all-a0a-00-000-hst-0031 revised

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HSE INCIDENT REPORTING ALL-A0A-00-000-HST-0031

Retention Code: CG01 - CA

Revised: April 2021

Owner: HSE Systems

Approved By: Manager, Health & Safety Operations

Review Frequency: Five years or less

This document contains proprietary information belonging to ConocoPhillips Canada. It is intended to govern activities of ConocoPhillips Canada employees and contractors who perform work at ConocoPhillips Canada worksites. Its most current version may only be relied upon by those parties who receive a copy provided by ConocoPhillips Canada directly.

About the Document .................................................................................................................................... 4

Purpose ......................................................................................................................................................................................... 4

Scope ............................................................................................................................................................................................ 4

1. General ................................................................................................................................................ 5

1.1. Initial Response and Information ............................................................................................................................ 5

All Events ...................................................................................................................................................................................... 5

1.2. Incident Reporting ................................................................................................................................................... 6

Incident Reporting ........................................................................................................................................................................ 6

Intelex ........................................................................................................................................................................................... 6

Risk Ranking .................................................................................................................................................................................. 7

Incident Owner ............................................................................................................................................................................. 7

Internal Reporting ......................................................................................................................................................................... 8

External (Regulatory) Reporting .................................................................................................................................................... 8

HSE Enforcement .......................................................................................................................................................................... 9

2. Illness and Injury Classification and Clarifications .............................................................................. 9

2.1. Injury and Illness Classifications .............................................................................................................................. 9

Near Miss (NM) ............................................................................................................................................................................. 9

First Aid Case (FAC) ....................................................................................................................................................................... 9

Medical Treatment Case (MTC) ................................................................................................................................................... 10

Process Safety Near Miss (PS NM) .............................................................................................................................................. 10

Restricted Workday Case (RWC) ................................................................................................................................................. 11

Lost Workday Case (LWC) ........................................................................................................................................................... 11

Industrial Hygiene Exposure Incident .......................................................................................................................................... 11

Tier 1 and 2 Process Safety Event (PSE) ...................................................................................................................................... 11

Tier 3 Process Safety Event (PSE) ................................................................................................................................................ 11

2.2. Clarifications .......................................................................................................................................................... 11

Administering Oxygen ................................................................................................................................................................. 11

Chipped Teeth ............................................................................................................................................................................. 12

Debris in Eyes .............................................................................................................................................................................. 12

Ergonomic ................................................................................................................................................................................... 12




Illness .......................................................................................................................................................................................... 12

Insect Bites/Stings ....................................................................................................................................................................... 12

Mental Illness .............................................................................................................................................................................. 12

Pre-Existing Conditions ............................................................................................................................................................... 12

Prescriptions ............................................................................................................................................................................... 12

3. Alberta - Surmont Reporting ............................................................................................................. 13

3.1. Potentially Serious Incidents (PSIs)........................................................................................................................ 13

Reporting Contacts ..................................................................................................................................................................... 13

Potentially Serious Incidents (PSIs) ............................................................................................................................................. 13

3.2. Injuries and Illnesses ............................................................................................................................................. 13


Reportable/Recordable Events ................................................................................................................................................... 14

3.3. Spills and Gaseous Releases .................................................................................................................................. 16


Reportable/ Recordable Events .................................................................................................................................................. 17

3.4. Other Reportable Events ....................................................................................................................................... 21


Reportable Events ....................................................................................................................................................................... 21

4. British Columbia – Montney Reporting ............................................................................................. 22

4.1. Injuries and Illnesses ............................................................................................................................................. 22


Reportable/ Recordable Events .................................................................................................................................................. 23

4.2. Spills and Gaseous Releases .................................................................................................................................. 25



4.3. Other Reportable Events ....................................................................................................................................... 30



Attachment 1 – Alberta Spill and Release Reporting Guidance.................................................................. 33

Attachment 2 – British Columbia Spill and Release Reporting Guidance ................................................... 36




Document History

Date Approved by Change Summary

April 2021

David Reaich • Usability Mapped

• Guidance for regulatory and internal reporting

• Addition of process safety event descriptions

• Addition of reportability requirements for gaseous releases.




About the Document

Purpose The purpose of this procedure is to define internal and external reporting requirements for:

• Near Misses

• Injuries and illness

• Liquid and gaseous releases

• Other regulatory reportable incidents

Scope This procedure applies to incidents/events which occur within ConocoPhillips Canada’s (CPC) operational control. CPC has operational control when they have decision authority on HSE-related elements of operation. Operational Control must be decided early in the procurement phase to ensure the proper duty and care of our contractors and to accurately capture incidents and contractor hours. If an event occurs during an acquisition or divestiture, operational control is based on closing date (i.e., once transaction is closed then CPC will report for newly acquired assets and stops reporting for divested properties).

