Contractor Safety Program
Pipelines and Distribution
TITLE
SECTION 01:
SUBJECT 01:
Contractor Safety Program – Pipeline & Distribution Edition
Index and Document Control
Table of Contents
01. Index and Document Control
01.01. Table of Contents.................................................................................................................................... 2
01.02.
Maintenance and Revision ...................................................................................................................... 5
01.03.
Acronyms .............................................................................................................................................. 8
02. Introduction
02.01. Commitment to Health & Safety ............................................................................................................ 12
02.02.
Goals and Expectations .......................................................................................................................... 14
02.03. ... Contractor Risk Mitigation Plan ............................................................................................................. 18
02.04. ... Contractor Supervisor ............................................................................................................................ 23
02.05.
BBS Philosophy...................................................................................................................................... 36
02.06.
Subcontractor Management .................................................................................................................... 40
02.07.
CMS Meetings ........................................................................................................................................ 44
02.08.
Weekly Safety Communication .............................................................................................................. 47
03. Behaviour Based Safety (BBS)
03.01. ... Contractor Stewardship………………………………………………………………………………….48
03.02.
Minimum BBS Activities ....................................................................................................................... 50
03.03.
Last Minute Risk Assessment (LMRA) .................................................................................................. 52
03.04.
Job Safety Analysis (JSA) ...................................................................................................................... 55
03.05.
Planned Job Observation (PJO) .............................................................................................................. 58
04. Work Control Procedures
04.01. Minimum Requirements and Process Map ............................................................................................. 61
04.02.
Job Training and Orientation .................................................................................................................. 62
04.03.
Site Safety Meetings ............................................................................................................................... 65
04.04.
Safety Assessment .................................................................................................................................. 67
04.05.
Critical Procedures ................................................................................................................................. 68
04.06.
Safety Rules ............................................................................................................................................ 70
04.07.
Confined Space Entry (Link to PDM)................................................................................................... 78
04.08.
Cranes and Lifting Operations (Link to PDM)....................................................................................... 79
04.09.
Opening Process Equipment .................................................................................................................. 80
04.010. Safe Electrical Work (Link to PDM) ..................................................................................................... 81
04.011. Working at Heights (Link to PDM) ....................................................................................................... 82
04.012. Energy Isolation ..................................................................................................................................... 83
04.013. Emergency Response and Incident - Near Miss - Hazard ID Reporting ................................................ 84
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Index and Document Control
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04.014. Physical Fitness and Modified Work ..................................................................................................... 89
04.015. Work Permits (Link to PDM)................................................................................................................. 91
04.016. Alcohol and Drug ................................................................................................................................... 92
04.017. (under development)
04.018. Standards for Contractor Gas Testing ................................................................................................... 95
04.019. Short Service Workers Program Guidance ............................................................................................. 100
05. Continuous Improvement and Performance review
05.01. ..........Contractor Evaluation ( Link to PDM)……………………………………………………………...105
06. Appendices (if necessary, select “Read Only” and save document with another title to download it)
06.01. .......... RMP Example
06.02. .......... Removed July 2011
06.03.
CSP JSA Quality Evaluation Tool (e-version)
CSP JSA Quality Evaluation Tool (print version)
06.04.
Imperial Oil Health & Safety Policy
06.05.
 P&D Contractor Risk Mitigation Plan
06.06.
 P&D Annual RMP Review Meeting
06.07.
P&D Contractor Supervisor Screening Questions
06.08.
 RMP Development Guide
06.09.
P&D Stop and Think Card
06.010.
 P&D JSA Template
06.011.
 P&D JSA Instruction Guide
06.012.
P&D LMRA Verification Record
06.013.
P&D PJO Report
06.014.
 P&D List of Job Documents
06.015.
P&D Job Demands Analysis
06.016.
P&D PIG Form 7 Preconstruction Meeting Topics
06.017.
 P&D Work Permit example
06.018.
P&D Weekly Safety Meeting
06.019.
P&D Emergency Contact List and Rescue Plan
06.020.
P&D Incident Report (Link to PDM)
06.021.
P&D Pre-placement Physical Questionnaire
06.022.
P&D Incident & Near Loss Report (Link to PDM)
06.023.
P&D PIG Form 18 Project Safety Assessment
06.024.
P&D Contractor Orientation Booklet
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06.025.
P&D Contractor Evaluation
06.026.
 P&D Contractor Safety Program Assessment
06.027.
(reserved)
06.028.
P&D LMRA Effectiveness (e-version)
06.029.
 App 29 - Tool Box Safety Meeting Quality Assessment
06.030.
 P&D Orientation Questionnaire Test 1
06.030.
 P&D Orientation Questionnaire Test 2
06.030.
 P&D Orientation Questionnaire Test 3
06.031.
P&D Scaffold Pre-use Checklist (Link to PDM)
06.032.
(Reserved)
06.033.
P&D (P&C) Contractor Supervisor Certification Summary
06.034.
P&D Gas Testing Log ( 0302F09)
06.035.
P&D SSW Day One (1) Requirements
06.036.
P&D SSW Safety Evaluation Requirements - Parts B, C & D
06.037.
P&D Example Glove Guide
06.038.
 Workplace Inspection Checklist - Office
06.039.
 P&D Contractor Supervisor Competency Tool
06.040.
 Subcontractor Selection Form (no exception form)
06.041.
 Subcontractor Management Form (example)
P&D LMRA Effectiveness (print version)
06.042. ........ Short Term Contractor Performance Evaluation
06.043. ........  Contractor Alcohol & Drug PSD Annual Letter - Example
06.044. ........ Contractor Alcohol & Drug Annual P&D Compliance Representation Letter
06.045. ........ Contractor Alcohol & Drug Program Assessment Tool
06.046. ........ Buddy Manager Contractor Scorecard
06.047. ........ Housekeeping Quality Assessment
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Index and Document Control
Maintenance and Revision
PURPOSE AND SCOPE
This subject describes the maintenance and revision procedures, and how to access the
“Contractor Safety Program – Pipeline and Distribution (P&D)” on-line edition.
PROCEDURE
Authorities
The Contractor Safety Program is issued, approved and owned by the Pipeline and
Distribution Safety, Security, Health & Environment Manager (P&D SSH&E Team
Lead)
The program is maintained and controlled by the P&D Contractor Services Advisor
(P&D CSA).
Changes to the content of the Contractor Safety Program require the endorsement of the
P&D CSA and the approval of the P&D SSH&E Manager. The P&D CSA ensures
approved changes are distributed to program holders according to the documented
change procedures. If a change is issued via the CSP, a Management of Change notice
is not required.
Responsibilities
The responsibilities of the P&D SSH&E Team Lead are to:
 Ensure the Safety Program is in compliance with Operation Integrity
Framework;
 Approve all changes to the Safety Program content.
The responsibilities of the P&D CSA or designate are to:
 Receive requests for revisions of the Safety Program;
 Review request content for national applicability and framework compliance;
 Issue approved revisions or inform requester of status;
 Maintain the Safety Program including issuing updates;
 Keep a permanent record of all revisions issued;
 Ensure revised material is highlighted blue;
 Maintain an up-to-date computerised backup of the Safety Program in a secure
location;
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Maintenance and Revision
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SUBJECT 03:

Issue the CSP to contractors on the P&D Contractor Management System
(CMS) list by granting access through Manuals LIVE.
The responsibilities of the Safety Program Holders are to:
 Remove previous versions of the CSP from circulation;
 Read all revisions thoroughly;
 Circulate changes to and provide training for those in their own organization
that need to be aware.
Review of the Contractor Safety Program
The P&D CSA reviews the entire Safety Program every five years at a minimum. The
date of the last review is documented in each Section’s footer.
Initiating Revisions
To initiate changes or add new text material, the program holder sends an email
detailing the revisions requested and why they are required, and forwards it to the P&D
CSA.
Revision Review
The P&D CSA reviews the proposed change and ensures no negative impact to the
intent of the Contractor Safety Program.
After the review, the originator is advised of the final disposition of the request by
return of the email. Approved changes are published as a revision to the Safety
Program.
Accessing the Contractor Safety Program manual on Manual’s LIVE
The official version of the P&D Contractors Safety Program manual is available on the
internet. This manual details the minimum expectations that P&D has for each of its
contractors regarding Safety, Security, Health and Environment.
A personal ID and Password must first be obtained by emailing the ExxonMobil
Terminal Operations Unit (TOU). Send the request to [email protected] with the
following information for each person requesting access:
 Name
 Work phone number
 Work email address
 Home email address (optional for receiving change notices at home)
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Index and Document Control
Maintenance and Revision

Request “Service Provider” access for P&D Orientation training and the
CSP & PDM manuals
Upon entering the Manuals LIVE site, the viewer will see a “My Training” tab in the
upper right hand corner which takes them to the Orientation Training video. The
Pipeline & Distribution Manual tabs are in the lower left section, with the yellow tab to
“Contractor Safety” beneath them. Selecting “Contractor Safety” will bring up the
“Contractor Safety Program”. Selecting “Documents” beneath the CSP title will show
the “CSP Manual” title. Selecting that will open up the Contractor Safety Program
manual. The alternate choice to the “CSP Manual” is the “Revision Log”. Selecting it
will open up the Revision Log showing all changes that have recently been made to the
manual.
Once the ‘Contractor Safety” title has been selected, the viewer will also be able to
select the “P&D General Procedures & Conditions”, a document that is attached to
every contract, detailing general expectations other than safety, of every contractor.
The web-address to access the manual is:
http://www.learningworks4u2.com/Esso/Student/MainFrame.asp
Issuing of Revisions
When a revision is issued, an email notice will be sent to all “Manual’s LIVE” users
that have a valid email address in the “My Account” tab on the opening page of
Manual’s LIVE, and to P&D managers.
Copying/Printing Sections
The electronic copy of the manual is the controlled copy. Holders may copy sections or
subjects of the safety guidelines but all copies and printouts of any part of the manual
are considered to be "UNCONTROLLED".
Note that all forms are uncontrolled documents.
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Contractor Safety Program – Pipelines and Distribution Edition
Index and Document Control
Acronyms
PURPOSE AND SCOPE
This subject lists the acronyms used throughout this manual.
ASSOCIATED DOCUMENTS
CSP 01-01 Table of Contents
PROCEDURE
A&D
Alcohol and Drug
ACL
Approved Contractor List
BBS
Behaviour Based Safety
BU
Business Unit (can refer to a division within IOL, region or a site. I.E.:
P&D is a BU of IOL, Calgary Distribution Terminal is a BU of P&D)
CMS
Contractor Managing System
CSA
Contractor Service Advisor
CSID
Contractor Safety Information Database
CSP
Contractor Safety Program
CSA
Construction Safety Associations (www.acsa-safety.org)
CSA
P&D Contractor Services Advisor
dB
Decibel
EM
Exxon Mobil
EMP
Engineering Maintenance and Projects
ERP
Emergency Response Plans
FA
First Aid Injury
GPR
Ground Penetrating Radar
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Index and Document Control
Acronyms
H&S
Health and Safety
Hazard ID
Hazard Identification
HID
Hazard Identification
Hz
Hertz
IOL
Imperial Oil Limited
IOL P&C
Imperial Oil Limited - Products and Chemicals
JSA
Job Safety Analysis
LMRA
Last Minute Risk Assessment
LHCP
Licensed Health Care Professional
LI
Loss Incident
LPO
Loss Prevention Observation
LPS
Loss Prevention System
LTI
Lost Time Injury
LTIR
Lost Time Injury Ratio
MSDS
Material Safety Data Sheet
MT
Medical Treatment Injury
NLI
Near Loss Incident
OHSA
Occupational Health and Safety Act
OSSR
On Site Safety Representative
OWSR
Owners Work Site Representative
P&C CSMP manual Products & Chemicals Contractor Safety Management Program
P&D
Pipelines and Distribution
PDM
Pipelines and Distribution Manual
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Index and Document Control
Acronyms
PJO
Planned Job Observation
PM
Project Manager
PME
Powered Mobile Equipment
POST
Petroleum Oriented Safety Training (www.posttraining.ca)
PPE
Personal Protective Equipment
Prime
Prime Contractor or Constructor
PSD
Procurement Services Department
PST
Petroleum Safety Training (www.enform.ca)
RMP
Risk Mitigation Plan
R&RS
Remediation and Reclamation Services
RW
Restricted Work Injury
SAI
Safe Acts Index (site walk around generates ratio of safe activities
observed versus number of unsafe actions)
SCP
Subsurface Clearance Protocol
Shell Agreement
Put in place with contractors to allow them to bid on construction
work. The scope of work being bid provides total contract. Some of
these companies may not have been awarded work for several years
and require special attention to safety programs when work is awarded.
SIAN
Site Investigation & Assessment Network
SPM
Surplus Property Management
SSH&E
Safety, Security, Health and Environment
SSW
Short Service Worker
T1BP
Tier 1 Best Practice – For specified critical procedures, there are
additional requirements and levels of oversight which have been
developed based on Global Tier 1 Best Practices (T1BP).
These have been classified as Level 1 procedures which require the
highest level of review before being undertaken. Specific requirements
are contained within the applicable procedure.
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Acronyms
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TRIR
Total Recordable Injury Ratio
TL
Team Leader
ULE
Utility Locate Equipment
WCB
Workers Compensation Board
WSIB
Workplace Safety and Insurance Board
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Contractor Safety Program – Pipelines and Distribution Edition
Introduction
Commitment to Health and Safety
PURPOSE AND SCOPE
This subject describes Pipeline & Distribution's commitment to contractor Health and
Safety.
ASSOCIATED DOCUMENTS
None
PROCEDURE
Commitment
The provision of a safe work place for all employees, contractors and others involved in
Pipelines & Distribution (P & D) activity is of paramount importance to Imperial Oil.
A specific policy has been developed to describe Imperial Oil's commitment to Safety
in its business dealings. This policy is presented in Appendix 4.
P & D has incorporated in this document entitled "Contractor Safety Program –
Pipeline & Distribution" the key components suitable to cover the intent of the Imperial
Oil’s Products & Chemicals: Contractor Safety Management Program. This program is
intended to guide contractors in order to meet P&D expectations when implementing
their safety program to achieve the goal of
Nobody Gets Hurt.
P & D is committed to continuously improve its safety programs by providing updates
to guidelines on a regular basis.
P & D is also committed to provide performance feedback to individual contractors
relative to defined goals and expectations and to share learning’s from captured data
from all contractors.
IOL employees and Contractors have the individual responsibility to ensure their own
safety and the safety of co-workers in everything they do. Safety rules alone cannot
prevent incidents. The indispensable ingredients of a safe working environment are:
 Management commitment and visible leadership
 Employee support and accountability
 Knowledgeable people executing assigned tasks as planned, working as a team
committed to carrying out assignments in the safest manner
 Continuous improvement of the safety program
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Contractor Safety Program – Pipelines and Distribution Edition
Introduction
Commitment to Health and Safety
IOL employees, contractors and workers have the responsibility and the obligation to
prevent all types of incidents including injuries by observing established working rules,
by practicing the principles taught in safety training and by providing new ideas on how
safety efforts might be further strengthened.
No business objective is so important that it will be pursued at the
expense of safety.
Contractors performing work on IOL premises shall be required to comply with IOL
safety guidelines and adopt safety practices equivalent or superior to those outlined in
these guidelines.
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Contractor Safety Program – Pipelines and Distribution Edition
Introduction
Goals and Expectations
PURPOSE AND SCOPE
This subject establishes clarity and accountability related to the safety performance of
contractors performing work on behalf of Pipelines and Distribution (P&D).
ASSOCIATED DOCUMENTS
NONE
GOALS AND EXPECTATIONS
The ultimate goal of P&D is to conduct its business in a manner that protects the Health
and Safety of its employees, others involved in its operations, contractors, customers
and the general public. IOL's goal is that "Nobody Gets Hurt" in its operations.
Commitment to this goal is essential to success. All must contribute to achieve a
workplace where nobody gets hurt. Contractors working on behalf of P&D shall
perform work in a manner that ensures an injury free workplace.
The safety guidelines documented in this program are the minimum required to achieve
a level of safety consistent with the goal of nobody gets hurt.
It is expected that all contractors will, at a minimum, follow the guidelines documented
in this Safety Program.
In specific instances, deviation to these guidelines can be authorized. In such cases, the
primary P&D contact documents the deviation and obtains approval of the team leader
and the Contractor Safety Advisor (CSA). The document must be signed prior to
authorizing a contractor to deviate from safety guidelines. Work applicable to the
deviation must stop until authorization is obtained. E-mail documentation and approval
is acceptable and must be retained in the project file.
Key expectations – Pipelines and Distribution
P&D shall be responsible to update this Contractor Safety Program as outlined in 01.03
of this document.
P&D shall be responsible to provide support to the designated contractor as described
in later sections of these guidelines with regard to the following:
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Introduction
Goals and Expectations










