maintained. A procedure for verifying the integrity of these structures must be included in the planned maintenance system.

FALL PROTECTION SYSTEMS AND PPE

Units or Divisions must define and approve specific fall protection equipment to meet the minimum standards outlined in this procedure and comply with local legislation.

Fall protection systems and equipment must be inspected before each use and included in the planned maintenance system.

Fall protection equipment inspection criteria and regime must meet the manufacturer’s recommendations for each.

The rescue of personnel working at elevated levels must be discussed and planned for during the THINK planning process for the relevant task. As a minimum, the following must be considered during discussion and planning:

Equipment required to perform rescue operations.

Length of time required to perform rescue operations.

Forces exerted on personnel from being suspended for that period of time.

Availability of alternative methods to perform rescue operations.

Equipment designed for rescue from heights must be stored, maintained and inspected as per the manufacturer recommendations and included in the installation’s planned maintenance system.

All fall protection PPE must be properly stowed in dedicated boxes or lockers when not in use.

FIXED VERTICAL LADDERS

A dedicated fixed-ladder climbing system is a system fitted to fixed ladders to provide personal fall protection during ascent or descent.

Only Company approved ladder-climbing systems, fall arrest devices and full body harnesses may be used for ladder climbing.

Back scratchers or ladder cages are not considered suitable or sufficient fall protection equipment.

All derrick ladders must be fitted with a dedicated fixed-ladder climbing system. Personnel on ladders must maintain a minimum of three points of contact at all

times.

All ladders designated “For Emergency Escape Only” must be clearly identified (for example, painted red) in a manner to avoid confusion with other ladders and maintained so it is accessible and kept clear of obstruction.

Any ladder used as a platform to perform work must be fitted with fall protection suitable for the work performed.

LADDERS OVER 10 FEET (3.05 METERS)

All fixed vertical ladders over 10 feet (3.05 meters), except those used solely for emergency escape, require one of the following during ascent or descent:

A dedicated fixed ladder climbing system OR

The use of a permanent or temporary fall arrest device OR

Fall prevention providing 100% tie off at all times.

All fixed vertical ladders over 10 feet (3.05 meters), except those used solely for emergency escape, must be assessed to determine a suitable means of fall protection. This assessment must include as a minimum:

Necessity of ladder

Feasibility of replacement with stairway

Location of ladder

Frequency and duration of use (rarely/often used)

Existing, normal condition of ladder (slippery, damaged, clean, dry, and so forth)

A procedure for installation of a temporary or permanent fall arrest device prior to use or procedure for use of fall prevention that provides 100% tie off at all times (if determined a fixed ladder system is not practical)

Risk assessments must be approved by the Rig Manager or Facility Manager, reviewed by the Division Manager and filed on the installation or at the facility.

All ladders assessed as unnecessary must be removed.

LADDERS 10 FEET (3.05 METERS) AND UNDER

Ladders not exceeding the height of 10 feet (3.05 meters) do not require the use of fall protection provided a formal risk assessment determines the appropriate answer is “no” to each of the following questions:

Is there a potential for falling a distance greater than 10 feet? (for example: into an open hole, overboard, or to a lower level landing, and so on)

Is the ladder used daily AND there is a danger of landing on sharp objects or moving machinery parts?

Is the normal condition of the ladder considered to be of poor traction AND the frequency of use is at least weekly?

NOTE: A “yes” answer to any of the above questions will require the use of fall protection and the assessment outlined in paragraph 4.5.1 (above) for ladders over 10 feet must be used.

When a formal risk assessment concludes that the fitting of a fall arrest system or device would likely encumber or restrict the user or increase the potential of the fall hazard, such a system or device does not need to be installed if appropriate alternative control measures are put in place.

Risk assessments must be approved by the Rig Manager or Facility Manager, reviewed by the Division Manager and filed on the installation or at the facility.

FALL ARREST SYSTEMS

All fall arrest systems must limit the arrest force to 1,800 lbs. (818 kg), use a Company approved full body harness, be connected to an acceptable anchor point and have compatible connectors throughout.

All materials and equipment used in fall arrest systems must be purpose bought for the use intended. Any equipment having potential to be confused with lifting gear must be identifiable as fall protection only.

An acceptable anchor point for a personal fall arrest system is a secure point of attachment (for example, a beam, girder, column, floor, or other fixed structural member capable of withstanding a minimum force of 5,000 lbs. (2273 kg) for each person attached to that anchor point). The anchor point must be located above personnel to minimize free-fall distance and swing-fall potential, which must not exceed the manufacturer's recommendations, or 30 degrees from vertical (whichever is less).

Compatible connectors (for example, D-rings, O-rings and eye bolts) are sized to reduce the possibility of rollout or side loading on the safety gate of the connecting snaphook or carabiner connector.

Snaphooks must not be connected to snaphooks and carabiner connectors must not be connected to carabiner connectors.

Fall arrest lanyards must be connected to an acceptable anchor point as high as reasonably practicable and adjusted to minimize free-fall distance.

Fall arrest systems, with the exception of ladder climbing systems and SRL’s, must include a shock-absorbing device and must be attached to the rear D-ring (dorsal attachment) of the full-body harness.

Manufacturer's recommendations of minimum working height must be followed when using shock-absorbing devices.

Fall arrest systems, in conjunction with a personal flotation device, must be utilized when there is a possibility of falling into the water.

Fall arrest systems must be used in workbaskets whenever practical.

Any component of a fall arrest system that is used to arrest a fall must be returned to a manufacturer authorized service center for re-certification.

LIFTING OF PERSONNEL

(See Section 4 Subsection 5.6, paragraph 4.4 Manriding)

SELF RETRACTING LIFELINES (SRLs)

Self retracting lifelines (inertia reels) must be retracted when not in use to prevent alteration of the spring memory or corrosion of the cable.

Additional shock absorbing devices must not be used in conjunction with inertia reels.

Connectors of self retracting lifelines to anchor points must be of a positive locking type. If shackles are to be used, they must be a four part shackle and controlled in a manner to ensure they will only be utilized with fall protection equipment.

Cargo type slings may be used to secure the SRL to the anchor point. Only sling type adaptors manufactured for this purpose and with compatible connectors may be utilized with fall protection equipment.

HORIZONTAL LIFELINES

DERRICK ACCESS

Access to the derrick is only with the driller's permission. A Derrick Log Book must be used to record personnel movement, tools taken into the derrick and any unsafe observations.

All derricks must be equipped with an emergency escape device or alternative escape route. If a device is used, it must be installed to allow escape of personnel from the derrick to a dedicated landing area free of hazards and obstructions.

DERRICKMAN CHANGEOUT PROCEDURE – MANUAL DERRICKS

The derrickman's safety harness must be stowed at the entrance of the monkey board to allow the derrickman to put it on prior to walking onto the work platform and to remove it after leaving the platform.

The derrickman must wear a fall arrest system in addition to a fall restraint system. The anchor point for the fall arrest system must be capable of withstanding a minimum force of 5,000 lbs. (2273 kg), and must be located above the monkey board to minimize free-fall distance and swing-fall potential.

The traveling block must remain near the rig floor while derrickmen are changing out until the new derrickman confirms that he has donned and secured the safety harness.

New derrickmen must be accompanied by experienced derrickmen or an Assistant Driller until they are considered capable of safely working on the monkey board by themselves.

CASING STABBING BOARD/BASKET

Casing stabbing boards must include the following safety devices:

Primary locking device

This device must operate when the lifting mechanism is not operating (command in neutral position). This locking device is an automatic fail-safe brake included by design in the winch.

Secondary locking device: Fall arrestor

This device must operate if the hoisting mechanism fails or if the wire breaks, and must prevent the traveling carriage assembly from free falling. This anti- fall device consists of a separate safety wire rope connected to the derrick, which passes through a slack rope safety lock connected to the traveling carriage assembly, which automatically operates in the event mentioned above. The safety lock is actuated by loss of tension in the main winch cable, which initiates an immediate stop of downward travel by the carriage. The safety rope runs between side rails for protection.

Tertiary locking device: Parking brake

A mechanically operated safety lock latch mechanism must be fitted to the carriage assembly framework with pawls which engage with the latch rails on the stabbing board when the carriage is stationary. Alternately, where restraints preclude using a mechanical lock latch system, a pneumatic fail safe lock can be used, operating on the same safety cable as the slack rope safety lock.

Extension platform position warning device

A safety indicator must be provided to warn the driller that the board is in the path of the traveling block assembly (the casing stabbing board is in the extended position/extension platform out). An example of a warning device is a limit switch that activates a red light in the driller’s house whenever the platform is extended.

Safety harness and fall arrestor at the casing stabbing board/basket.

A safety harness connected to a fall arrestor must be available at the casing stabbing board. The fall arrestor must be secured to the derrick/mast. It is forbidden to install the harness to the traveling part of the platform. The fall arrestor must be of an inertia reel type to accommodate the traveling up or down of the casing operator and platform.

The fall arrest system for personnel working from the stabbing board/basket must include:

An anchor point located on the derrick structure (not on the stabbing board/basket or stabbing board structure).

A self retracting lifeline to allow vertical movement of the stabbing board/basket.

The casing stabbing board/basket must be labeled:

“SUITABLE FOR CARRYING PEOPLE”

To indicate the number of personnel it is rated to hold/carry

SCAFFOLDING

Company personnel that erect, maintain or inspect must successfully complete a training course appropriate for the type of scaffolding erected, maintained or inspected.

All scaffold training must be approved by the Division Manager. (See Section 4 Subsection 1.3)

All scaffolding erected, dismantled, maintained or inspected by Company personnel must be approved by the Division Manager.

The OIM must designate a competent person to perform scaffold inspections aboard the installation.

Scaffold must be clearly marked by the competent person who inspected it to indicate that it is safe/unsafe for use, and the loading it can support.

Light Duty – 25lbs/sq ft

Medium Duty – 50 lbs/sq ft

Heavy Duty – 75 lbs/sq ft

Inspection of scaffold must take place:

At the start of each tour when it is to be utilized

Following any alterations

After any adverse weather or vessel motion

Every 7 days whether used or not

Note: The inspection criteria applies to all scaffold which has been erected on the installation.

All scaffolding erected aboard the installation must have the following specifications as a minimum:

Handrails

Ladders (to enable easy entrance and exit)

Toe boards (to eliminate loose items or tools from falling)

Clean walkways that are clear of loose objects and debris

RESPONSIBILITY

5.1 ALL PERSONNEL:

Utilize a Company approved method of fall protection when working at an elevated position that is more than 6 feet, 7 inches (2 meters) above normal working surfaces and where any fall hazard exists.

SCAFFOLD COMPETANT PERSON

Complete the Division approved training for the erection and inspection of scaffolding

Inspect all scaffold erected on the installation as required

Determine if scaffolding is safe or unsafe for use

Clearly mark scaffolding and identify the safe working load

OIM:

Only permit Company personnel who have completed the Division approved training to erect scaffolding.

Designate a Competent Person to inspect the type of scaffold that is erected on the installation.

Ensure all employees are trained to recognize the hazards of falling and the procedures to be followed in order to minimize any associated risk.

Ensure there is one person on the installation at all times, trained as a Competent Person by a Company approved instructor in the following:

Fall protection

Confined space rescue

Rescue from heights

Ensure an integrity verification procedure for handrails, barriers, stairways, gratings, elevated walkways and elevated working areas is included in the installation’s planned maintenance system.

Ensure rescue from heights equipment is included in the installation’s planned maintenance system.

RIG MANAGER:

Approve risk assessments for ladders up to 10 feet (3.05 meters) not requiring installation of a fall protection system.

DIVISION MANAGER/UNIT OPERATIONS MANAGER:

Review risk assessments for ladders up to 10 feet (3.05 meters) not requiring installation of a fall protection system.

Approve scaffold material that Company personnel may erect, dismantle, maintain or inspect within their area of responsibility.

Approve scaffold training providers within their area of responsibility.

BUSINESS UNIT VICE PRESIDENT:

Approve fall protection training providers within their Unit.

Approve specific fall protection equipment used within their Unit to meet the minimum standards outlined in this procedure, and ensure equipment selected complies with local legislation.

6 DOCUMENTATION

The form indicated below is included in the manual as an example only and is intended to allow operations to take advantage of a preset form rather than having to create their own. Use of this form is not mandatory. However, if the example is not used exactly as it is included, the form used must include the key elements of the example and must be approved by the Unit Vice President.

Derrick Log Book (Figure A)

(Must be retained in installation or facility files for a period of one year after the last entry date.)

IMPLEMENTING AND MONITORING

Mechanical Lifting

POLICY

Mechanical lifting devices must only be operated by competent personnel or trainees while under direct supervision of competent personnel.

All lifting equipment in service must have current certification or have been successfully load tested within the last year.

All lifting equipment must be suitable for the lift and visually inspected for condition prior to each use.

Padeyes or lifting lugs must be properly designed, manufactured, installed and tested prior to use.

PURPOSE

The purpose of this policy is to prevent injury or incidents during mechanical lifting operations.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

Lifting equipment includes lifting gear and lifting appliances as described below. Lifting Gear – Any device that is used or designed to be used directly or indirectly to

connect a load to a lifting appliance and does not form part of the load. Examples of lifting gear are: slings, wire rope, hook, plate clamp, scissor clamp, shackle, eyebolt,

lifting beam, bushing puller, lifting caps and so on.

Lifting Appliances – Any mechanical device capable of raising or lowering a load (for example, crane, chain block, pull lift, winch, drawworks, and so on).

Cargo Carrying Unit – any equipment used to contain or transfer a load. Examples are: containers, baskets, gas bottle racks, personnel transfer baskets, waste skips, and so on.

Padeye – An engineered load bearing attachment point designed to be used with a shackle. It is either integrated or welded into a structure, piece of equipment or lifting appliance and used to transfer a dynamic load or secure a static load.

4.1 MAINTENANCE AND USE OF LIFTING EQUIPMENT

Any person using lifting equipment must be trained in the rigging practices and load handling methods used for that equipment. They must also have working knowledge of its capabilities and any defects likely to arise in service. (See Section 4 Subsection 1.3)

Equipment found to have a defect affecting the safe operation must be removed from service and repaired, load tested and authorized for use or destroyed.

A register of all lifting equipment must be maintained at each installation and facility. This register must be able to trace any piece of lifting equipment back to a current load test certificate. Every effort must be made to retain the original manufacturer certificate aboard the installation. All lifting appliances must be included in a planned maintenance system.

A system that uniquely identifies the Safe Working Load (SWL), inspection frequency and individual identification of each piece of lifting equipment and each padeye must be maintained at each installation and facility.

A competent person must inspect all lifting equipment and padeyes at least every 12 months. A record of that inspection must be kept at the installation or facility. All recommendations made within the report must be acted upon and, if necessary, inserted in the FOCUS Planning and Tracking software.

Color coding must be used to clearly identify the last inspection date of all lifting equipment. The table below describes the Company color coding system to be utilized at installations and facilities.

In the event the color code for a specific year conflicts with an external source, such as client requirements, the color scheme may be reversed.

All new lifting equipment placed in service shall be marked with the current color code.

Lifting equipment must be used only for the specific purpose for which it was designed. Before a lifting operation commences the following checks must be made:

A SWL must be clearly marked on the lifting appliance

The weight of the load must be within the SWL rating of the lifting appliance

The lifting gear and appliance has been inspected and marked with the current color code

The lifting gear and appliance do not display any visual signs of damage

Any item of lifting equipment subjected to repair or alteration in the design must be re-certified and authorized for use before being reinstated. For example, a padeye welded on at the wrong load-pull angle should not be used until it is welded on at the correct pull angle, to avoid side loading. The padeye must be re-certified following the repair.

Natural or manmade fiber rope must not be used for lifting purposes. Recommended rope usage includes tag lines for moving cargo, tailing casing, and securing items. Tag lines must be used to assist with the control of loads handled by the crane within the installation. Sufficient taglines should be used whenever practicable for the transfer of loads to and from the installation.

Chains must not be used for lifting purposes with the exception of:

Bushing pullers

Manual and powered chain hoists (for example: stabbing board and BOP handling hoists).

Specialized sea fastenings

Tail chain equipped to monkey board pullback tugger

Crane wires must be changed out at the following intervals:

Whip line, main block and boom hoist – every two years

Boom pendant lines – every 5 years

PADEYES

All existing padeyes must be machine fabricated. This may include padeyes with a drilled bore, plasma cut bore, or forged bore design. Plasma cut bores should represent a finish and tolerance standard equal to a drilled bore.

Padeyes with flame-cut (hand-held torch) bores are not permitted.

The existing structure to which a padeye is to be installed or attached must be suitable for design requirements. Design calculations are required if there is any doubt regarding the adequacy of the support structure.

Surface preparation prior to a padeye welding attachment must be appropriate to the weld specification. Welding must only be performed by an appropriately certified (coded) welder.

Special use or seldom used padeyes are exempt from annual inspection and color coding provided they are clearly identifiable by red paint and physically locked out of service. These padeyes must be inspected and load tested prior to return to service. A log of locked out padeyes must be maintained aboard the installation.