For Emergencies call 911 and/or contact CPC 24 Hour Emergency Response (800) 661-9525 as appropriate




1. General

1.1. Initial Response and Information

All Events If applicable, respond to any event by:

• Attending to injured persons

• Preventing further injuries

• Protecting property that is endangered because of the incident.

NOTE: Freeze and secure the incident scene unless otherwise directed by authorities.

Collect all required information as indicated in the table below:

Event Type Information

All Events

• Location of the incident

• Site

• Function (e.g., Operations and Maintenance, General

Drilling and Completions)

• Event Type (e.g., incident, near miss)

• Date and time

• Event description

• Immediate actions taken

• Contractor involvement

Liquid and Gaseous Releases

• Source of release

• Material released

• Volume released




1.2. Incident Reporting

Incident Reporting Regardless of severity, the following incident and near miss types must be reported internally:

• Environmental

• Injury/Illness

• Process Safety Events

• Vehicle

• Property Damage

• Enforcement

• Community

• Security

NOTE: Reportability thresholds and CPC/COP recordability thresholds are in the jurisdiction specific sections below. Incidents will be investigated when required as per the Pre-Incident and Incident Investigation Procedure.

Intelex Intelex is ConocoPhillips’ HSE data management software. All incidents and near misses are tracked in the EHS Event Management module:

Pertaining to incident reporting only:

1. Draft report is entered by affected business representative.

2.

Draft report is verified by the affected leadership (Verifier 1) as follows:

Function Incident Verifier

Montney Operations Operations Leader

Surmont Operations Shift Supervisor

CMT Construction Manager

Wells Field Superintendent

Calgary Calgary HSE or REFS

Then by HSE (Verifier 2). Search Location Role: CAN HSE (Intelex), for Incidents in the Calgary office, Verifier 2 is the H&S office safety coordinator.




NOTE: Incidents and near misses must be closed once corrective actions are complete. An investigation may be required, see Pre-Incident and Incident Investigation Procedure for details.

NOTE: Only security incidents that are either associated with another subevent or are corporate reportable are entered into Intelex. All other security events are recorded in D3 Security Management Software.

Risk Ranking All incidents must be:

• Risk ranked by the Incident Owner and HSE

• Risk ranked according to the CPC Risk Matrix Card

• Verified as appropriate in Intelex.

NOTE: The H&S Manager & Functional Manager are responsible for risk ranking incidents which require Crisis Hotline Notification.

NOTE: Risk must be accepted according to the Risk Matrix Card.

Incident Owner An incident owner must be assigned to all events according to the highest risk rank (actual or potential) and applies to any consequence.

Risk Category Incident Owner

Category IV – High 20-25 President

Category III – Significant 12-16 VP

Category II – Medium 8-10 VP + 1

Category I – II Medium 1-6 VP + 2

The incident owner is responsible to:

• Verify the risk rank is appropriate and incident classification is correct.

• Ensure that regulatory notifications are completed on time.




• Initiate development of the Learning Plan. See Pre-Incident and Incident Investigation Procedure for details.

Internal Reporting All incidents:

• Must be immediately reported to the work supervisor and HSE.

• Should be entered in Intelex within 24 hours of occurrence.

The following are considered CPC recordable. Specifics can be found in the jurisdiction specific sections below.

Incident Type Recordable Consequences

Injuries/ Illness

• Medical Treatment Case

• Restricted Workday Case

• Lost Workday Case

• Fatality

• Industrial Hygiene Occupational Exposure Incident

Environmental Regulatory reportable liquid and gaseous releases

Process Safety Events Tier 1 process safety events

External (Regulatory) Reporting

External reporting requirements are detailed in the jurisdiction specific sections below.

NOTE: All electrical incident regulatory notifications are handled by the electrical department.




HSE Enforcement Assessed or paid HSE‐related fines or penalties; government allegations of violation(s); assessment of a violation by a federal, provincial, local or municipal agency or entity; and certain self‐disclosed violations. HSE Enforcement may be a result of either:

• Inspections by regulatory authorities

• Persistent non-compliance raised by a regulatory authority.

See COP HSE Management System Standard - HSE Fines and Enforcement Actions

2. Illness and Injury Classification and Clarifications

2.1. Injury and Illness Classifications

Near Miss (NM) An event with no consequences, but with other circumstances could have resulted in fire, injury, property damage, process upset, spill, release, or some other failure.