Identify potential site hazards as outlined in the Safe Work Permit for
individual projects with the designated prime contractor.
Participate in kick-off meetings.
Conduct analysis of incidents for P&D activities to facilitate continuous
improvement of program.
Conduct near miss/hazard identification trend analysis for continuous
improvement of program.
Participate in the investigation of safety and environmental incidents, at
P&D's discretion or when requested by the contractor.
Perform safety assessments and BBS activities as required.
Organize annual contractor meetings to review performance, improvement
areas and program amendments and other forms of communication to
support contractors' program development implementation.
Project managers and Operations to provide evaluations on contractor's
performance to the CSA for RMP discussions and PSD evaluations.
Review the status of contractor RMP's against approved plans and provide
feedback to contractors.
Monitor the results of BBS stewardship and provide feedback to contractors.
P&D shall measure a contractor's safety performance based on:
1. Safety program implementation as demonstrated during safety assessments.
2. Proactive safety indicators including near miss reporting, nature and capability
of Contractor's Safety Program, and areas where initiatives are demonstrated.
3. The degree to which the contractor achieves the stated goals and meets other
related expectations of the safety program.
4. Implementation of, and proficiency with, Behaviour Based Safety tools.
5. Average contractor TRIR and LTIR for the past three years.
Key expectations - Contractors
The expectations that are outlined in this program are believed to be the minimum
acceptable to achieve a level of safety consistent with the above goals. Contractor shall
have a documented safety program and policy that normally contains the following key
elements:
 Commitment and involvement at all levels of the organization
 Orientation and training requirements
 Safety Communications
 Behaviour Based Safety Activities including: Hazard assessment and
control, Job Safety Analysis (JSA's), Hazard ID's, Planned Job Observation
(PJO), Last Minute Risk Assessment (LMRA) and LMRA verification.
 Rules and work procedures
 Incident investigation and analysis
 Modified work program
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Contractor Safety Program – Pipelines and Distribution Edition
Introduction
Goals and Expectations








Discipline and corrective actions program
A&D policy that includes post incident testing for all lost , restricted work
and medical treatment injuries, and for serious near losses
Subcontractor managing program
Injury case management
Short service worker program
Worker fatigue policy
Safe driving program
Supervisor competency programs
A Certificate of Recognition under any of the Provincial Partnership Programs or
Industry Safety Associations is mandatory and at contractor's expense. An evaluation
score of at least 80% with no element less than 50% will be recognized as evidence of
an adequate Safety Program. The safety program shall be audited by a qualified auditor
external to the Contractor's organization, a minimum of once every three years.
Contractor is expected to supply or to confirm the training of its employees and
subcontractors. In addition to this training, contractor and subcontractor employees
shall receive an orientation prior to the start of work on IOL sites as described in
subject 04.02.
The contractor shall maintain a process for:
 Identifying hazards and near misses/near losses
 Correcting or mitigating the hazards, if necessary, to the suitable level
 Documenting and communicating to workers the disposition of all identified
hazards with appropriate working procedures
 Preparing an emergency plan and contact list in case of incident
 Conducting a kick-off meeting prior to work commencement with
employees and subcontractors closely involved in the project and submitting
a copy to Imperial Oil as soon as possible
 Completing a weekly safety meeting
 Completing a daily work permit & toolbox meeting on site to specifically
identify project risks of the day and obtaining the signatures of all people on
site
 Incorporating prescribed Behaviour Based Safety (BBS) activities and
providing stewardship as required
 The closure of identified RMP gaps and having a current inventory of
screened, trained and approved supervisors.
Contractor shall demonstrate loss control management by properly reporting incidents,
near miss/losses and hazard identifications, conducting investigations, implementing
corrective and preventive actions and analyzing performance.
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Contractor Safety Program – Pipelines and Distribution Edition
Introduction
Goals and Expectations
Contractor must ensure that all workers understand the consequences of violating any
of the Life Saving Rules and IOL/Contractor Company Rules. A contractor can receive
a major suspension or be permanently banned from P&D sites for violation of a Life
Saving Rule. Life Saving Rules are listed in section 04.06. Contractors are to apply
their own disciplinary policy.
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Contractor Safety Program - Pipelines & Distribution Edition
Introduction
Contractor Risk Mitigation Plan
PURPOSE AND SCOPE
The Risk Mitigation Plan (RMP) process within Imperial Oil identifies the focused
improvement actions that a contractor must take to achieve an acceptable level of safety
performance while working for Imperial Oil. The RMP may also identify actions by
Imperial Oil to support the contractor’s efforts in safety.
ASSOCIATED DOCUMENTS

App 1 - RMP Example

App 5 - Contractor Risk Mitigation Plan

App 6 - Annual RMP Review Meeting Process Cycle

App 8 - RMP Development Guide
PROCEDURE
THE RMP OWNER
There shall be only one RMP Owner within Imperial Oil Products and Chemicals
Division (Imperial Oil) for each Contractor that has an RMP. The RMP Owner should
be selected from an appropriate management level or position that will have the
necessary credibility with the management of the Contractor Company.
The RMP Owner will directly include regional and national Contractor management in
RMP discussions to drive regional and national improvements in the Contractor’s
safety programs and performance for the benefit of all the Imperial Oil contract users.
RMP OWNER ROLES AND RESPONSIBILITIES
The RMP Owner speaks on behalf of Imperial Oil and its contract users to ensure that
the Contractor’s management is aware of all focused safety improvements required for
their work at Imperial Oil BU’s/Sites, and that the Contractor’s management is
committed to addressing fully the improvements per the RMP.
The RMP Owner will:
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Introduction
Contractor Risk Mitigation Plan

prepare jointly with the assigned Contractor Company and other IOL Business
Unit users, the initial development and subsequent updates of the RMP for new
and renewed contracts

ensure the scope, integrity and quality of the RMP for their assigned Contractor
Company will continuously improve the safety performance of the Contractor
on Imperial Oil work sites

ensure that both the RMP Owner and the Contractor sign the RMP

ensure that the necessary Imperial Oil management approval of the RMP is in
place consistent with risk matrix approval requirements as per the RMP
Development User’s Guide;

review periodically with the Contractor Company the status of focused
improvements identified on the RMP and update the RMP when needed

conduct an annual review and update of the RMP with the Contractor Company.
The RMP Owner will use Appendix 6 - Annual RMP Review Meeting to guide
the meeting with the Contractor Company. Contractors must be familiar with
the contents of the Appendix and be prepared to present the information at the
meeting.

update the IOL master Contractor Safety Information Database (CSID) with the
latest, updated RMP and inform the RMP User Contacts that the updated RMP
is available for their use.
THE RMP USER CONTACT
Every Contractor that has an RMP may have an RMP User Contact at each Imperial Oil
Business Unit and Manufacturing Site.
RMP USER CONTACT ROLES AND RESPONSIBILITIES
In support of the RMP Owner, the other Imperial Oil BU and Manufacturing Site users
of the Contractor shall designate their RMP User Contact. The RMP User Contact
speaks on behalf of their BU or Site and shall be the single point of contact with the
local, immediate management representatives of the Contractor Company for matters
related to the RMP applicable to their BU or Site.
The RMP User Contact is responsible for:
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Introduction
Contractor Risk Mitigation Plan

supporting the RMP Owner in the initial development and subsequent reviews of
the RMP

engage the local, immediate management of the Contractor Company, and the local
IOL Buddy Manager (if established) to:

review the new or updated RMP. If needed, supplement the RMP with
additional local requirements and advise the RMP Owner

endorse a copy of the RMP

review periodically the status of the focused improvements identified on the
RMP to ensure progress is being made

conduct an annual review and update of the RMP. The RMP User Contact
should use the Annual RMP Review Meeting Process Cycle to guide the
meeting with the Contractor Company. If the RMP Owner exists at another
BU/site, then the timing of this review should align with the annual RMP
review process conducted by the RMP Owner.
PROCEDURE
1. When P&D identifies a Contractor Company that will provide the needed
work/service, the P&D User shall first confirm whether or not the Contractor
Company is on the Approved Contractor List (ACL). A Contractor Company is on
the ACL when there is an active contract in place and the Contractor Company has
done work with no significant issues, and no known significant Contractor
organizational changes have occurred (i.e. company level changes such as mergers,
acquisitions, divestitures, etc.). If the Contractor Company is on the ACL but has
not performed like services required by the BU/Site or is not on the ACL, then the
Contractor Qualification and Selection Process shall be followed (refer to P&C
CSMP manual). Contractor Companies that have active contracts are identified in
CSID.
2. The BU shall review the Contractor Companies corporate injury performance data
for the past three calendar years from CSID (or PSD if not available) to determine
the risk level of the Contractor, per the risk matrix in the RMP Development User’s
Guide. Contractors with a “Higher” or “Intermediate” risk level shall require an
RMP. For a “Lower” risk level, the BU is to assess whether an RMP is required for
the Contractor, based on operational risks or need for a focused safety improvement
plan to address known deficiencies. An RMP is optional for a contractor initially
deemed to be “Lower” risk. The decision to not complete an RMP is to be
documented with rational and retained on file by the BU.
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Contractor Risk Mitigation Plan
3. When an RMP is required, the BU shall confirm whether an existing RMP is in
place by checking CSID or other Imperial Oil users of the contract. If an RMP
exists, then the BU or Site shall review the RMP with the local, immediate
management of the Contractor Company applicable to the BU or Site and update it
if needed. The BU or Site shall inform the RMP Owner of any updates to the RMP
and the name of their RMP User Contact.
4. When an RMP is required but does not exist, the BU shall work with the other
Imperial Oil users to determine who will be the RMP Owner, and confirm the
names of the RMP User Contacts.
5. The RMP Owner shall prepare the initial RMP with the Contractor Company using
the RMP Development User’s Guide document and input from the RMP User
Contacts. The findings from the Contractor Safety Program Assessment that was
completed during qualification of the Contractor should also be used as input during
preparation of the initial RMP. The RMP Template shall be used for documenting
the RMP. The RMP shall be signed by the Contractor Company representative, the
RMP Owner and the local Buddy Manager (if established) to signify their
agreement and commitment to the improvement plans. An example of a completed
RMP is provided.
6. The RMP Owner shall ensure that the correct level of Imperial Oil management
approval is obtained for the RMP, consistent with the approval levels identified in
the RMP Development User’s Guide document. The RMP Owner shall address the
feedback from the approver and additional requests or requirements.
7. The RMP Owner shall add the approved RMP to CSID, inform the RMP User
Contacts and PSD that the RMP is approved and available in CSID, and provide a
copy of the approved RMP to the Contractor Company.
8. The RMP User contacts shall engage their local, immediate management of the
Contract Company and the local IOL Buddy Manager for the Contract Company (if
established) to implement the RMP, consistent with requirements in the RMP User
Contact Roles and Responsibilities discussed earlier in this section.
9. The RMP Owner and RMP User Contacts shall identify to their respective
management contacts with the Contractor Company any requirements for a periodic
review of the status of the focused improvements identified on the RMP, and
implement these periodic reviews accordingly to ensure continued progress by the
Contractor. Failure to close in a timely manner may result in a non-conformance
being filed with the procurement services department and potential termination of
the contract.
10. The RMP Owner shall conduct an annual review and update of the RMP with the
Contractor Company and RMP User Contacts. The annual RMP Review Meeting
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Contractor Risk Mitigation Plan
Process Cycle should be used to guide the annual meeting with the Contractor. If
the Contractor’s corporate annual safety performance has deteriorated to a point
that results in an increase in the RMP risk level, then the RMP Owner is required to
obtain appropriate Imperial Oil management re-approval of the updated RMP to
allow continued use of the Contractor.
11. Upon a review, the RMP Owner shall update CSID with the latest, updated RMP
and inform the RMP User Contacts that the approved RMP is available for their
use.

RETURN TO INDEX
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Introduction
Contractor Supervisors
PURPOSE AND SCOPE
The site supervisor is the most critical driver of site safety performance. They are the
contractor's representative responsible for controlling the safe and efficient performance at the
site by all direct hired contractor employees and subcontractors.
It is therefore imperative that the site supervisor has strong supervisory skills, is
knowledgeable and is motivated, especially in the area of workplace safety.
The Contractor Supervisor screening process is intended to qualify only those supervisors who
are familiar with the Imperial Oil safety requirements, possess the desire to encourage safety in
others, and will provide visible and active leadership to ensure a safe work site. Contractor
Supervisor screening is required for all levels of contractor supervision responsible for
conducting work on Imperial Oil sites and can include subcontractor supervisors. P&D
exceptions to the screening process and the SLD program shall be approved by the P&D OIMS
8A Administrator and documented in this procedure.
The ability to maintain the designation of approved supervisor will depend on meeting the
intent of the Safety Leadership Development (SLD) program that is discussed in this Section.
The requirement to provide a SLD program or a similar one that meets the intent of this one,
applies to Contractor Companies who are conducting work at Safety Work Levels 1, 2 and 3
(defined in PDM 01-14-03). It is the responsibility of the Contractor Company requiring a
SLD program, to ensure that all supervisors and subcontracted supervisors are fully included.
It is recommended that the Contractor Safety Advisors be included in part or the entire
program described in this Section, particularly the screening process.
The Contractor Company is responsible for the development of their supervisors. Field
Supervisors are responsible for the safety of the workers under their supervision and must
reinforce the appropriate safety culture throughout the worksite. The purpose of a structured
evaluation program for Contractor Supervisors is to:

Reinforce the understanding and value of a Contractor Company’s safety management
values and expectations, consistent with the drive to Nobody Gets Hurt

Continuously develop the safety leadership capabilities of field supervisors
(superintendents, foremen, supervisors, lead hands) and enhance their skills in their
area of accountability to support and manage direct reports and subcontractors to
complete work safely without incident

Increase the effectiveness of the use of key safe work practices and tools in the
workplace
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Introduction
Contractor Supervisors
Ensure personal development plans, called Supervisor Improvement Plans (SIP’s) are
formalized and documented to put learning into practice in the workplace, and improve
individual knowledge and skill.
ASSOCIATED DOCUMENTS
App 7 - Contractor Supervisor Screening Evaluation Part 1, 2, & 3
App 39 - Contractor Supervisor Competency Tool (SLPI Ranking and Scorecard)
DEFINITIONS
Contractor Supervisor: A supervisor with the Contractor Company or its subcontractors who
provides oversight and work direction to one or more of the Contractor’s or subcontractors
work crews at an IOL work site. This includes the positions of superintendent, supervisor,
foreman, and lead hand.
PROCEDURES
This Contractor Supervisor Evaluation subject is delineated in 10 sections:
1. Supervisor preparation before working for IOL
2. Supervisor screening process
3. Supervisor responsibilities working for P&D
4. Supervisor duties working for IOL and P&D
5. The initial development period of a supervisor
6. Ongoing monitoring and development of the Supervisor
7. Supervisor evaluation and improvement period
8. Verification, coaching and mentoring of the Supervisor
9. Supervisor evaluation scoring
10. Attesting and stewardship of contractor supervisor safety development
1. SUPERVISOR PREPARATION BEFORE WORKING FOR IOL
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Contractor Supervisors
It is incumbent upon the Contractor Company to offer the best candidate supervisors for work
at an Imperial Oil site. The Contractor Company shall ensure that the supervisor has completed
the following before the supervisor undertakes the Supervisor Screening Process so that the
candidate has the best chance of success to graduate through the program:

Industry Safety Orientation training such as PST, CSTS, POST

A provincial construction association Basic Supervisor Course or ExxonMobil
Fundamentals of Safety (or obtain within the first 6 months of becoming an IOL
Approved Supervisor)

Trade and craft training appropriate for the types of tasks and jobs that the
supervisor will be involved with at the worksite

Contractor Company’s Safety Orientation program

Contractor Company’s Supervisor Training program. This should include any
key safety rules and regulations, and safe work practices applicable to the
Imperial Oil worksite

Use and care of PPE required for the job

Behavior Based Safety training in LMRA, JSA, Observations and field-level
risk assessment processes that include Hazard Recognition and Risk tolerance

A&D Screening, as applicable

Background Screening checks, as applicable

An IOL Safety Orientation

Review and understand the contractor’s Risk Mitigation Plan with IOL

Review and understand the P&D Contractor Safety Program manual which
contains minimum expectations the supervisor must be aware of
2. SUPERVISOR SCREENING PROCESS
The award of a job requires IOL approval of the proposed supervisor.

