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SAFETY MANAGEMENT SYSTEM MANUAL

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S A F E T Y

M A N A G E M E N T

S Y S T E M

( S M S )

M A N U A L

COPY NUMBER:

HOLDER:


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S A F E T Y

M A N A G E M E N T

S Y S T E M

(SMS)MANUAL

THIS DOCUMENT SHALL BE SUBJECT TO FORMAL REVISIONCONTROLS ONLY WHEN OVERSTAMPED CONTROLLED COPY INRED INK AND THE CONTROL COPY NUMBER IS ENTERED BELOW.

COPY NUMBER:

HOLDER:

THIS DOCUMENT IS THE PROPERTY OF TUBOSCOPE (UK) LTD EASTERNHEMISPHERE OPERATIONS. IT SHOULD NOT BE COPIED OR REPRODUCED INANY FORM WITHOUT THE CONSENT OF TUBOSCOPE (UK) LTD.

ISSUE STATUS:-

ISSUE EFFECTIVE DATEA MAY 1998

PREPARED REVIEWED AUTHORISED SIGNATURE DATE

J.H. BULLOCH J.E. BUTTON P.STUARTVICE PRESIDENT


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AMENDMENT RECORD

SECTIONPAGE

NONEWREV

DESCRIPTION REF. DATE/AUTH


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CONTROLLED COPY HOLDERS

Copy/ChartNumber

NAME TITLE LOCATIONP Y

0.0 P. Stuart VP Eastern Hemisphere x

5.0 C. Harriman Regional Mgr. North Sea x

5.1 I Newell Ops Mgr Solids Control x

5.2 R. Samuel Ops. Mgr. Coating / Insp. x

5.24 J Leggett Operations Supervisor x

11.2 J. Bulloch QA / Safety Manager Originals

LOCATION KEY:-

P PORTLETHEN,

Y GREAT YARMOUTH - Denotes Controlled Copy of SMS ManualHolders of Procedures Manual

Document Control

All of the above noted copy holders shall receive authorised updatedpages from the Safety Manager or designee. The above senior sitemanagers may also distribute Controlled Copies of the SMS manualwithin the areas of their responsibilities.


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(I) Amendment Log Sheet

(II) Distribution List(III) Contents(IV) Foreword to Safety Management System

1.0 SAFETY MANAGEMENT SYSTEM OVERVIEW1.1 HS & E Management Philosophy1.2 Scope of the SMS1.3 SMS Documentation Structure1.4 Project Specific Safety Plan1.5 Performance Monitoring

2.0 HEALTH, SAFETY and ENVIRONMENTAL POLICY OBJECTIVES2.1 HS & E Policy Statement2.2 HS & E Objectives

3.0 HEALTH SAFETY and ENVIRONMENTAL RESPONSIBILITIES3.1 Responsibilities against Policy Objectives3.2 Responsibilities against job positions

4.0 ORGANISATION for HS & E MANAGEMENT4.1 Company Organisation

Organisation charts Appendices 1 to 5

5.0 WORKFORCE INVOLVEMENT in HS & E MANAGEMENT

6.0 ELEMENTS for SAFETY MANAGEMENT6.1 Personnel Management6.2 Risk Management6.3 Communication6.4 Occupational Health6.5 Work Procedures and Controls6.6 Environmental Management6.7 Contractor Safety Management6.8 Accident & Incident Reporting & Investigation6.9 Contingency Planning6.10 Performance Monitoring


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Tuboscope (UK) Ltd provides an essential support service and equipment supply to

many companies within the Oil and Gas Industry. In providing this service thecompany recognises that its operations may involve potential hazards and thereforeit is the primary and continuing policy of the company to identify all such hazardsand, through the implementation of management systems, to reduce the risk to all,as is reasonably practical.

In meeting this commitment, Tuboscope is aware of its responsibilities to protectand secure the health and safety of its employees, its sub-contractors and anypersons who may come into contact with the Company during the course of theiractivities. In addition we recognise and take fully into account, the effect of ouractivities on the environment, in which we live and work.

To provide a structured approach towards achieving our objective, the Companyhas developed this Safety Management System (SMS). The term SMS encompassesall of our activities connected with health, safety and the environment, whichcontribute towards the establishment of a safe system of work. Legislation andcurrent industry practise however, necessitates that we re-structure these into anauditable management system. This document, level 1 of the system, together withits support documentation provides a single source of reference for all HS & Erelated affairs within the Company Divisions as listed below.