First Aid Case (FAC) Injury where treatment is limited to:

• Using non‐prescription medication at non‐prescription strength.

• Administering tetanus (only) 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.

• Using temporary immobilization devices while transporting an accident 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 by irrigation, tweezers, cotton swabs or other simple means.

• Using finger guards.

• Using massages other than chiropractic treatment or physical therapy.

• Drinking fluids for relief of heat stress.




Medical Treatment Case (MTC)

An injury or illness involving any treatment other than what is listed as first aid treatment. This includes:

• Stitches or surgical/medical glue used to close a wound.

• Prescribed or prescription strength medications.

• Physical therapy or chiropractic treatment prescribed by a physician.

• Application of fiberglass, plaster, or other rigid supports structures.

• Surgical procedures not requiring restricted work or days away.

• IV administration of saline or glucose.

Process Safety Near Miss (PS NM)

Entered into Intelex by Operations: • Process shutdown system trips and activation of safety system that was not

intentional (e.g., fault wire causes plant trip or activation during device testing).

• A frozen or plugged process line that could have led to loss of primary containment.

• Formation of a hydrate that requires hydrate management.

• Process isolation errors that were caught prior to work execution.

• Performing work on an incorrect line, piece of equipment, valve, etc. that could have realistically led to loss of primary containment.

• Safety Critical Element Impairment (i.e., bypass forms are not filled out or when a bypass is not removed when work is complete)

• Anomalies identified on car seal list (i.e., missing car seals, valves car sealed in the wrong position, engineering car seal errors)

• Engineering design anomalies (system not operating as expected or documented). E.g., control system programming errors prior to errors resulting in loss of primary containment, potential for excessive vibrations with observable damage or potential damage (i.e., loose fittings), anything that should have been designed out, resistance temperature detector in wrong location.

• Any impairment of relief device discharge path to safe location (flare system challenges)

• MOC not completed for a MOC covered change that could have led to loss of primary containment.

• PSV fails to activate when it should have on high pressure

Entered into Intelex by Asset Integrity: • Asset Integrity inspection results below Tmin or cracking of pressure equipment.

• Relief valve failure to activate within tolerance on demand during operations or test (entered in Intelex as one entry monthly)

For Wells: • Safe Operating Limit(s) are defined in the Well Operating Guideline / Well Design

Envelope as “the design limits for the well including allowable pressures and temperatures, maximum flow/injection rates, etc.” has (have) been executed

• BOP (secondary barrier) is closed in order to raise mud weight (required to maintain the primary barrier)




Restricted Workday Case (RWC)

An injury or an illness that prevents the employee from performing one or more of the routine functions of their job or from working the full workday that he or she would otherwise have been scheduled to work.

NOTE: The day of injury is not considered a Restricted Workday. If the Injured party cannot return to full duties the next calendar day, regardless of whether they are scheduled to work, this day is considered the first restricted day for the count.

Lost Workday Case (LWC)

An injury or an illness in which the employee is unable to or prescribed by a licensed health care provider not to return to work the next calendar day, whether the employee is scheduled to work that day (day of injury is not considered lost work).

Industrial Hygiene Exposure Incident

An event where a worker’s exposure to a chemical or nonchemical agent is measured and found to be higher than a corresponding guidance (e.g., ConocoPhillips Occupational Exposure Limit) or regulatory standard and the worker did not have correct protection against that exposure. For guidance and regulatory standards and exposure event classification, see Industrial Hygiene Metrics Reporting Procedure. For incident investigation purposes, an exposure incident is a type of incident.

Tier 1 and 2 Process Safety Event (PSE)

Defined in corporate Process Safety Metrics Guideline. Aligns with API 754 and IOGP 456

Tier 3 Process Safety Event (PSE)

• Any PSE that does not meet Tier 1 or 2 criteria.

• A loss of primary containment when any of the below are met: o Process equipment is the source of release. o Fresh water is > 60 C o A PSV relieves to flare or atmosphere (reporting purposes only) o It involves unplanned venting of blanketed tanks. o It involves vendor equipment while connected to CPC process

equipment. o It results in fire from or near process equipment regardless of damage

value

NOTE: PSEs will be risk ranked for all consequences except business interruption.

2.2. Clarifications

Administering Oxygen

Recordable only when worker is exhibiting symptoms related to breathing.




Chipped Teeth Recordable as a bone has been chipped or broken.

Debris in Eyes Only recordable if a method more invasive than irrigation or a cotton swab is used for removal.

Ergonomic Only recordable if work-related and leads to a recordable injury. See section 1.2, Internal Reporting.