Frequently used padeyes must be examined as per the required criteria.

PADEYE DESIGN

For padeyes with rated loads exceeding 6 short tons, the padeye must be designed and engineered by Rig Oilfield-Services Engineering Department.

NEW PADEYE INSTALLATION AND TESTING

The fabrication of padeyes at Company facilities or onboard installations is dependent upon the ability to achieve the Company approved padeye design.

Pre-fabricated padeyes should be obtained and made available for new installation and use. All padeyes must be provided with supporting design calculations, material specifications and approved welding procedures.

After installation, all welds must be thoroughly inspected to locate defects such as surface cracks, surface porosity, incomplete root penetration and undercut.

After the installation of a padeye, proof load test with load at 150% of the rated load must be performed. The load test must include the side load conditions that the padeye is designed to handle. Items in the test assembly must be inspected and their SWL at least that of the proof load being applied to the item being proof loaded.

After the proof load test, the padeye, welds, and all lifting gear used to perform the test must be inspected to observe whether any part has been damaged or

permanently deformed by the test, and whether any crack in the welds has been initiated. This will be confirmed by both visual inspection and non-destructive tests, either Liquid (Dye) Penetrate Examination conforming to ASTM E165 or wet Magnetic Particle Examination conforming to ASTM E709.

Padeyes to be installed onto the following structures, for the purpose of supporting loads, require prior Engineering approval:

Derrick

Crown Block

Piping

Side shell

Jackup legs

Diagonal and horizontal braces of semi-submersible’s hull

Any other structure where high strength steel alloys are believed to have been used

TUGGER WINCHES – GENERAL USE

All tugger winches must be maintained in good working order and ready for immediate use. Any defects must be reported immediately.

A ball valve must be fitted on the supply line adjacent to each tugger winch to allow rapid shutdown.

A manual or automatic spooling guide must be fitted to all tugger winches.

The working end of a tugger wire must be color-coded the same as the tugger. This is to provide a means for the tugger operator to visually monitor which wire he is controlling. This must be verified during pre-use inspection.

The working end of tugger winch wires must not be wrapped around equipment for hoisting or pulling. Slings and snatch blocks must be correctly used to avoid damaging the tugger wires.

Rig floor tugger lines used for picking up and laying down tubulars must be equipped with a shackle and ball bearing swivel of adequate SWL.

Hooks must not be used on tuggers for lifting purposes with the exception of:

Diverter packer element

Riser handling tool

Tow bridle tuggers

Specific instances as authorized by the OIM under control of the Permit to Work system

TUGGER WINCH LIFTING OPERATION – BEFORE USE

The following checks should be made before using any tugger winch:

There is enough wire on the drum. (Always leave a minimum of five wraps on the winch drum.)

The wire is evenly and tightly spooled with no apparent defects or damage.

Winch drum guards are in place.

Control levers are clearly marked “Up” and “Down.”

Tugger brake is operational and hoist controls return to neutral when released

Load weight is within the SWL of the tugger

TUGGER WINCH LIFTING OPERATION – DURING USE

Only trained and authorized personnel may operate tugger winches. (See Section 4 Subsection 1.3) and must ensure the following is adhered to:

Personnel are standing clear of all wire, ropes and moving equipment.

Direct full attention to the lifting operation .

Maintain clear visual contact with the lifting operation. If this is not practicable, a banksman must be deployed.

Stand on the correct side of the tugger when operating the controls.

Never leave the winch running unattended.

Never exceed the SWL of the wire/winch in use.

Never touch the wire by hand.

MANRIDING

Due to the relatively high risk of personal injury during manriding operations, ALL alternative methods of accomplishing the job must be considered prior to manriding operations being authorized.

A written THINK plan must be led by the Toolpusher or OIM before beginning any manriding operations. Depending on the planned operation, a Permit to Work may be required. The START process must be used to monitor the work, and if any changes occur, the work should be interrupted and the written THINK plan revised. As a minimum, the THINK plan must include:

consideration of a contingency rescue/recovery plan in the event of possible equipment failure or power loss

weather and lighting conditions

counter balancing effects of the winch wire

Work that might interfere with the manriding operation must be assessed, and if necessary, suspended.

The Toolpusher or OIM must be present during all manriding operations.

Except in extenuating circumstances, the Toolpusher or OIM must ensure the drawworks brake is adequately secured or in the parked position.

The person in charge of the manriding area may only select trained personnel to perform the manriding operations. Everyone involved in winch/tugger operations must have successfully completed Company approved manriding awareness training and a practical exercise using installation specific equipment. (See Section 4 Subsection 1.3)

All winches used for manriding must be designed for manriding and be inherently safe (that is, no clutch mechanism and no possibility for the winch to go into freewheeling mode).

General-use winches may not be used for hoisting personnel unless also designed and approved by manufacturer for manriding.

All winches used for manriding (both dedicated and general use/manrider approved) must have the following features, as a minimum:

Manufacturer label indicating operational parameters and approval for manriding.

A sign affixed to winch clearly indicating suitability for manriding (for example, “SUITABLE FOR MANRIDING”).

The winch operating lever must automatically return to neutral when released

An automatic brake that will engage upon returning the operating lever to neutral or on loss of power.

A secondary braking system for the wire drum that functions in the event the automatic brake fails or does not engage. This brake may be automated or manual.

A guide (manual or automatic) for spooling the wire rope onto the drum.

Have an OEM approved procedure, or be supplied from an air pressure vessel or hydraulic accumulator bank with sufficient reserve capacity available, to lower rider in a controlled manner in the event of the loss of main rig power.

An emergency shut off valve to isolate air or hydraulic power to the winch located within the winch operator's reach.

Air or hydraulic supply to hoist must be regulated to the manufacturer’s recommended pressure.

Non-rotating wire must be used on dedicated manrider winches.

Personnel being lifted must wear a Company approved full-body harness that is in good condition. A triple action carabiner must be used to attach the safety harness directly to the hoist wire.

During manriding operations, care must be exercised to ensure that the person being lifted is not put at risk of being jammed under any obstructions.

The Company does not mandate the use of secondary fall protection during manriding operations. However, all client and regulatory requirements must be complied with.

Hand signals must be used as the primary means of communication for all manriding operations. If, at any time, hand signals cannot be used as the primary means of communication, the written THINK Plan for manriding must be reviewed and further risk assessment performed. Following this review the department supervisor must re-approve the written THINK Plan.

Manriding operations require a minimum of three trained and competent personnel: a winch operator, a person suspended in the manriding harness, and a dedicated person whose sole duties are to watch the person in the riding harness and signal the winch operator using appropriate hand signals. Radios may be used only as a means of communication for conveying information concerning the task, not for signaling the winch operator.

Manriding underneath the drill floor in the moonpool or cellar deck area using a winch from the drill floor is prohibited.

Controls must be in place to prevent the risk of any objects being dropped. All tools and equipment carried aloft must be tied off at all times.

No other equipment may be lifted, simultaneously, utilizing the same hoist.

All air tuggers must be operated according to the manufacturer's instructions and fitted with drum guards and control levers that are clearly marked "Up" and "Down."

Wire rope clips or grips must not be used on manriding equipment.

The winch operator must not leave the controls at any time during a manriding operation.

Personnel must not ride on a crane's hook, sling or load.

A person other than the one being lifted must visually inspect the harness for proper fitting and safe attachment to the lifting wire before manriding.

LIFTING EQUIPMENT USED FOR LIFTING PERSONS

Due to the risk of personal injury during lifting of personnel, lifting equipment used for lifting personnel must be certified for the purpose.

During the THINK Planning stage of all tasks where the lifting of personnel is required, controls must be utilized to reduce the likelihood of an incident occurring from people from being crushed, trapped, struck by or falling from the equipment. “Rescue from Heights” must be part of the THINK plan when lifting of personnel is involved.

Personnel being lifted must utilize fall protection when working inboard the installation or from a Spider basket. The use of fall protection equipment is not a requirement when utilizing a totally enclosed elevator in the derrick, column, accommodation, and so on.

If access doors are fitted to the carrier they should not open outwards and should be fitted with a device to prevent inadvertent opening. A means of rescue must be available on the installation in the event of loss of power or malfunction of the lifting equipment.

STABBING BOARD

See Fall Protection, Section 4 Subsection 5.5, paragraph 4.12.

SCISSOR LIFTS / BOOM SUPPORTED WORK BASKETS

Personnel utilizing scissor lifts and boom supported work baskets must be trained in their safe operation. There must be a standby man at the worksite to monitor operations and they must be in constant verbal and visual contact of the personnel operating the equipment.

Controls must be utilized to prevent the Scissor Lift or Boom Supported Work Basket from being struck by other lifting equipment or load.

Scissor lifts and Boom Supported Work Baskets must be fitted with an emergency stop at the control points. These stops must be easily reached and actuated.

Scissor lifts must not be moved while in the elevated position.

Scissor lifts must be stabilized and located on a solid, level foundation to prevent them from rocking or moving due to weather conditions and/or vessel motion.

Risks to assess as part of the THINK planning process before and while monitoring the task include but are not limited to the following:

Electric shock – contact between lifting equipment and electrical wiring

Caught between – piping, beams, overhead walkways, cables, and so on

Tipover – inadequate stabilzation, equipment failure, struck by external force, exceeding rated capacity of equipment

Falls – thrown from basket by lift striking against fixed structure or struck by, personnel overreaching from basket

Struck by – dropped objects

PERSONNEL ELEVATORS

All personnel elevators must be included in the planned maintenance system and the lifting gear register. These must be inspected by specialized third party personnel.

TUGGER AND CRANE HOISTED WORK BASKETS

When utilizing a work basket, the total weight of the basket, equipment and personnel must be determined to ensure the safe working load of the lifting appliance is not exceeded. Grab rails must be fitted inside the basket to prevent personnel exposing their hands to caught between/crush points.

Personnel riding in the basket must use fall protection unless working over the water. Consideration should be given to utilizing a tie off point independent of the basket.

SPIDER BASKETS

When utilizing a spider basket, the total weight of the basket, equipment and personnel must be determined to ensure the safe working load of the lifting appliance is not exceeded. Grab rails must be fitted inside the basket to prevent personnel exposing their hands to caught between/crush points.

Personnel riding in the basket must use fall protection.

DRILL LINE

A drilling line record containing the line certificate or origin, service date, slipping and cutting details, as well as record of inspections must be kept on all installations.

After slipping and cutting, the crown-o-matic must be reset and tested.

The line pull reading must be available at all times by a maintained and calibrated weight indicator.

No part of the drilling line must be in contact with the metal components of the installation that may damage the cable.

A visual inspection must be carried out by a competent person after an operation involving work that may have caused extra wear and tear on the drilling line (jarring, fishing, running heavy casing, and so on).

During slip and cut operations the travelling equipment (blocks and hook) must be properly secured so that inadvertent movement is not possible. (For example, with hang-off pendants)

Use of the weight of the drill string to facilitate slipping is prohibited.

PORTABLE LIFTING GEAR AND APPLIANCES

Hand-spliced wires and slings are not permitted.

WIRE SLINGS

The following applies to wire sling certificates:

Wire slings delivered onboard must be provided with a certificate.

The certificates of scrapped wire slings must be destroyed.

The following applies to wire sling usage:

Slings in daily use must be inspected regularly for damage or overload.

Damaged slings must be destroyed and removed from the working area.

Slings must be protected against sharp edges, and so on.

Wire slings must be clearly identified with the SWL.

When slings are not in use, they must be stored in an appropriate place, protected against weathering.

No hammering or other use of force may be used on the ferrule.

Slings not recorded in the lifting equipment register must be kept separate from those tracked in the register (that is, client or transit slings that do not belong to the installation).

WIRE

The following must be followed when using wire:

Wire must be maintained according to vendor specifications, following the supplier's recommended safety factor.

Business Unit Management must establish inspection programs and discard criteria for all wire rope uses including anchor lines and standing rigging.

Wire drums must be inspected by a competent person before use. During operation, the wire must be regularly inspected by a competent person and replaced if damage or wear and tear makes further use unsafe.

When wire is removed due to damage or wear and tear, it must be clearly marked and removed from the installation.

Kinks and turns on wire must be avoided. Wire with a kink or turn must be replaced or re-terminated.

Wire must always be secured to the winch drum with at least five wire wraps on the drum when in use.

(See Technical Information Bulletin: HQS-OPS-TIB-905-01 Crane Wire Rope – Maintenance, Inspection and Rejection Criteria for further guidance)

WEB SLINGS

Slings made of synthetic fiber may be used in special cases, for example lifting of chromium pipes, special drill pipe, engine cylinder heads, and so on. A Permit to Work must be issued for their use.

The storage and handling of webbing slings must be strictly controlled to conserve condition and prevent contamination.

Exposing webbing slings to sharp edges and chemicals must be avoided.

All web slings must be discarded after one year in service with the exception of special application slings.

EYE BOLTS

Loose eyebolts screwed into holes provided in the equipment to be lifted, must have sufficient strength and be screwed entirely in and correctly oriented.

Perform the lifting on the eye as vertically as possible in order to prevent bending and eventually breaking the eyebolt.

BARREL SLINGS

Barrel slings must be certified and marked with their SWL.

For lifting barrels made of plastic or PVC, do not use the conventional barrel slings of chain and hooks. Using a net, basket or specialized device is recommended.

HOOKS

The use of open-ended pipe hooks is prohibited.

Slings or positive locking pipe hooks must be used when lifting casing by the box and pin ends with a crane within the confines of the installation.

Pipe hooks may not be used for loading/off loading of tubulars to or from a supply boat. All tubulars must be pre-slung.

RE-TERMINATING WIRES ONBOARD

Any wires that have been re-terminated onboard must be load tested, documented and authorized for use.

The re-termination of wires onboard using composite resin is permissible provided the person carrying out the operation is competent and follows the correct procedures detailed by the manufacturer.

ALL OTHER LIFTING GEAR AND APPLIANCES (CHAIN BLOCKS, SNATCH BLOCKS, TROLLEYS, SHACKLES, AND SO ON.)

Must be marked with SWL.

Chain Blocks must be included in the planned maintenance system of the installation.

Any damage detected must be reported and appliances taken out of service for repair.

CRANE AND LIFTING OPERATIONS

When planning all crane and lifting operations the hazards must be identified and the risk reduced. The factors that must be considered include:

The type of load being lifted, its weight, and shape (wind effect).

The preventive controls to reduce the likelihood of a load falling or striking a person or object and the mitigating controls to reduce the consequences.

The preventive controls to reduce the likelihood of the lifting equipment falling, striking a person or some other object and the mitigating controls to reduce the consequences.

The selection of the lifting equipment to reduce ergonomic risk.

Operating limits of lifting equipment (static and dynamic loading).

Inspection of lifting gear for defects prior to use:

− Special straps – damaged, cut, abraded or stretched;

− Chains – deformed or stretched links, cracks; and

− Wire ropes – broken wires or kinks.

A Lift Plan or checklist should be considered to ensure all hazards have been identified and risks reduced. For more information on Lift Plans see HQS-HSE-HB- 01 Lifting Operations Handbook.

CRANE OPERATORS

Crane Operators must verify correct rigging arrangements prior to all crane lifts. Crane Operators must individually demonstrate their knowledge by answering

questions given to them by the OIM or designee. The subjects must include but are not limited to the following:

Hand signals

Appropriate use of a radio during lifting operations

Handling of the load

Attaching the load

Moving the load

Holding the load

Operating practices

Daily, weekly, or monthly crane maintenance

Personnel transfer

Demonstrating the proper use of load charts at different angles

Each Crane Operator must be certified for the type of crane to be operated, by a Company approved instructor meeting Company specified criteria.

Each Crane Operator must complete the ‘OJT’ Module for Crane Operator prior to demonstrating their knowledge to the OIM.

The OIM must authorize Crane Operators to operate cranes on the installation. A list of authorized crane operators must be available at the worksite.

Only competent Crane Operators are authorized to operate cranes on Company installations or facilities. Exceptions, however, are made for the training of new Crane Operators or in connection with maintenance work.

Only Crane Operators authorized by the OIM can train or instruct trainees. Trainee(s) must not operate the crane without an authorized operator present.

It is the responsibility of the Crane Operator to verify the weight of each load before proceeding with offload and backload to supply vessels by:

Reviewing Cargo Manifest to identify weight of loads,

Communicate with supply vessel or supervisor on deck to verify the load being lifted is the correct item listed on the manifest and,

When initially lifting the load monitor weight indicator to verify weight of load is as expected, if not load is to be lowered and landed immediately.

Crane Operators must be able to clearly communicate with the handling crew, only one of which may be designated as the banksman. If the crane operator receives instructions or signals from more than one person at a time, the crane operator must interrupt the operation. If the Crane Operator cannot see the banksman at any time when the load is being moved, he must immediately interrupt the operation and only resume when he has re-established visual contact with the banksman.

BANKSMAN

The Banksman will have no other duties while so assigned. Banksmen may not participate in simultaneous operations (for example, supervising the lift while supervising boat operations alongside the installation). For boat operations it may be necessary to assign a banksman for the boat as well as a banksman on the installation.