Failure of a Contractor to provide an approved supervisor listed in the master IOL
Contractor Safety Information Database (CSID) for the job will eliminate the contractor
from being awarded the job.
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Contractor Supervisors
Any supervision substitution requires prior approval by IOL
The initial Contractor Supervisor Evaluation and Screening process consists of four parts. To
be listed in CSID, the contractor supervisor shall complete Appendix 7, Part 1, 2 & 3 and
submit these sections to a P&D CSA. Part 4 requires the candidate supervisor to be
interviewed.
Part 1 consists of a privacy statement and consent that will allow the results of the evaluation
to be recorded in CSID. It also provides for a contractor management guarantee that the
screening evaluation has been completed independently by the candidate supervisor.
Part 2 consists of 25 questions. The first twenty questions are generic to all Imperial Oil
business units/sites. The last five questions may be specific to the business unit/site
administering the evaluation. The evaluation consists of multiple choices, true or false, and
short answer questions. In preparation for the screening questions, supervisors should review
the P&D Contractor Safety Program (CSP). A score of 85% is required to successfully
complete Part 2 of the evaluation.
Part 3 consists of a review and confirmation by the Contractor Company of the Contractor
Supervisor's safety training and knowledge of the RMP/Focused Safety Improvement Plan for
the Contractor. At a minimum, all supervisors are required to complete a provincial
construction association Basic Supervisor Course or an industrial equivalent. The ExxonMobil
Fundamentals of Safety course for Managers/Supervisors is considered an equivalent. If the
supervisor has not previously taken a basic supervisor course, then they must take the course
within six months of submitting the screening evaluation. The supervisor will be allowed to
work as a supervisor during that six month period, providing they were successful in
completing the other sections of the evaluation. The supervisor must provide a copy of the
course certificate as proof of course completion to a P&D CSA.
Part 4 consists of a Desire Questions interview by an IOL supervisor or manager. The
contractor supervisor is to arrange for an interview appointment with a designated Imperial
Oil interviewer. The P&D Project Manager, Local Site Manager or CSA can be contacted for
a list of potential interviewers.

Preparation is not required for the interview. The interview is intended to assess the
supervisor's safety desire and attitude. The candidate supervisor will be asked to
respond to three scenario based questions and provide information on how they
would handle the situation.

The interviewer will determine if the response warrants successful qualification of
the candidate supervisor. The candidate must satisfactorily address two of the three
questions to qualify. The interviewer will advise the candidate of the interview
results and will forward an interview results summary to the P&D CSA (screening
coordinator), along with any suggestions for the Supervisor Improvement Plan.
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Contractor Supervisors
The P&D CSA will mark Part 2 of the screening document, review Part 3 and obtain results of
Part 4. They will also communicate results to the contractor management representative. The
communication will indicate if there are any limitations, restrictions or follow-up action
required for the Contractor Supervisor as part of his/her overall Supervisor Improvement Plan.

Once a supervisor has been screened and is approved, approved subject to an
improvement plan or rejected, their name is entered into CSID for retention by IOL.
Any improvement opportunities identified from Parts 2 to 4 of the screening
process shall be listed in CSID as an overall SIP that is to be shared with the
candidate and Contractor Company. If approved, the supervisor is eligible to be a
supervisor on any IOL project unless removed for performance reasons (which will
change his or her approved status in the database).

The SIP may also identify any limitations, restrictions on use of the supervisor at
Imperial Oil until the person obtains further qualifications or experience.
When a Contractor Supervisor does not successfully pass this screening process, the candidate
supervisor is allowed to attempt evaluation again after two months. Contractor Management is
responsible for communicating the results of the screening to the Contractor Supervisor and for
improving the candidate supervisor's capability prior to rewriting the evaluation.
Every three years the screened supervisor must complete and re-submit Parts 1, 2, & 3 for
evaluation. It is the responsibility of the Contractor to ensure their supervisors re-submit in
time to remain on the approved list. If a supervisor has successfully remained on the approved
list during the interval, Part 4 is not required.
Verification of supervisor status will be made by IOL staff prior to projects or maintenance to
ensure that only approved supervisors are used.
3. SUPERVISOR RESPONSIBILITIES WORKING ON PIPELINE & DISTRIBUTION SITES
In the absence of direct supervision at all times provided by the Owner of the site, the criteria
for determining supervisor requirements at P&D sites are:
The general expectation for project work is that contractor crews will be led on site at all
times.
The general expectation for maintenance work is that contractor crews will be led by an
IOL approved supervisor who is either on site or available by phone.

For crews of 1 or 2 workers the site manager and contractor shall mutually determine
the requirements for on-site supervision based upon the risk of the work. The
minimum requirement will be a daily IOL approved supervisor phone call to the
crew lead/foreman to discuss BBS activities, environmental conditions, risk of
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Contractor Supervisors
hazards associated with tasks to be completed, how the hazards were mitigated and
other activities on the owner’s site that may impact work

For crews of three and larger, an IOL approved supervisor will be on site, as a
minimum, for the beginning of the workday and until a toolbox meeting is
conducted, work activities discussed with crew, hazards mitigated and planned work
is underway
The following tasks are exempt from the above processes providing an introductory meeting
has taken place which includes a job scope and hazards review:

Any task 100 % supervised by P&D representative (including but not limited to
telecom services, electrical or gov't inspectors)

Janitorial work

Snow Removal (providing each worker has attended an orientation meeting at
the beginning of the winter season. If not, an approved supervisor must be on
site directing the work)

Worker on site for less than one hour (including but not limited to mat change
out, indoor pest control, delivery or pick, waste pickup, etc )

Secondary site Operational Contractor

Aerial Line Patrol

Rail yard shunting
4. SUPERVISOR DUTIES WORKING FOR IOL AND P&D
Supervisors are responsible for but not limited to performing the following activities:
1. Supervisors have the ultimate responsibility to ensure that all workers are in
compliance with company/client rules and provincial regulations on the work site.
2. Supervisors must ensure that work activities are conducted in a safe and constructive
manner. Supervisors must know what each crew member is doing at all times, what
equipment they are involved with and what tools are being used.
3. Supervisors must ensure they have a completed pre-qualification document, including
an RMP if required, on file for each subcontracted crew.
4. Supervisors must ensure that all new employees and subcontractors have current
contractor's and client's orientation and understand the information provided.
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Contractor Supervisors
5. The approved supervisor will provide basic BBS training explaining LMRA, JSA, HID,
and PJO's to all workers including subcontractors, prior to start of work. Contractor
supervisor is responsible to ensure BBS requirements are met by work crew even when
the supervisor is not on site. Supervisors must review elements of the BBS program
with new workers to the site and ensure they understand the purpose of each element.
6. Supervisors are to discuss risk tolerance to new workers and calibrate new workers '
risk tolerance to the site's acceptable level.
7. Supervisors will occasionally review the risk tolerance expectation with all crew
members and recalibrate as required.
8. Supervisors are responsible for subcontractor safety performance - even if
subcontractor has their own health and safety program.
9. Supervisors must ensure workers have proper PPE for the job and know how to use it
correctly.
10. Supervisors must immediately intervene when the safety rules and procedures are not
followed. Once the workers are safe, the supervisor is to investigate the cause and
initiate the contractor's discipline process with their immediate supervisor.
11. Supervisors must ensure all workers:
 have received proper training and are competent,
 have the right tools & work instructions,
 know & understand Life Saving and General Site Rules. Life Saving Rules are
critical safety rules that if broken, require executing the contractors discipline
policy
12. An up-to-date Job Safety Analysis (JSA) is to be available for each daily task.
Supervisors must ensure it adequately addresses risk of work activities and is reviewed
with all crew members assigned to the task prior to going to work. The approved
supervisor must verify the JSA quality and that mitigation plans are actionable and
carried out. Contractor Supervisor to complete with subcontractor if work
subcontracted.
13. Supervisors must provide workers with clear instructions or communication of policies,
initiatives and work procedures at daily toolbox meetings and safety meetings.
14. Supervisors must provide visible leadership in the field and provide coaching during
safety walkabouts. Verification of workers compliance to expectations requires
supervisors to be in the field a significant part of their day. Verification requires more
than just asking if worker is compliant, it requires observation in the field.
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Contractor Supervisors
15. Supervisors must be zero tolerant - hold people accountable for their actions. Be
consistent and always take action. i.e. commend for safe behaviours and correct unsafe
behaviour and initiate the discipline policy as per company standards (except where
BBS tool process allows other solutions).
16. Contractor's supervisor shall represent Contractor when accepting a Safe Work Permit
and shall ensure that work agreements are obtained, fully communicated to the
applicable personnel, complete with workers signature, and hazard mitigation
implemented before work is started.
17. Contractor supervisor is responsible to complete daily LMRA verifications, be able to
provide a list of the workers verified back to Owner, and provide the number planned
vs. completed during quarterly stewardship submissions to the Owner.
18. Contractor supervisor is responsible to complete Planned Jobs Observations (PJO) as
per frequency agreed to with owner but in no case less than weekly, document and
retain them for quality reviews, and provide the number planned vs. completed back to
Owner.
19. Contractor Supervisor must obtain the current MSDS for all hazardous substances and
receive permission to bring the substance on-site.
20. The Contractor’s Supervisor must report to the Workplace Safety and Insurance Board
(WSIB) and/or OH&S or provincial equivalents, for any incident that meets the
regulatory boards requirements. Where an employee fails to report an injury incident
and obtain proper medical attention in a timely fashion, an injured employee’s right to
compensation may be delayed, especially in cases where the disability does not
immediately follow the incident.
21. When an incident or near-incident (near miss/loss) occurs, the approved supervisor
must stop the work, ensure safety of all, implement appropriate response and
communications, resolve situations in order to return to work including a preliminary
investigation to find out why the event occurred before work continues and, file
preliminary reports and complete full investigation and report per incident reporting
guidelines.
5. INITIAL DEVELOPMENT PERIOD OF THE SUPERVISOR
The initial development period follows the supervisor screening process. The Contractor
Company shall establish and communicate to the supervisor the duration of each review
period. For the Initial Development Period, the maximum duration of the review period is 6
months. Competency can be acquired and demonstrated in less than 6-months by the
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Contractor Supervisor so that he or she ‘graduates’ beyond the Initial Development Period. As
well, the Contractor Company may decide in less than 6 months that the supervisor will not be
able to show the required competency by the end of the Initial Development Period and
remove the supervisor from the position.
Once the Contractor Supervisor ‘graduates’ beyond the Initial Development Period, the
Contractor Company shall update the SIP, and share this with their IOL contact who will
ensure that CSID is updated accordingly.
The program is directed at improving safety performance at the worksite by improving
supervisor competency in Safety Leadership. To ‘graduate’ beyond the Initial Development
Period, the Contractor Supervisor must demonstrate consistently and effectively the following
four key aspects of Safety Leadership Development (SLD):

Prepare to Work Safely – Plan the successful execution of the job tasks. Everyone
involved in undertaking the job must have the willingness, knowledge and ability to
execute the task without incident

Formulate a Risk Plan – Understand the task at hand and how it will be executed.
Based on practice or procedure, prepare a risk plan that eliminates, controls and
protects against risk of incident. The supervisor may use such tools as the Job Safety
Information Package, Job Safety Analysis and FLJSA to fulfill this expectation

Verify Safe Work - Verify the execution of work tasks according to the risk plan.
“Stop the work” if it is not going according to plan

Learn the Lessons – Include “After Action” reviews and Incident Investigations.
Update work practices, procedures and risk plans.
The Contractor Supervisor shall also demonstrate knowledge and skills regarding worksite
hazards, hazard management, and safe work practices, and be able to lead competently
tailgate/toolbox meetings, pre-job and safety meetings, JSA/FLJSA discussions, LPO feedback
sessions and incident investigations, as applicable.
SLD is an approach using persistent and consistent encouragement by the Contractor Company
through verification, coaching and mentoring, including a formal evaluation scoring process
and the Supervisor Improvement Plan described earlier, to establish new behaviors. The
scorecard, ranking guide and descriptions are shown in CSP Appendix 38 - Contractor
Evaluation Competency Tool. This scorecard and ranking guide or an equivalent tool, is used
to evaluate the supervisors’ safety knowledge, skill and desire. It is to be used by the
Contractor Company for the Initial Development Period and the Ongoing Monitoring and
Development Period of the supervisor. The SLD utilizes this measurement model for the
continuous improvement of a supervisor’s capability.
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EXEMPTIONS FROM SLD PROGRAM PARTICIPATION
Exemption from the SLD program has been granted to supervisors working for subcontractors
that are on site for a short period of time and may not benefit from this program.
6. ONGOING MONITORING AND DEVELOPMENT
The ongoing evaluation of the Contractor Supervisors shall be managed by the Contractor
Company.
The Contractor Supervisor has now successfully progressed through screening and the initial
development period, and has demonstrated the required skills, knowledge, behaviors and desire
to ensure safe work at an Imperial Oil worksite. The Contractor Company has used the rating
tool in CSP Appendix 38 or its equivalent to establish the next review periods.
When the supervisor has progressed to the Ongoing Monitoring and Development phase, the
duration of a review period is up to 12 months. In this phase, it is expected that the Contractor
Company shall meet one-on-one with each of its supervisors on a periodic basis (quarterly as a
minimum). The meeting is to provide ongoing feedback to the supervisor and to document
progress by the supervisor on closing the action items in the Supervisor Improvement Plan.
The Contractor Company should update the evaluation scoring prior to each meeting with the
supervisor to monitor trends in the supervisor’s performance and progress in their
development.
7. SUPERVISOR EVALUATION AND IMPROVEMENT
At the end of a review period, the Contractor Company shall complete a formal evaluation of
the supervisor using their Contractor Supervisor Competency Tool. The outcome of this review
will be a decision by the Contractor Company on continued use of the supervisor and an
upgrading of the Supervisor Improvement Plan to reflect improvements needed by the
supervisor for the next review period. The Contractor Company shall meet with the supervisor
to communicate the results of the review, and the expectations/actions for the next review
period if the supervisor’s performance is acceptable for continued use. This process will
continue through the term of the active contract, or until the supervisor stops working for the
Contractor Company during the contract term.
Examples of performance areas that can be reviewed, understood and agreed with the
supervisor being evaluated include:
1. Understanding of Safety Vision and Priorities for Operating & the Risk Mitigation Plan
(RMP)
2.
Work Intervention / Stop the Job
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3.
Hazard Identification and Mitigation
4.
Pre-Job Planning - Job Safety Analysis and Field Level JSA
5.
SPSA (Last Minute Risk Assessment)
6.
Safe Work Practices / Procedures
7.
Safety Observations, LPO’s and feedback sessions
8.
Lowering the Risk Tolerance of the workforce
9.
Communication methods – Trust & Verify Understanding
10. Performance Standards
11. Incident Management
Detailed descriptions, suggested techniques and measureable elements for the above
performance areas are outlined in CSP Appendix 38, attachment 3.
8. VERIFICATION, COACHING AND MENTORING
During the review period of a supervisor, it is expected that the Contractor Company will
monitor the supervisor’s performance to ensure role, responsibilities and expectations are being
met. The Contractor Company shall also provide ongoing coaching and mentoring to
continually develop their supervisors, and ensure they understand and apply any training
received. Meeting with supervisors in their work environment conveys the expectation that
their development and improvement plans are to be applied at the worksite. It provides
opportunity for supervisors to receive coaching, support and encouragement on how well they
are applying their learning into practice.
Some key questions for the Contractor Company to ask its supervisors during observations in
the field to support implementation of development plans, coaching and training received
include:

What are you doing differently? … due to SLD training knowledge

Has it worked? Why / Why Not? … What can we do about it?