Illness Only recordable if the illness is identified by a licensed health care professional and is suspected to be caused by workplace exposures.

Insect Bites/Stings Only recordable if intravenous saline or glucose is administered.

Mental Illness Only recordable if:

• Determined by a licensed health care professional (e.g., physician,

psychiatrist etc.) and

• The employee chooses to disclose the information to CPC.

Pre-Existing Conditions

Only recordable if a new treatment is received or a medication dosage is changed due to a workplace injury.

Prescriptions If a worker is prescribed prescription strength medication, the incident is recordable regardless of whether the prescription is filled.




3. Alberta - Surmont Reporting

NOTE: “CPC”, in and of the below tables indicates recordable events only. Regardless of severity, all events must be reported and recorded in Intelex.

“CN” indicates when COP Crisis Notification is required. If COP column is checked, Intelex notification must be made within 2 business days.

3.1. Potentially Serious Incidents (PSIs)

Reporting Contacts Report To Contact Timeline Responsible

Alberta Occupational Health and Safety (OHS)

866-415-8690

As soon as possible

HSE or delegate

Provide a copy of the incident investigation report to the Director of Inspection as soon as possible.

Potentially Serious Incidents (PSIs)

A PSI is any event where a reasonable and informed person would determine that under slightly different circumstances, there would be a high likelihood for serious injury to a person. PSIs are recorded in Intelex as Near Misses.

NOTE: A PSI is not limited to workers and it does not require the occurrence of an injury.

When determining if an event is a PSI, consider:

• Actual circumstances of the incident

• Hazards present at the time of the incident.

• Appropriate controls in place at the time of the incident

• Slightly different circumstances (timing, distance, body position, etc.) that may have resulted in a serious injury.

• Similar incidents that have occurred at ConocoPhillips within the past two years that resulted in injury.

3.2. Injuries and Illnesses





Royal Canadian Mounted Police (RCMP), non-emergency

403-204-8900

Immediately VP HSE SD or delegate

Corporate Crisis Hotline

Primary:

1-281-293-1746 / 1-281-493-2767

Alternate:

1-918-661-7888 / 1-918-661-6529


Alberta Occupational Health and Safety (OHS)

866-415-8690

As soon as possible

HSE, Regulatory or delegate

Alberta Workers Compensation Board (WCB)

866-922-9221 With 72 hours of occurrence

Health Services or delegate

Alberta Boilers Safety Association (ABSA)

780-437-9100

As per the CPC Pressure Equipment Integrity Manual (ALL-A0A-00-000-FST-0001)

CPC Chief Inspector or delegate

NOTE: ABSA reporting requirements are not identified in this procedure. Refer to CPC Pressure Equipment Integrity Manual (ALL-A0A-00-000-FST-0001)

Reportable/Recordable Events

Review the following reportability criteria following any event.

Regulatory / External

ConocoPhillips

Illness / Injury

OH

S

WC

B

RC

MP

CP

C

CO

P

Death ✓ ✓ ✓ ✓ ✓

CN




NOTE: While ALL events are CPC reportable those checked are considered recordable and contribute to internal statistics

NOTE: All WCB notifications are completed by CPC Health Services

Permanent Disability (e.g., amputation, hearing loss, etc.)

✓ ✓

First Aid

Any hospital admittance due to a workplace injury or illness

✓ ✓

CN

Hospitalization (more than two days or expected duration of more than two)

✓ ✓

Loss of Consciousness ✓ ✓

Lost Time/ Workday Injury ✓ ✓ ✓

Incidents resulting in multiple injuries/ illnesses to employees, contractors, or the public

✓ ✓

CN

Medical Aid Expenses (e.g., dental treatment, prescription medication, etc.)

✓

Medical Treatment Case ✓

Modified Restricted Duties ✓

Over Exposure resulting in disabling or potentially disabling conditions

✓

Over Exposure events per the COP Occupational Health Standard

✓ ✓




3.3. Spills and Gaseous Releases

See Attachment 1 for Alberta Spill and Release Reporting Guidance.



Primary:

1-281-293-1746 / 1-281-493-2767

Alternate:

1-918-661-7888 / 1-918-661-6529


Alberta Energy Regulator (AER)

1-800-222-6514

Verbal Immediately, written within 7 days of verbal report.

7-day follow-up letter for TDG releases

Incident Owner or delegate

Alberta Boilers Safety Association (ABSA)

780-437-9100


CPC Chief Inspector or delegate-

Environment Canada (EC/CEPA)

1-800-222-6514 (same as AER)

Immediately Incident Owner or delegate

Transport Canada

1-888-226-883 *611

Verify only, carrier to report events.