The designated banksman must be easily identified as such (for example, wearing a special color vest).

The designated banksman shall not be both banksman and rigger. It is the banksman’s responsibility to:

Check the area around the load to be lifted to ensure it is clear and the load is not attached to the deck, transportation cradle, or adjacent equipment.

Continuously monitor lifting operations to retain an overview at all times.

Be aware of any obstructions within the crane’s radius and working area.

Be aware of potential snagging points in the vicinity of the load while hoisting and lowering loads by checking above to ensure that the crane’s hoist wire rope, boom tip, and hook block assembly attachments have a clear unobstructed passage.

Ensure prior to lifting the load that it is not secured to the deck, transportation cradle, or could become entangled in adjacent equipment.

Ensure that tag lines in use are not secured or tied off to adjacent equipment or structures.

The banksman must not become involved in physically handling lifts. The Crane Operator must interrupt the operation immediately if this occurs.

Only personnel that have successfully completed a Company approved rigging practices course may be assigned as a banksman.

CRANE OPERATIONS

Hand signals must be used as the primary means of communication for all crane signaling. Radios may be used in conjunction with hand signals, but they are considered secondary. Boom cameras may not be used as a means of communication.

Hand signals used on all installations must be available and must be understood by every person involved in crane and lifting operations.

Conditions that may require exclusive reliance on a secondary means of communication (handheld radios) are:

Environmental conditions that impact the effectiveness of hand signals.

Blind lifts associated with rig design. (See HQS-OPS-TIB-461-01 Technical Information Bulletin for Deck Crane Boom Cameras)

(A crane boom camera can be used as a tool to view the proximity of the lift to personnel and the surrounding area. Use of the camera for the purpose of maintaining visual contact with the banksman’s signals or in lieu of a banksman is prohibited.)

If a secondary means of communication (handheld radios) is used in lieu of hand signals, a written THINK plan must be conducted by the supervisor responsible for the operation.

The crane must not be used for operations where the angle indicates that damage may occur to wires or sheaves.

The crane boom must not be used as a ladder or gangway. Personnel performing work on the crane boom must always address the hazard of falling.

All hooks on the travelling blocks, whip line and safety slings must have positive locking safety latches that are in good working order.

When a crane is shut down, all controls must be left in the neutral position and the brakes locked. Where applicable, the rotation lock must be engaged at all times when the crane is unattended.

CRANE EQUIPMENT AND MAINTENANCE

Cranes must be fitted with a minimum of:

Communication systems that must allow:

Attracting of personnel's attention (for example, with a horn)

Verbal communication to personnel (for example, loudspeaker system)

Two-way radio communication (for example, VHF radio communication to communicate with deck crew, supply boats and control room)

Load and radius charts

Radius indicator

An over-boom limit switch

An under-boom limit switch

Anti-two-block limit on the main line and fast line

A load watcher giving a continuous indication of the hook load and rated load for each radius (The indicator must give a clear and continuous warning when approaching the rated capacity of the crane)

A portable fire extinguisher suitable for class A, B, and C fires

Operating controls clearly labeled as to function (in English and the predominant local language) and the label visible to the operator during all hours, day or night

Emergency stop device (ESD)

Routine maintenance of cranes must be performed in accordance with a planned maintenance system. A crane log book must be maintained and include as a minimum:

Record of maintenance performed

Wire rope installation dates

Safety device inspection dates

Certificate and reel number of wire currently in use

Depending on the crane design and manufacturer's recommendations, crane wires may need to be replaced annually.

BOP CRANES, BOP HANDLERS, PIPE HANDLING CRANES, GANTRY CRANES AND OVERHEAD TROLLEY/BEAM MOUNTED CRANES

Only competent operators are authorized to operate BOP cranes, BOP handlers, pipe handling cranes, gantry cranes, and overhead trolley/beam mounted cranes at Company installations and facilities. Exceptions are made for the training of new operators, or in connection with maintenance work.

Cranes which operate on rails located at deck level (main deck or elevated level) must be provided with audible and visual warnings which alert everyone in the area when the crane is traveling.

All overhead crane operations must have a designated operator. The operator will not be involved in material handling/ positioning of loads while operating the crane.

All overhead crane operations will have, in addition to the designated crane operator, one employee designated for monitoring/positioning the crane load.

If material handling/positioning is required, tag lines must be used, (for example, If you anticipate you will have to put a hand on the load during the operation – Use a tag line).

All cranes must be fitted with an emergency stop device (ESD) at the level of the rails accessible by personnel in the area.

ISO LIFTING BLOCKS

Any cargo carrying unit fitted with ISO lifting blocks must not be modified without engineering approval.

All lifting gear used in conjunction with ISO lifting blocks must be fit for purpose. For additional information on sling configuration and ISO containers.

FORKLIFTS

All installations and facilities must carry out training unique and specific to the forklift(s) found there. The training must cover both theory and practical demonstration. (See Section 4 Subsection 1.3) A record must be kept of this training.

The OIM must approve the content and instructors for all forklift training given onboard.

Only competent forklift operators who have completed Company approved training are authorized to operate forklifts. A list of competent forklift operators must be available at the work site.

Forklifts must be maintained and rated to meet the zone classifications of the area in which they are to operate.

FORKLIFT EQUIPMENT

Forklifts must be fitted with a minimum of:

A permanently fitted means to prevent the load falling from the forks/mast onto the operator or controls.

An overhead guard to protect the driver from falling objects.

An audible warning for reversing.

A visual warning in noisy areas.

A reversing mirror

A means to prevent forks from going over height.

A portable fire extinguisher.

Operating controls clearly labeled as to function (in English and the predominant local language) and the label visible to the operator during all hours, day or night.

FORKLIFT OPERATIONS

The forks must be lowered to the lowest practical position to provide maximum view and stability. The mast must be tilted backwards to increase load stability.

Forklifts may not be used for the transport of personnel.

Forklifts should only be used on flat, level surfaces and must carry loads within their rated capacity.

Drivers must pause before doorways then proceed slowly through.

Forklifts should be driven in reverse when high loads restrict forward vision. Drivers must not drive over unprotected cables, pipes, and so on.

When left unattended, forklifts must be in neutral with the parking brake on, the forks lowered and the power switched off.

Forklifts should not be parked in an enclosed area with the engine running.

If a forklift was manufactured with a seat belt, one must be fitted and worn by the operator while the forklift is in use.

A basket engineered and manufactured for the purpose of lifting personnel may be used to lift personnel to perform routine maintenance work. This may take place when other means of access are considered impractical, and only after a documented risk assessment (Written THINK Plan as a minimum) has been performed and signed by the OIM or designee. This basket must be treated as a piece of lifting equipment and inspected as such.

RESPONSIBILITY

ALL PERSONNEL:

LIFTING EQUIPMENT:

Prior to using equipment, be trained in the rigging practices and load handling methods used for that equipment.

Have working knowledge of its capabilities and any defects likely to arise in service.

TUGGER OPERATIONS:

Stand clear of all wires, ropes and moving equipment.

Direct full attention to the operation at hand.

Maintain clear visual contact with the operation. If this is not possible, a banksman must be deployed.

Stand in a safe position that is easily visible, but will not affect the operation.

Always keep the equipment under observation.

Stand on the correct side of the tugger when operating the controls.

Never leave the winch running unattended.

Never stand on the machinery to get a better view.

Never exceed the SWL of the wire/winch in use.

Never touch the wire by hand.

MANRIDING OPERATIONS

The person in charge of the manriding area must nominate only trained personnel to perform the manriding operations. In the case of manriding in the derrick, a permit to work must be issued prior to the operation commencing

Everyone involved in winch/tugger operations must have successfully completed the manriding awareness training.

Personnel being lifted must wear a Company approved full body harness that is in good condition.

FORKLIFT OPERATOR:

Complete the Company approved awareness training course (RSTC toolbox).

If additional training is required to meet regulatory requirements then this must be taken prior to operating a forklift.

Complete installation/facility forklift training, both practical and theory, that is unique to the equipment on the installation or at the facility.

BANKSMAN:

Do not perform other duties while so assigned.

Do not participate in simultaneous operations.

Successfully complete a course in rigging practices prior to being assigned as a banksman.

CRANE OPERATOR:

Know the weight of cargo before proceeding with the lift.

Clearly communicate with the handling crew.

Must be able to clearly communicate with the handling crew, only one of which may be designated as the banksman.

Must interrupt the operation if he receives instructions or signals from more than one person at a time.

Must immediately interrupt the operation if he cannot see the banksman at any time when the load is being moved.

Must only use the crane boom camera as a tool to view the proximity of the lift to personnel and the surrounding area and not for the purpose of maintaining visual contact with the banksman’s signals.

Perform maintenance tasks required in the installation’s planned maintenance system.

MAINTENANCE SUPERVISOR

Ensure maintenance tasks are carried out on cranes, hoists and so on.

OIM:

Authorize Crane Operators to train or instruct trainees.

Approve risk assessments in the event that hand signals cannot be used as the primary means of communication during any manriding operation.

Approve risk assessments for any operations involving any purpose-made lifting basket to lift personnel in connection with routine maintenance work.

Ensure a list of authorized crane operators is available at the work site.

Ensure a list of authorized forklift operators is available at the work site.

Approve the content and instructors for all forklift training given onboard the installation.

Ensure that a Lifting Equipment Register is maintained on the installation.

BUSINESS UNIT/DIVISION TRAINING MANAGER:

Ensure that Company approved training meets the requirements of local regulatory bodies. If conflicts exist, training must be made available to personnel which satisfies both Company and regulatory requirements.

Where there is conflict between Company approved training and regulatory requirements then this must be brought to the attention of Business Unit management.

DIVISION MANAGER / BUSINESS UNIT OPERATIONS MANAGER:

Ensure that a Lifting Equipment Register is maintained at the facility.

Approve all non Company required training (Regulatory, Client).

Ensure all installations and facilities have established forklift training that is unique to the equipment found there.

DOCUMENTATION

The Crane Signals (Figure A) is included in the manual to illustrate the type of hand signals which all personnel involved in Crane operations must be aware of for their primary means of communication. It is included in the manual as an example only and is intended to allow operations to take advantage of a preset informative poster. It is not mandatory that these actual signals are used on an installation/facility It is mandatory that “hand signals to be used” are approved by Business Unit Management and that these are clearly understood and posted at the installation/facility. The signals approved by Business Unit Management must include key elements of the Crane Signals (Figure A) included in the example shown.

The Manriding Signals (Figure B) included in this manual are mandatory and are not to be modified from the original format. Personnel involved in manriding operations must be aware of them, utilize them and they must be clearly posted in appropriate areas.

A register of all lifting equipment must be maintained and documented for the installation/facility (normally supplied by lifting equipment inspectors following annual inspections).

Figure A

Figure B

IMPLEMENTING AND MONITORING

Hazardous Materials

POLICY

All hazardous materials must be identified, labeled and effectively controlled at any installation or facility. Hazardous Material Identification System (HMIS) information concerning this material must be available at the installation or facility.

PURPOSE

The purpose of this policy is to heighten the awareness of personnel and reduce exposure to harmful effects associated with hazardous materials onshore and offshore.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

Great care must be exercised to protect personnel when being exposed to hazardous materials, which includes substances that may have an adverse effect on health or the environment.

Personnel who are required to handle hazardous materials must be made aware of the hazards, the nature of the material, risks created by exposure, safe handling instructions, precautions to be taken, use of PPE, emergency procedures and proper storage instructions for the materials.

TRAINING

All personnel must be given Company approved hazardous materials awareness training. This training must be given in an organized manner and fully documented. (See Section 4 Subsection 1.3)

At least one materials person that has attended a Unit approved course in the handling/shipping of hazardous materials must be onboard at all times. (See Section 4 Subsection 1.3)

MATERIAL SAFETY DATA SHEETS (MSDS)

A MSDS must be available for use in the THINK plan prior to offloading any hazardous materials onto an installation or at a facility.

A system that ensures up to date MSDS are available for all hazardous materials being used or stored at the installation or facility must be in place and maintained by the Installation Medical Person.

MARKING AND STORAGE

Hazardous materials must be labeled to indicate the name or trade name of the material, and the Hazardous Materials Identification System (HMIS) information. This information must be in English and the predominant local language.

Hazardous materials must be stored in dedicated areas that have adequate containment facilities. Products that may react with one another must be separated. (See Section 5.1)

During storage, all hazardous material must be arranged so HMIS markings are clearly visible.

Food goods must be stored away from any chemicals or other hazardous materials. Oxidizing agents, such as nitric acid, must be stored away from combustible

materials.

When products covered by this procedure are packaged for shipment, the trained materials person must supervise the work and the following must be observed:

Products that may react with one another must be separated.

All material must be properly secured.

If a container is used to ship more than one material, it must be marked with the symbol for the most hazardous material stored within the container.

The cargo manifests must indicate the following in sequential order: (proper/scientific) shipping name, hazard class, identification number UN #, package group (S.H.I.P.).

Hazardous materials/waste must appear first on the manifest, or be clearly identified by use of a box or “Hazardous” column. Additionally, the S.H.I.P. must be the only entry on the first line. Additional lines below the S.H.I.P. may be used to describe the product for internal or third party ease.

Figures C and D are examples of HMIS information.

Figure C, HMIS Poster

Figure D, HMIS Label

INVENTORY CONTROL

A system must be developed and maintained to ensure that the OIM or designee is aware of the location of all types and quantities of all hazardous materials that are onboard the installation or at any facility. The inventory of hazardous materials must be regularly checked.

The Hazardous Material Identification System (HMIS) must be used to ensure that relevant information from MSDS concerning the handling and use of hazardous material is readily available in the storage and handling areas and MSDS referred to as required for additional information.

The inventory of hazardous materials by location and type must be made available to the Emergency Response Teams.

HAZARDOUS MATERIALS/WASTE

Basic principles covering the handling of hazardous materials/waste include the following:

Hazardous materials/waste must always be identified as such and must be labeled or placarded.

Hazardous materials/waste that may react dangerously when mixed must be stored/handled separately.

Hazardous materials/waste must only be stored in clearly marked specific containers, which must be sent ashore for disposal.

WORKING WITH HAZARDOUS MATERIALS

Before using any material, personnel must:

Refer to the HMIS for storage and handling information.

Read the labels on the containers.

Be aware of the relevant information from MSDS.

Check for warning signs or special instructions posted in the area.

WORKING WITH HAZARDOUS MATERIALS

Before using any material, personnel must:

Refer to the HMIS for storage and handling information.

Read the labels on the containers.

Be aware of the relevant information from MSDS.

Check for warning signs or special instructions posted in the area.

A THINK plan must be conducted before hazardous materials are unloaded from supply vessels and the relevant information from MSDS or HMIS specific to the chemicals must be discussed and understood by all personnel involved in the operation.

Containers and sacks should be inspected for leaks, rips or tears prior to use.

Sacks should be set down easily to prevent tearing. Sacked material should be placed with the mouth of the sack toward the inside of the pile when stacking.

Empty sacks must be disposed of properly and excess chemicals cleaned up. On completion of the work, residue on gloves, boots, aprons and other protective clothing should be appropriately cleaned. When necessary, personnel involved should take showers as soon as possible after completion of the work.

Emergency eyewash stations and emergency showers must be strategically positioned in areas where personnel are likely to be exposed to hazardous materials.

Proper safety precautions must be followed when working with flammable solvents. There must be adequate ventilation in enclosed spaces.

The use of solvents to clean hands or skin is not permitted. If clothes become soaked with solvent, they must be removed and a shower must be taken.

Personnel must not eat, drink, or touch eyes, nose or mouth after handling hazardous materials without first washing hands with soap and water.

RADIOACTIVE MATERIALS, EXPLOSIVES, DANGEROUS LIQUIDS AND GASES

The handling of explosives, radioactive materials, dangerous liquids or gases must be controlled by the Permit to Work system and only done by approved personnel.

The OIM/Facility Manager must be responsible for the placement and security of any such materials brought onboard an installation or to a facility.

All such materials must be stored in an approved and secured area away from passageways, living quarters or areas that are usually manned. Storage containers must be closed and locked at all times and clearly identified with appropriate labels.

All such storage areas must be clearly marked and designated as an approved storage area.

Amounts of the previously mentioned materials stored onboard an installation or at a facility at any given time must be kept to the minimum required to carry out operations. Amounts must be known by the OIM/Facility Manager, and an inventory maintained.

WORKING WITH DANGEROUS LIQUIDS

All work involved in the transfer of concentrated acid and other such dangerous liquid requires a Permit to Work.

Sufficient personnel and equipment must be assigned to the operation to effectively contain a significant leak.

All assigned personnel must wear appropriate protective clothing, such as resistant suits, rubber boots, gloves and face visors.

All transfer equipment must be pressure tested before introducing dangerous liquid into the system.

All areas where pumping equipment is located (including flow lines) must have a barrier, and warning notices must be posted prohibiting unauthorized access.

Flow lines must be secured before introducing dangerous liquid.