How can I provide further support?
9. SUPERVISOR EVALUATION SCORING
Scoring is to be completed by competent Contractor Company staff with an overall interest in
the quality of work done by the supervisor and their crew. It should be done on a regular basis
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Contractor Safety Program - Pipelines & Distribution Edition
Introduction
Contractor Supervisors
to assess trends. The evaluations shall be discussed with the supervisor to allow for appropriate
follow up and improvement.
Scoring is typically done more frequently during the supervisors Initial Development Period,
and should be done at least once per year for the Ongoing Monitoring and Development
Period. The scorecard template is provided in CSP Appendix 38, attachments 1 and 2. The
Contractor Company may have or develop an equivalent scorecard.
Initially there may be greater involvement by IOL representatives (Buddy Managers, Project
Managers, RMP Owners, Team Leaders and SHE representatives, etc.) to help establish the
scoring process.
The scorecard results for supervisors (Safety Leadership Performance Indicator or SLPI) are
expected to be reviewed and stewarded internally within the Contractor Company.
At the end of the specified review period for each supervisor, the Contractor Company shall
share the updated Supervisor Improvement Plan with their IOL contact who will ensure that
CSID is updated accordingly.
10. ATTESTING & STEWARDSHIP OF CONTRACTOR SUPERVISOR DEVELOPMENT
P&D shall attest periodically the overall program and Contractor supervisor scoring. This can
be accomplished through the regularly scheduled meetings for reviews of RMP’s or Buddy
Manager scorecards, or done as a separate, distinct activity. Key components to be attested
include:

Has the scoring document captured scores for Knowledge, Skill & Desire

Has mitigating action been identified and communicated to the supervisor being
scored for elements scored 2 or lower

Have responsibilities been assigned to mitigating actions and have action items
been closed out?
The P&D CSA also has the responsibility to ensure that CSID is maintained up-to-date with
the current listing of names of the active, screened supervisors, and their individual SIP’s.
The Contractor Company shall monitor and track regularly the status of its Supervisor
Development program using the following metrics as a minimum:

% of Supervisors screened

% of Supervisors with SIP
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Contractor Supervisors

% of SIP’s with action items overdue for closure

% of overdue meetings with supervisor at end of a review period
The metrics shall be stewarded to P&D quarterly. Stewardship of the Supervisor Leadership
Development program should be reviewed at CSA meetings and/or annual RMP review
meetings.
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SECTION 02:
SUBJECT 05:
Contractor Safety Program - Pipelines & Distribution Edition
Introduction
BBS Philosophy
PURPOSE AND SCOPE
To outline the key concepts behind the use of Behaviour Based Safety principles and
their importance to establishing a "Nobody Gets Hurt" work environment.
ASSOCIATED DOCUMENTS
CSP 03.02 Behaviour Based Safety: Minimum BBS Activities
 PDM 01-04-31 The Loss Prevention System (LPS)
DISCUSSION
It is important that the right level of information on safe work expectations of IOL and
P&D is communicated to the contractor before the work begins. P&D contractors that
have personnel working full time (embedded) on P&D sites will follow the Loss
Prevention System (LPS) of Behaviour Based Safety (BBS). The system is described in
PDM 01-04-31. All other contractors (short term projects, intermittent, infrequent or
on-site less than 180 days per year) will use a BBS system that meets the intent of the
following discussion.
Personal safety incidents are a result of a momentary loss of control which results in the
incident. The outcome of the incident is unpredictable. For example, if a worker was to
fall from a ladder there are many outcomes that could result from this incident. The
worker could land on the ground, cat-like on their feet, and suffer no injury. Equally,
the worker could land awkwardly and twist an ankle, knee, wrist, or fracture a bone or
skull. The outcome is a function of circumstances outside the worker’s direct control
and is often characterized as “luck”. As we cannot control the outcome of the incident
and it would be irresponsible to rely on luck, we must work to prevent the incident in
the first place.
The prevention of all incidents does not happen by itself. It requires deliberate action
by management and worker alike. Management must establish a work environment,
which provides for worker safety (appropriate procedures, safety equipment, employee
selection and skill development, critical safety expectations and requirements). The
workers must ensure that safety is built into each and every aspect of their behaviour.
In other words, management is responsible for establishing an environment for safe
behaviour and the worker is responsible for behaving safely.
Behaviour Based Safety tools are established to encourage workers to do effective risk
analysis before launching into an activity. The tools are simple and are founded on the
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BBS Philosophy
belief that a low risk tolerance and a mind engaged on the task will eliminate all
incidents. Both conditions, a low risk tolerance and a mind engaged in the task, need to
be discussed to better understand both management’s and the worker’s role in
preventing incidents.
Generally speaking, every individual has a different tolerance or acceptance of risk. To
some, taking a risk is nothing more than a means to an end and the degree to which this
is done varies dramatically. There is no such thing as zero risk. When we breathe, we
take risks. However, there is a point beyond which the outcome is likely to become an
unfavourable result. Collectively, we must be smart enough to determine the
unfavourable result threshold. Determining this requires deliberate thought and is
where the three basic steps of risk management come into play.
Risk management is a simple process where one identifies all the hazards that could
occur as a result of the planned activity, assesses those hazards to determine which
would result in an unfavourable outcome and mitigates or prevents those outcomes
from happening through deliberate action before the task is started. Simply stated the
process is identify, assess, mitigate and act. Management must create an environment
that ensures that this happens and the workers must execute their work such that it is
happening with each and every action.
The regimented use of behaviour based safety tools is a simple and proven managing
system approach to encouraging effective risk assessment. The behaviour based safety
system outlined in this manual addresses risk assessment at two levels:

for routine, generally lower risk activities (activities for which no reasonable
person would require a documented procedure)

for commonly identified, higher risk activities (activities where there is a
generally accepted need for documenting a more thorough consideration of the risks
and how they will be mitigated and better co-ordination of all parts of the activity)
Last Minute Risk Assessment (LMRA)
Managing the routine, generally lower risk activities, is done through the deliberate use
of what is generically called an LMRA. Many companies encourage/require the use of
a similar tool to manage this routine risk e.g. programs such as “Take Two”, “Stop and
Think”, "Safe Performance Self Assessment". These programs all advocate the same
thing – the last minute before you embark upon an activity, do a risk assessment, ensure
that you have analyzed how to mitigate the risks, and then complete the necessary
action so that there is not an incident. The LMRA is a mental process for which there
is no documentation required. If the routine activity involves other workers, then the
process needs to be discussed (still not requiring documentation). It is to be used
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BBS Philosophy
before and during all routine activities and it is a skill that needs to be encouraged and
honed.
The LMRA tool is based on the principle of employees taking responsibility for their
own safety in all daily work activities and taking the necessary time to:

Assess the risk

Analyze how to reduce the risk

Act to ensure safe operations
Job Safety Analysis (JSA)
Managing commonly identified, higher risk activities requires a more formal and
documented risk management process.
This process is generically referred to as a JSA or Job Safety Analysis. A job safety
analysis has exactly the same considerations as does an LMRA. However, since the
JSA is protecting against a more substantial risk, it needs to be documented, discussed
with everyone in the work crew involved and then reviewed by the site supervisor to
ensure that the appropriate level of risk management is brought to the task.
The JSA development process is described in CSP Section 03.04.
Effective employment of the above two behaviour based risk management tools,
LMRA and JSA, will eliminate all incidents. It is the worker’s responsibility to
understand and use the tools. It is management’s responsibility to ensure that the
worker does understand and is using the tools.
In addition to the above two risk management tools, there are three equally simple
diagnostic tools that can be used by management to gauge the quality of execution of
each of the two risk assessment tools. The LMRA Verification, LMRA Effectiveness
Check and the JSA Quality Evaluation Tool assess worker knowledge and are required
to continually improve worker awareness. Discussion of each tool is covered in 03-03
(LMRA) and 03-04 (JSA).
A fourth diagnostic tool is the Planned Job Observation.
Planned Job Observation (PJO)
The effective use of risk management in general, and the job safety analysis tool
specifically, can be done through the use of a simple diagnostic tool called a Planned
Job Observation Report (Appendix 13) or PJO. In a planned job observation the
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BBS Philosophy
supervisor, manager or any other interested party stands back from the work and
observes it in progress. The observer then documents their observations and determines
(in their opinion) whether the work activity is being done leaving the worker(s) “safe”
or “at risk”. The observations are done against a predetermined checklist of typical
items to look for and/or against the JSA that was prepared by the work crew for the task
in progress (i.e. is the work crew following the job steps and mitigation that they built
into the JSA). Once the observations are made and recorded, the observer must engage
the crew in a discussion of what was observed. It is to be an open, constructive
discussion and consideration should be given to the worker’s opinions on “safe” or “at
risk” judgment as well.
The PJO will likely result in follow-up which should be appropriately closed
(occasionally the follow-up required is by others not associated with the task being
observed). As in the case of the LMRA verification, the outcome of the PJO must be
collected and used to direct the site and company safety program. This will address the
remaining 30% of the behaviour-based failures resulting in personal injury incidents in
IOL experience.
It is worth noting that this Behaviour Based Safety approach is focused on adjusting
every worker’s risk tolerance and improve their risk management awareness and skills.
This means that the program is attempting to change people’s behaviours, whether they
are on an IOL site, other client’s sites or off the job. Therefore it is important that due
consideration be given to promoting off the job safety with the same techniques and
discipline as on the job safety such that nobody gets hurt, anywhere.
It is also worth noting that the observation process is for the education of the individual,
their peers, crew members, and the organization. As such, the learning’s are free and
non-punitive. Just as near-losses must be celebrated when reported, the same is true of
PJO’s.
The observation process is discussed in CSP 03.05.
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SUBJECT 06:
Contractor Safety Program - Pipelines and Distribution Edition
Introduction
Subcontractor Management
PURPOSE AND SCOPE
This subject describes Pipeline & Distribution's expectations regarding subcontractor
management by the contractor.
ASSOCIATED DOCUMENTS
 Appendix 40 - Subcontractor Selection Form (“no exception” form)
 Appendix 41 - Subcontractor Management Form (2012)
 Appendix 42 – Short Term Contractor Performance Evaluation
DEFINITIONS
Embedded Contractors: Are those that typically provide contractor services full time
on site as part of the regular contractor workforce. Such contractors may also be
referred to as “base contractors”. Other common terms used are General Contractor
(GC) or General Service Provider (GSP). Note: in some cases the GC may be
considered to be a “Prime” contractor as identified further in the definitions.
Short Term Contractor: Includes contractors that are not part of the full time regular
contractor workforce. Such contractors typically perform short term work activity and
then leave the site. Some examples of Short Term Contractors include routine
maintenance contractors’ onsite intermittently and project contractors.
Subcontractor: A contractor that has been sourced by the base or short term contractor
to perform a specific scope of work. In these cases, subcontractors are managed by the
main contractor, i.e., IOL does not recognize the subcontractor as a separate entity from
the main contractor.
Prime Contractor: A contractor that has been assigned in writing as “Prime” or
“Constructor” per provincial regulation designations to complete a scope-of-work. The
prime contractor carries obligations as defined by provincial regulations to carry out the
duties to ensure the safety of site workers and, to co-ordinate / manage safely other
trades that may be on the work site.
For clarity and ease of use in this practice, the term ‘Contractor’ is used in this
procedure to mean embedded, GC, GSP or Short Term Contractor.
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SUBJECT 06:
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Introduction
Subcontractor Management
PROCEDURE
Contractors using subcontractors to perform work must ensure their subcontractors
understand the expectations of P&D management. A subcontractor is the full
responsibility of the contractor, and their workers are considered to be employees of the
Contractor. The work must be performed safely, and to the specifications stated in job
scopes and drawings.
SUBCONTRACTING REQUIREMENTS
A Contractor using a subcontractor to complete a specified scope-of-work is obligated
to have in place a subcontractor management process that conforms with the job
specification in the formal contract with Imperial Oil. In general, this means:

The Contractor has a qualification process in place to obtain a subcontractor for the
work. An initial listing of the names of subcontractor companies that the Contractor
plans to use shall be provided by the Contractor during the contracting process.
Once a contract is in place, the Contractor shall utilize their documented process
and complete Appendix 06.040 P&D Subcontractor Selection Form when
additional subcontractors are required.
Note: For Prime Contractors, similar minimum expectations are established at the
start of the contract and managed by the Prime as agreed upon in the contract with
the client.

When the Contractor identifies a subcontractor supervisor is required to complete
the work scope, the Contractor shall advise the appropriate P&D contact, i.e., CSA
or Buddy Manager; and follow through with contractor supervisor screening per
CSP Section 02.04. Note: from IOL’s view, subcontractor supervisor screening is
handled the same way as a Contractor’s supervisor, e.g., in CSID the subcontractor
supervisor’s name would be included under the Contractor Company name, the
following way: A. Sub (AIM Services).

The Contractor shall establish a safety improvement plan with the subcontractor
when the safety risk level of the subcontractor is Intermediate or Higher risk per
Appendix 5 - Contractor Risk Mitigation Plan. The base Contractor can use a
similar process to the Risk Mitigation Plan that is described in CSP Section 02-03.

Where a Contractor has an active RMP in place and uses subcontractors, the list of
subcontractors shall be kept up-to-date in the RMP as part of the annual review
process. In cases where the contractor’s level of safety risk is Lower and an RMP is
not in place with the Contractor, but the safety risk level of the subcontractors is
Intermediate or Higher risk, the Contractor shall still establish a safety improvement
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Subcontractor Management
plan or RMP with the subcontractor and send completed Subcontractor Selection
Forms to the P&D CSA.

The Contractor shall utilize a Short Service Worker Program for all subcontractors
while on the work site.

The subcontractor performance should be considered in Contractor stewardship /
reviews with the Buddy Manager Program while working for the Contractor on the
site.

Where a Buddy Manager has been assigned, the Contractor is required to review the
list of subcontractors with their Buddy Manager and to keep the list current. This
enables the appropriate discussion with the Buddy Manager of any specific safety
improvement plans established by the Contractor with the subcontractor while
working at an Imperial Oil work site.

The Contractor is required to establish with the Imperial Oil BU or Site a
documented communication protocol for work initiation or management with
clearly identified contact positions and phone numbers. This should define whether
the Contractor allows the subcontractor to be contacted directly by Imperial Oil and
with prescribed follow-up after the fact. This is particularly important during off
hours such as at night or during the weekend.

When a Contractor brings in a subcontractor for a short period of time, the
subcontractor shall be included in the overall Contractor’s safety management
process, e.g. SSW program.
REQUIREMENT EXPLANATIONS
Contractors must conduct a pre-qualification of their subcontractors that includes safety
performance statistics, Workers Compensation Board [WCB or Workplace Safety and
Insurance Board (WSIB)] letter of good standing, presence of a safety program
including behavior based safety tools, worker training, 3rd party accreditation of safety
program, alcohol and drug program and short service worker program. Where
subcontractors' programs or safety performance do not meet these expectations, the
general contractor shall develop a plan to control subcontractor risks. Appendix 06.041
Subcontractor Management Form is provided as an example.
Contractors should avoid a subcontractor with poor safety performance (TRIR
performance exceeding 1.0 or LTIR performances exceeding 0.1). When the use of a
high-risk subcontractor is necessary, the contractor shall document a strategy to control
the risk prior to work. A sample of RMP is provided in Appendix 5. A Contractor
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Subcontractor Management
should communicate safety expectations to subcontractors in conjunction with the
scope of work. This should include requirements for: PPE, A&D expectations and
testing, site safety orientation, work permits, use of BBS tools and certification
documents for personnel, and major equipment.
Once the Contractor has qualified the subcontractor, it must complete Appendix 40 –
P&D Subcontractor Selection Form, and have it signed by a P&D representative. The
representative signs the form indicating they do not take exception to the Contractor
using their qualified subcontractor. Both the Contractor and P&D must agree the
subcontractor is acceptable to use. Completed forms are sent to a P&D CSA.
The requirement for direct supervision of subcontractors is to be determined by the
owner and contractor representatives, at the time of work release. One of Contractor's
personnel who is suitably qualified shall be designated the responsible supervisor for
the subcontractor. The decision for direct supervision of subcontractor workforce is to
be based on complexity of the work, subcontractor safety performance, and contractor's
familiarity with subcontractor.
Contractor shall prior to commencement of work, effectively inform subcontractor of
the pertinent regulations, standards and procedures that apply within the boundaries of
work site.
If pre-qualification determines that subcontractor is unfamiliar with BBS, contractor
shall provide a BBS overview to subcontractor workers during site orientation.
Contractor shall perform planned job observations (Appendix 13) on subcontractors to
ensure safe work practices and compliance to IOL safety expectations.
Contractor shall perform last minute risk assessment verifications (LMRA
Effectiveness Tool) (Appendix 28) on subcontractors to ensure safe work practices and
compliance to IOL safety expectations.
Contractor shall ensure that subcontractors develop JSAs for their daily activities and
meet IOL safety expectations. If subcontractors require training in JSA development,
the contractor is expected to guide them through this process using the JSA Instruction
Guide (Appendix 11).
Contractor should include frequently used subcontractors in safety communications by
providing materials such as safety alerts/bulletins, near miss reports and BBS learnings.
Contractor should include subcontractor personnel in tailgate/toolbox meetings and
other safety training.
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SUBJECT 07:
Contractor Safety Program - Pipelines and Distribution Edition
Introduction
Contractor Management System (CMS) Meetings
PURPOSE AND SCOPE
This subject describes Pipeline & Distribution's expectations regarding periodic
meetings between contractor management and a P&D CSA. P&D believes that
participation in the Contractor Management System (CMS) meetings and the annual
safety forum is critical to contractor safety performance improvement.
ASSOCIATED DOCUMENTS
None
PROCEDURE
Planned CMS Meetings
Contractor Service Advisors meet on a pre-determined basis with contractors included
in the CMS program. Meetings may be at the contractor's office, work site or P&D field
offices.
Meeting frequencies or contact with contractors are based on the volume of work, type
of services provided by contractor, contractor safety performance risk rating and
duration and type of contractor exposure on site.
A CMS contact is identified as:
Type 1 - Receive only weekly safety communication emails.
Type 2 - Invited to the Contractor Safety Forum and receive weekly safety
communication emails.
Type 3 - Semi Annual CMS meeting in addition to the Contractor Safety
Forum, and weekly safety communication emails.
Type 4 - Three CMS meetings in addition to the Contractor Safety Forum, and
weekly safety communication emails.
The CMS meeting agenda may include items such as:


Review of identified issues with contractors compliance to job specification
Post-incident A&D testing results and A&D compliance issues and pre-access
testing
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SUBJECT 07:
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Introduction
Contractor Management System (CMS) Meetings








Compliance to Behavioural Based Safety Initiatives
Progress with Risk Mitigation Plan gaps and review of any required changes to
RMP
Progress with Contractor Supervisor Screening gaps and review of any required
changes to plans
Review and follow-up of contractor incidents and performance rates including
LTIR, TRIR,
Review of learnings from other company / industry incidents
Development and monitoring of plans to resolve contract non-conformances
identified by P&D's field and maintenance personnel
Development and monitoring of plans to resolve interface and commercial
issues between the contractor and the company
Identification evaluation and implementation status of continuous improvement
initiatives that mutually benefit the contractor and the company
The CSA will issue minutes of the meetings with contractors as well as updated
RMP’s.
The CSA will attempt to conduct some of the CMS meeting on site with contractor
management. Any time the CSA is on site they will conduct a LMRA effectiveness
check on a contractor worker. The effectiveness check will provide feedback to the
contractor on the health of their LMRA program and determine if additional training or
motivation for implementation of the program is required.
Annual Safety Forum
Regionally, P&D will hold an annual safety forum with its major contractors to focus
on safety. The meeting shall be held early in the year in order to reinforce the safety
program for the working season ahead.
It is expected that contractors will have representation at one of the regional sessions.
Representation should be at the owner or management level. In addition field
supervisors are encouraged to attend.
Subjects to be covered shall include but are not limited to the following:
 Incident, near miss/hazard identification statistics and any identified corrective
actions
 Safety assessment results and improvement areas
 IOL and P&D year objectives and priorities
 Contractors and P&D performance in terms of defined expectations
 Improvements to the safety program
 Safety discussions, open forum, and contractor current interests.
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Introduction
Contractor Management System (CMS) Meetings
The annual safety meeting is also the main forum to exchange safety experiences and
initiatives between contractors. From time to time, it is anticipated that contractors will
share their experiences and thereby increase the overall level of understanding and
effectiveness of the safety program.
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SUBJECT 08:
Contractor Safety Program - Pipelines and Distribution Edition
Introduction
Weekly Safety Communications
PURPOSE AND SCOPE
This subject describes Pipeline & Distribution's expectations for contractors to
communicate safety information to their staff and frequently used subcontractors. The
use of this safety information assists in the increased awareness of workers and
therefore prevention of incidents.
ASSOCIATED DOCUMENTS
None
PROCEDURE
The CSA will issue safety communications to contractors included in the CMS
program. The suggested frequency of the safety communications is weekly. The safety
communication may be in various formats. Safety Alerts, Incidents learnings, LPO
learnings from P&D or obtained from the safety resources.
Contractors are expected to review the safety communications with their staff and
frequently used subcontractors if applicable.
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SUBJECT 01:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Contractor Stewardship
PURPOSE AND SCOPE
This subject identifies the requirements of contractor Stewardship to IOL P&D.
Stewardship is required for each element of Behaviour Based Safety to ensure that the
necessary activities are taking place. It also includes gathering of other important information
required for focused improvement of contractor programs.
PROCEDURE
The benefits of a BBS program are maximized when the learnings of LMRA verifications,
LMRA effectiveness tests and PJO's are analyzed to obtain learnings and trends.
It is expected that contractors will review all PJO's (Appendix 13), LMRA effectiveness tests
(Appendix 28) and the number of JSA Quality Evaluation Tool (Appendix 3) reviews
completed along with their average score, to determine any adverse trends and improvement
opportunities.
The contractor will also provide:
 a summary of the current quarter observations,
 at risk behaviours,
 status on planned initiatives, including RMP gap closure status
 A&D test and Background Screening results
 number of hours worked for IOL and P&D
 number of subcontractor hours for IOL and P&D
 number of incidents and First Aids
Contractor BBS stewardship is to be provided by the contractor to the P&D CSA by the 15th
of the month following the end of the quarter. It is submitted via this internet link:
http://www.surveymonkey.com/s_pass.aspx?sm=Gwlw5WPtvcxG%2bTwNqIf7Aw%3d%3d
NOTE: A logon ID is NOT required but a password is. The current password which you can
copy and paste into the logon, is: pdstewardship
Upon completion of the form, a copy can be printed should the contractor wish to have one.
The contractor must keep copies of PJO’s, JSA QE’s and LMRA checks as P&D will verify
numbers submitted during their office visits.
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SUBJECT 01:
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Behaviour Based Safety (BBS)
Contractor Stewardship
Some P&D contractors are assigned a Buddy Manager who will work more frequently with
the contractor than contractors working with the CSA in the CMS process. An example of a
Buddy Manager scorecard is provided in Appendix 46 – Buddy Manager Contractor
Scorecard
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Behaviour Based Safety (BBS)
Minimum BBS Activities
PURPOSE
This subject outlines the minimum BBS activities to be implemented by contractors
participating in the CMS program. A BBS program augments the existing contractor
safety program through the addition of Behaviour Based Safety tools.

Establishing a more aggressive "Nobody Gets Hurt" approach to safety
management
 Better engage all personnel (both IOL and contractor) in the pursuit of safety
excellence
 Advancing Behaviour Based Safety to make a pronounced improvement in
awareness, risk mitigation and safety performance
ASSOCIATED DOCUMENTS
JSA Instruction Guide (Appendix 11)
PROCEDURES
Three BBS tools are integrated into the P & D contractor safety program to increase
risk awareness, assessment and mitigation:
 Last Minute Risk Assessment which is a "Stop and Think" process for routine
activities.
 Job Safety Analysis which identifies risk and appropriate mitigation for daily
work.
 Planned Job Observation which identifies safe and/or at risk behaviour of
workers.
Two tools are used to assess LMRA quality:
 Last Minute Risk Assessment Verification: a process to encourage the habit of
conducting LMRA's. Verifications are verbal but should be documented on
Appedix #12, or similar form, to demonstrate they are being conducted.
 Last Minute Risk Assessment Effectiveness Check: a documented process
(Appendix #28) for Contractor Management and IOL to evaluate the
effectiveness of contractor's LMRA program.
One tool is used to assess JSA quality:
 JSA Quality Evaluation Tool (Appendix 3): a documented process producing a
quantitative result for a JSA review.
In the following subjects, each BBS tool will be expanded upon to describe the tool,
when, how and by whom it is to be used.
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Contractor Safety Program - Pipelines & Distribution Edition
Behaviour Based Safety (BBS)
Minimum BBS Activities
Overall Behaviour Based Safety (BBS) activity summary:
ACTIVITY
PERFORMED
BY
FREQUENCY
STEWARD/TEST/VERIFY
REVIEWER
LMRA
all workers
before activity
Contractor Site Supervisor verification once per day.
IOL staff
during field
visit
Contractor Owners /
Managers- each visit
LMRA
Verification
Contractor
Supervisors
Once per day
Quarterly to CSA
PM / CSA
LMRA
Effectiveness
Checks
Contractor
Management
During each site
visit
Quarterly to CSA
PM / CSA
JSA
Workers
Generally, for
every work permit
Project safety assessments
or CSA meeting
PM / CSA
JSA quality
evaluation
reviews
Contractor
Workers,
Supervisors and
Management
During each site
visit
Submit quarterly to P&D
CSA, the total number
completed with the results
averaged, on BBS form
Contract
Management
*
IOL Reps
IOL Reps
PJO
*
Contractor Site
supervisor
Contractor Safety
Advisor
Weekly
Submit forms to PM and
CSA
1/week
PM / CSA
PM /CSA
Quarterly to CSA
During each site
visit
Contractor
Management
During each site
visit
* Peer to peer LMRA testing and PJOs is also encouraged
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P&D 03.02 Minimum BBS Activities
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TITLE
SECTION 03:
SUBJECT 03:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Last Minute Risk Assessment (LMRA)
PURPOSE AND SCOPE
This subject outlines the expectations for contractor staff to conduct Last Minute Risk
Assessments (LMRA) and Last Minute Risk Assessment verifications.
PROCEDURE
Last Minute Risk Assessment (LMRA)
The LMRA is a mental process executed by each individual worker to prompt risk
mitigation. It can also be performed by a team just before working collectively on a
task.
The LMRA tool is based on the principle of employees taking responsibility for their
own safety in all daily work activities and taking the necessary time to:

ASSESS the risk,

ANALYZE how to reduce the risk,

ACT to ensure safe operations!
The LMRA should take into consideration what could go wrong with:

The physical and mental preparedness & fitness for duty of the personnel involved,

risk to self or others,

changes that could occur resulting in new risk,

environmental conditions,

proper tools and equipment for the job,

body position,

procedures or JSA,

communications.
Use of a last minute risk assessment tool or Stop and Think, is required before and
during the execution of every routine task. Last minute risk assessment consists of
taking a minute to stop and think, in advance of launching into the work activity, and
deliberately identify and mitigate the identified risks associated with the task. It is an
undocumented, mental process. It is being mentally aware of the situation the worker
is in at that specific moment. A Stop and Think card is provided in Appendix #9 for
reference.
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P&D 03.03 Last Minute Risk Assessment (LMRA)
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TITLE
SECTION 03:
SUBJECT 03:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Last Minute Risk Assessment (LMRA)
LMRA Verification
The effective use of LMRA's is tested verbally through the practice of LMRA
verifications. The tester safely interrupts the work in progress and samples the
worker(s) awareness of the scope of work being executed, the risks associated with the
work and how those risks were being mitigated through an open-ended discussion with
the worker(s). The interested party must execute this task using an "ask, listen, learn"
approach to ensure that the worker has an opportunity to demonstrate the quality of
his/her LMRA skills.
In a proper LMRA verification, the tester should be assessing the following areas:
1. The worker is in the habit of conducting LMRAs.
2. The worker understands his/her task
3. The worker has identified the risks to themselves and others
4. The worker has sufficiently mitigated the risks through his/her actions
5. The worker has a positive attitude to site safety and risk management
Contractor supervisors will perform LMRA verifications at a frequency of one per day
and provide a list of workers verified available for review by the owner. A sample
LMRA Verification Record is in Appendix 12. LMRA verification by telephone in the
case of a remote work location is acceptable. However, a face to face test is strongly
preferred.
LMRA Effectiveness Check
A third party, generally uninvolved with the task, does LMRA Effectiveness Checks.
Typically, a manager or another interested party. Contractor Management and Safety
Advisors are encouraged to utilize Appendix 28 to conduct LMRA Effectiveness
checks on their LMRA program. P&D representatives will evaluate the effectiveness
of the contractors LMRA program by conducting an LMRA Effectiveness Check
(Appendix 28).
The Effectiveness Check should not only test a specific worker on use of LMRA's but
allow the tester to understand the effectiveness of the contractor's LMRA program on
site and commitment from the worker's supervisor. The following questions can be
used to guide a tester's check:

How many LMRA's have you done today?

Tell me about a specific LMRA?

Has your supervisor asked you or any of your co-workers about LMRA's
within the past day?

Describe to me the task you are completing?
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TITLE
SECTION 03:
SUBJECT 03:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Last Minute Risk Assessment (LMRA)

What potential risks have you identified for the work that you are doing?

Can you show me (or tell me) how you are managing the hazards or risks?
P&D representatives will evaluate the effectiveness of the contractors LMRA program
by conducting an LMRA Effectiveness test. Contractor Management and Safety
Advisors are encouraged to utilize Appendix 28 to conduct LMRA effectiveness
checks on their LMRA program.

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TITLE
SECTION 03:
SUBJECT 04:
Contractor Safety Program - Pipelines & Distribution Edition
Behaviour Based Safety (BBS)
Job Safety Analysis (JSA)
PURPOSE AND SCOPE
This subject outlines the expectations for contractors to conduct Job Safety Analyses
(JSA). A JSA is a documented process executed by a worker or a team, to prompt
safety awareness and mitigate risk just prior to execution of all contractor tasks.
PROCEDURES
Use a Job Safety Analysis (JSA) form (Appendix 10) before work execution in order
to mitigate risk. Generally, a JSA should be developed for each Work Permit, but if a
Work Permit includes more than 1 task, a JSA is required for each task. The JSA
Instruction Guide (Appendix 11) can be used as a reference.
The value of the JSA lies in the quality and thoroughness of the discussion amongst
the work crew. A JSA is to be developed by all members of the work crew and
approved by a supervisor if a reference JSA built by a team of experts is not available.
A reference JSA is preferred, as it will contain insights to hazards that an
inexperienced crew may not be aware of, but it must be upgraded every use to include
additional hazards specific to the current location.
A work stoppage and review of the JSA is driven by a change in any one of the
following parameters/conditions:
 site,
 activity,
 work scope,
 time,
 environment or
 crew.
A change in one of these requires an immediate review prior to work proceeding and
the JSA tailored to meet the new parameter/condition.
If the task involves a critical procedure work permit then a JSA is required. However,
any additional checklist/procedures for hazard control shall be reviewed and attached
to the JSA rather than repeating in the JSA (refer to section 04-02 for more details and
the JSA Instruction Guide (Appendix 11).
Where work is carried over into another day, the JSA must be reviewed, updated and
re-signed. Consideration should be given to any changes in site conditions, scope, and
personnel. If the task for which the JSA is being completed contains any of the critical
procedures noted on the Daily Work Permit then that critical procedure must be
incorporated in a JSA.
The site/task/crew/equipment/time specific JSA should consider:
 Specific hazard identification
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TITLE
SECTION 03:
SUBJECT 04:
Contractor Safety Program - Pipelines & Distribution Edition
Behaviour Based Safety (BBS)
Job Safety Analysis (JSA)










Sequence of events or steps required to complete the job
List of other potential hazards associated with the task
Work conditions
Work coordination
Changes that could result in new risk
Proposed tools and equipment to be used
Personal Protective Equipment required
Safety controls required to mitigate hazards
Critical procedures/T1BP’s as required
Contractor supervisor reviews JSA for accuracy to ensure hazards are addressed
and all workers understand and can follow steps.
 Space for signatures of person(s) responsible for preparing the JSA, all workers
involved in the task and the site supervisor's approval
 Person responsible for specific tasks
An effective JSA must outline mitigating steps that are clearly defined and actionable.
Examples of effective mitigating controls:
 Is clearly understood by the crew not just responsible worker
 Provides protection for all workers for probable exposure
 Prescriptive enough to lower risk to acceptable level
 identify what is required
 identify when it is required
 identify where it is required
 identify who is required
 Practical to implement and appropriate to risk
 Workers buy into hazard identification process and
 implement mitigation during work execution
Examples of ineffective mitigating controls:
 Does not provide a clear or specific instruction or method for action
 Leaves instruction open for interpretation
 Lacks assigned responsibility for execution
 Does not sufficiently lower risk, residual risk is too high
 Does not address safety of others in the work area
 Lack of compliance to execution of mitigation is not corrected by peers, supervisor
or management
JSA Quality Evaluation Reviews
Management will review JSAs regularly for quality and provide coaching as required.
Quality can be assessed using Appendix 3 - JSA Quality Evaluation Tool or a similar
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TITLE
SECTION 03:
SUBJECT 04:
Contractor Safety Program - Pipelines & Distribution Edition
Behaviour Based Safety (BBS)
Job Safety Analysis (JSA)
form producing documented results. Contract management and workers, both office
and field, should perform reviews within the expected frequency documented in CSP
03-02. Providing frequent reviews will improve the quality of field JSA's. Submit the
total number completed with the results averaged, quarterly, to the P&D CSA.
The Quality Evaluation check involves approaching a worker crew in the field and
assessing the degree of risk identification and management using the guide in
Appendix 3. Feedback to the work crew should be immediate and include
commending for positive behaviors, actions and coaching for areas requiring
improvement.