Incident owner or delegate

Dangerous Goods 24-Hour Information

N/A N/A




Reportable/ Recordable Events

Review the following reportability criteria following any event:

NOTE: While all events must be reported, any spill or release that is regulatory reportable is considered internally (CPC) recordable.

Regulatory / External

ConocoPhillips

Liquid Release

AER

EPEA

(E&

P)

EC (

CEP

A)

Tran

spo

rt C

anad

a

CP

C

CO

P

On-Lease - >2 m3 ✓ ✓

Off-Lease – Any Volume (includes transportation incidents)

✓ ✓

Pipeline – Any Volume (includes leak or break during pressure testing)

✓ ✓

Oilfield Wastes – Any Volume ✓ ✓

Class 3 Flammable Liquids – 200 litres ✓ ✓ ✓

Class 3 Flammable Liquids – 200 litres ✓ ✓ ✓

Class 4 Flammable Solids – 25 kilograms ✓ ✓ ✓

Class 5.1 Oxidizing Substances – 50 kilograms or 50 litres

✓ ✓ ✓

Class 5.2 Organic Peroxides – 1 kilogram or 1 litre

✓ ✓ ✓

Class 6.1 Toxic Substances – 5 Kilograms or 5 litres

✓ ✓ ✓

Class 8 Corrosives – 5 kilograms or 5 litres ✓ ✓ ✓

Class 9 Miscellaneous Products, Substances or Organisms – 25 kg or 25 litres

✓ ✓ ✓

TDG Class 3 Flammable Liquids (Packing Group I or II)– Any Quantity

✓ ✓




TDG Class 4 Flammable Solids (Packing Group I or II) – Any Quantity

✓ ✓

TDG Class 5 Oxidizing Substances and Organic Peroxides (Packing Group I or II) – Any Quantity

✓ ✓

TDG Class 6.1 Toxic and Infectious Substances (Packing Group I or II) – Any Quantity

✓ ✓

TDG Class 8 Corrosives (Packing Group I or II) - Any Quantity

✓ ✓

TDG Class 3 Flammable Liquids (Packing Group III) – 30 litres or 30 kilograms

✓ ✓

TDG Class 4 Flammable Solids (Packing Group III) – 30 litres or 30 kilograms

✓ ✓

TDG Class 5 Oxidizing Substances and Organic Peroxides (Packing Group III) – 30 litres or 30 kilograms

✓ ✓

TDG Class 6.1 Toxic and Infectious Substances (Packing Group III) – 30 litres or 30 kilograms

✓ ✓

TDG Class 6.2 Toxic and Infectious Substances (Category A or B) - Any Quantity

✓ ✓

TDG Class 7 Radioactive Materials – A level of ionizing radiation greater than the level established in section 39 of the “packaging and transport of nuclear substances Regulations 2015”

✓ ✓

TDG Class 8 Corrosives (Packing Group III) - 30 litres or 30 kilograms

✓ ✓

TDG Class 9 Miscellaneous Products, Substances, Organisms (Packing Group II or III, or without packing group) - 30 litres or 30 kilograms

✓ ✓

Fluid Release >10 litres from pressure vessel

✓

Tier 1 or Tier 2 PSE (API RP 754) ✓

Tier 3 PSE if deviation from Safe Operating Limits

✓




Liquid hydrocarbon spills (any volume) to environmentally sensitive areas, recreational areas or wildlife habitats/refuges which are likely to attract media attention or cause closure, stoppage or re-routing of traffic on public road or waterway.

✓ ✓

CN

Liquid hydrocarbon spills or releases from primary containment greater than 100 barrels (15.9 cubic meters)

✓ ✓

CN

Hazardous chemical spills or releases from primary containment greater than 5000 pounds (2.27 metric tons)

✓ ✓

On-shore produced water spills or releases from primary containment greater than 100 barrels (15.9 cubic meters)

✓ ✓

On-shore produced water spills or releases from primary containment greater than 1000 barrels (159 cubic meters)

✓ ✓

CN

NOTE: ABSA reporting requirements are not identified in this procedure. Refer to CPC Pressure Equipment Integrity Manual (ALL-A0A-00-000-FST-0001)

Regulator / External

ConocoPhillips

Gaseous Release

AER

CP

C

CO

P

Venting 15 e3m3 Cumulative Monthly Volume

(= 1 CPC recordable event)

✓ ✓

Any volume released to environmentally sensitive areas, recreational areas or wildlife habitats/refuges which are likely to attract media attention or cause closure, stoppage or re-routing of traffic on public road or waterway.