An isolation valve must be located near, but not underneath, the holding tank and a member of the work party stationed nearby. The valve must be closed if a leak develops in the system.

Water hoses must be run to appropriate work locations before pumping the dangerous liquid, and the water supply must be checked.

Spill trays must be provided at all critical points within the work area.

Storage containers should have suitable means for safely extracting the contents. Dangerous liquids must only be used in open or well-ventilated areas.

FLAMMABLE LIQUIDS

Flammable liquids such as gasoline, diesel or helicopter fuel must not be used for cleaning purposes. Non-flammable products must be used, preferably non-toxic and biodegradable.

Storage areas must have containment facilities to prevent spillage and minimize fire hazards.

CONTAINERS

All bottles, drums or other such vessels must be clearly labeled with contents and appropriate warning notices. This information must be in English and the predominant local language.

Empty drums must be kept in a secure area until they can be shipped ashore.

45/55 gallon drums must not be modified in any way or used other than originally intended; they must not be used for trash, work platforms, storage of protectors, and so on.

Hot work must never be performed on or near any drum or other container that contains or previously contained hazardous materials.

PAINT

All paint products and thinners must be stored in closed containers and stored in designated paint lockers.

Paint lockers must be in designated areas and marked with appropriate safety signs and warnings.

The paint locker must be an enclosed space with:

A fire detection system.

A fixed fire extinguishing system.

An explosion-proof fan.

Firefighting instructions clearly posted in English and the predominant local language.

Painting in an unventilated area is not permitted without the use of air-supplied respirators.

When using spray equipment, painters must wear filter masks, goggles and further appropriate PPE. Exposed skin must be coated with barrier cream as a minimum.

ASBESTOS

A survey must be conducted to determine the extent of asbestos at any installation or facility. The results must be documented and retained, and made available upon

request. Steps must be taken to identify and clearly mark any asbestos or Asbestos Containing Materials (ACM) at Company installations and facilities.

All personnel must be made aware of the hazards of asbestos exposure. (See Section 4 Subsection 1.3) Personnel must be made aware of the extent of asbestos if there is any at the installation or facility.

Only certified qualified subcontracted personnel can perform the removal of asbestos or remedial work that may disturb otherwise encapsulated or non-friable asbestos.

Disturbance or removal of materials that contain the unique material properties of asbestos or ACM, must only be done, if:

The Company employee performing the work has a valid training certificate qualifying the employee in asbestos removal.(See Section 4 Subsection 1.3)

All the regulatory mandated safety equipment is available.

The work area is completely isolated and warning signs posted.

A Permit to Work is complete.

RADIO SILENCE

Radio silence must be required when there is a risk of accidental activation of explosive materials from radio/electrical transmissions.

Radio silence normally occurs in conjunction with an operation that requires a Permit to Work (for example, use of explosives).

The OIM or designee must coordinate the preparations and the monitoring of the period of radio silence.

The following must be adhered to whenever an installation is required to enter a period of radio silence:

The person requiring radio silence (for example, wireline operator) must inform the radio room well in advance that radio silence is required. This is to ensure that all potential hazards associated with radio silence can be addressed.

When radio silence has been requested, the Radio Operator must inform the OIM so an assessment can be made of the safety implications associated with suspending the installation communications at that time (for example, supply vessel alongside, divers in the water, helicopter due, and so on.)

Suspend all hot work, work over the side, or any other work covered by the Permit to Work system that may affect or be affected by a safe period of radio silence.

Isolation performed, tags posted and reporting of the following must be completed:

Welding plants

Crane radios

Lifeboat radios

Top drive

Impressed current systems (this does not include anti-fouling/corrosion reduction systems for internal pipe work)

Radar

Portable gas detectors (if not intrinsically safe)

All portable VHF and UHF sets to be returned and checked (subcontractors, such as divers, must ensure all their portable and fixed radios are accounted for and immobilized).

Ensure all cellular telephones are switched off.

Inform standby vessel to proceed outside the 500m zone and act as a guard ship while maintaining radio watch on VHF Channel 16 and any additional frequencies which may be in use in the field such as, company radios and helicopter air band radios.

All data communications (including wireless) must be suspended. (Microwave link may be maintained.)

Supply vessel operations to be suspended.

Dependent upon the location, all installations in the vicinity are to be informed. This is of vital importance if the installation is involved in combined operations with another installation.

Radio Operator must send via telex, fax, email, or phone a notice advising of radio silence, giving the approximate length of time the installation must be in radio silence, to the following parties:

Division or base office

Client

Helicopter company

NOTE: If a helicopter is in the air and inbound for the installation, radio silence must not commence until the helicopter has departed the installation.

A second telex, fax, email or phone call must be sent when the installation is out of radio silence.

Radio Operator must make a general broadcast on:

Appropriate local frequencies.

Channel 16 VHF.

The installation’s working channels.

All radio equipment (including satellite communications) in the radio room/control room must be isolated.

Before entering radio silence, a PA announcement must be made advising all personnel that the installation is entering radio silence, stating that use of all radios and welding equipment is prohibited until further notice.

On completion of radio silence, a PA announcement must be made advising all personnel that the installation is out of radio silence.

All periods of radio silence must be recorded in the installation's radio and marine log.

A Radio Silence THINK Checklist should be used to ensure radio silence is achieved.

RESPONSIBILITY

ALL PERSONNEL:

Receive Company approved hazardous materials awareness training.

Before using any hazardous material, personnel must:

Refer to the HMIS for storage and handling information.

Read the labels on the containers.

Be aware of the relevant information from MSDS.

Check for warning signs or special instructions posted in the area.

Use the PPE stated on the HMIS placard as a minimum requirement.

RADIO OPERATOR:

Inform the OIM that radio silence has been requested, so an assessment can be made of the safety implications associated with suspending the installation communications.

Send via telex, fax, email, or phone a notice advising of radio silence, giving the approximate length of time the installation must be in radio silence, to the following parties:

Division or base office

Client

Helicopter company

Send a second telex, fax, email or phone call when the installation is out of radio silence.

Make a general broadcast on:

Appropriate local frequencies.

Channel 16 VHF.

The installation’s working channels.

Isolate all radio equipment (including satellite communications) in the radio room/control room.

Ensure all cellular telephones and wireless data communications equipment are switched off.

Before entering radio silence, make a PA announcement advising all personnel that the installation is entering radio silence, stating that use of all radios and welding equipment is prohibited until further notice.

On completion of radio silence, make a PA announcement advising all personnel that the installation is out of radio silence.

MATERIALS PERSON:

Attend a Company approved course in the handling/shipping of hazardous materials.

Ensure the packaging and manifesting for shipment of all hazardous material meets both company and regulatory requirements.

Ensure that an applicable MSDS is received with all hazardous materials received at the location.

Ensure MSDSs for received Hazardous materials are forwarded to the Installation Medical Person.

INSTALLATION MEDICAL PERSON:

Maintain the system at the installation that ensures up-to-date MSDS are available.

OIM:

Ensure a THINK plan is conducted before hazardous materials are unloaded from supply vessels and the relevant information from MSDS or HMIS specific to the chemicals is discussed and understood.

Ensure subcontractor personnel handling hazardous materials have applicable training and documentation to handle explosives, radioactive materials, dangerous liquids and gasses and approve those personnel to handle these materials at the installation or facility. (See Section 4 Subsection 2.3)

Be responsible for the placement and security of any explosives, radioactive materials, dangerous liquids or gases brought onboard an installation or to a facility.

Ensure a survey is conducted to determine the extent of asbestos, the results are documented and retained, and made available upon request.

Coordinate the preparations and the monitoring of the period of radio silence.

Ensure all periods of radio silence are recorded in the installation's radio and marine log.

BUSINESS UNIT TRAINING MANAGER

Ensure Company approved training for shipping of hazardous materials meets the requirements of local regulatory bodies. If conflicts exist, training must be made available to personnel which satisfies both Company and regulatory requirements.

Approve the selection of asbestos awareness training and ensure the training includes an installation/facility specific briefing on the extent of asbestos, if there is any, at the installation or facility.

DOCUMENTATION

The forms indicated below are included in the manual as examples only and are intended to allow operations to take advantage of a preset form rather than having to create their own. Use of these forms is not mandatory. However, if the examples are not used exactly as included, the forms used must include the key elements of the examples and must be approved by the Business Unit Vice President.

Radio Silence THINK Checklist (Figure A)

(Must be retained in the installation files for a period of one year.)

S.H.I.P. Manifest (Figure B)

(Must be retained in the installation files for a period of one year.)

Figure A, Radio Silence THINK Checklist

Figure B, S.H.I.P. Manifest

IMPLEMENTING AND MONITORING

Personal Impairment

POLICY

When physical, mental or emotional impairment is recognized, it must be managed.

PURPOSE

The purpose of this policy is to reduce the risk of incidents caused by an individual’s impairment.

SCOPE

This policy covers all Company personnel.

PROCEDURE

Ineffective communication can lead to impairment. It is of utmost importance that effective understanding is established by treating people as THEY need to be treated.

DETERMINING IMPAIRMENT

Efforts must be made to ensure that personnel are not allowed to work while impaired physically, emotionally or mentally.

Some forms of impairment can be difficult to recognize by people other than the person affected. Personnel must be actively encouraged to alert their supervisor or co-workers if they feel they are unable to perform their duties at full capacity.

Any person who suspects a co-worker to be impaired in any way must bring the situation to the attention of the supervisor in charge.

Should any form of impairment be identified or suspected, the person affected must be assessed and given immediate appropriate care. The person must not return to normal duties until the impairment has been dealt with and no longer adversely affects or puts at risk the individual, others, the environment or Company property.

PHYSICAL IMPAIRMENT

Physical impairment could be caused by an unknown or unreported injury, illness or fatigue, returning to active duty too quickly after an injury, illness, exposure to

extreme temperatures, excessive working hours or numerous other issues which can effect a person’s physical capabilities.

All working hours must be monitored. Work should be planned and resources allocated to ensure additional working hours are not required. If this is not possible, any requirement for personnel to work additional hours must be approved by the OIM/Facility Manager/Office Department Head.

0 – 12 Hours No additional authorization required

12 – 16 Hours Agreement of supervisor, authorization by OIM/Facility Manager/Office Department Head

Over 16 hours Abnormal Circumstances – Agreement of supervisor, authorization by OIM/Facility Manager/Office Department Head.

For any person to work in excess of a 16 hour continuous period the following factors must be considered:

The nature of the demands (physical and mental) during both the previous 16 hours.

The nature of the demands (physical and mental) for the extended work period.

The working environment – noise, temperature, and weather conditions.

Type of work – supervisory, administrative, or manual.

Self supervision or working alone.

Is the task HSE critical?

Personnel must have a minimum 6 hour rest period after any extended work period.

EMOTIONAL IMPAIRMENT

Emotional impairment could be caused by severe rage, upsetting news from home or the work place, depression, excitement, or other emotions.

Each Business Unit must have a system in place to identify when grief counseling may be needed. If a need for grief counseling is identified, it should be provided for personnel as soon as practicable.

MENTAL IMPAIRMENT

Mental impairment could be caused by improper managing of any physical or emotional issues, fatigue, stress, phobias, obsessions, medicines, and mind altering substances such as alcohol, drugs, vapors, caffeine, nicotine, etc.

RESPONSIBILITY

ALL PERSONNEL:

Immediately bring any recognized impairment to the attention of the supervisor in charge.

ALL SUPERVISORS:

Immediately notify the OIM/Office Department Head when anyone is recognized as impaired in any way.

Monitor working hours of personnel under their supervision and ensure any additional working hours are assesses and approved.

OIM/FACILITY MANAGER/OFFICE DEPARTMENT HEAD:

Assess and approve all requirements for additional working hours.

Manage impaired individual(s) with all available resources.

Notify the Installation Medical Person for evaluation of all suspected impairment cases.

BUSINESS UNIT OPERATIONS MANAGER

Ensure a system is in place to identify the need for grief counseling and initiate when identified.

DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

IMPLEMENTING AND MONITORING

Electrical Safety

POLICY

Only competent personnel authorized by the OIM may perform electrical work.

PURPOSE

The purpose of this policy is to protect personnel and equipment from the hazards associated with electricity.

SCOPE

This policy covers Company personnel, installations and facilities.

This policy also covers employees of any client, contractor or outside agency that work at any Company installation or facility.

PROCEDURE

For the purpose of this policy and procedure electrical systems and equipment includes electronic systems and equipment.

ELECTRICAL SAFETY

The OIM must designate a specific person as the electrical responsible person for the installation. Only personnel authorized by the electrical responsible person who have undergone approved electrical safety training and those under training may perform any work on electrical equipment. (See Section 4 Subsection 1.3)

All electrical faults must be reported as soon as possible to the electrical responsible person or designee.

All electrical systems and equipment must be installed, operated and maintained in a safe manner.

TOOLS AND PORTABLE APPARATUS

Ladders and steps used for working on electrical equipment must be constructed from non-conductive materials. (See Section 4 Subsection 5.3).

Hand held tools and portable apparatus may be subject to extreme abuse of insulation, which could allow the casing to become live. It is essential to use equipment that withstands the particularly adverse conditions found on an

installation; in addition, the importance of correct protection and grounding cannot be over emphasized.

All portable electrical equipment, including flexible cables and cords, must be permanently numbered and clearly identified with the last inspection date and regularly maintained through the planned maintenance system. Flexible cables and cords must be in a sound condition and not kinked or damaged in any way. All defective cables must be withdrawn from service.

All portable cables/cords, electrically powered portable equipment (drills, hand lamps, and so on) and portable receptacles must be used in conjunction with a ground fault circuit interrupter. The GFCI protection must be installed as close to the power source as practicable.

All test and calibration equipment must be maintained and checked for accuracy against independently certified calibration equipment.

The electrical responsible person must check all portable electrical apparatus or electrically driven equipment brought onto an installation for general condition and verification of “fitness for purpose.” (See Section 4 Subsection 2.3)

A system must be in place to ensure the safe use of personal electrical apparatus, for example, TV’s, video players, electric shavers, and so on.

All portable electrical apparatus (tools, leads, flexible cables, cords and crossovers, and so on) intended for use in hazardous areas must be of a type certified by an approved body for use in hazardous areas.

Approved air driven portable tools must be used in hazardous areas when portable electrical apparatus, tools, cross-overs, GFCIs, and so on, are not of the type certified by an approved body for use in hazardous areas.

When not in use, portable apparatus must be left switched off and disconnected from the supply. Portable equipment and flexible cables must be removed from the work area and suitably stored so they are not likely to cause or be damaged.

Portable electrical hand tools must not have the capability to be locked in the “On” position.

GENERAL

Metal watchstraps and conductive bracelets must not be worn when working on or near electrical components due to the hazards of electrical shock.

All entryways to switchgear rooms must have posted notices stating “Danger-High Voltage.”

Any instructions to make apparatus “live” or “dead” must be given verbally or written at the time and not by a pre-arranged signal.

No circuit breaker may be reset after a fault trip until the cause of tripping has been definitely ascertained, except at the discretion of the electrical responsible person.

Washing down electrical equipment using water is strictly prohibited. Extreme caution must be taken when washing down with power washers in the vicinity of electrical equipment.

All electrical motors must have an effective safety ground.

Switchgear rooms, transformer rooms and bays may not be used for general storage. The switchgear and floors of these rooms must be kept clear of all materials and obstructions.

Materials and equipment may be stored in switchgear and transformer rooms provided they are in purpose made containers and stored in cabinets or on shelving.

Access to electrical switchgear and transformer areas must be restricted to authorized personnel only.

Appropriate non-conductive mats must be placed in front of switchboards and transformers. These mats must be maintained in a clean and dry condition.

At least one pair of electrically non-conducting (dielectric) gloves must be available in each switchgear/ transformer room. These gloves must be inspected per the manufacturer recommendations and included in the installation’s planned maintenance system.

Switchgear installed in various spaces must be kept clear of obstructions and nothing may be stored on top of switchgear.

Flammable materials must not be stored or left in switchgear rooms

Only authorized persons may perform the testing and adjustments of safety devices.

All electrical panels and enclosures containing electrical switchgear must have their integrity fully intact, e.g. all securing bolts in place, redundant openings and glands sealed.

Redundant or spare cables must be properly terminated and marked for identification on both ends, or removed.

All cableways through bulkheads must be properly sealed.

Cable trays must be maintained to fully support the cable installation. Outlets must be marked to indicate voltage.

HIGH VOLTAGE

All personnel performing electrical work must be made aware of the special considerations involved with testing or performing work on high voltage.

High voltage is defined as voltage exceeding 1000VAC or 1500VDC. No repair work on live high voltage equipment may be performed.

To ensure high voltage systems are dead, testing may only be performed with use of a live line tester. A suitable risk assessment must be performed prior to this task.

All personnel performing work on high voltage systems must receive training by a Company approved instructor.

There must be two electrical personnel present while maintenance, testing or repair work is being performed on high voltage equipment.

When testing of live high voltage equipment must be performed, appropriately rated equipment with fused leads and probes must be used. High Voltage test equipment must be inspected prior to use.