Safety must be considered an integral part of the daily responsibility for all

managers, supervisors and employees. Your co-operation and positive contributionis achieved by your understanding and participation in effectively implementing thisSafety Management System.

SAFETY MANAGER

This manual is applicable to the following Divisions of Tuboscope (UK) Ltd:

Brandt Solids Control DivisionTuboscope Inspection DivisionTuboscope Coating Division


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1.1 HS & E Management Philosophy

The Company strives to achieve a philosophy of continuous improvements in itsmanagement of Health, Safety and Environmental Affairs modelled on HS (G) 65Successful Health & Safety Management (see section 1.7 for details).

Successful HS & E Management relies upon the relationship between managementphilosophy, policy and objectives, employees and contractors, facilities andequipment. The Vice President has established HS & E objectives, the intent ofwhich has been adopted by all of the affected divisions within the Company andmade specific to these divisions. In line with Health and Safety Executive guidancethese objectives are:

Specific

Measurable

Achievable

Realistic

Timescoped

The objectives are achieved by implementing the key elements of safetymanagement, which form the body of the SMS. These, together with the interfaces,are demonstrated on the figure below. Each division philosophy of continuous

improvement is achieved through the procedures of audit, inspection andmanagement review which form the control loops essential to identifying areas ofimprovement and implementation of the improvement plan.

Successful implementation of this philosophy provides the safe system of work whichis inherent in the Safety Management System.

ManagementPhilosophy

Policy and ObjectivesPersonnel Management

CommunicationOccupational Health

OperationsOccupational Health

Environmental ManagementMaintenance

AuditInspection

Incident Investigation

Employees /Contractors

Facilities /Equipment

Hazard ManagementJob Procedures

Contingency Planning


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1.2 Scope of the SMS

The Safety Management System (SMS) is an integral part of the way the Companycarries out its business of providing support services to the oil and gas industry. Assuch it is integral with all aspects of Company activity and is allied to the qualitymanagement system.

The Safety Management system Manual (Level 1) provides the policies, objectives,organisation and responsibilities in addition to an overview of the key elementsestablished to achieve the objectives. This document is synonymous with the QualityManual, the intent being to provide a standardised approach, as far as possible,between HS & E, it forms the basis for employee instruction to increase the level of

understanding of HS & E affairs. In this way employees are in a better position toparticipate in the process of continuous improvement.

Level 2 of the SMS provides the procedures, which make up the key elements ofsafety management. The format of the procedures is based on the QualityManagement System to maintain standardisation. Where common procedures existwithin the quality system, they are only referenced in the SMS to avoid duplication.The procedures define the management standards of who is going to do what andwhen. In this way performance monitoring can be established.

Level 3 of the SMS provides the working instructions. These are detailed instructions

to be utilised by employees at the workplace. They are developed in conjunction withthe employees so that maximum benefit can be gained from their experience. Inaddition to work instructions are job rules, which are mandatory.

The SMS, used effectively, will enable the Company to maintain and improve itssafety performance and also provide a commercial advantage through which, it canmaintain stability for its workforce.


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1.3 SMS Documentation Structure

The structure of the documentation is based on The Company Quality ManagementSystem.

Level 1 Policy, objectives, responsibilities, organisation (QAM B)

Level 2 Procedures (QAM C)

Level 3 Work Instructions (QAM D)

This is primarily to achieve standardisation but also to facilitate the process of audit.The concept of the system is that any topic be traceable from company objectives,through division objectives, to procedures and finally work instructions. In addition

procedures are linked, where appropriate, in a horizontal direction thus ensuring thesystem is totally integrated.

The SMS is specific to the referenced divisions of Tuboscope (UK) Ltd and is notinfluenced by, or biased towards, any one client.

COMPANY OBJECTIVESMS MANUAL

HS & E Procedures

HS & E Working Instructions

LEVEL 1

LEVEL 2

LEVEL 3


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1.4 Project Specific Safety Plan

The Company recognises that effective safety requires that policies, procedures andwork instructions be applicable to the location in which they are to be utilised. In themajority of cases the Company SMS will suffice. Should client requirements,operating or environmental conditions indicate that additional procedures arenecessary these will be developed and becomeproject specific safety plans.