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TITLE
SECTION 03:
SUBJECT 05:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Planned Job Observations (PJO's)
PURPOSE AND SCOPE
This subject outlines P&D's expectations for conducting and administering Planned
Job Observations (PJOs). A PJO is a disciplined, documented observation of a work
task. This observation may be done against a formal procedure or it may be an
observation of routine work. The observation is focused on the behaviours of the
individual performing the task to identify at-risk and safe behaviours.
PROCEDURE
Contractor management and supervisors use the Planned Job Observations form
(Appendix #13) on activities for which there are documented procedures, a JSA in
place, or where random observation is done to evaluate the safety practices being
employed in routine tasks.
In all cases, the observer(s) and the observed are to compare notes in a proactive safety
conversation to permit both parties an opportunity to better understand and conclude
on the safest approach to do the task. This discussion is to take place the same day as
the observation and preferably, as soon as practical. If procedures or JSAs are in place,
then they are to be compared against the actions observed to ensure compliance to the
JSA. Additionally, observations provide an opportunity to update the JSA or
procedures.
The observer and supervisor must ensure that the worker being observed while using
this tool is not disciplined. It is important to remember that the process is non-punitive.
Observations do not find fault. Observations find free learnings that are meant to
benefit the entire organization. Unsafe behaviors can cause injury, property or
equipment damage, or damage to the environment. It is critical to think of why we
conduct work in a manner that could allow an incident to happen, put steps in place to
eliminate that behavior, and help others to learn from it as well. Using this approach
instead of discipline facilitates learning opportunities to remove the poor working
behaviors from work habits. If the worker being observed understands that, they
should be willing to participate in order to potentially save a fellow worker from an
incident.
It is also important that the supervisor, worker and crew understand why the worker
observed decided to perform the work using behaviors that put themselves or others
“at risk”. To drill down into why a worker used at risk behavior keep asking the
worker “why”, usually 4 or 5 times, until you hear the worker say:
“I didn’t follow an established procedure or safe working process because:
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P&D 03.05 Planned Job Observations (PJO’s)
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TITLE
SECTION 03:
SUBJECT 05:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Planned Job Observations (PJO's)
1. I don’t know the procedure (lack of skill or training);
2. I didn’t have resources that I required to follow it this time;
3. I was being pressured to get it done, or;
4. I have never had an incident when not following this procedure”.
Or, the worker may say, if it was not one of the 4 personal factors:
1. “There is no procedure or, I was following the procedure but the procedure is
incorrect;
2. There was a procedure change but it was not communicated to me, or;
3. There was a problem with the tool or equipment that I had no control over”.
PJOs shall be conducted regularly by the contractor. Frequency of PJO’s is outlined in
CSP subject 03.02
Contractors should analyze their PJO’s looking for trends and learnings and review a
summary of learnings with their staff.
P&D will periodically request copies of PJO's for a quality review and provide
feedback to contractor on the quality of PJO's reviewed. Quality reviews by P&D will
assess the following:
 Generally, it is expected that each PJO will have 1 or 2 at risk behaviours
(based on typical performance).
 Are PJO's discerning enough? This judgment can be made based on the
reviewer's knowledge of jobsite performance or through analyzing several
PJO's received from a contractor supervisor, or other contractor
representatives.
 Both positive and negative feedback was given to the observed as appropriate.
Special attention must be paid to try and assess the depth/quality of feedback
given. Both positive reinforcement and constructive criticism must be given to
reinforce and improve safety performance.
 Was a probing analysis conducted, and were recommendations made to correct
identified deficiencies (e.g. training, changes to managing systems)?
 Appropriate recommendations for improvements to the contractor's safety
program are made for noted deficiencies. Not all deficiencies will drive a need
for change to the contractor's safety program.
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P&D 03.05 Planned Job Observations (PJO’s)
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TITLE
SECTION 03:
SUBJECT 05:
Contractor Safety Program - Pipelines and Distribution Edition
Behaviour Based Safety (BBS)
Planned Job Observations (PJO's)
 Feedback will be provided by P&D staff to the contractor's representative.
P&D utilises a BBS program called the Loss Prevention System (LPS). P&D staff and
representatives will use a document called a Loss Prevention Observation (LPO) for
Job Observations. The LPO process is the same as PJO's, consisting of the
observation, determining safe or questionable behaviours, and provides feedback to
the observed. The additional step of the LPO process is that you determine why the
incorrect behaviour occurred and identify follow-up action to prevent repeat
occurrences of that behaviour. A completed LPO will be given to the contractor's site
supervisor or sent to the contractor office to review and complete any assigned followup.
Contractors will report the number of completed PJO's to the P&D CSA.

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P&D 03.05 Planned Job Observations (PJO’s)
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Contractor Safety Program – Pipelines and Distribution Edition
Work Control Procedures
Minimum Requirements
TITLE
SECTION 04:
SUBJECT 01:
PURPOSE AND SCOPE
Provide an overview of documents necessary to follow safety guidelines established in
this program when managing a project and /or conducting maintenance work.
ASSOCIATED DOCUMENTS
None
PROCEDURES
MINIMUM SAFETY PROGRAM REQUIREMENTS
Projects1
Requirements
Maintenance
Responsibility
Weekly Safety Meeting
Once every 5 days
Only if > 3 days
Contractor
Daily Toolbox Safety
Meeting
Daily
Daily
Contractor
Kick-off Meeting (w/Job
Safety Plan)
One per Project
At beginning of contract
Contractor /
Owner
Safety Assessment
One per month for
projects > 500 person
hours
NA
Owner site orientation
Annually (1/worker/yr)
Annually (1/worker/yr)
Contractor
Work Permits
Daily
Daily
Owner /
Contractor
Job Safety Analysis
Generally For each WP
Generally For each WP
Contractor
Incident Reporting
(includes near miss/hazard ID)
As per guidelines
As per guidelines
Contractor
List of Project Documents
One per Project
NA
Contractor
Emergency Contact List
One per Project
NA
Contractor
BBS activities
(see Section 3)
(see Section 3)
Contractor
1.

Owner
All projects (capital and expense) of duration greater than one week
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P&D 04.01 Minimum Requirements
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TITLE
SECTION 04:
SUBJECT 02:
Contractor Safety program - Pipelines and Distribution Edition
Work Control Procedures
Job Training and Orientation
PURPOSE AND SCOPE
This subject describes the job preparation steps that occur before on-site activities.
PROCEDURES
Work Place hazard identification & risk assessment orientation
Hazard identification and risk assessment is performed for all activities in order to
reduce risk. There are several forms of hazard identification and risk management:
 JSA: Details related to JSA are located in section 03.04. The training is to include
hazard awareness.
 Toolbox Meetings (daily, pre-job discussion of day's activities): Details for Toolbox
meetings are located in section 04.03.
 LMRA or Stop and Think (done by workers just before routine tasks): Details
related to LMRA are located in section 03.03.
 Risk Tolerance DVD training from the ExxonMobil Center of Excellence is
available to all contractors. All workers need to be aware of the 10 factors
affecting their tolerance to accepting risk. The DVD is available from P&D
Contractor Services Advisors (CSA)
Contractors, as part of their staff training, must include training on the above tools so
that staff is familiar with these risk mitigation tools. Training is to ensure that workers
are capable to identify hazards and apply actionable mitigation.
Worker training and orientation
All workers involved in jobs on Owner sites are required to be trained as per OH&S
regulation depending on project scope. Owner reserves the right to request proof of
training.
Training for all workers is to include:
 contractor’s orientation
 P&D / IOL orientation
 oil & gas industry specific awareness orientation training (ENFORM, POST
or other endorsed by IOL)
 alcohol & drug awareness training
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P&D 04.02 Job Training and Orientation
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TITLE
SECTION 04:
SUBJECT 02:
Contractor Safety program - Pipelines and Distribution Edition
Work Control Procedures
Job Training and Orientation









short service worker review
general safety rules and regulations
first aid as required by provincial regulations
trade certification as required (e.g. electrician, welder)
safe work methods
responsibility and accountability for safety
use and care of Personal Protective Equipment
WHMIS training as per legislation
behaviour based Observations
Training may also include depending on involvement but may not be limited to:
 confined space awareness or training as required by province working in
 competent in the critical procedure/T1PB being performed
 defensive driving if operating vehicle on P&D time
 respiratory equipment use and maintenance
 H2S awareness certificate
 gas detection certification
 scaffold erection and dismantling
 fall protection
 fire extinguisher use
 ground disturbance
Subcontractor supervisor and worker training/knowledge expectations are the same as
for the Contractor.
Worker Orientation to the OWNER Contractor Safety Program
Workers must understand the fundamentals of the safety program to be able to
execute it. This includes an outline of the basic control documents in the
program (daily work agreements, incident reports) and the behaviour based
safety tools to be employed [LMRA, LMRA testing, JSAs (including critical
procedures) and PJOs].
This requires, on either a project or annual basis, that all contractor and
subcontractor employees are instructed on the basic elements of the OWNER
Contractor Safety Program – Pipelines and Distribution Edition.
A summary of the CSP is contained in the P&D Safety Orientation CD or
through the “My Training” tab in Manuals LIVE (upper right hand corner of
the home page). The orientation process itself is described in PDM 01-14-01
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P&D 04.02 Job Training and Orientation
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TITLE
SECTION 04:
SUBJECT 02:
Contractor Safety program - Pipelines and Distribution Edition
Work Control Procedures
Job Training and Orientation
Contractor Site Orientation. Contractors must review the process well in
advance of workers arriving on site.
Each worker will be provided a copy of the Pipelines & Distribution
Orientation booklet by P&D operations (Appendix 24).
Project Kick-off Process (see section 04.03)
In advance of coming on site, a project kickoff meeting is held that covers:
 scope of work, skills required, consideration of project risks,
schedule
 the requirements of the project risks including training requirements,
JSAs, Critical Procedure/T1BP etc.
 a review of contractor responsibilities for their subcontractors
Worker Site Orientation
The on-site orientation reviews the safety philosophy, general site rules, site
orientation, emergency response plan, other activity on the site, and the current
risks to all on site.
 Daily Work Permit Process
The Work Permit is an important interface document. It coordinates activities
and outlines risks that may be present during the performance of the permitted
task. It will include a review of critical procedures required for the day’s work
and associated JSAs. It is discussed in CSP 04-15.
Approved Supervisor Training
Prior to supervising any work on a P&D site, contractor supervisors must go through a
screening process to become approved. This process can take up to several weeks. A
supervisor applying for approval will have the training noted above for workers and
must have the training outlined in Section 02-04.

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TITLE
SECTION 04:
SUBJECT 03:
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Site Safety Meetings
PURPOSE AND SCOPE
This section describes the requirement of on-site safety meetings to be held during
projects. These meetings consist of project kick-offs, daily tool boxes and weekly
safety meetings.
PROCEDURES
1. Kick-off meeting
Prior to project commencement, a kick-off meeting, shall be held in order to review:
 Scope of work and schedule
 Safety policies and general requirements
 Safety expectations (including behaviour based safety requirements)
 Protective clothing & equipment
 Required Job Safety Analyses (as required)
 Incident and near miss/hazard identification reporting requirements and testing
requirements (including Alcohol and Drug policy compliance)
 Training and orientation requirements.
The contractor supervisor and PM or designate will ensure a Kick-off meeting occurs
before work begins. IOL operational staff may participate. The contractor refers to
App 16 - Project Form 7 - Pre-Construction Meeting to ensure all key items are
covered.
Contractor's site supervisor, contractor's employees and subcontractors on site for an
extended period of time should attend this meeting. A completed kick-off meeting
checklist shall be available on site for consultation during the project, with a copy
provided to the IOL PM. This meeting requires careful preparation in advance by all
parties for it to be effective.
Topics reviewed at the kick off meeting should be documented and reviewed with any
subcontractors or other crews that did not attend the kick off meeting.
Documents required to be available on site during project will be listed in the List of
Job Documents (Appendix 14).
2. Daily Toolbox (tail gate)
Every working day, a brief safety meeting shall be held before work commences. (If
work will conclude in less than 4 days, a weekly meeting is not required). Minutes of
this meeting shall be documented on a form similar to Appendix 18: P&D Weekly
Safety Meeting. The primary purpose of the daily safety meeting is for the workers to
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TITLE
SECTION 04:
SUBJECT 03:
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Site Safety Meetings
discuss the specific tasks for the day. This discussion must include what is being done,
by whom, and how it is to be done.
 Items for discussion during this meeting should include review of higher risk tasks,
the associated risks and the related precautions and controls to do them safely
(including review of JSAs for the day), other related safety topics (e.g. safety
alerts, previous incidents) as appropriate.
 Coordinate work activities and consider weather conditions, traffic, equipment
being used and housekeeping
 Toolbox meeting content must be reviewed by the contractor supervisor or with
those arriving later in the day to ensure common understanding of risks
 Duration of daily toolbox meeting is at the discretion of the site supervisor but shall
be sufficient to review above topics and encourage group participation. A typical
toolbox meeting is between 20 and 30 minutes.
 Use App 29 - Tool Box Meeting Quality Assessment tool to assess meeting quality.
3. Weekly Safety meetings App 18 - P&D Weekly Safety Meeting.
For projects extending beyond four consecutive days, the contractor must sponsor a
more extensive weekly safety meeting at the site. Again, it is an opportunity to discuss
issues and to focus on safety objectives and learnings. Minutes of this meeting shall be
documented on a form similar to Appendix 18: P&D Weekly Safety Meeting (see link
above). Items for discussion during this meeting should include:
 Review of incidents and near miss/hazard identifications
 Explore how to apply lessons learned to work that still lies ahead
 Develop and discuss a special safety topic for the meeting
 Discuss housekeeping expectations – use App 47 – Housekeeping Quality
Review
 Increasing commitment to behaviour based safety practices and Nobody Gets
Hurt
 Duration of weekly safety meeting is at the discretion of the site supervisor but
shall be sufficient to review above topics and encourage group participation. A
typical weekly meeting is between 30 and 40 minutes.
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TITLE
SECTION 04:
SUBJECT 04:
Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Safety Assessment
PURPOSE AND SCOPE
The purpose of this subject is to describe the proposed procedures in regards to project
safety assessments and observations.
PROCEDURES
Project Safety Assessment
Project Manager or designate occasionally conducts safety assessments of projects in
order to evaluate performance against the outlined expectations.
The Project Safety Assessment must be utilized when the duration of the field work
exceeds 500 person hours and then verify continued performance to the original
assessment once per month thereafter. The Contractor is asked to accompany the IOL
representative during these assessments and should consider conducting safety
assessments on themselves and their subcontractors. The safety overview includes
document verifications, worker observations, interviews, and site safety observations
on the following subjects:
 Policies & general requirements
 Operation integrity
 Site housekeeping
 Public safety and security
The Project Safety Assessment (Appendix 23) is the tool to be used to conduct the
inspection. Any negative responses should be explained and should result in a follow
up action. Additional comments for other items can be provided even if a satisfactory
response was noted.
Deficiencies, actions and timing are to be documented on the summary page. A copy
of the completed form is then sent to the contractor and CSA. The contractor should
take appropriate action to resolve any identified deficiencies. Notification is to be
provided by the contractor once all items have been satisfactorily corrected.
The results of the assessments for all contractors are summarized on an annual basis to
help identify strengths and weaknesses within the system and to provide focus. The
findings are shared with contractors annually and are used for continuous
improvement of the contractor's Risk Mitigation Plan (RMP).

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SUBJECT 05:
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Work Control Procedures
 Critical Procedures
PURPOSE AND SCOPE
The purpose of this subject is to identify the tasks that P&D has deemed as critical
procedure. Critical procedures are now also referred to as Tier 1 Best Practices (T1BP)
and/or Higher Risk Operations (HRO).
A link is provided to the Pipelines & Distribution Manual PDM 03-02-01 Critical
Procedures - General. Within the PDM is a complete list of procedures that have been
designated as a critical or T1BP or HRO procedures. Definitions, specific instructions
and links to critical procedures, are provided in the PDM.