To ensure that the risk to personnel is minimized all conductors should be grounded using grounding devices or leads applied to all points where the circuit or equipment is isolated from the supply. Additional grounds at the point of work may also be necessary if this is remote from the point of isolation. Additional grounds should be

applied ONLY after proving the circuit dead at the point of work. This procedure is essential for high voltage and stored energy equipment (containing capacitors). All grounding conductors and their connections must be rated for the potential circuit energy in the event of a failure of precautions.

ELECTRICAL EMERGENCY RESPONSE

RESCUE

A special insulated tool (Shepherd’s Hook) must be available in all switchgear/transformer rooms for the purpose of removing persons from live conductors. All relevant personnel must be trained in its use. (See Section 4 Subsection 1.3)

When working on switchgear not located in a designated switchgear/transformer room, a special insulated rescue tool and one pair of electrically non-conducting (dielectric) gloves must be made available at the work site.

FIRST AID

The specific procedures for treating persons suffering from electric shock must be displayed in all switchgear/transformer rooms. All persons engaged in electrical work must familiarize themselves with these instructions.

If a person suffers an electric shock, carry out the following:

Switch off current immediately; if not possible, do not waste time searching for the switch.

In High Voltage situations DO NOT approach the casualty until the power has been switched off. Safeguard yourself when removing a casualty from electrical contact. Stand on non-conducting material (rubber-mat, dry wood, dry linoleum) considering the level of voltage involved. Use rubber gloves, dry clothing and a special insulated tool to separate the casualty from contact.

Call for assistance.

Check for consciousness, breathing and pulse. If trained, start CPR as indicated.

FIRE FIGHTING

Fire fighting equipment using water or foam must not be used on electrical apparatus. Extinguishing agents suitable for dealing with fires involving electrical equipment and switchgear are, in order of preference:

Carbon Dioxide

Dry Powder

Class D type fire extinguishers

Fire fighting appliances containing any one of these agents may be used in the vicinity of live electrical apparatus provided that safe distances are kept between the extinguishers and live parts. It is preferable to switch off the current if possible. Since CO2 can prove toxic in confined spaces, everyone (including the person discharging the extinguisher) should withdraw immediately.

Note: All nozzle outlets must be of non-conductive construction.

PERMIT TO WORK

All electrical work in any designated hazardous area or areas in which an explosive gas mixture is likely to occur in normal operations, requires a Permit to Work.

If, for any particular reason, an electrical apparatus cannot be made dead and is considered hazardous to life, relevant precautions must be taken and a Permit to Work must cover the work.

ISOLATION (SEE SECTION 4 SUBSECTION 5.4)

Before work is carried out on remote or automatically controlled equipment (such as circuit breakers, motor driven equipment and emergency generators), isolation of fuses or disconnection of terminals must first render the automatic remote control feature inoperative.

Before any cable is cut it must be made dead, positively identified and, where practicable, grounded.

During failure of electrical supply, all apparatus, equipment and conductors must be regarded as being “live” until isolated and tested.

Electrical apparatus and electrically driven equipment must be made safe from any electrical source by the opening of the appropriate circuit breakers, fused isolators,

isolators, links or fuses and closing of earth switches or installation of approved grounds before any work is carried out on it.

All possible back feeds from the low voltage sides of power transformers, voltage transformers or auxiliary transformers must be isolated.

BATTERIES

Acid resistant protective clothing must be worn at all times when working with or immediately near batteries, however minor the work may be. Acid resistant protective clothing consists of suit, gloves and safety goggles in conjunction with a face shield.

Only approved insulated tools may be used to connect or disconnect cells. The insulation on these tools must be in good condition and checked before use. Non- insulated tools and metal objects must not be used near batteries.

No person working on batteries should work alone.

Before cells can be disconnected, battery chargers must be isolated. Before being disconnected, fully charged batteries should be allowed to stand at least 12 hours (24 where possible) after charging has ceased.

When a battery is being charged the potential exists for emission of hydrogen and oxygen gases. No naked lights should be used or any work done that may produce a spark near batteries on charge.

All efforts must be made to ventilate battery cabinets before work commences. Batteries must be disposed of properly (sent ashore for recycling when possible).

5 RESPONSIBILITY

5.1 ELECTRICAL RESPONSIBLE PERSON:

Authorize personnel to perform work on electrical equipment.

Check all portable electrical apparatus or electrically driven equipment brought onto an installation for general condition and verification of “fitness for purpose.”

Ensure all electrical PPE is available where required and in a safe working condition.

Verify equipment is electrically dead and any stored energy sources have been discharged.

PERSONNEL AUTHORIZED TO PERFORM ELECTRICAL WORK:

Familiarize themselves with instructions for treating persons suffering from electric shock.

OIM:

Designate an electrical responsible person for the installation.

Ensure all relevant personnel are trained in the use of a special insulated tool for separation of persons from live conductors.

6 DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

Refer to (Section 4 Subsection 5.4) for electrical isolations and Energy Isolation Certificate.

EVALUATING AND IMPROVING

HSE Recognition

POLICY

Effective HSE performance will be recognized.

PURPOSE

The purpose of this policy is to motivate all personnel to take a proactive role in all HSE efforts.

The Company recognizes that true HSE motivation lies in proactive leadership and a person's continued well being. Awards are only a part of the recognition process. The Company strongly supports the HSE efforts of the individuals and teams and believes that proactive HSE performance should be recognized.

SCOPE

This policy covers all Company personnel.

PROCEDURE

The HSE Recognition Program must be based on a combination of proactive involvement in the various processes and not just on HSE statistics.

4.1 CORPORATE HSE RECOGNITION

Units, Divisions and installations must be recognized for outstanding HSE performance. The criteria must be based on the following:

An effective Performance Monitoring Audit and Assessment process.

A high degree of compliance to the HSE Management System.

A proactive approach to apply Company HSE processes.

An incident rate better than Corporate goal.

Innovative HSE improvement and corrective ideas.

UNIT, DIVISION AND INSTALLATION HSE RECOGNITION PROGRAMS

Individuals and teams must be recognized and rewarded for achieving and maintaining a high standard of HSE performance.

Each Unit Vice President, Division Manager and Rig Manager must determine the structure and approval process for the award and recognition system within their area of responsibility.

The HSE award structure must be based on a combination of the processes by which HSE results are achieved and not just by the end results themselves. Vice Presidents and Managers must carefully consider the criteria by which HSE awards are given, as rewarding individuals and teams on HSE results alone can be counterproductive and encourages the non-reporting of incidents.

SUGGESTED HSE AWARD CRITERIA

An effective way to set and track Unit, Division, installation or facility specific objectives would be to use key performance indicators that could be a combination of some of the HSE improvement criteria listed below:

Proactive promotion and use the Platinum Rule, “Treat people as THEY NEED to be treated.”

Effective use of leadership skills in the management of people.

Effective mentoring of co-workers.

Imparting a sense of HSE excellence in people and making positive contributions to the HSE culture of the Company.

Exhibiting a positive HSE attitude.

Participation and use of THINK Planning Process.

Participation and use of START Observation and Monitoring Process.

Effective and timely close out of FOCUS, Corrective and Improvement Actions.

Individual or team participation to facilitate effective HSE meetings.

Full compliance with the HSE Policies and Procedures.

Accurate and timely reporting of incidents as defined by the HSE system.

Holding effective discussions with personnel for the purpose of personal development and HSE performance recognition as well as providing direction for HSE improvement. (Mentoring)

Establishment of installation, facility or personal HSE goals and plans.

Achievement of installation, facility or personal HSE goals and established plans (Annual, Quarterly, Monthly).

Involvement in conducting audits and assessments to the Company HSE System.

Continuous improvement of audit and assessment results of the HSE system

Emergency Response Drill Briefing, Practice and Debriefing.

Training compliance.

Client satisfaction/recognition.

Use of effective incident analysis to determine the possible causes of incidents and resolve any corrective action that may be necessary to prevent recurrence.

RESPONSIBILITY

Corporate QHSE Services, Business Unit Vice Presidents, Division Managers and Rig Managers are responsible for determining the structure and approval process for the award and recognition system within their area of responsibility.

DOCUMENTATION

There is currently no documentation associated with this Policy or Procedure.

SAFETY POLICIES, PROCEDURES AND DOCUMENTATION

EVALUATING AND IMPROVING

FOCUS Improvement Process

POLICY

The FOCUS Improvement Process must be used to Formulate, Organize, Communicate, Undertake and Summarize corrective and improvement action points to improve Company performance and capture lessons learned.

PURPOSE

The purpose of this policy is to provide a consistent means of ensuring action points that add value are completed, Company performance is improved, and lessons learned made available.

SCOPE

This policy covers all Company personnel.

PROCEDURE

The FOCUS Improvement Process provides a consistent means to improve Company performance by formulating an action plan, organizing resources to carry out the plan, communicating the action plan, undertaking the action, summarizing the results and capturing lessons learned.

See the FOCUS section of the Management System Manual, HQS-CMS-GOV for a more detailed FOCUS procedure.

FOCUS IMPROVEMENT PROCESS

The FOCUS Improvement Process consists of steps to address improvement and corrective opportunities.

FOCUS enhances the execution of THINK and START within the Management of Change Process.

The FOCUS Improvement Process incorporates a planning and tracking tool (FOCUS tool) located within the Global Reporting System (GRS) as a means to efficiently manage the steps of formulating the plan, organizing the resources, communicating the plan, undertaking the improvement/corrective opportunities and summarizing the results.

The feedback from the FOCUS Improvement Process is lessons learned. Use of GRS enables the Company to capture lessons learned and to make them available.

The first step in the FOCUS Improvement Process is to determine if the opportunity is “improvement” or “corrective,” as described in paragraph 4.2, “Sources of Outputs and Results (Opportunities).”

After determining whether the opportunity is “improvement” or “corrective” the FOCUS tool within GRS is used to develop the improvement and corrective opportunity actions.

FORMULATE THE PLAN (THINK)

Analyze the improvement or corrective opportunity actions required.

If a corrective opportunity action is required, address the causal factors (change, condition, action and inaction). Determine if any interim actions are required as part of the corrective action.

For corrective opportunity actions, develop plans, identifying effective solutions and steps to implement the plan. Identify and assess any risks and determine the necessary controls to safely and effectively support the steps of the plan.

For improvement plans, define the steps required to improve performance.

For executing plans, define the steps required to ensure that an expected level of performance is maintained. Identify and assess any risks and determine the necessary controls to safely and effectively support the steps of the plan.

Assign the priority (high, medium, low) to prioritize the planned actions.

ORGANIZE RESOURCES (THINK)

Identify the resources required for the successful implementation of the planned actions. This may involve requesting expertise (knowledge, practice, skill and approval) and other resources from departments within the Company such as engineering (REA), technical field support, QHSE, training, operations, and so on, or outside parties such as clients, vendors, regulatory agencies or others.

Determine a target date for completion of the planned actions.

COMMUNICATE THE PLAN (THINK)

Determine if other parties are affected by the planned actions.

Identify the responsible person for communicating the planned actions to parties that may be affected.

Define the method the responsible person uses to communicate the planned actions.

Responsible person communicates the planned actions to all parties involved or affected by the proposed changes.

Submit the plan for approval per established authority limits.

UNDERTAKE THE ACTIONS (START )

Implement the actions. Monitor, track and recognize changes that may affect the planned actions.

Review any delays or alterations to or deviations from the planned actions and formulate alternative actions as agreed by the affected parties.

Inform all affected parties of any changes to the planned actions.

Ensure the successful implementation of the planned actions and inform all appropriate parties of their completion.

Submit approval for any extension(s) of the target completion date of the planned actions.

SUMMARIZE THE RESULTS

Evaluate the effectiveness of the completed work. Address the original improvement and/or corrective opportunity to determine if the planned actions achieved what they were intended to achieve.

Confirm the completed planned actions do not result in any unforeseen adverse effects.

Ensure lessons learned are clearly described based on the review of the improvement or corrective opportunity actions completed.

Responsible Person confirms planned actions were completed and implemented prior to submitting for close out.

Maintain availability of lessons learned from improvement and corrective opportunity actions.

Communicate lessons learned to the Company as required.

Determine if Company’s performance was improved by the improvement or corrective actions completed.

USE OF GRS FOR PLANNING AND TRACKING OPPORTUITIES

Every corrective or improvement opportunity requires an appropriate action. Actions are carefully planned to ensure they are appropriately applied and effectively

managed. Actions are tracked to ensure they are monitored, followed through and the results are communicated to those who may benefit from the lessons learned.

The decision to use the FOCUS tool is based on the complexity or criticality of the actions taken and whether the source of opportunity is discretionary or non- discretionary.

Sources of opportunity include both mandatory and discretionary (optional) sources.

MANDATORY SOURCES OF OPPORTUNITY

Mandatory sources of opportunity are sources that the Company has identified as being important and/or critical to performance. They require the use of the FOCUS tool to ensure corrective or improvement actions are effectively planned and tracked to completion. The following list includes all mandatory sources that require using the FOCUS tool:

Company management system, SMART – Implementation Plans

Performance Monitoring Audit and Assessment – Corrective and Improvement Actions Plans

ISM Code, ISPS Code, Client, Flag State and Regulatory Audits – Corrective and Improvement Actions Plans.

HSE Alerts, Corporate and Unit – Corrective and Preventive Actions

HSE Incident Analysis Result – Corrective and Improvement Actions Plans

Service Quality Appraisals – Corrective and Improvement Actions Plans

HSE Meetings – Corrective and Improvement Actions Plans (See Note.)

NOTE: The use of the FOCUS planning and tracking tool is not required in the case of action points originating from HSE Meetings where:

the emphasis is on tracking actions rather than planning action

a limited work scope is confined to the location

the risk has been assessed to be minimal

the simple approach to Management of Change is used

DISCRETIONARY SOURCES OF OPPORTUNITY

Discretionary sources of opportunity are sources that require managers and supervisors to decide if the FOCUS tool should be used to ensure corrective or improvement actions are effectively planned and tracked.

It is recommended managers and supervisors use the FOCUS tool in the case of discretionary sources when:

A complex and/or critical situation or action has been identified.

Managers and supervisors require a formal review and approval process.

Significant lessons learned must be captured so they are available to users.

Actions that require an extended period of time to complete (not related to maintenance or procurement activities).

NOTE: Regardless of the source of opportunity, when the “enhanced” approach to management of change is used, the FOCUS tool must be used.

The following list includes examples of discretionary sources where using the

FOCUS tool is optional (these sources are available for selection in the tool):

Advisory – Operations, Safety

Alerts – Client, Equipment, Regulatory

Annual Installation HSE Plan

Client/Industry Meeting

Exemption Request

Feedback Form

Lesson Learned*

Management Review

Management Visit

Operational Event Report (OER)

Security Incident

START – Monitoring, Observation

Start-up Plan – Installation, Office/Facility

Steering Committee Meeting – QHSE

THINK Plan – HAZOP/HAZID, Individual, MAHRA, Operation Integrity Case, Safety Case, Task Risk Assessment, Task Specific THINK Procedure, Verbal, Written

Figure A, FOCUS Improvement Process Improvement and Corrective Opportunities

SOURCE OF OPPORTUNITY (RESULTS AND OUTPUTS)

Type of Opportunity

Corrective Opportunity Improvement Opportunity

FOCUS Planning and Tracking Software

Corrective Opportunity Actio

FOCUS AND MANAGEMENT OF CHANGE

FOCUS enhances the execution of THINK and START within the Management of Change Process when Company expertise is requested based on the knowledge, experience, skills and approval available at the installation or within a work group. (See Figure B, Management of Change Process)

Figure B, Management of Change Process

RESPONSIBILITY

ALL PERSONNEL:

Improve Company performance through the effective use of the FOCUS

Improvement Process.

Utilize FOCUS in the “enhanced” approach to Management of Change.

Use FOCUS to plan, risk assess, monitor, track and complete planned actions.

OIM / SUPERVISOR:

Ensure corrective and/or improvement opportunities are planned and tracked in the FOCUS tool when the source of opportunity is classified as “mandatory.”

Ensure corrective and/or improvement opportunities identified add value and improve Company performance.

For discretionary sources, determine if the FOCUS tool is necessary to ensure actions are adequately planned and tracked to completion.

Approve corrective and improvement action plans per FOCUS Approval Authority Limits.

Monitor approved actions to ensure appropriate implementation is achieved and lessons learned are captured.

Ensure approved actions are completed and closed out within the approved Target Completion Date.

Review and approve requests for Target Date Extensions per FOCUS

Approval Authority Limits.

RIG MANAGER/DEPARTMENT HEAD

Monitor the GRS tracking tool regularly to ensure timely implementation and close out is achieved.

Ensure corrective and/or improvement opportunities are planned and tracked in the FOCUS tool when the source of opportunity is classified as “mandatory.”

Ensure corrective and improvement opportunities identified add value and improve Company performance.

For discretionary sources or opportunity, determine if the FOCUS tool is required.

When actions plans are referred by OIM, review action plans and determine if additional expertise is required and/or other parties are affected, prior to approving.