These plans effectively form level 4 of the documentation structure and provide asingle source of reference on HS & E affairs for Company personnel at the location.

The origin of such plans is demonstrated below. Initially the Company, together with

the client, will identify the key elements of safety management to be utilised at thatlocation. The client will specify which of their procedures are mandatory, e.g. PermitTo Work, and the remainder of the document will comprise the Company proceduresdrawn from Levels 1, 2 and 3 of the Company SMS.

These documents are controlled in the same way as the Company SMS to ensurethat they are maintained current.

Client SMS

Level 1

Level 3

Pro ect Safet Plan


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1.5 Performance Monitoring

In order to ensure the ongoing effectiveness of the Safety Management System, thecompany has put in place several control procedures. These are in three groupingsto provide control in the short, medium and long term. Within the SMS, performancemonitoring is a combination of several activities which are specifically undertaken to:

Demonstrate performance and achievement.

Measure effectiveness

Confirm compliance

Improve the SMS on a continuous basis.

They are based on the management business model shown below, whereperformance monitoring is achieved through control correction improvement

The company implements performance monitoring through:

Statistical analysis

Inspection Audit

Management Review

POLICY AND OBJECTIVES

ORGANISATION,RESPONSIBILITY, RESOURCE

IMPLEMENTATION,PERFORMANCE, MONITOR

MANAGEMENT REVIEW

CONTROL

CORRECTION

IMPROVEMENT


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2.2 HS & E Objectives

Tuboscope through commitment to the HS & E Policy and the objectives outlined below,ensures that the it has in place effective, practical and achievable means to provide for thehealth, safety, protection and welfare of employees, contractors, clients and the environment.

The Company shall:

Comply with all applicable legislation, codes of practice and industry standards.

Establish procedures and implement work instructions sufficient to avoid injury toemployees and others that may be affected by company operations.

Establish standards and procedures to minimise harm to employees and others throughoccupational health and substance abuse.

Have in place controls to minimise the impact of the companies activities on theenvironment.

Provide properly engineered facilities, plant and equipment and maintain them in safecondition.

Employ at all levels, a competent and trained workforce through appropriaterecruitment, selection, training, and when necessary, retraining.

Provide an effective system of communication throughout the Company and with clientsto ensure active participation in all aspects of Safety Management.

Develop and maintain effective contingency plans adequate to meet all identifiedscenarios.

Through investigation, follow up, and analysis of incident reports, strive to eliminateaccidents and incidents within the Companys operations.

Have in place monitoring and review systems to measure the success of the SafetyManagement System and provide for ongoing improvement.


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3.1 Responsibility against Policy Objectives

The following levels in the Organisation are identified as having commonresponsibilities against the Policy objectives and are shown on the organisationcharts. These responsibilities are shown below:

3.1.1 Company Management

To establish the Health, Safety and Environmental Policy of the Company and itsDivisions and to promote its implementation.

To ensure that adequate resources are made available within the Divisions to

implement the SMS.

3.1.2 Division Management

To ensure that the operations within their responsibility are conducted inaccordance with the SMS and that plant and equipment is maintained so as tocomply with established standards.

To ensure compliance with the Company HS & E Policy.

To support the QA/Safety Manager in the implementation of the SMS.

To ensure that the causes of any reported accident or incident are investigated,the cause(s) identified and plans developed to prevent recurrence.

To set a personal example in demonstrating a concern for safety matters.

To ensure that statutory requirements are complied with.

To ensure that satisfactory arrangements exist for effective employeeinvolvement.

3.1.3 Vice President, Eastern Hemisphere

Establish the company HS & E Policy and promote its implementation.

Provide adequate resources to implement the SMS.

Review the SMS annually and implement change as required.


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3.1.4 QA/Safety Manager

Manage all aspects of health, safety and environmental protection within theCompany.

Maintain the Company SMS Manual.

Co-ordinate new safety procedures as and when required and regularly reviewexisting procedures.

Compile and maintain accurate records and statistics on safety matters.

Regularly visit sites to carry out audits and encourage safety awareness.

In conjunction with line managers, identify safety and training requirements.

Maintain regular contact with the clients safety department.

Maintain regular contact with material and equipment suppliers; so as to beaware of current trends.