✓

CN




Flaring Black Smoke ✓ ✓

30 e3m3 Flare Volume (single event) ✓ ✓

Flaring event > 4 hours ✓ ✓




3.4. Other Reportable Events

Reporting Contacts See section 3.2, Reporting Contacts.

Reportable Events Regulator / External

ConocoPhillips

Incident

AER

OH

S

RC

MP

CO

P

Collapse of derrick or crane ✓

Explosion – unplanned or uncontrolled (injury or potential for injury)

✓

Failure of well integrity ✓

Fire – caused by flare or incinerator ✓

Fire – causing loss of 2m3 oil or 30 e3m3 gas or wellhead damage

✓

Fire – deployment of major fire-fighting equipment (Oil Sands)

✓

Fire – unplanned or uncontrolled (injury or potential for injury)

✓

Flood – unplanned or uncontrolled (injury or potential for injury)

✓

Fire – well, facility or pipeline related ✓

Pipeline incidents (including all contact) – construction or operations

✓

Pressure equipment incidents (resulting in property damage or injury)

Structural failure of building or structure component when necessary for structural

integrity

✓

Off-Site vehicle incident (damage greater than $2000)

✓

Property damage events likely to exceed $1 000 000 USD net in estimated damages (example fires, explosions, collisions, acts of nature, vandalism, theft, etc.)

✓

CN




Unscheduled HSE related business interruption that will likely result in $5 000 000 USD or more in estimated losses.

✓

CN

Any situation that should be brought to the attention of corporate management due to actual or potential impact on the company.

✓

CN

Evacuation beyond the facilities of company employees or contractor personnel

✓

CN

Sheltering-in-place of the public

✓

CN

Mandatory evacuation of the public

✓

CN

Loss of well control that endangers the rig, onsite personnel, or the environment

✓

CN

Serious ranked marine, truck, aviation, rail, pipeline or other transportation incident involving our products, property damage, spills or releases, traffic stoppages, evacuations etc.

✓

CN

Acts of terrorism (e.g., bomb threats, sabotage, kidnapping, employee violence, etc.)

✓

CN

Any incident that attracts or could attract media attention including but not limited to confrontations with anti-industry groups

✓

CN

Multiple complaints of acute illness by third parties allegedly caused by our operations or products (i.e. calls by more than one individual)

✓

CN

4. British Columbia – Montney Reporting

NOTE: “CPC”, in and of the below tables indicates recordable events only. Regardless of severity, all events must be reported and recorded in Intelex.

“CN” indicates when COP Crisis Notification is required. If COP column is checked, Intelex notification must be made within 2 business days.

4.1. Injuries and Illnesses





Royal Canadian Mounted Police (RCMP), non-emergency

250-787-8140

Immediately. VP HSE SD or delegate.


Primary:

1-281-293-1746 / 1-281-493-2767

Alternate:

1-918-661-7888 / 1-918-661-6529

Immediately. VP HSE SD or delegate.

WorkSafe BC

1-888-967-5377

(online report does not serve as immediate notification)


HSE, Regulatory or delegate

Technical Safety BC

1-866-566-7233

or webform.

24 hours – fatality or serious damage must be reported immediately

CPC Chief Inspector or delegate.

NOTE: Technical Safety BC reporting requirements are not identified in this procedure. Refer to CPC Pressure Equipment Integrity Manual (ALL-A0A-00-000-FST-0001)

Reportable/ Recordable Events


ConocoPhillips

Illness / Injury

Wo

rk

Safe

BC

RC

MP

CP

C

CO

P

Death ✓ ✓ ✓ ✓

CN

Loss of Consciousness ✓




Any hospital admittance due to a workplace injury or illness

✓ ✓

CN

Lost Time/ Workday Injury ✓ ✓ ✓

Incidents resulting in multiple injuries/ illnesses to employees, contractors, or the public

✓

CN

Serious injuries including loss of consciousness, major fractures, respiratory compromise, amputations, lacerations causing hemorrhage, penetrating injuries, major burns, traumatic injuries likely resulting in loss of sight, hearing, or touch.

✓

Medical Treatment Case ✓

Modified Restricted Duties ✓

Over Exposure resulting in disabling or potentially disabling conditions

✓

Over Exposure events per the COP Occupational Health Standard

✓




4.2. Spills and Gaseous Releases

See Attachment 2 for BC Spill and Release Reporting Guidance.



Primary:

1-281-293-1746 / 1-281-493-2767

Alternate:

1-918-661-7888 / 1-918-661-6529

Immediately VP HSE SD or delegate.