Communicate requirements to the appropriate expertise (for example, Engineering, Technical Field Support, Operations, and QHSE) using the defined request processes.

Approve corrective and improvement action plans per FOCUS Approval Authority Limits.

Monitor approved action plans to ensure appropriate implementation is achieved and lessons learned are captured.

Ensure approved actions are completed and closed out within the approved Target Completion Date.

Ensure actions plans utilize Company time and resources efficiently and effectively.

BUSINESS UNIT QHSE MANAGER

Ensure the FOCUS Approval Authority Limits have been established and forwarded to Quality Services in Dubai.

BUSINESS UNIT VICE PRESIDENT

Establish Unit and Division criteria for FOCUS Approval Authority Limits.

Define any Unit requirements for the use of the FOCUS tool in addition to mandatory sources already identified in the Company Management system (for example: SMART – Implementation Plans, PMAA, Management of Change – Enhanced Approach).

DOCUMENTATION

See the GRS Help file (Online and Rig versions) for information on the use of the GRS FOCUS planning and tracking tool.

EVALUATING AND IMPROVING

Incident Reporting

POLICY

All work related incidents must be reported and reviewed by the Rig Manager. All non-work related incidents resulting in trauma and requiring care at the

Medical Treatment level must be reported and reviewed by the Rig Manager.

The Rig Manager must evaluate incidents, develop and implement appropriate improvement opportunities and track performance to confirm effectiveness.

PURPOSE

The purpose of this policy is to ensure a three-phase process is initiated following the occurrence of an incident on a Company installation, facility or office:

Action must be taken to ensure the area is safe and medical attention provided if required.

The incident must be reported internally and externally, as required.

The incident must be investigated.

SCOPE

This policy covers Company personnel, installations, facilities and offices.

This policy also covers employees and property of any Client, Subcontractor or outside agency that work at any Company installation, facility, or office.

PROCEDURE

REPORTING PROCEDURE

Only through open and honest reporting can we improve our HSE performance.

All medical attention rendered on a Company installation or facility (including “work related” or “non-work related” First Aid cases) must be accurately recorded as defined in the Medical Documentation procedure. (See Section 3 Subsection 2.1)

Instructions for completion of an Incident Report can be found in the Medical Protocols Manual.

NON-WORK RELATED INCIDENTS

MEDICAL CARE PROVIDED OFFSHORE

For traumatic events (injuries) resulting in Medical Treatment, the initial factual points must be reported and documented on an Incident Report form within the Global Reporting System (GRS) and validated by the Rig Manager before the conclusion of the next business day.

For illness, all medical treatment provided is documented as per Section 3 Subsection 2.1.

If the event affects the ability of an employee to perform his routine job functions, the OIM and the employee’s immediate supervisor must be notified of the employee’s inability to perform those functions.

MEDICAL CARE PROVIDED ONSHORE

Upon return to the installation, Company employees must provide the IMP with a document signed by the treating physician if:

a scheduled return crew change was missed as a result of any non-work related injury or illness, or

they departed the installation prior to scheduled crew change due to a need to receive medical care onshore.

The document signed by the treating physician must detail the following:

Any restrictions

Any residual effects as a result of the injury or illness

Any medications prescribed and duration of treatment

Any follow up care or treatment required

Physician contact information

Medical care onshore includes treatment of non-work related incidents that occur while at work and incidents occurring while at home that affects the employee’s ability to perform routine job functions.

For non-work related incidents, medical care provided onshore is defined as being provided by the employee’s personal physician or Company authorized physician.

If any event affects the ability of an employee to perform his routine job functions, the OIM must be notified of the employee’s inability to perform those functions. This includes events happening at home while on field break.

WORK RELATED INCIDENTS

WORK RELATED FIRST AID, MEDICAL TREATMENT, RESTRICTED WORK, AND SERIOUS INJURY CASES

The initial factual points must be reported and documented on an Incident Report form within the Global Reporting System (GRS) and validated by the Rig Manager before the conclusion of the next business day.

For work related incidents resulting in injury or illness to personnel, the Incident Type is “Personnel”.

Any work related incident resulting in injury or illness to personnel must be reported on the daily operations report.

FATALITY

The Chief Executive Officer and Chief Operations Officer must be notified by the fastest available means should a fatality occur at any installation, facility or office.

The initial factual points must be reported and documented on an Incident Report form within the GRS and validated by the Rig Manager before the conclusion of the next business day.

NON-PERSONAL INJURY REPORTING

UNSAFE OBSERVATIONS

Unsafe Observations that cannot be immediately corrected must be reported to the supervisor by the person(s) conducting the observation and must be documented on a START Card.

NEAR HITS AND SERIOUS NEAR HITS

The initial factual points of any Near Hit or Serious Near Hit must be reported and documented on an Incident Report form within the GRS and reviewed by the Rig Manager before the conclusion of the next business day.

Near Hits must be reported verbally to their supervisor by the persons that witnessed the event. The OIM must be notified of any Near Hit.

Serious Near Hits must be reported verbally to their supervisor and OIM by the persons that witnessed the event.

Any Serious Near Hit must be reported on the daily operations report.

If an incident resulting in injury or loss of containment could also be a Serious Near Hit, it may be reported as such. However, a second Incident Report must be completed for the Serious Near Hit. The potential severity should only be captured once, either on the original Incident Report or the Incident Report used to record the Serious Near Hit.

LOSS OF CONTAINMENT REPORTING

See HQS-HSE-PP-02 Environmental Management Manual.

PROPERTY DAMAGE REPORTING

Property damage must be reported on an Operational Event Report (OER).

SEVERITY

The Rig Manager, upon review of the Incident Report, must determine the actual and potential severity of all work-related incidents. The table below outlines the parameters for assignment of severity.

Table 1: Personnel Incident Severity (consequence) Rating and Values

DETERMINING SEVERITY OF NEAR HITS AND SERIOUS NEAR HITS

Near Hits and Serious Near Hits result in only potential severity and no actual severity. Potential severity of a Serious Near Hit is represented in the shaded areas of Table 1. Potential severity of a Near Hit is represented in the non-shaded areas of Table 1.

The Potential Severity value does not determine the classification of Near Hit or Serious Near Hit. The Severity rating determines classification of a Near Hit or Serious Near Hit.

There is no relationship between Potential Severity value and the classification of Near Hits or Serious Near Hits.

SEVERITY RATE – SAFETY PERFORMANCE INDICATOR

Severity Rate is a leading and lagging safety performance indicator.

Severity Rate is derived from the cumulative severity values of a series of incidents that represents relative changes in severity as a function of time.

There are two types of severity rates, actual and potential.

ACTUAL SEVERITY RATE – LAGGING SAFETY PERFORMANCE INDICATOR

The Actual Severity Rate represents incident severity over a period of time. The “Actual Severity Rate” represents the sum of all actual severity values assigned to incidents occurring in the specified time frame. The “Working Hours” represents the sum of all working man-hours in the specified time frame.

The Actual Severity Rate is calculated using the following equation:

Actual Severity Rate = Actual Severity value sum x 200,000

Working Hours

The Actual Severity Rate is comprised of actual severity values for all categories of work related personnel injury or illness incidents.

POTENTIAL SEVERITY RATE – LEADING SAFETY PERFORMANCE INDICATOR

The Potential Severity Rate is a representation of incident potential severity over a period of time. The “Potential Severity Rate” represents the sum of all potential severity values assigned to incidents occurring in the specified time frame. The “Working Hours” represents the sum of all working man-hours in the specified time frame.

The Potential Severity Rate is calculated using the following equation:

Potential Severity Rate = Potential Severity value sum x 200,000

Working Hours

The Potential Severity Rate is comprised of potential severity values for work related personnel injury or illness (all categories) and Near Hits and Serious Near Hits involving potential personnel injury.

SEVERITY CALCULATOR

The severity calculator allows the Rig Manager to assign the severity ratings and carry out on an ongoing basis the computations that result in the severity rate. The Rig Manager must maintain the severity calculator within the GRS.

The Rig Manager must use the severity values to determine if an action needs to be taken.

The Division Manager must ensure that the severity calculator is applied in a consistent manner.

INCIDENT ANALYSIS

Incidents indicate where performance can be improved. Incident analysis uses critical information to establish what happened but, more significantly, determines how important it is for the Company to act on it. Incident analysis identifies corrective and improvement opportunities that represent lessons learned which must be reviewed against the Company Management System for change and/or improvement.

Each Business Unit must have a specific procedure in place for incident analysis which takes into account the following factors:

Location of Business Unit and Division Management’s Incident Fact-Finding Team

Availability of specialized expertise

Regulatory requirements

Geographical locations

Transportation infrastructure

Local customs and cultures

Although the Business Unit Incident Analysis procedure is approved by the Business Unit Vice President, Corporate QHSE Services (in conjunction with the Business Unit and Division QHSE Manager) must also review the procedure to ensure it adequately addresses the following:

COMMUNICATION PLAN

Establishing a Communication Plan – installations, Clients and Regulatory Bodies

Sharing Lessons Learned and Incident Follow up Plans

ORGANIZING FACT-FINDING

Identifying and Collecting Facts – Who, What, Where, When

Interviewing Witness(s)

Maintaining a Log of Events

Summarizing of Facts

Preserving and Representing Evidence

Managing Factual Statements

Defining the Role of Witnesses

FACT FINDING DOCUMENT AND EVIDENCE CONTROL

Source, Flow and Retention

MANAGEMENT REVIEW OF FACTS

Analyzing Facts Effectively

Determining Corrective Opportunities

Managing Speculation in Incident Analysis Reporting

Determining Corrective and Improvement Opportunities (as defined in the

FOCUS process)

Determining Corrective, Preventive and Improvement Actions (as defined in the FOCUS process )

Summarizing conclusions effectively.

The four key steps required to complete an incident analysis are:

Fact-finding. This must take place at the site of the incident.

Management review of facts.

Communication of Corrective and Improvement Opportunities.

Development of Corrective and Improvement Action plans in the FOCUS

Planning and Tracking software.

FACT-FINDING

Designation of the appropriate responsible person for managing the fact-finding step is determined by the severity value initially assigned by the Rig Manager as it is applied to the Fact-Finding Table of Responsibilities.

The decision of what resources and personnel are assigned to the fact-finding process must be based on the areas of expertise required, the level of experience available, the local environment and the level of direct management involvement necessary to complete the fact-finding step.

The table below identifies the responsible person for ensuring adequate resources and trained personnel are assigned to the fact-finding step.

A – OIM

B – Rig Manager or Division Manager/Unit Operations Manager

Fact-Finding Table of Responsibilities

Note: For Near Hits & Serious Near Hits, the potential severity value determines the incident type.

The following persons may be asked to lead the fact-finding step of the investigation:

Independent investigator

Company legal representative

Business Unit Vice President

Business Unit QHSE Manager

Business Unit/Corporate OSA

Division Manager/Operations Manager

Division HSE Manager, where applicable

Rig Manager

OIM

Crew supervisor

Safety representative, where applicable

Rig Safety Training Coordinator (RSTC), where applicable

Crewmembers may be asked to assist in the fact-finding component of the investigation.

MANAGEMENT REVIEW OF FACTS

The Management Review of Facts should focus on how to prevent the incident from happening again and what can be learned from the incident. The Management Review determines whether corrective and improvement opportunities are needed to improve safety. Responsibility for ensuring adequate resources for carrying out the Management Review of Facts is determined by the Division Manager.

Corporate Operations Group conducts the Management Review of Facts for all fatalities. Business Unit Management may be requested to assist in the fact-finding step, but the overall responsibility for Management Review of Facts resides with Corporate Operations Group.

COMMUNICATION OF CORRECTIVE AND IMPROVEMENT OPPORTUNITIES

Upon completion of the Management Review of Facts, corrective and improvement opportunities are communicated through line management and, when deemed appropriate by QHSE Management (Corporate/Business Unit/Division), also by HSE Alert, HSE Bulletin or HSE Advisory. All Incident Analysis Results are non- discretionary sources of opportunities and must be entered into the FOCUS tracking software.

STATISTICAL REPORTING

The Monthly Statistics Report consists of two sections:

Company personnel (including leased labor)

Company hired subcontractor (catering, project welders, and so on)

Information in each list includes the number of:

Working hours

Work-related first aid cases

Work-related medical treatment cases

Restricted work cases

Serious injury cases

Fatalities

Serious near hits

This information must be reported for the current month, year to date and the 12- month rolling recordable rate for all “work related” medical treatment cases, restricted work cases, serious injury cases and fatalities combined into one figure.

Business Units must report to Corporate any personnel unable to return to work as the result of a Serious Injury Case, including the actual days the individual is unable to work in any capacity during the reporting period.

TOTAL RECORDABLE INCIDENT RATE – LAGGING SAFETY PERFORMANCE INDICATOR

To ensure uniformity in computations the Total Recordable Incident Rate (TRIR) must be calculated as follows:

Total Recordable Incident Rate = (MTC + RWC + SIC + FAT) x 200,000

Working Hours

The total recordable incident rate tracked by the Company is year-to-date and a rolling rate over the previous 12 months. To compute the rolling rate, the (MTC + RWC + SIC + FAT) and the Working Hour figures in the formula above are the figures for the previous 12-month period. For example, the rolling rate for the month

ending on March 31, 2003 is the figures from April 1, 2002 through March 31, 2003. The next report at the end of April is from May 1, 2002 through April 30, 2003.

All incidents used in calculation of the TRIR must be work related.

If an installation moves from one Business Unit to another, the working hours and incidents (if any) remain with the Business Unit that the installation is departing. The new Business Unit begins counting working hours (man-hours) when the new Business Unit assumes control of and responsibility for the installation. The hand over point for the installation is determined by agreement between the two Business Units involved.

As an installation moves from one Business Unit to another, the YTD TRIR resets to zero each time; however the 12-month rolling average is calculated from the past 12 calendar months’ working hours and incidents, regardless of area or location of operation.

The YTD TRIR and 12-month rolling average are used equally together to evaluate an installation’s safety performance.

WORKING HOURS

INSTALLATION WORKING HOURS

Only installation on-tour working hours are to be counted for computation of statistics. Installation working hours is defined as hours worked by all Company personnel and Company hired subcontractor employees assigned to an installation.

The working hours must be tracked separately for Company personnel and Company hired subcontracted employees.

Transportation to and from the installation and off-tour hours are excluded from the working hours count.

INSTALLATION WORKING HOURS — COMPANY PERSONNEL (COMPANY EMPLOYEES AND LEASED LABOR)

The working hours and incident data for any “leased laborers” who are under the direct supervision of the Company must be included with the installation working hours and incident data for Company personnel. “Leased laborers” are anyone fulfilling the duties normally undertaken by a Company employee and supplied by

such sources as labor contractors, temporary agencies, leasing companies, or other labor sources.

Hourly paid Company personnel hours are calculated as the number of hours reported on the payroll that includes overtime worked.

Salaried/Monthly paid Company personnel who do not have a relief onboard are calculated as the number of days on the installation times 14 hours per day plus actual overtime hours worked in any given day.

Salaried/Monthly paid Company personnel that have a relief onboard are calculated as the number of days on the installation times 12 hours per day plus actual overtime hours worked in any given day.

To calculate the total installation reported working-hours, add Hourly Company personnel hours plus Salaried/Monthly Company personnel hours for the calendar month being reported.

INSTALLATION WORKING HOURS — COMPANY HIRED SUBCONTRACTOR EMPLOYEES

Company Hired Subcontractor employees on a subcontract basis, such as catering crews, project welders, and so on, are not considered leased labor.

The work hours and incident data for these employees must be included in the Company Hired Subcontractors Statistics.

Company Hired Subcontractor Employee working hours must be tracked by the supervisor on the installation or by specific timesheets, as appropriate.

ONSHORE ADMINISTRATIVE HOURS

Working hours for personnel working onshore, not including subcontractor labor, must be reported separately under Administrative Hours.

Hourly/non-exempt (employees who receive overtime) office employee hours are calculated as the number of hours reported on the payroll, normally eight hours per day, and any overtime worked.

Salaried/exempt (employees who do not receive overtime) office employee hours are calculated as the number of days worked per month times eight hours per day.

If installation personnel are temporarily working in the warehouse or yard area (onshore) regardless of the reason, their hours and any incidents that occur fall under that warehouse or yard area’s calculations.

To calculate total Administrative Hours, add hourly/non-exempt office employee hours, salaried/exempt office employee hours, and the actual hours of warehouse personnel (not including Subcontractors) and training center personnel.

Hourly Company hired subcontractors employee hours are calculated as the number of working hours reported on their timesheet.

COMPANY TRAINING FACILITY (IF APPLICABLE)

Actual hours of Training Instructors and attendees must be added to the total Administrative Hours. All training facility hours and any incidents that may occur fall under the training facility calculations and are added into the administrative statistics.

DAYS UNABLE TO WORK IN ANY CAPACITY

The day of the injury/occupational illness and the day the individual returns to work are not to be counted as days unable to work. All other days the individual is unable to work in any capacity as stated on a doctor’s certificate are counted as days unable to work. For example: An individual is injured on the 22nd day of a 28-day “hitch” and is unable to return on their next shift, or any subsequent shift. The actual workdays and field break days will be counted as days unable to work, until a doctor releases the injured person for work in any capacity.