3.1.5 Line Supervision

To ensure that operations under their control are carried out in compliance withthe SMS.

To ensure adequate provision of personal protective equipment (PPE) inaccordance with Statutory Regulations, SMS and client requirements.

To set a personal example in demonstrating a concern for safety matters.

To carry out, as necessary, the investigation of accidents and incidents.

To ensure that all-necessary safety inductions are carried out in accordance withSMS and client requirements.

To hold Safety Meetings and Toolbox Talks as required by the standard.

To ensure careful and proper onsite instruction and training is given to personnelunder their direction in the correct operation and maintenance of machinery andequipment and control of health hazards.

To ensure that all-necessary health and safety data sheets are made available

and employees understand their content.


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3.1.6 Employees and Contractors

Make every endeavour to assist in ensuring that the working conditions andenvironment are maintained in a safe and healthy condition.

Act responsibly and take all necessary precautions to protect themselves, theirfellow workers and any other persons who may be affected by their activities frominjury and its potential.

Ensure that any defects in machinery, tools, equipment, protective measures PPEare immediately brought to the attention of their Supervisor so that steps can beimplemented to remedy the defect or take the equipment out of service to berepaired or made safe.

Report immediately to their Supervisor any unsafe practices and conditionsdiscovered.

Co-operate fully in the investigation of an accident or incident.

Where doubt exists, seek guidance from supervision or management as to theintegrity of procedures, work instructions, plant or equipment.


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ORGANISATION CHART TUBOSCOPE (U.K.) LTD BRANDT, ENACO & TUBOSCOPE

DIVISIONS

1.0 0.0

2.0 11.0 5.0 6.0 7.0

11.2 11.1

HEALTH, SAFETYAND

ENVIRONMENTQUALITY

ASSURANCE/TRAINING

QUALITYASSURANCE

ANDTRAINING

VICE PRESIDENTACCOUNTS

PERSONNELADMINISTRATION NORTH SEAREGION MACHINESHOP LINERHANGER

HEALTH, SAFETYANDENVIRONMENT


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Tuboscope Group of Companies Organisation Chart

CHART NO. 5.0

O.C.T.G. Inspection Vendor Inspection Services Coating and Brandt (Solids Control) Divisions

5.0

5.1 5.2

5.2.4

11.2

REPRESENTS LINK TO MANAGEMENT SYSTEMS PERSONNEL HAVING DIRECTREPORT TO VICE-PRESIDENT EASTERN HEMISPHERE OPERATIONS.