Owner Procedures
In situations where a contractor must execute one of the following procedures,
Pipeline and Distribution procedures and related checklists shall be used (use the link
above to access):







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
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

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Confined Space Entry involving hydrocarbons
Vapour Recovery Bed Burn In
Decommissioning Tankage
Commissioning Tankage
Lockouts and Forceful Removal of a Lock
Entering on Internal Floating Roofs – Tanks
Landing and Raising Floating Roof - Continued Service
Landing and Raising Floating Roof - Maintenance Activities
Penetration of Pressure Piping
Crossing Procedures
Cleaning and Gas Freeing Storage Tanks
Working on Pipelines under High Voltage Power Multi-Phase Lines
Contractor Critical Procedures
For procedures not listed above, Contractors will develop their own procedures to
manage the execution of all other critical and non-critical procedures.
Critical and T1BP procedures must be endorsed by a P&D representative before use on
site. The contractor must demonstrate and is responsible to track, that the specific
procedure to be used has been endorsed by the Owner and that no changes have been
made since the endorsement. Contractors should contact their PM or Site Manager for
the PDM 03-02-01 list of P&D Subject Matter Experts that can provide endorsement.
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Work Control Procedures
 Critical Procedures
Executing a Critical Procedure
Contractors must reference the PDM to ensure their procedures meet P&D minimum
expectations, and to understand additional planning and preparation that P&D expects
to be included prior to, during and post execution of actual work. One of the planning
requirements will be to include a pre-job meeting the day of executing a critical/T1BP
procedure. The pre-job meeting will be successful if in addition to specific steps listed
in the procedure, the following outcomes are achieved:
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
Contractor procedures have been endorsed for use
Personnel are assigned to complete the steps prior to work commencing
Controls are in place for all hazards identified
All workers involved understand their roles and responsibilities
Verified that all workers are competent: trained, have experience and are
capable
Emergency response plan is in place with appropriate equipment and response
team notified
Warning devices such as continuous monitors and safety watches are trained
and identified
Egress and evacuation plan developed and understood including equipment
such as ladders etc in place
All groups understand the job sequence and the key interfaces and hazards
introduced by the workers
All workers have an opportunity for input into the JSA and work plan.
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Work Control Procedures
Safety Rules
PURPOSE AND SCOPE
The purpose of this subject is to introduce the Life Saving Safety Rules and identify
other site safety rules that apply to P&D operating sites.
PROCEDURES
The Owner has identified a set of safety rules to ensure best work practices and
established procedures for high-risk work are adhered to at all times. This set of rules
is referred to as the Life Saving Rules. Contractor's supervisors must ensure that all
workers understand the consequences of violating any of the Life Saving Rules and
IOL/Contractor Company Rules. A contractor can receive a major suspension or be
permanently banned from P&D sites for violating a Life Saving Rule. Contractors are
responsible for applying their disciplinary policy to their employees.
Life Saving Rules:
Violation of the following Life Saving Rules can result in major suspension or
Termination:
1. Failure to follow 100% tie-off requirements when working at heights.
2. Violating Work Permitting Procedures
 Entering a confined space without prior approval or a valid permit or
standby person present where required
 Issuing or receiving a work permit without a required gas test being
conducted
 Working without a valid permit on jobs that require a permit
 Issuing or receiving a permit without job-site verification where required by
site safety standards.
3. Failure to follow Hazardous Energy Control Procedures
 Conducting maintenance on equipment without all hazardous energy
isolated and controlled
 Unauthorized removal or tampering with Hazardous Energy Control
Devices (lock-out/tag-out devices)
 Opening Process Equipment without verifying the equipment is properly
cleared, isolated, and de-energized or without wearing proper PPE.
4. Defeat of SSH&E Critical Devices without Proper Authorization.
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Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Safety Rules
General Site Rules
The following general site rules and requirements were developed in response to incident
learnings and clarifications to frequently asked questions. The Contractor is to ensure
both their employees and subcontractors are aware of the requirements and enforce these
rules to prevent incidents.

Contractor shall provide and maintain all barricades, guard fences and lights
necessary to restrict access to roads and work areas. Barricades, guard fences,
lights and other safety protection require the approval of Owner's representative
and shall also comply with all governing safety requirements.

Contractor shall supply and maintain all safety equipment required to perform
work in a safe manner including, but not limited to, safety harnesses, signs, safety
glasses, goggles, gloves, hard hats, fire retardant clothing, nets, ropes, face shield,
respiratory equipment, boots, fire extinguishers and air monitoring equipment.

Contractor shall ensure that its Subcontractors' personnel use and receive
appropriate training in the use of required safety equipment.

Conflict between various safety regulations and practices must be brought to the
immediate attention of Owner for clarification. The most stringent of safety
regulations is to be followed until Contractor receives explicit written clarification
from Owner.

For all work at Owner's site, the Contractor is to forward to the Owner's
representative, any safety inspection reports and related follow-up completed by or
for the benefit of the Workplace Safety and Insurance Board (WSIB), a provincial
member of the Association of Workers Compensation Boards of Canada (WCB) or
any other outside agency (insurance companies, industry safety association). A
copy of all orders written to the Contractor while on the owner's work site shall
also be forwarded to the Owner's representative.

Contractor is required to obtain Owner's approval prior to bringing any hazardous
material on site. Contractor is responsible for Material Safety Data Sheets (MSDS)
for all hazardous materials brought on site by its personnel and is required to
provide a copy of the MSDS to the work site representative.

The Owner shall have MSDS's accessible for all hazardous materials that the
Contractor's personnel may come into contact with at work site. It is the
Contractor's responsibility to ensure that their employees are familiar with MSDS's
and request the site to provide a copy of the MSDS if required for worker review.
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Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Safety Rules
Personal Protective Equipment (PPE)
When working in operating areas of the work site, minimum P&D requirements as
detailed in PDM 01-04-06, PPE Requirements must be met. By carefully referencing
PDM 01-04-06, workers will arrive on site ready to work in all situations.
Other Safety Rules

Unless specifically approved by the Owner’s representative, walking on pipelines is
not permitted

Working while standing or sitting on pipelines is not permitted. Scaffolding is to be
erected to avoid standing on pipes

Smoking is not permitted except in designated areas and ONLY at times approved
by the Owner. This “NO SMOKING” regulation must be enforced by the
Contractor. Contractor’s personnel and/or its subcontractor personnel violating this
regulation will be removed from the site

Safety matches (the type that can be ignited only on the box or folder) and cigarette
lighters with enclosed mechanisms are permitted in the work site. Strike anywhere
matches and open mechanism (single action) lighters are not permitted

Access/egress to exit doors, electric or elevator panels, fire extinguishers, fire alarm
pull stations, or other safety devices or equipment, shall not be blocked at any time

Gas cylinders shall be stored and used in accordance with applicable government
legislation. Materials used to secure cylinders shall be of non-combustible materials

Storage and use of flammable materials will be subject to the approval of the
Owner. Safety cabinets and cans shall be used for storage and dispensing
flammable liquids and must have prior approval of the Owner. Gasoline-powered
tools or Equipment are not permitted inside buildings. Dirty or oily rags shall be
kept in a fireproof metal container with self-closing lid and removed from the
premises daily

Explosive activated fastening systems are not permitted at the work site without
written approval from the Owner’s representative

Electrical lights and cords:
a. All electrical cables, extension-cords, connections and fittings shall be in good
condition and of the grounded type
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Work Control Procedures
Safety Rules
b. "Electrical Extension Cords" will be CSA type SOW as per Canadian Electrical
Code Part I (possible CSA code restrictions may also apply)
c. "Portable Electrical Lights" will be suitable for Class I Division 1 Atmosphere
as per Canadian Electrical Code Part I
d. Only authorized personnel designated by the Owner’s representative shall
remove protective vapor tight or explosion type globes on electric lights
e. The Contractor shall provide ground fault circuit interrupter protection when
using electrical tools and equipment: i.e. lighting and power cords

All portable radios, cell phones, flashlights, pagers and gas detectors used by the
Contractor personnel at the work site must be intrinsically safe, CSA certified as
safe for Div 1, Class A, B, C, D. or else a hot work permit must be issued

When driving railway spikes or markers into ground, utilize pneumatic/hydraulic
equipment if possible, to avoid hand spiking. Where hand spiking cannot be
avoided, a spike holding tool must be utilized

When locating depths of underground structures, utilize electronic equipment if
possible versus hand probing tool. When hand probing cannot be avoided, exercise
care during probe removal to avoid injury. Utilize additional help if probe becomes
stuck

All welding Equipment shall be of the gasoline or diesel drive type unless agreed to
in advance by Owner:
 Each welding machine being supplied or used by Contractor on the work site
shall be equipped with a minimum of 2-20 lb. extinguishers. One 20-pound (10
kg) minimum capacity dry chemical fire extinguisher at the welding machine
and a second 20-pound (10 kg) extinguisher at the location of the hot work
operation
 Contractor shall keep extinguishers in good working order throughout the
duration of work
 If used, Contractor shall immediately have extinguishers recharged and made
ready for continued service at the work site
 Welding ground returns must be placed on the material being welded and
closely adjacent to the arc unless the Owner's representative has approved an
alternative system
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Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Safety Rules
Contractors shall perform the work in an environmentally responsible manner. This
includes, but should not be limited to:
 Ensuring that the work will not adversely impact the surrounding community
 Ensuring that the Contractor’s activity will not cause a discomfort to workers or
surrounding community from dust, smells or from a flammable vapor release
 Ensuring zero spillage of petroleum products or other wastes onto the ground,
water or into a sewer system
 Contractor shall ensure that the deposit of debris or rubble near or in manholes,
catch basins and sewers is prevented. The Contractor shall remove any
obstruction or deposit found upon final inspection of work
 Ensuring that work will not produce noise levels above current background
noise measured at closest fence or property line, without prior approval of the
Owner
 Install noise attenuation barriers to minimize the impact on surrounding
communities for work extending beyond normal hours of work. Maximum
acceptable levels shall be 85 DBA

Contractor and its personnel shall be familiar with general environmental
regulations applicable to Province, work site and municipality where it is operating

Contractor shall report to the Owner any situation potentially harmful to the
environment, such as spills, emissions, noise etc. and complete a P&D Incident
Report (Link to PDM) within one business day from the time the incident or near
miss occurred

For tasks which require a person with legally prescribed certification, training or
permits, the Contractor shall provide the Owner with written records and evidence
that this requirement has been met. Operator must have certificate on their person
when operating such equipment

Contractor who transports or handles, for disposal or treatment, any waste
originating from the Owner’s property, shall submit copies of all waste manifests
and other written documentation that certifies waste disposition, volume, quantity,
location and receipt of the waste from the disposal facility, as per provincial
regulations

Any requirement for a planned release of material that could impact the
environment, must be approved by the owner
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Work Control Procedures
Safety Rules

Contractor shall provide licensed operators for power mobile construction
equipment (PME). The owner reserves the right to request a copy of the license at
time of work - Operator must have certificate on their person when operating such
equipment

All equipment including powered mobile equipment must have up-to-date
maintenance & inspection records with the equipment, and must be able to perform
the work required without performing repairs or maintenance while it is on site

PME is a hazardous energy source requiring lockout procedures before undergoing
maintenance, repairs or inspections

The use of any type of cellular device while driving is prohibited while on owner
business

Contractor employees operating vehicles while on Owner’s time shall be competent
drivers and trained in defensive driving

All trucks and mobile equipment used at a work site must be equipped with a
working audible back-up alarm

All mobile equipment to be used on the work site roads shall be mounted on rubber
tired wheels or tracks without cleats

All terrain vehicles (ATVs) are not permitted on P&D sites. Exemptions may be
granted on an individual basis using the Owner's Management of Change process

Owner has the right to inspect Contractor’s equipment, vehicles and property upon
entry or departure from the work site

Access to the work site shall be as identified by Owner during the pre-work safety
meeting

The Owner reserves the right to refuse entry to Contractor and/or its Subcontractor
personnel who violate recognized Owner's safety rules and/or practices

Contractors workforce is to report to the work site supervisor upon arrival, prior to
starting work

Contractor workforce shall only enter secured area after owner's representative
grants access permission

Contractor shall register all of its personnel and its Subcontractors with the work
site by signing in using the Visitor’s Log or Safe Work Permit and the Daily Work
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Work Control Procedures
Safety Rules
Permit if applicable. This is to be performed upon arrival at the site and upon
exiting the site

The security and upkeep of Contractor's materials, tools, construction equipment,
facilities, etc. on Owner's property, is the sole responsibility of the Contractor.
Owner shall not reimburse the Contractor for loss of, or damage to any of these
items

Contractor shall furnish all equipment, including tools, required to perform work.
Contractor or its Subcontractors personnel shall not use Owner's tools or equipment
and shall not work in Owner's shops unless the written approval of Owner's
representative is obtained

At the Contractor's discretion, Contractor shall provide and maintain at no
additional cost to Owner, the following temporary facilities, including but not
limited to: field office, lunch room, tool storage, warehousing and fabrication
facilities required to perform the work

Contractor shall obtain owners approval in advance for all temporary facilities

All temporary facilities must be Canadian Standards Association approved

Contractor shall maintain a complete set of Contract Documents, up-to-date
drawings, bill of material and material receipts in its work site office and these shall
be available to Owner for its use and inspection

All use of temporary connections to work site water systems, steam and other
utilities shall require Owner’s prior approval

All first cuts into existing piping shall be cold cuts and the Contractor shall supply
and utilize pipe plugs where necessary to render piping safe for field welds. Pipe
plugs utilized are required to have de-pressuring capability. Alternate to pipe plugs
(i.e. Mud plugs) must be specifically approved by Owner

Trailers brought on site (tool, equipment or office) must be approved for the
intended use including meeting appropriate building codes if intended for
occupancy
Open Excavations
a) Trenching of roads shall not close more than half the road to traffic at any one time,
including emergency vehicles.
b) Full access shall be restored as soon as possible.
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Work Control Procedures
Safety Rules
c) If it becomes necessary to completely close any roadways, it shall be the
Contractor's responsibility to notify Owner prior to such closure.
d) Excavated materials shall not obstruct sewers, valve boxes, hydrants or access
ways.
e) Excavations shall be adequately barricaded and delineated with warning lights.
f) Contractor needs to ensure access for emergency vehicles if road trenching is not
complete.
g) Sufficient pumping equipment shall be maintained and operated as required to keep
excavations free of normal run off and seepage water at all times. The water shall be
discharged to the existing storm sewer system or as permitted by local regulations.

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P&D 04.06 Safety Rules
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SUBJECT 07:
Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Confined Space Entry
PURPOSE AND SCOPE
The objective of this document is to establish guidelines intended to satisfy minimum
criteria for Confined Space Entry at P&D facilities.
Contractors are expected to establish work plans and procedures which are consistent
with the guidelines outlined in this document and local legal requirements.
Contractors must also be aware that the majority of Confined Space Entries done on a
P&D work site will require special endorsements well in advance of the actual work.
Refer to PDM 03-02-01: Critical Procedures - General for P&D expectations around
critical work including Confined Space Entry.
The Confined Space Entry procedure is described in the PDM (Pipeline & Distribution
Manual) via the following link:
PDM 03-02-02: Critical Procedures - Confined Space Entry
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P&D 04.07 Confined Space Entry
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SUBJECT 08:
Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Cranes & Lifting Operations
The Cranes & Lifting Operations procedure is described in the PDM (Pipeline &
Distribution Manual) via the following link:
PDM 03-02-09: Cranes & Lifting Operations
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P&D 04.09 Opening Process Equipment
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Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Opening Process Equipment
PURPOSE AND SCOPE
The objective of this document is to establish guidelines intended to satisfy minimum
criteria for Opening Process Equipment at P&D facilities. Contractors are expected to
establish work plans and procedures which are consistent with the guidelines outlined
in this document and local legal requirements.
Opening Process Equipment has important procedural criteria that sites and
contractors must adhere to. They are described in the PDM (Pipeline & Distribution
Manual) via the following link:
PDM 03-08-21 Opening Process Equipment
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P&D 04.09 Opening Process Equipment
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SUBJECT 10:
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Work Control Procedures
Safe Electrical Work
The Safe Electrical Work process is described in the PDM (Pipeline & Distribution
Manual) via the following link:
Safe Electrical Work (Link to PDM)
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P&D 04.10 Safe Electrical Work
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SUBJECT 11:
Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Working at Height
The Working at Height process is described in the PDM (Pipeline & Distribution
Manual) via the following link:
Working at Heights (Link to PDM)