ANSI Z16.1 must be used to compute days for death, permanent total and permanent partial disability. (The ANSI Z16.1 definition is: 6,000 days for each death, permanent total disability and permanent partial disability.)

REPORT FLOW

BUSINESS UNIT TO CORPORATE

The Monthly Statistics Report must be prepared and submitted to Corporate HSE Services to arrive no later than the third business day after the end of the reported month. With the deployment of GRS Online version 3.x (May 2004), all Monthly Statistics Reports will be generated from GRS On-Line. It is the responsibility of each Rig Manager to ensure the HSE performance incurred and reported within GRS is accurate and meets the requirements for reporting in section 4.1.3 above.

CORPORATE TO FIELD

Monthly Incident Rate Chart:

Corporate HSE Services must provide a Monthly Incident Rate Chart to all Company installations and facilities. (See Section 4.4.1)

The Monthly Incident Rate Chart provides a statistical comparison within the Company.

5 RESPONSIBILITY

5.1 ALL PERSONNEL:

Report all incidents.

Be prepared to assist in the fact-finding component of an investigation.

Prior to return from field break, notify the OIM anytime an incident occurs at home that affects the ability to perform routine job functions.

Provide the IMP with a document signed by the treating physician anytime any work is missed as a result of a non-work related incident.

INSTALLATION MEDICAL PERSON:

Document all medical attention rendered as defined in the Medical Documentation procedure.

Report to the immediate supervisor and the OIM if an event occurs that affects the ability of an employee to perform his routine job functions.

Keep the OIM informed of the status of all ongoing medical events that may require emergency or non-emergency medical evacuation.

Receive and review any documents related to non-work related incidents that caused an employee to miss any work.

Notify the OIM anytime an employee returns to the installation after receiving medical care onshore if the employee:

has restrictions that may affect his ability to perform his routine job functions or,

returns to the installation without a document signed by the treating physician.

OIM:

Ensure the initial factual points are reported and documented on an Incident Report form within the Global Reporting System (GRS) for all required events.

Ensure any work related FAC, MTC, RWC, SIC and any EVDM, EVDS, PRDM or PRDS is reported on the daily operations report.

Ensure adequate resources for fact-finding are allocated, if determined to be the responsible person by severity assignment.

Ensure the Monthly Incident Rate Chart is posted for personnel to review.

Keep the client representative informed of the status of all ongoing medical events that may require emergency or non-emergency medical evacuation.

RIG OR DIVISION MANAGER:

Validate Incident Reports entered in the GRS before the conclusion of the next business day following the event.

Notify the Business Unit Vice President and the Corporate Risk Department of a fatality immediately upon notification from the OIM.

Determine the severity of all work-related incidents entered in the GRS.

Ensure adequate resources for fact-finding are allocated, if determined to be the responsible person by severity assignment.

Ensure the HSE performance incurred and reported within GRS is accurate and meets the requirements for incident reporting.

Ensure that persons identified in the Business Unit Incident Analysis procedure as have received the required training.

UNIT/DIVISION/SECTOR QHSE MANAGER:

Ensure the severity calculator is applied in a consistent manner.

Review all incidents to confirm correct classification for reporting purposes.

Monitor Division/Sector/Branch management follow up and close out of

FOCUS proposals related to incidents.

BUSINESS UNIT VICE PRESIDENT:

Notify the Chief Executive Officer, Chief Operating Officer and the Corporate QHSE Department of any fatality immediately upon notification from the Rig or Division Manager.

Ensure an approved specific procedure is in place to perform Incident Analysis.

Ensure effective is training is available for the Business Unit Incident Analysis procedure

Ensure the procedure to perform Incident Analysis is performed in four separate and independent components:

Fact-Finding

Management Review of Facts

Communication of corrective and improvement opportunities

Follow up and close out of corrective and improvement opportunity actions

Ensure there are adequate resources for carrying out the Management Review of Facts.

Monitor Division/Sector/Branch management follow up and close out of

FOCUS proposals related to incidents.

CORPORATE HSE DEPARTMENT:

Provide a Monthly Incident Rate Chart to all Company installations and facilities.

Monitor Business Unit management follow up and close out of FOCUS

proposals related to incidents.

CORPORATE QHSE DIRECTOR:

Review Business Unit incident analysis procedures to ensure they adequately address requirements.

6 DOCUMENTATION

The Fact-Finding Guidelines (Figure A) are included in the manual as a tool for an initial gathering of facts relevant to an incident. It is not a requirement of this policy to use these guidelines. If these guidelines are used, they should not be considered “all inclusive” and should be helpful to generate further questions relevant to the incident.

Fact Finding Guidelines (Figure A)

The Incident Report form is located within the Global Reporting System (GRS) and must be completed electronically. The complete Incident Report created in GRS- Rig/GRS-Online is confidential and must be treated as such. A copy must be printed and signed to be retained in the installation or facility files for a period of not less than three years.

An abbreviated Incident Report generated from GRS Online is suitable for sharing the relevant facts of the incident.

The form indicated below is included as an alternate in the event it is not possible to complete the Incident Report within GRS. Once complete, the signed hard copy is considered confidential and must be treated as such. Use of this format is mandatory and is not to be modified. It has been developed by Corporate HSE Services and is a requirement of this policy.

Incident Report (Figure B )

(Copies of this form must be signed and retained in the installation or facility files for a period of not less than three years

The intended purpose of these guidelines is to serve as a reminder of the types of items that might be addressed during the Fact Finding step. The severity and circumstances of the incident best determine if fewer or more questions, observations, or documentation are appropriate. The guidelines help keep you on the right track of documenting just the facts and avoiding opinions.

The key considerations when completing the Fact Finding step include:

Keep an open mind and maintain a neutral point of view.

Remember that you are on a fact-finding mission – report the facts only.

Do NOT form opinions, find fault, or place blame.

Do NOT speculate what the causes may have been.

Do NOT speculate what corrective actions might minimize recurrence.

Interviews

Who witnessed the incident?

Where were the witnesses when the incident occurred? (Be specific.)

What did the witnesses see when the incident occurred? (Be specific.)

What did the witnesses hear when the incident occurred? (Be specific.)

What did the witnesses feel (physically) when the incident occurred? (Be specific.)

What instructions were given to each person before the incident occurred and who gave the instructions? (Include all crewmembers, injured party, supervisors and other crewmembers.)

Who was operating what equipment?

Where is the equipment located in relation to the incident scene?

What inspections were performed before the incident occurred, who performed them and when were they performed? (List all equipment and material inspections and their findings.)

What potential hazards were identified before the task was begun and what (if any) control measures were implemented to ensure it did not result in an incident?

Figure A, Fact Finding Guidelines

Interviews (continued)

What potential hazards were identified when conducting the operation and what (if any) control measures were implemented to ensure it did not result in an incident?

What training had the injured party or other crewmembers received in conducting the operation underway at the time of the incident?

What instruction had the injured party or other crewmembers received in conducting the operation underway at the time of the incident?

How many times had the injured party or other crewmembers previously conducted the operation underway at the time of the incident?

Observations

What were the conditions of the work area where the incident occurred? (Steps, grating, decking. Be descriptive. For example, “Steps are made of expanded metal and are free of grease and mud, providing good traction.”).

What lighting was provided? [Clear skies, (8) 600W lights, and so on. Be descriptive. For example, “There was enough light to read.”]

What was the availability of help – mechanical service (in This area, this room adjacent rooms)?

What was the availability of cleaning equipment (mops, brooms, and so on, in this area or room, and adjacent rooms)?

What (if any) barriers were in place at the time the incident occurred?

What (if any) lock-out/tag-out devices were in place at the time the incident occurred?

What (if any) work permits were in place at the time the incident occurred?

What personal protective equipment and clothing were being utilized by the injured party at the time of the incident (boots, gloves, coveralls, hard hats, safety glasses, safety goggles, safety harnesses, retractable lines, and so on)?

What was the condition of the equipment and clothing being used? (Be descriptive. For example: “Boots were free of oil and mud, and provided good traction.”)

What was the availability of personal protective equipment and clothing (in this area or room, adjacent rooms, and so on.).

Figure B. Incident Report

TABLE OF CONTENTS

SECTION 5 …………………………………………………………………………………………………. ANNEX

SUBSECTION 1 ACRONYMS/ABBREVIATIONS

SUBSECTION 2 DEFINITIONS

SUBSECTION INDEX OF DOCUMENTATION SUBSECTION 4 FILING OF DOCUMENTATION SUBSECTION 5 INDEX OF KEYWORDS

ALARP As Low As Reasonably Practicable

BHA Bottom Hole Assembly

BOP Blow Out Preventer

CFC Chlorinated fluorocarbons (including halon and freon)

DC Direct Current

DROPS Dropped Objects Prevention Scheme

FAC First Aid Case

FOCUS Formulate, Organize, Communicate, Undertake, Summarize

FAT Fatality

FMECA Failure Mode, Effects and Criticality Assessment

GMDSS Global Marine Distress Safety System

GRS Global Reporting System

H2S Hydrogen Sulfide HAZID

Hazard Identification HAZOP Hazard Operability Study HLO Helicopter Landing Officer

HMIS Hazardous Materials Identification System

HSE Health, Safety and Environmental

HVAC Heating Ventilation and Cooling (Systems)

IMP Installation Medical Person

IADC International Association of Drilling Contractors

IMO International Maritime Organization

ISM International Safety Management (Code) ISPS International Ship and Port Facilities (Code) LEL Lower Explosive Limit

LMP Local Medical Provider

MAHRA Major Accident Hazard Risk Assessment

MODU Mobile Offshore Drilling Unit

MSCAT Incident Analysis Software (used in Norway).

MSDS Material Safety Data Sheets

MTC Medical Treatment Case

NH Near Hit

NWR Non Work Related

OIC Operation Integrity Case

OIM Offshore Installation Manager

OJT On-Job Training

PCR Patient Contact Report

PMAA Performance Monitoring, Audit & Assessment

PPE Personal Protective Equipment

PPM Parts Per Million

PRS Pipe Racking System

PSI Pounds per Square Inch (of pressure)

QHSE Quality, Health, Safety and Environmental

RPM Revolutions Per Minute

RWC Restricted Work Case

SCBA Self Contained Breathing Apparatus

SCE Safety Critical Equipment

SHIP Shippng Name – Hazard Class – UN Identification number – Packaging Group.

SIC Serious Injury Case

SMS Safety Management System

SNH Serious Near Hit

SOPEP Shipboard Oil Pollution Emergency Plan

SRL Self-Retracting Lifelines

START See, Think, Act, Reinforce, Track

SWL Safe Working Load

TRA Task Risk Assessment

TRIR Total Recordable Incident Rate

ANNEX

DEFINITIONS

Accountable — Liable for the consequences of an action or lack of action.

Administrative Hours — Hours worked in offices, yards and training facilities.

All Personnel — All people employed by Rig Oilfield Services or its subsidiaries, including any employee working as leased labor; any employee of Rig Oilfield Services Subcontractors, Client and Client Subcontractors; visitors and other relevant stakeholders.

Approved — Met Company standard.

As Low As Reasonably Practicable (ALARP) – A process for assessing the amount of effort and resources that should reasonably be applied to reduce risk. Reducing risk to a level which is ALARP involves objectively determining the balance where the effort and cost of further reduction measures become disproportionate to the additional amount of risk reduction obtained.

Authority — Permission to take action.

Authorized — Granted permission for specified action.

Authorization – Permission (usually written) for specific action. Authorization may be granted verbally in urgent and exceptional situations but must be followed up with a formal hard copy approval within seven days.

Barrier – Measure which reduces the probability of releasing a hazard’s potential for harm or which reduces it’s consequences.

Barrier Cream – A special cream applied to exposed skin (especially hands and arms) to minimize direct contact with hazardous or particularly messy materials/chemicals; another type of PPE. Also called "invisible glove" or "silicon glove."

Buddy System – A process where two people are paired (or sometimes several people are grouped) to provide mutual (short- or long-term) service(s) or benefit.(s), such as teaching, support, safety, accountability, encouragement, friendship, etc.

Certified — Documented as having passed a defined examination.

Change — Event or process that transfers energy or alters a situation, either immediately or in the future, all at once or gradually.

Client — A customer to whom Rig Oilfield Services provides service.

ANNEX

DEFINITIONS

Company — Rig Oilfield Services LLC and its subsidiaries.

Condition — Element present in an environment that, when a change occurs, interacts with the change and other circumstances.

Contain – To control the movement/flow of materials (especially hazardous liquids or gasses) or to keep them within limits to prevent their release, spill or spread; hold to prevent damage, injury or harm, or risk of damage, injury or harm.

Controlled Drugs — All medications (painkillers, sedatives, tranquilizers, etc.) that may induce dependence. Controlled drugs are secured in a locked cabinet. The OIM is responsible for controlling issuance, disposal, and inventories. See Unit specific medications for list of controlled drugs.

Controls — Essential/specific barriers established between identified hazards and risks (and the consequences of those hazards and risks) to demonstrate those risks are ALARP. Examples of controls include:

Company Management System

Level 1 – Corporate Policies and Procedures

Level 2 – Unit Procedures

Level 3 – Installation Specific Procedures

Regulatory requirements

Client requirements

Equipment / product manufacturer recommendations / requirements

Company Authorized Physician — A qualified and licensed medical doctor who practices medicine, preferably near or in the area of the country concerned. The physician has an expertise of the local diseases and a good knowledge of the local medical resources; serves as the focal point for health-related matters for Rig Oilfield Services for the area or country of assignment; and is reachable 24-hours a day.

Company Employee — An individual on the direct payroll of Rig Oilfield Services.

Company Personnel — Company employees and any subcontracted personnel under the direct supervision of the Company including leased laborers filling positions that are considered normal crew complement.

Company Vehicle — Those owned by the Company or on long-term lease (over one month) for use on public roads.

Competent — Able to perform specified tasks to a defined standard.

Confined Space — A space that is not normally lit, not normally ventilated and not normally manned.

Contingency Plan – A program of action designed for handling possible future circumstances or events.

Controlled Area – A space to which access is restricted or limited, usually to certain categories of person (authorized, certified, of a certain rank, etc.) or in certain circumstances (emergencies, etc.); spaces marked to limit access.

Core Values – Financial Discipline; Integrity and Honesty; Respect for Employees, Customers and Suppliers; Safety; and Technical Leadership. Referred to by the acronym FIRST.

Corrective Action – An action determined by management/supervisor that is taken to eliminate the causes of a deficiency in order to prevent recurrence. Interim action is part of the corrective action taken.

Corrective Opportunities – Opportunities to correct factors that cause or may cause incidents, events, conditions or inactions to occur or recur.

Corrective (and Improvement) Opportunity Actions – Measures determined by management/supervisors to address actual and potential causal factors to prevent incidents, events, conditions or inaction from occurring or recurring.

Critical – Vital, crucial or decisive.

Critical Personal Protection Equipment — Specialized clothing, gear and other items designed to protect personnel from contact with hazards that would reasonably cause serious injury or death. (For example: SCBA, acid battery suit, proximity suit, fire fighting PPE, and so on.)

Critical Safety Systems — Systems that affect crucial safety factors, including the overall stability, seaworthiness, or safety of the installation; welfare of personnel; or environment.

Critical Task — A task that if not performed correctly can cause significant loss to people, the environment or property.

Designate — To indicate or specify; point out; select and set aside for a duty, purpose or assignment.

Designee — A person who has been designated or appointed to act on behalf of another person.

Disposable – Designed to be disposed of after use. For medical equipment, usually an item meant to be used just once, then discarded; used to prevent the spread of disease and pathogens and promote/protect safety/health.

Documented – Supported or back up with paperwork contained relevant information; requirement that something be documented means having ALL required/relevant facts and information collected and recorded.

DROPS – Dropped Objects Prevention Scheme Effective – Having an intended or expected effect.

Emergency – A serious situation or occurrence that happens unexpectedly and demands immediate action.

Emergency Response Plan – Policies and procedures for responding in a safe manner to life-threatening or damaging situations.

Emissions – Gas(es) released from equipment, especially engines used for power generation, refrigeration systems and fire-fighting systems.

Employee – A person paid and supervised directly by the Company. (Compare to Personnel and Contractor/Subcontractor.)

Endemic — Prevalent in a particular Unit or locality (e.g., a malaria endemic area).

Ensure – To make certain.

Exemption – Action or procedure that does not comply with the company Management System. Exemptions from Company Management System procedures are reviewed and approved on a case-by-case basis. Must be applied for with a “Request for Exemption.”

Facility — Any onshore yard, warehouse or similar that is owned, leased, operated or managed by the Company.

Fact Finding — The act or process of gathering facts without a bias towards a presumed result.

Fatality (FAT) — A work-related injury or illness that results in death.

Fire Watcher – A person closely monitors the area where welding is being done to eliminate risks and dangers, avoid fires, fight any resulting fires and institute all procedure necessary to respond to any issue or problem with the Hot Work; fire watchers must have no other assigned duties while fire watching.