REGIONAL MANAGERNORTH SEA

DIVISION

SOLIDSCONTROL

INSPECTIONAND

COATING

OPERATIONSUPPORT

OUTSIDESALES

ENGINEERINGMANAGER

PORTLETHENINSPECTION

SERVICEMANAGER

PORTLETHENCOATING

MATERIALSMANAGER

PORTLETHENVENDOR

INSPECTION

REFURBISHMENTSUPERVISOR

GREAT YARMOUTHINSPECTION

MANUFACTURINGSUPERVISOR

QUALITY CONTROLTECHNICIAN

INSIDESALES

IMPORT/EXPORTCUSTOMS

PURCHASING

BRANDT

INSPECTION

COATING

AQUA CHEM

MANAGEMENT SYSTEMSHEALTH, SAFETY AND

ENVIRONMENT


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CHART NO. 6.0

Machine Shop Division

6.0

11.2


GENERALMANAGER

PRODUCTIONCONTROLLER

STORESDISPATCH

PRODUCTIONSCHEDULER

PRODUCTIONCO-ORDINATOR

SENIOR TECHNICIANS

QUALITY CONTROLTECHNICIANS

MANAGEMENT SYSTEMSHEALTH, SAFETY AND

ENVIRONMENT


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CHART NO. 7.0

Enaco Liner Hanger Division

7.0

WORKSHOP

11.2

ADMINISTRATION


VICEPRESIDENTEASTERN

HEMISPHERE

TECHNICALMANAGER

SALESMANAGER

APPLICATIONSENGINEER

SALESENGINEERS

SERVICEENGINEERS

MANAGEMENTSYSTEMS

HEALTH, SAFETY ANDENVIRONMENT


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CHART NO. 11.2

HEALTH, SAFETY AND ENVIRONMENT

Tuboscope (UK) Management System

5.0 5.2

5.2.4

5.1

6.0

7.0

QUALITY ASSURANCE/SAFETY MANAGER

REGIONAL MANAGERNORTH SEA

OPERATIONS MANAGERCOATING/INSPECTION

TUBOSCOPEPORTLETHEN

SAFETY COMMITTEE

OPERATIONS SUPERVISORINSPECTION DIVISION

TUBOSCOPEGREAT YARMOUTH

SAFETY COMMITTEE

OPERATIONS MANAGERSOLIDS CONTROL DIVISION

BRANDTABERDEEN

SAFETY COMMITTEE

GENERAL MANAGERMACHINING DIVISION

SALES MANAGERLINER HANGER DIVISION

TUBOSCOPE

DUNDEESAFETY COMMITTEE

ENACOABERDEEN

SAFETY COMMITTEE


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4.1 Company Organisation

The following organisation charts indicate the organisational levels with reference toHealth, Safety and Environment responsibilities defined in Section 3.1. Whereindividuals are assigned specific responsibilities this is noted for ease of referenceand audit purposes.

Appendix 1 Organisation Chart Tuboscope (UK) Ltd.

Appendix 2 Chart Number 5 OCTG Inspection / Vendor Inspection / Coating /

Solids Control.

Appendix 3 Chart Number 6 Machine Shop Division.

Appendix 4 Chart Number 7 Liner Hanger Division.

Appendix 5 Chart Number 11.2 Health, Safety and Environment.


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5.0 Workforce Involvement

The key to the success of the Companys SMS is workforce involvement at all levelswithin the Divisions. This is achieved not only through daily ad-hoc contact but alsoformal methods. The following represent the main areas of participation:

5.1 Safety Meetings

These meetings will be held regularly as defined in the procedure. All availableemployees will attend and the agenda is so designed as to encourage participationfrom the employees. The intent is that matters of concern can be identified andfeedback provided. When more than one Division occupies the facility, employees

from all Divisions can attend.

5.2 Toolbox Talks

Held prior to or during the carrying out of a job should circumstances change. Thesediscussion sessions provide the opportunity for employee participation. They areinformal and are conducted by a member of the workforce.

5.3 SMS Procedure Development and Implementation

The importance of workforce involvement in the development of the SMS procedures

is of prime importance. It is recognised that unless procedures are seen to becredible and practicable then they will not be used and short cuts will be the result.To avoid this, the assistance of the most appropriate person or persons in thepreparation of documentation will be enlisted. The definition most appropriate willtake into account factors such as experience, skill levels, training levels and provencompetency.


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6.1 Personnel Management

Effective personnel management ensures that, in a systematic manner, the companyemploys and utilises the right man for the job. This provides for the provision ofeffective managers, suitably qualified supervisors and competent employees. Inattaining this status employees must be experienced, well trained and assessedcompetent. The following are the procedures utilised by the company to achieve this:

6.1.1 Company Induction

Each employee new to the Company or any Division within the Company receives aninduction. Emphasis is placed upon imparting the critical information required to get

them through the initial employment period in a safe and confident manner.

6.1.2 Personnel Assessment

Each Division operates a procedure for appraising performance on an annual basis.The objective is to reaffirm objectives, discuss past performance and identify problemareas.

6.1.3 Job Training Profiles

These are provided for each job within each company and define the training

requirements. They are used to identify shortfall for input to training programmes.

6.1.4 Training Programme

From the personal training profiles, the overall company training needs are identifiedand a corporate training programme developed.


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6.2 Risk Management

The Management of Health and Safety at Work Regulations 1992 requires that eachcompany carries out a Risk Assessment at each location at which they haveemployees. This assessment addresses the following:

The risk to the health and safety of company employees at locations / sites at whichthey work.

The risks to the health and safety of persons, not company employees, who may beexposed to the work carried out by company employees.

The Regulation requires that the assessment be a systematic general examination ofthe work activity and that the significant findings be recorded.

In compliance to this requirement the Company has developed a procedurecomprising the following steps.

Identification of Assessment Units.

then within each unit

Identify activities undertaken.

Identify the jobs within each activity.

Identify the risk of each task- severity of hazard.- Frequency of occurrence.- Numbers involved.- Other tasks affecting.- Probability of occurrence.- Controls currently implemented.

Recommend further controls (if necessary).

When implementing controls, the risks identified will be prioritised so that best use ofresources can be made.