EMBC 1-800-663-3456 Immediately Incident Owner

or delegate

Environment Canada (EC/CEPA)

1-800-222-6514 (same as AER)

Immediately Incident owner or delegate

Technical Safety BC

1-866-566-7233


CPC Chief Inspector or delegate.

Transport Canada

1-888-226-883 *611

Verify only, carrier to report events.

Incident Owner or delegate

Dangerous Goods 24-Hour Information

1-800-226-9600

N/A N/A

NOTE: All environmental releases in BC are reported through the one window EMBC Spill Reporting Line. EMBC triages the event, which is then forwarded to both the MOE and OGC for follow up by the appropriate regulator.




Reportable Events

Regulator / External ConocoPhillips

Liquid Release

OG

C

MO

E

EPEA

(E&

P)

EC (

CEP

A)

Tran

spo

rt

Can

ada

CP

C

CO

P

Hydrocarbons – 100 litres (contains no toxic materials and does not impact water way)

✓

Produced/Salt Water – 200 litres (contains not toxic materials)

✓

Fresh Water – 10,000 litres ✓

Drilling Mud or Invert Mud – 100 litres

✓

Condensate – 100 litres ✓

Any Other Fluid Which Contains Toxic Substances – 25 litres

✓

Class 3 Flammable Liquids – 100 litres

✓ ✓

Class 3 Flammable Liquids – 200 litres

✓ ✓ ✓ ✓

Class 4 Flammable Solids – 25 kilograms

✓ ✓ ✓ ✓

Class 5.1 Oxidizing Substances – 50 kilograms or 50 litres

✓ ✓ ✓ ✓

Class 5.2 Organic Peroxides – 1 kilogram or 1 litre

✓ ✓ ✓ ✓

Class 6.1 Toxic Substances – 5 Kilograms or 5 litres

✓ ✓ ✓ ✓

Class 8 Corrosives – 5 kilograms or 5 litres

✓ ✓ ✓ ✓

Class 9 Miscellaneous Products, Substances or Organisms – 25 kg or 25 litres

✓ ✓ ✓ ✓

Waste Containing Dioxin – 1 kg or 1 litre

✓




Leachable Toxic Waste – 25 kg or 25 litres

✓

Waste Containing Polycyclic Aromatic Hydrocarbons – 5 kg or 5 litres

✓

Waste Oil – 100 litres ✓

Waste Containing Tetrachloroethylene – 50 kg or 50 litres

✓

Hazardous Waste – 25 kg or 25 litres

✓

Substance Not Covered by Items Above (up to Class 3) – 200 kg or 200 litres

✓

Hazardous Substance Release – Any Volume

TDG Class 3 Flammable Liquids (Packing Group I or II)– Any Quantity

✓ ✓ ✓

TDG Class 4 Flammable Solids (Packing Group I or II) – Any Quantity

✓ ✓ ✓

TDG Class 5 Oxidizing Substances and Organic Peroxides (Packing Group I or II) – Any Quantity

✓ ✓ ✓

TDG Class 6.1 Toxic and Infectious Substances (Packing Group I or II) – Any Quantity

✓ ✓ ✓

TDG Class 8 Corrosives (Packing Group I or II) - Any Quantity

✓ ✓ ✓

TDG Class 3 Flammable Liquids (Packing Group III) – 30 litres or 30 kilograms

✓ ✓ ✓

TDG Class 4 Flammable Solids (Packing Group III) – 30 litres or 30 kilograms

✓ ✓ ✓

TDG Class 5 Oxidizing Substances and Organic Peroxides (Packing

✓ ✓ ✓




Group III) – 30 litres or 30 kilograms

TDG Class 6.1 Toxic and Infectious Substances (Packing Group III) – 30 litres or 30 kilograms

✓ ✓ ✓

TDG Class 6.2 Toxic and Infectious Substances (Category A or B) - Any Quantity

✓ ✓ ✓

TDG Class 7 Radioactive Materials – A level of ionizing radiation greater than the level established in section 39 of the “packaging and transport of nuclear substances Regulations 2015”

✓ ✓ ✓

TDG Class 8 Corrosives (Packing Group III) - 30 litres or 30 kilograms

✓ ✓ ✓

TDG Class 9 Miscellaneous Products, Substances, Organisms (Packing Group II or III, or without packing group) - 30 litres or 30 kilograms

✓ ✓ ✓

Fluid Release >10 litres from pressure vessel

✓

Tier 1 or Tier 2 PSE (API RP 754) ✓

Tier 3 PSE if deviation from Safe Operating Limits

✓

Liquid hydrocarbon spills (any volume) to environmentally sensitive areas, recreational areas or wildlife habitats/refuges which are likely to attract media attention or cause closure, stoppage or re-routing of traffic on public road or waterway.