First Aid Case (FAC) — Any treatment of an injury or illness that is the result of an event or exposure in the work environment (including minor scratches, cuts, burns, splinters and so forth), and any follow-up visits for the purpose of observation. The following are generally considered first aid treatment:

Using a non-prescription medication at non-prescription strength.

Administering tetanus immunizations.

Cleaning, flushing or soaking wounds on the surface of the skin.

Using wound coverings such as bandages, Band-Aids, gauze pads, etc., or using butterfly bandages or Steri-Strips.

Using hot or cold therapy.

Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment).

Using temporary immobilization devices while transporting an incident victim (e.g., splints, slings, neck collars, backboards, etc.).

Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister.

Using eye patches.

Removing foreign bodies from the eye using only irrigation or a cotton swab.

Removing splinters or foreign material from areas other than the eye using irrigation, tweezers, cotton swabs or other simple means.

Using finger guards.

Using massages. (physical therapy and chiropractic treatment are considered medical treatment.)

Drinking fluids for relief of heat stress.

Use of an IV lock (Saline or Heparin) for preventive or precautionary measures. (Use of the IV lock to administer any medications, including Saline, is considered medical treatment.)

FOCUS — The Company improvement process.

Frog — A rigid, buoyant personnel transfer device.

Global Reporting System – The Company electronic reporting system

Hazard — Anything that can cause harm to people, the environment, property or Company reputation.

Hazard Mapping — The process of establishing where and to what extent particular phenomena are likely to pose a threat to people, property, infrastructure, and economic activities. Hazard mapping represents the results of hazard assessment on a map, showing the frequency/probability of occurrences of various magnitudes or durations.

Hazard Register — Brief but complete summary that demonstrates that the hazards have been identified, assessed, and that controls (preventative and mitigating)

Hazardous — Capable of producing adverse effects; especially exposing people, property, the environment to risk of danger, harm or injury.

Hazardous Materials — Any substance or mixture of substances having properties capable of producing adverse effects on the health or safety of a human being.

He, Him and His — For the purpose of this manual means: he/she, him/her and his/hers

Head Protection – Items, equipment or procedures designed to safeguard a person’s head. Primary head protection is a hard hat, properly fitted and secured with a chin strap. Hard hats must be worn by all personnel outside the accommodation at all times except in designated areas.

Health — An individual’s degree of physical, mental and emotional soundness

Hearing Protection – Items, equipment or procedures designed to safeguard a person’s hearing when in a high-noise area. Typical hearing protection includes ear plugs and headsets to cover the ears; hearing protections are provided outside high-noise areas for use by anyone entering.

High Noise – Over 83dB.

Impairment – Any temporary or permanent emotional, mental or physical condition or status, as well as drugs, substances, emotions or other factors (stress, fatigue, etc.) that cause an individual’s capacities to be impaired.

Inaction — Something that should or could happen to control an event or incident, but did not.

Improvement Opportunity Actions — Improvement measures determined by management/supervisors to maintain an existing process and/or procedure at a required level or to improve a process and/or procedure.

Incident — The occurrence of an action which causes, or has the potential to cause, injury, environmental damage, or property damage.

Incident Analysis — Use of critical information to establish what happened and, more significantly, determine how important it is for the Company to act on it. Identification of corrective and improvement opportunities that represent lessons learned which must be reviewed against the Company Management System for change and/or improvement. Incident Analysis consists of four steps: fact-finding, management review of facts, communication of corrective and improvement opportunities, and development of corrective and improvement action plans in the FOCUS Planning and Tracking software.

Injury — Physical harm to a person. (For the purposes of this manual, the word “injury” will be used to indicate injury or occupational illness.)

Installation — Any offshore installation owned, leased, operated or managed by the Company, such as a swamp barge, tender, jack-up, drill-ship, semi-submersible or similar.

Installation Medical Person — The person most responsible for providing medical care onboard the installation.

Interim Action — An action determined by management/supervisor that is taken to correct the deficiency but not the cause of the deficiency until such time that the corrective action can be taken; part of a corrective action.

Isolated (In Isolation) — Rendered completely inoperable and safe to work on; especially, cut off from all source of power/electricity. Also, marked with signs and barricades to signify something is completely inoperable.

Investigation — A systematic inquiry to gather the facts.

Leased Labor — Any personnel supplied by outside sources such as temporary agencies, leasing companies or other labor sources that fill a position that is considered normal crew complement.

Levels (of Management) — Level 1 is Corporate; Level 2 is Business Unit and Division; and Level 3 is Installation.

Lifting Appliances – Any mechanical device capable of raising or lowering a load (for example, crane, chain block, pull lift, winch, drawworks and so on).

Lifting Equipment – Lifting gear and lifting appliances.

Lifting Gear – Any device that is used or designed to be used directly or indirectly to connect a load to a lifting appliance (for example, crane or chain block) and does not form part of the load (for example, sling, wire rope, chain, hook, plate clamp, scissor clamp, shackle, eyebolt, lifting beam, bushing puller, lifting device,etc.).

Likelihood — The chance a hazard could lead to an incident.

Load Test — An inspection pull-test to a pre-determined level and re-inspection of a piece of equipment.

Location – An office, facility or installation

Major Hazard – A hazard with the potential to result in multiple fatalities or permanent total disabilities; extensive damage to the installation; or massive effect to the environment (persistent and severe environmental damage that may lead to loss of commercial, recreational use, or loss of natural resources over a wide area).

Medical Treatment Case (MTC) — Any injury case requiring medical care or treatment beyond first aid (regardless of the provider of such treatment) and any illness, abnormal condition or disorder of an employee that does not result in a Restricted Work Case or Serious Injury Case. Medical treatment does not include first aid treatment even if provided by a physician or registered professional personnel. Medical treatment cases can include, but are not limited to:

Any first-, second-, or third-degree burn that results in one or more outcomes such as medical treatment, work restrictions, or days away from work.

Administration of immunizations post exposure, such as Hepatitis B vaccine (excluding tetanus).

Removal of foreign bodies embedded in the body, including the eyes.

Admission to hospital or equivalent medical facility for treatment.

Needle sticks and “sharps” injuries (needle sticks and injuries that result from sharps potentially contaminated with another person’s blood or other potentially infectious material).

Use of sutures, staples or surgical glue.

Massage treatment given by a Physical Therapist or Chiropractor.

Intravenous administration of fluids to treat work-related heat stress.

Administration of one dose of prescription medication for treatment of the injury or illness.

Use of non-prescription medication (over the counter medication) at prescription strength for treatment of the injury or illness.

Positive x-ray diagnosis of fractures, cracked or broken bones.

The following incidents are recordable and are to be classified as MTC, even if no medical treatment was given, unless they result in RWC, SIC or Fatality.

Punctured ear drum

Loss of consciousness

Medical Treatment does not include:

Visits to a physician or other licensed health care professional solely for observation or consultation.

Diagnostic procedures such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (e.g., eye drops to dilate pupils).

Mitigating — Reducing the consequences of an incident if preventative controls fail or are not effective.

Must — Mandatory requirement.

Near Hit — Any event (not resulting in actual damage) that under slightly different circumstances could have resulted in:

a first-aid case

a medical treatment case

a restricted work case

a serious injury case with less than 6 months off

light environmental damage

Non-Prescription Drugs – see “Over-the-Counter Drugs.”

Non-Work Related

The following types of incidents are considered to be non-work related:

Off-duty injuries occurring in crew accommodations, galley, or away from the work site.

Symptoms arising on Company property totally due to outside factors such as injuries, illnesses, or fatalities due to a natural disaster (hurricane or earthquake) that are otherwise not related to Company operations.

Injury or illness involving signs or symptoms that surface at work but result from a non-work related event or exposure that occurs outside the work environment.

Injury to or illness of members of the general public, visitors, regulatory agents, employee(s) off duty waiting for transportation to shore or off of the location.

An injury or illness that results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or other sports activity.

Injury or illness resulting from the employee eating, drinking, or preparing food or drink for personal consumption.

Injury or illness resulting from an employee doing personal tasks (unrelated to their employment) at the establishment.

Injury or illness resulting from personal grooming or self-medication for a non-work related condition, or is intentionally self-inflicted.

Cold or flu.

Office — Any onshore office or similar that is owned, leased, operated or managed by the Company. An office may be housed as part of a facility. The office area is defined as an area where the main function of personnel is administrative support for facilities or installations.

OIM — Offshore Installation Manager. For the purpose of this manual, it also means Platform Manager and may mean Person in Charge and, where applicable, Facility Manager or Master.

Operation Risk Assessment – A risk assessment performed on an organization or location to identify, assess and control risks associated with Health, Safety, Environment and Performance.

Over-the-Counter Drugs (OTC) — Any medicine that would normally be available without a physician’s prescription. See Unit specific medications for list of over-the-counter drugs.

Padeye — An engineered load bearing attachment point designed to be used with a shackle, either integrated or welded into a structure, piece of equipment or lifting appliance to transfer a dynamic load or secure a static load.

Pathogen — An agent that causes disease. Common pathogens are microorganisms, such as bacterium. A disease is contracted by absorbing foreign body fluids containing pathogens. Pathogenic diseases include, but are not limited to, AIDS-HIV, malaria, syphilis and hepatitis B (HBV).

Permit To Work – Authorization to carry out specific work at a certain time and place.

Personal Protective Equipment (PPE) – Clothing, equipment and other items designed to protect personnel from environmental elements and relevant workplace hazards where it is not practical to reduce relevant exposure to acceptable levels by using engineering control or practices. PPE include hard hats, steel toe boots, harnesses, respirators, face masks, hearing protectors, etc. PPE may be supplied by the employee and/or by the Company and may be assigned to one individual to use (hard hat, steel toe shoes) or available for anyone to use (emergency ladder, SCBAs, etc.). See also Critical Personal Protective Equipment.

Personal Risk Tolerance – An individual’s or team’s willingness to personally accept the likelihood of negative consequences prior to and during a task or activity. Personal risk tolerance evolves from personal knowledge, experience, beliefs and expectations related to the consequences and likelihood of what may happen. Assessing risk as acceptable to a personal risk tolerance may not adequately demonstrate risks are ALARP.

Policy — A minimum requirement that must be strictly adhered to by all personnel at all times.

Corporate policy applies worldwide

Business Unit policy applies to a specific Business Unit

Installation policy applies to a specific installation

Prescription Drugs — Any medicine that would normally require a prescription from a physician prior to procurement within the United States. This category includes all non- prescription drugs used at prescription strength. See Unit specific medications for list of prescription drugs.

Preventive Action — An action determined by management/supervisor that is taken to eliminate the causes of a potential deficiency in order to prevent occurrence.

Preventive Controls — Specific barriers that minimize or eliminate the risk of an incident by reducing the likelihood an incident will occur.

Privileged Document — A medical document that contains confidential information about a patient’s current or previous medical history. This document may be viewed only by personnel directly involved in the medical care of the patient, personnel authorized by the Company Medical Advisor, and any person authorized by the patient via a signed release form.

Procedure — A series of steps followed in a particular order.

Process — A series of actions, changes or functions that produce progress toward a desired result.

Public Domain — A medical document that contains no confidential medical information about any specific person. This document may be viewed by the Company Medical Advisor (or designee) and others at the discretion of the Rig Manager.

Purpose — The reason for the policy.

Qualified Medical Person — An individual with a locally recognized current certificate or license to provide medical care. This person may be a paramedic, registered nurse, physician, etc.

Qualitative Risk Assessment — A determination of risk based on relative levels of likelihood and severity which are determined using the experience and expertise of those contributing to the assessment. Any risk assessment that is not quantitative is considered qualitative.

Quantitative Risk Assessment — A determination of risk where numerical values for likelihood and severity are based on historical data or other statistically-significant data.

Radio Silence – The state of ceasing, preventing and protecting against all radio signals; used when activities on an installation are vulnerable to explosion.

Reporting — Informing others verbally or in writing.

Respiratory Protection – Items, equipment or procedures to safeguard a person’s airways, lungs and breathing capacity. Primary respiratory protection includes masks, respirators and proper ventilation.

Restricted Work Case (RWC) — A situation in which an employee cannot perform all assigned routine job functions, but does not result in a SIC. An RWC occurs when, as a consequence of a work-related injury or illness:

The employee is temporarily assigned to another job.

The employee cannot perform all of his routine job functions for all or part of his tour, or the employee works his regularly assigned job but cannot work the full tour.

An injured person resumes work normally after an injury but later, as a consequence of that injury, has to be put on restricted work. The injury is then be reclassified as a RWC.

Restricted or light duty the day of the injury or illness does not make the incident a restricted work case. If the employee continues under restricted duty the day after the incident, the case becomes a restricted work case.

Example 1: An employee injures a knee. The treatment only involves first aid level care and put on bed rest for the rest of the tour and returns next tour with no limitations. The incident is classified as a FAC.

Example 2: If an employee experiences minor musculoskeletal discomfort, such as muscle pains or strains, and a physician or licensed health care professional determines that the employee is fully able to perform all of his routine job functions, and the employer assigns work restriction to that employee or restricts the employee’s job functions for purpose of preventing a more serious condition from developing, the case is not recordable as a restricted work case.

Responsibility — Obligation to take action.

Risk — The possibility of suffering harm or loss.

Risk Level — A measure of the severity of any potential incident and the probability of it occurring.

Routine Job Functions — Those work activities that an employee performs regularly (at least once a week).

Safety Case — A document that contains a summary of the details of the Installation, Installation management and Company safety management system. The Safety Case is the highest level of THINK Planning Process for risk management available in the Company and is used to demonstrate major HSE risks are ALARP to meet regulatory requirements in the United Kingdom, Norway, Australia and Canada.

Safety Management System – A structured and documented system enabling Company personnel to implement effectively the Company safety and environmental protection policy.

Scope — Where, when and to whom the policies and procedures apply.

Serious Injury Case (SIC) — Any injury resulting from a work-related incident that prevents the injured person from continuing on his next shift. Logistical delay for the purpose of medical examination shall not be taken into account.

If the injury happens just before the victim goes on vacation and a medical examination reveals later on that the injured person is unfit for work, the injury is a SIC.

If the injured person resumes work normally after the injury but later, as a consequence of the same injury, has to be put off work, the injury is reclassified as a SIC.

Serious Near Hit — Any event (not resulting in actual damage) that under slightly different circumstances could have resulted in:

a serious injury case requiring at least 6 months off

a fatality

serious or major environmental damage

Severity Index — A number derived from the measurement of the severity of a series of incidents; it represents relative changes in severity over time.

Severity – Seriousness, degree or measurement (of damage), the cause of great danger, harm, damage, discomfort, or distress.

Actual Severity Rate = Actual Severity value sum x 200,000 Working Hours

Potential Severity Rate = Potential Severity value sum x 200,000 Working Hours

Should — Indicates a recommendation.

Spill — An unintentional or unplanned discharge.

START — The Company monitoring and observation process.

Subcontractor — Any company hired by Rig Oilfield Services or a client to perform work

SOOB — Summary of Operational Boundaries. A summary of defeating factors (either single or in combination) That have the potential to exceed the tolerability limits of safe operations.

Suitable — Appropriate and sufficient for a purpose, condition or occasion.

Supervisor — One who directs and watches over the work and performance of others.

Synovial Fluid — A clear, viscid lubricating fluid secreted by membranes in joint cavities, sheaths of tendons, and bursae.

Task — An individual work assignment carried out by one or more people and which may be their complete job or a part of a larger job.

Their — His/her

THINK — The Company planning process.

Tolerability — Is the willingness to operate with a risk to secure certain benefits and in the confidence that it is being properly controlled

Topside Support – A communication process between people who have responsibilities to provide oversight, monitoring and support to medical personnel to support the Company’s operations. The purpose of Topside Support is to ensure Unit, Division, Sector and Branch management have essential medical support available to their personnel.

Total Recordable Incident Rate (TRIR) — The rate of incidents as tracked on a 12-month rolling average. TRIR is calculated by the formula:

(12 months MTC + RWC + SIC + Fatality) x 200,000 12 months Working Hours

Trauma — An injury to the body resulting in an abrasion, laceration, puncture, sprain, bruising, and so on.

Unexpected Changes – Changes of any kind that were not predicted and planned for, whether temporary or permanent, particularly changes in expected results, participating personnel, environment or work conditions, or priorities.

Weapon — Any item used threateningly against a person.

Will — Mandatory requirement.

Work — An individual work assignment carried out by one or more people and which may be their complete job or a part of a larger job.

Work Related — A case is work-related anytime work hours are being recorded and an event or exposure in the work environment is the discernable cause or contributes to an injury or illness or significantly aggravates a pre-existing injury or illness.

Working Hours — Number of hours worked by employees, including overtime and training, but excluding travel time, leave or other absences.

ANNEX

INDEX OF DOCUMENTATION

These forms are not to be modified in any way. It is mandatory that they be used in their current format.

ANNEX

FILING OF DOCUMENTATION

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Health And Safety Policies And Procedures Manual

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