6.3 Communication

Effective communication is seen as the key to the success of the SMS. Each Divisionwill utilise the methods highlighted below to achieve this, incorporating, maximumnumber of employees where possible.


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6.3.1 Safety Meetings

Meetings will be held as defined in the procedure. All available employees will attendand the agenda be so designed as to encourage participation from the employees.The intent is that matters of concern can be identified and feedback provided.Meetings will also be utilised to communicate other health and safety relatedinformation such as the results of inspections and audits. Minutes will be taken anddisplayed for reference. When more than one Division occupies the facility,employees from all Divisions can attend.

6.3.2 Toolbox Talks

Experience shows toolbox talks to be prime contributors to a safe work place. Thesetake place at the worksite and are conducted by the person in charge. Theyaddress how the job is to be completed, it being incumbent upon the person incharge to be confident that all employees in the team are aware of theirresponsibilities and that they have the knowledge and skill to complete the job in asafe manner.

6.3.3 Safety Bulletins

The company is aware of the importance of providing information to employees onhealth and safety matters. To achieve this, the Company has established a system of

bulletins issued by the QA/Safety Manager. These are issued on controlled basisand address legislative requirements, information on incidents applicable to Companyoperations, etc. They have a finite life and must be reviewed and/or cancelledperiodically.

6.4 Occupational Health

6.4.1 Personal Protective Equipment (PPE)

In the hierarchy of control measures PPE is considered to be the last resort inprotecting personnel against risks to safety and health; engineering controls and safesystems of work are considered first. The Company provides PPE commensuratewith the identified risk and in compliance with the Personal Protective EquipmentRegulations 1992 covering body, feet, hands, head and ears.


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6.4.2 Control of Substances Hazardous to Health (COSHH)

To comply with the current Regulations each Division has carried out Assessmentsutilising the procedure detailed in level 2, and is implementing the additional controlsidentified.

6.4.3 Facility Surveys

These are carried out in compliance with the following Regulations and incorporatedwith the Risk Assessment process:

Health and Safety (Display Screen Equipment) Regs. 1992. Workplace (Health, Safety and Welfare) Regs. 1992.

Manual Handling Operations Regs. 1992.

6.4.4 Medical Arrangements

The Company considers this employee care activity as an important issue. There isan appointed Medical Practitioner who deals with all medical examinations, recordsetc. whilst there is a programme of training for appointed First Aiders. All offshorepersonnel attend the mandatory courses. The company Alcohol and SubstanceAbuse Policy is seen as a key proactive tool in employee care, as is the smoking

policy.

6.5 Work Procedures and Controls

Clear, concise, well understood work procedures are an essential element of healthand safety in the workplace. To support the safe execution of these procedures,control mechanisms must be established.

6.5.1 Work Procedures

For work procedures to be effective and hence utilised by the workforce, they must bestandardised in format, easily accessible, but more importantly, developed inconjunction with the personnel who are to use them. The Company has establisheda procedure, detailed in level 2, which allows for the systematic evaluation of work,and results in detailed procedures being developed which are owned by theworkforce.


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6.5.2 Procurement

The level of risk at a location may be increased considerably by importing hazardsassociated with goods or equipment. The Company has procedures in place via thequality management system to minimise such risk. There is an established list ofApproved Vendors to ensure required standards (British, European and International)and it is against this listing that all purchases are made.

6.5.3 Certification

All equipment utilised in the Companys operations, requiring to be certified to anapplicable standard is dealt with under the quality management system but is

referenced within the SMS for completeness.

6.6 Environmental Management

Tuboscope recognises and accepts that concern for the environment is an integraland fundamental part of the Companys business strategy. It is the intent of theCompany, that in all matters of environmental control it will adhere to, or do betterthan, all applicable legislation.

To achieve this intent each Division shall:

Achieve the environmental objectives.

Comply with not only current and legislative requirements, but seek continuedimprovement of standards and procedures.

Demonstrate compliance with company objectives and legal requirements.

This is achieved through:

6.6.1 Environmental Management Plans (EMP)

The EMP provides a structure whereby the environmental aspects and considerationsof the company operations are assessed and required action taken.

6.6.2 Environmental Review

These are undertaken on an annual basis to review the level of compliance to theenvironmental objectives and to both current and forthcoming legislation.