✓ ✓

CN

Liquid hydrocarbon spills or releases from primary containment greater than 100 barrels (15.9 cubic meters)

✓ ✓

CN

Hazardous chemical spills or releases from primary

✓ ✓





Conoco- Phillips

Gaseous Release

OG

C

MO

E

CP

C

CO

P

Venting 10 kg or 15 m3 of sweet natural gas with operating pressure >100 PSI (see additional information below)

✓

✓

✓

Any volume released to environmentally sensitive areas, recreational areas or wildlife habitats/refuges which are likely to attract media attention or cause closure, stoppage or re-routing of traffic on public road or waterway.

✓

Flaring ≥100 e3m3 if approved inlet capacity is >500 e3m3/d

✓

✓

20% of daily inlet capacity if approved inlet capacity is 150-500 e3m3/d

✓

✓

≥30 e3m3 if approved inlet capacity is <150 e3m3/d

✓ ✓

Report gaseous releases if they meet the above criteria and any of the below:

• Are from a sweet or sour gas pipeline or associated fitting.

• A hazardous/unsafe condition exists (i.e., potential for explosion, fire, facility shutdown).

• Off-lease odors are evident (through smell or measurement).

• If there has been or if there is potential for public complaints.

• If it takes > 4 hours to gain control (i.e., fitting leak).

containment greater than 5000 pounds (2.27 metric tons)

On-shore produced water spills or releases from primary containment greater than 100 barrels (15.9 cubic meters)

✓ ✓

On-shore produced water spills or releases from primary containment greater than 1000 barrels (159 cubic meters)

✓ ✓

CN




• Total volume vented is equal to or exceed 100 m3/month. Use Ministry of Finance Forms – BC 19 and BC-20 as appropriate.

4.3. Other Reportable Events

Reporting Contacts See Sections 3.1 and 3.2, Reporting Contacts.

Reportable Events Regulator / External

Conoco-Phillips

Incident

Wo

rkSa

fe B

C

OG

C

RC

MP

CO

P

Explosion – unplanned or uncontrolled ✓

Fire – unplanned or uncontrolled (injury or potential for injury)

✓ ✓ ✓

Fire – well, facility or pipeline related ✓ ✓ ✓

Pipeline incidents – construction or operations ✓

Pressure equipment incidents (resulting in property damage or injury)

Roads or road structure – significant damage ✓

Security incidents ✓




Structural failure of building or structure component when necessary for structural integrity

✓

Off-site vehicle incident (damage greater than $1000) ✓

Spills or releases of hazardous substances which are not provincially regulated, such as radioactive substances

✓

Major damage to oil and gas roads or road structures ✓

Drilling Kicks – Pit gain of 3m3 or greater, or casing pressure 85% of MA, or 50% out of hole when kicked, well taking fluid (LC), associated spill, or general situation deterioration

✓

Pipeline Incidents, such as spills during construction phase, exposed pipe caused by flooding, pipeline over pressure, failure (without release) or any pressure control or ESD device during operations

✓

Security related issues ✓

Property damage events likely to exceed $1 000 000 USD net in estimated damages (example fires, explosions, collisions, acts of nature, vandalism, theft, etc.)

✓

CN

Unscheduled HSE related business interruption that will likely result in $5 000 000 USD or more in estimated losses.

✓

CN

Any situation that should be brought to the attention of corporate management due to actual or potential impact on the company.

✓

CN

Evacuation beyond the facilities of company employees or contractor personnel

✓

CN

Sheltering-in-place of the public

✓

CN

Mandatory evacuation of the public

✓

CN

Loss of well control that endangers the rig, onsite personnel, or the environment

✓

CN

Serious ranked marine, truck aviation, rail, pipeline, or other transportation incident involving our products, property damage, spills or releases, traffic stoppages, evacuations etc.

✓

CN

Acts of terrorism (e.g., bomb threats, sabotage, kidnapping employee violence, etc.)

✓

CN




Any incident that attracts or could attract media attention including but not limited to confrontations with anti-industry groups

✓

CN

Multiple complaints of acute illness by third parties allegedly caused by our operations or products (i.e. calls by more than one individual)

✓

CN




Attachment 1 – Alberta Spill and Release Reporting Guidance




Attachment 2 – British Columbia Spill and Release Reporting Guidance

all-a0a-00-000-hst-0031 revised

Documents