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6.7 Contractor Safety Management

Each Division, within the Company, requires that contractors working on its behalfshall:

demonstrate that they are capable of conducting themselves in a safe andcompetent manner.

apply health, safety and environmental measures fully consistent with those of thecompany and achieve comparable levels of performance.

consistently demonstrate an acceptable standard of safety awareness.

To assess the level of compliance to the above, the Divisions may carry out thefollowing:

6.7.1 Contractor Assessment

Contractors bidding for work which may present or introduce a hazard to theCompany shall be subjected to the Company Contractor Safety Assessmentprocedure. The results of this assessment will be a major deciding factor in contractaward.

6.7.2 Contractor Monitoring and Review

A single assessment is not considered adequate on contracts over 6 monthsduration. Importance is placed on periodic monitoring and review at pre-determinedintervals through a contract and on its termination. In this way the companyinfluences its contractors and builds up a database of contracting companies inwhich it has confidence.


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6.8 Accident and Incident Reporting & Investigation

This important tool proactively seeks ways to prevent accidents and incidentsrecurring. The objectives of the reporting and investigation procedures are:

to investigate all accidents and incidents which are reported at a levelcommensurate with their potential.

to utilise the recommendations to prevent recurrence of similar incidents.

to communicate the findings of investigations to all employees and other

interested parties.

to identify trends so that appropriate actions can be taken proactively.

To meet these objectives the Company has established the following:

6.8.1 Reporting Procedure

This provides a standardised format for reporting which facilitates the process ofinvestigation. The format gathers all the information required by the Company,

legislation and clients. The procedure is used not only at onshore facilities,Employees involved in accidents or incidents at remote locations shall also completethe report form as required.

6.8.2 Investigation Procedure

Following the reporting of an accident or incident, it shall be investigated as defined inthe procedure. The level of investigation shall depend on the actual and / or potentialloss identified. Management shall be fully involved and have a responsibility to closeout any recommendations to prevent recurrence as recorded on the investigationform.


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6.9 Contingency Planning

The Company recognises the need to have in place contingency plans should they berequired.The following are established:

6.9.1 Emergency Organisation

Clearly defined responsibilities have been laid down for the establishment of anemergency response team based upon the severity or potential of a reported incident.These address emergency situations either at the company facilities or at a remotelocation.

6.9.2 Emergency Plans

In order to facilitate the process of emergency response, the Company has identifiedwhat are believed to be the emergency scenarios that are most likely to occur. Theseare documented and personnel responsibilities assigned. In this way subjectivity atthe time of the incident can be dealt with in the most efficient manner.

6.9.3 Training and Drills

It is recognised that emergency response duty forms only a minor part of an

employees normal duties and hence to ensure a competent response when it isrequired, training sessions based on selected sections of the Emergency Plans areheld. These range from location fire drills to participating in exercises with clients asrequested.

6.10 Performance Monitoring

This element includes the three control loops from the management model defined insection 1.0. These are achieved through the following procedures, which togetherprovide the Company with the ability to continuously monitor its performance in thefield of health, safety and environmental management.

6.10.1 Statistical Reports

These statistics record the occurrence of lost time accidents (LTA) and non-lost timeaccidents (NLTA) and incidents (near misses). They are recognised as reactiveindicators.


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6.10.2 Cause Analysis

Stemming from incident reports these indicators provide guidance as to trends andthe causes of incidents and provide indication of the success or otherwise of specificHS & E campaigns.

6.10.3 Incident Potential

Utilising the Company potential matrixall reported accidents and incidents areassigned a potential rating. This provides a guide as to what might have happenedhad the situation been slightly different.

6.10.4 Safety Management System Audits

Audits are carried out to identify the level of compliance by each Division to theprocedures contained within the Safety Management System. These are formalaudits undertaken scheduled in conjunction with the QA System audits. A pre-definedchecklist and scoring regime may be utilised.

6.10.5 Location Inspections

Inspections are carried out to identify the level of compliance to established standardsconnected with plant and equipment. They are based on a predetermined

programme and involve employees at all levels.

6.10.6 Management Review and Improvement Process

This activity closes the management control loop of the Safety Management Systemby providing the means for improvement. On annual basis the companymanagement reviews HS & E performance based on the indicators and defines theaction plan to maintain the continuous improvement process of the SMS.

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