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P&D 04.12 Energy Isolation
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SUBJECT 12:
Contractor Safety Program - Pipelines and Distribution Edition
Work Control Procedures
Energy Isolation
Energy Isolation processes on P&D sites are explained in PDM 03-02-05. This process
must be followed by contractors working on P&D sites. The procedure is accessed via
the following link:
PDM 03-02-05 Energy Isolation and Lock-Outs
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P&D 04.12 Energy Isolation
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SUBJECT 13:
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Emergency Response and Incident/Near Miss/ Hazard ID Reporting
PURPOSE AND SCOPE
This section describes P&D's requirements for emergency response preparedness and
reporting.
PROCEDURES
Emergency Response
Emergency response procedures shall be established before work begins and followed by
contractors working on IOL properties when facing risk of serious injuries or incidents (fire,
spills, explosion, etc.). The developed emergency response plan shall consider the best
procedures on how to safeguard life, limb, environment and property, in that order. A list of
emergency phone numbers and contacts must be available.
The plan and contact list shall be posted in a visible location and be used for discussion,
initially during the kick-off meeting and occasionally at site safety meetings. A draft
emergency contact list plan is available for consideration in CSP Appendix 19.
Each contractor is to develop their own plan based on their own individual needs and
requirements. A sketch is required that outlines the route to the nearest hospital or medical
clinic in order to save time and complication in case of an incident.
If contractor has an emergency at an unattended IOL site, initiate emergency response as per
plan and obtain response by dialing 911. Initiate reporting criteria to contractor management
and IOL operational staff as soon as work site is stable and safe to make notifications.
If contractor has an emergency at an attended IOL site stop work, contact operations staff
immediately and activate emergency response as per plan.
If the site general alarm is sounded:
 Ensure all workers in the immediate work area evacuate to muster location
 Report to site staff any of work crew not accounted for at muster point
 Assist in response only if requested by site personnel
If a worker is seriously injured and needs to be transported to the hospital:
 Assign someone to accompany the injured worker to ensure that their needs are met
 Ensure communication is maintained to obtain location and status of injured worker
 Ensure work area is safe,
 Secure incident scene and preserve scene for investigation team
 Report incident to IOL contact and Contractor Management immediately and discuss
requirements for A&D testing
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P&D 04.13 Emergency Response and Incident/Near Miss/ Hazard ID Reporting
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SUBJECT 13:
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Emergency Response and Incident/Near Miss/ Hazard ID Reporting
Incident Reporting and Investigation
An Incident can be defined as:
An undesired event which resulted in:
 harm to people;
 an adverse effect to the environment;
 loss of property;
 damage to equipment; or
 interruption of business.
Contractors shall institute appropriate incident management by properly reporting incidents,
conducting investigations, implementing corrective and preventive actions and analyzing
performance. The objective is to avoid incident repetition and to detect incorrect procedures,
attitudes or other problems. Contractor will document on their own form or P&D Incident
Report (Link to PDM) and send a copy to local operations staff or PM. Reports will be
forwarded to CSAs as appropriate. In all cases, a verbal notification should be provided
immediately with the written report submitted within 24 hours.
Incidents can be classified by type and severity. Types of incidents are:
 Personal health and safety that includes fatality, lost time injury, restricted work,
medical treatment, first aid, and occupational illness.
 Environmental that includes spill and leak.
 Downgrading that includes fire, explosion, vehicle accident, and damage to IOL
property (greater than 5 K$).
 Liability that includes damage to third party property.
 Inspection reports or orders (including charges) from a government agency such as
Ministry of Labour.
Complete and accurate information is essential to determine preventive measures, to analyze
root or systemic causes and to retain proper record. The supervisor responsible for the work
resulting in an incident should conduct the investigation or at a minimum participate with
contractor management.
P & D reserves the right to participate in the investigation of any incident.
The process of an investigation includes the following steps:
 Describe what happened.
 Identify the exact sequence of events that led to the incident (timeline).
 Identify the incident root cause, which corresponds to action, omission, equipment
problem or other factor resulting in the incident. A root cause can be defined as “if it
had not occurred the incident would have not happened”. By asking why an incident
occurred and questioning each answer with another why that event happened, will
reveal the actual root cause.
 Identify other contributing factors that lead to the incident.
 Review the safety program and its implementation to determine if there are any
obvious corrections necessary to address the root cause identified.
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Work Control Procedures
Emergency Response and Incident/Near Miss/ Hazard ID Reporting


Provide workable solutions to prevent recurrence of similar incidents.
Review the report with the PM/CSA to ensure completeness of information and followup.
When preparing the incident report, contractor should remember to:
 Be factual, not give opinions or speculate
 Avoid estimates, guesses, exaggerations, generalisations
 Avoid language that is inflammatory, judgemental or emotional. Sharing near
miss/hazard identification experiences is an excellent way to identify higher risk
situations caused either by human attitude, inadequate work procedures or inadequate
managing system. Studies suggest that for each reportable incident at least 15 near
miss/hazard identifications occur. As such, the greatest learning opportunity to prevent
accidents on work sites is related to adequate recognition and notification of near
miss/hazard identification. P & D requires that contractors support and promote near
miss/hazard information reporting accordingly.
Follow-up actions identified to prevent recurrence shall be implemented as soon as possible. A
notification shall be sent by the contractor to the PM/CSA to advise that appropriate actions
have been taken.
The Contractor’s Supervisor must report to the Workplace Safety and Insurance Board (WSIB)
or Workers Compensation Board (WCB), any accident that meets the provincial requirement.
Where an employee fails to report accidents and obtain proper first aid attention in a timely
fashion, an employee’s right to compensation may be delayed, especially in cases where the
disability does not immediately follow the accident.
Injury Case Management Program
Contractors shall have an injury case management system to support workers involved in
injuries or potential injuries. An injury case management system should include education for
all workers on the distinction between the 3 types of injury classifications, medical treatment,
restricted work and lost time. The contractor's case management system should include a
notification protocol to both contractor management and client. Contractor supervisors should
be trained to manage injuries and potential injuries and equipped with a case management
reference package in the field that includes relevant contact information, a description of the
contractor's modified work program (refer to next CSP Subject) and if applicable, release
waivers signed by all field staff granting permission for treating physicians to discuss injury
details with contractor representatives.
Incident Classifications:
1) A medical treatment incident is a work-related injury or illness that involves neither lost
workdays nor restricted workdays, however requires treatment by a physician or other licensed
health care professional (LHCP) that is beyond the level of first aid treatment. Note that
observation, counseling or diagnostic procedures are not considered to be treatment.
First aid is defined as any of the following treatments:
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
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Emergency Response and Incident/Near Miss/ Hazard ID Reporting
1. Use of non-prescription medication at non-prescription strength (further specifics are
defined).
2. Tetanus immunization (other immunizations, such as Hepatitis B vaccine or rabies
vaccine are medical treatment).
3. Cleaning, flushing or soaking wounds on the surface of skin.
4. Using wound coverings such as bandages, Band-Aids, gauge pads, butterfly bandages
or Steri-Strips (Other wound closing devices such as sutures, staples, tapes/glues etc.
are considered medical treatment).
5. Using hot or cold therapy (e.g. compresses, soaking, whirlpools).
6. Using any non-rigid means of support, such as elastic bandages, wrap non- rigid back
belts etc. (devices with rigid stays or other systems designed to immobilize parts of the
body are considered medical treatment).
7. Using temporary immobilization devises while transporting a victim (e.g. splints,
slings, neck collars, back boards etc.).
8. Drilling of a fingernail or toenail to relieve pressure, or draining fluid blister.
9. Using eye patches.
10. Removing foreign bodies from the eye using only irrigation or a cotton swab.
11. Removing splinters or foreign material from areas other than the eye by irrigation,
tweezers, cotton swabs or other simple means (procedures involving the cutting of the
outer layer of skin are considered medical treatment).
12. Using finger guards.
13. Using massages (physical therapy or chiropractic treatment are considered medical
treatment).
14. Drinking fluids for relief of heat stress.
Note: Preventive use of Oxygen in ABSENCE of symptoms is NOT considered a medical
treatment.
In addition, certain other conditions upon diagnosis by a physician are considered to be at least
medical treatment, even if no specific treatment is rendered. This includes:
 Medical removal from the work-environment due to exceeding exposure criteria for
Lead, Cadmium, Methylene Chloride, Formaldehyde, Benzene
 Hearing loss beyond specifically defined threshold hearing loss shifts
 Loss of consciousness
 A fractured or cracked bone (or teeth)
 Punctured eardrum.
2) A restricted work incident is a work-related injury which results in an individual being
unable to perform all normally assigned work functions during any scheduled work shift; or
being assigned to another job on a temporary or permanent basis after the day of the injury or
illness.
Restricted work activity occurs when the worker, because of the job-related injury, is physically
or mentally unable to perform:
 all or any part of his or her normal assignment during all or any part of the normal
workday or shift. The emphasis is on the worker's inability to perform normal job
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Work Control Procedures
Emergency Response and Incident/Near Miss/ Hazard ID Reporting
duties over a normal work shift. "Normally assigned work," means any tasks that the
employee performs or is expected to perform as part of their job.
 all duties or normally assigned work functions at their normal schedule.
3) A lost time incident is any work-related injury, which results in at least one lost workday,
after the day of the incident. If a worker's condition resulting from an injury causes him or her
to be unable to return to work on any of the individual's scheduled work shifts after the shift on
which the incident occurred, the case should be recorded as a "Lost Time Incident". Working at
home is not an acceptable alternative unless performing the work at home would be considered
"normal and customary". An injury is classified as Lost Time even if the following day is a
weekend or the worker takes a vacation day. The intent of classification is to determine whether
the worker could have worked the following day if scheduled to do so.
Near Miss Reporting
Near misses (also termed near losses) can be defined as:
An undesired event which, under slightly different circumstances, could have caused,
contributed to, or resulted in harm to people, an adverse effect to the environment, loss of
property, damage to equipment, or interruption of business.
Contractors shall institute appropriate incident management by properly reporting near misses,
implementing corrective and preventive actions and analyzing performance. The objective is to
avoid incident repetition and to detect potential incorrect procedures, attitudes or other
problems. Contractor will document on their own form or P&D Near Loss form, and send a
copy to local operations staff or PM. Reports will be forwarded to CSA as appropriate.
Hazard Identification (HID)
Hazard Identification is an informal process in which workers through either inspections or
general site activities, identify potential hazards that if left uncorrected may result in an injury
or equipment damage. It typically focuses on facilities and their use and impact on behaviours.
At minimum, the items should be physically marked to ensure workers are not injured prior to
the final corrective action taking place
HID key components are:
 Identifies the hazard including potential injury or damage
 Identifies the action required to mitigate the risk both short term and final
 Identifies who is responsible for the follow-up activities

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Work Control Procedures
Physical Fitness for Duty and Modified Work
PURPOSE AND SCOPE
It is expected that all contractors will have Fitness for Duty and Modified Work
programs. This section describes the minimum expectations of a program.
PROCEDURES
Physical Fitness for Duty
Contractors should evaluate the physical requirements for each job function within their
operation (e.g. lifting, climbing, standing requirements). A sample Job Demand
Analysis form is available in Appendix 15.
Contractor should consider screening, the potential candidate during the hiring process
to ensure they are physically able to perform the required tasks without causing injury.
A sample Pre-placement Physical Questionnaire can be found in Appendix 21.
Contractor must have a process for workers to identify any temporary or long term
physical limitations to their supervisor. Supervisor must consider that information when
preparing daily work assignments.
Modified Work Program
A modified work program focuses on rehabilitation-on work abilities as opposed to
work limitations. It supports accommodation and an early return to work following
injury or illness.
By providing focused leadership and coordination in the area of recovery and
rehabilitation from disability, program aims to:

promote a healthier workforce by reducing the occurrence and impact of
disability on employees

promote a timely and safe return to work following illness or injury

foster a collaborative approach to rehabilitation and accommodation

minimize the impact and cost of disabilities to employees and to the company

workers may recover from their illness or injury sooner and be able to
resume their regular lifestyle sooner
The contractor is responsible for managing an employee's absence and return to work,
including implementing rehabilitation plans and accommodation with the guidance of
health professionals and initiates referrals as medically necessary.
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Work Control Procedures
Physical Fitness for Duty and Modified Work
Employee Responsibilities
If you become ill or are injured and will be away from work, advise your manager on or
before the first day of absence and provide full and correct information regarding your
illness or injury.
If required by the company, undergo examinations or assessments by a health
professional selected by the company to assist with rehabilitation, accommodation.
Participate in rehabilitation and modified work if available.
What is a rehabilitation plan?
If a worker requires some accommodation upon returning to work, a rehabilitation plan, may be
developed to plan for and manage your eventual return to work. The development of this plan
involves the contractor management, and attending physician. It may also be appropriate to
consult with other specialists such as physiotherapists, ergonomists, pain management
specialists, rehabilitation specialists, occupational therapists and others.
Rehabilitation is multifaceted. It includes personal adjustments, health-related and vocational
factors. Effective rehabilitation plans are tailored to the individual and address each of these
factors.
What is modified work?
Work that enables the recovering employee to gradually return to work in the company
and that ultimately leads to a return to regular employment. Modified work may include
the employee’s own job with reduced duties, on a full- or part-time basis. Modified
work may also include an unrelated job on a full- or part-time basis. An employee who
is receiving extended disability benefits may qualify for a modified program if
medically capable.
In a typical modified work program:


Manager is responsible for managing an employee’s absence and return to
work. This includes developing accommodation options, and implementing and
facilitating achievement of the objectives of modified work plans and
accommodations. The manager also maintains communication with the absent
employee, as appropriate

Employee is responsible for providing timely information to management
regarding his or her absence and any change in ability to do his or her job. An
employee absent from work must be available for evaluation or possible return
to work, as appropriate. Failure to cooperate in rehabilitation or continue
appropriate treatment may result in the termination of disability benefits.
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SUBJECT 15:
Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Work Permits
The Work Permitting program is described in the PDM (Pipeline & Distribution
Manual) via the following link:
All contractors receive Work Permit Receiver training as part of the annual P&D Safety
Orientation.
Work Permits (Link to PDM)

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Work Control Procedures
Alcohol & Drug and Background Screening Guidance
PURPOSE AND SCOPE
This section describes the P&D requirements for control of alcohol and non-prescribed
drugs on P&D sites. The subject will include some best practices to assist the contractor
to execute against the requirements of the A&D program. The Owner's policy around
A&D programs and testing is contained in the Contract Job Specification attached to
the Contract between the Owner and the contractor.
PROCEDURES
Documented Program Requirements
Contractors shall have a documented A&D program that meets the criteria set out
in the contract.
The following paragraphs will attempt to clarify the expectations for field staff.
However contractor should refer to the A&D program requirements in the contract for
the detailed requirements of the contractor A&D program.





During hiring process communicate A&D program expectations and testing
requirements. This will avoid worker being surprised if testing is required. Have
worker sign off on requirements on an annual basis.
A random testing program is required for safety sensitive positions.
Pre-access testing is required for risk sensitive positions. In Alberta all trades
and trade helpers fit into this category. The test does not have to be specifically
for IOL, as long as the testing of the worker has been completed in the past 12
months.
Reasonable cause testing is required if there is an observation of physical
impairment, possession of or use of Alcohol or Drugs or related paraphernalia.
Confirm reasonable cause testing preferably with another supervisor or another
worker.
Action required when a report that a worker smells of alcohol is received by a
supervisor:
 Notify immediate supervisor.
 Supervisor to investigate with another supervisor or foreman or other
worker if another supervisor is not available.
 Determine if the worker does smell of alcohol and if there is at least one
other indicator. e.g. slurring speech, unable to walk properly, abusive or
unexplained non-compliance to safety rules or procedures.
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Work Control Procedures
Alcohol & Drug and Background Screening Guidance



If answer is yes, advise immediate supervisor and initiate A&D testing
process, keep worker under observation until testing conducted.
 If answer is no, advise worker that observation was reported and provide
some coaching on potential issues.
Post incident testing is required within 4 hours of injury or incident.
o Testing is to be conducted even if the 4 hour time frame cannot be met.
o Contractor is required to provide a documented reason why, if the 4 hour
time frame was not met.
o Post Incident testing is required to rule out impairment as a contributing
cause to an incident and is required for the following situations:
 Equipment damage exceeding $5 K
 Reportable spill depending on size (depends on provincial
jurisdiction)
 Medical Treatment, Restricted Work, or Loss Time injury or
potential for injury to become one of these
 Any significant near miss at IOL's discretion
o Post incident testing is not required for first aids
o The worker being tested must be kept under direct observation at all
times until the test has been administered.
Contractor shall have a documented protocol that explains to contractor
supervisor exactly how to execute the A&D testing requirements complete with
contact names and numbers. This protocol is to be posted in project trailer or
kept on site with contractor supervisor.
o Contractor should conduct A&D simulations to test understanding of
site supervisors to execute testing protocol and test capability of A&D
testing vendor to meet the 4 hour time commitment,
o When working in remote areas contractor should contact A&D testing
vendor and pre-notify of work in area. This will assist in preplanning for
collection of sample if required.
o If testing requirement is determined as being necessary, have worker
accompanied at all times.
IOL Attesting of Program

IOL PSD will send out an annual Alcohol & Drug Program Reminder letter.
An example is shown in Appendix 43 – “Contractor Alcohol & Drug PSD
Annual Letter – Example”

P&D will request an annual Appendix 44 - “Contractor A&D Compliance
Representation” form to be completed by select contractors whose personnel are
working in IOL/ExxonMobil categorized Comparable-to-Designated and/or
Safety-Sensitive and/or Risk Sensitive positions.
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Work Control Procedures
Alcohol & Drug and Background Screening Guidance
o Contractors chosen will be at P&D’s discretion, considering previous
A&D performance, assessments, overall performance, and nature of
work
o Contractor will certify compliance with all contractual requirements, or
indicate their plan and time-line to address variances

As per contract requirements, the contractor will allow P&D access to A&D test
results. P&D will be conducting in-office visits on one or more contractors that
are a subset to those sent the compliance representation letter, to verify that
workers requiring program testing are being tested. Appendix 45 – Contractor
Alcohol & Drug Program Assessment Tool, or a similar tool, or a third party
hired by IOL, will be utilized to document the assessment.
IOL Background Screening
 IOL/contractor safety advisors (CSA’s) will conduct background/security screening
attests for security sensitive positions (not to be confused with safety sensitive positions).
CSA’s will contact a selection of IOL terminal managers/personnel as well as IOL
personnel from the projects group, to provide selection of contractors to be attested. Yearly
the CSA’s to contact selected contractors and confirm required background/security
screening has been completed on individuals by the contractor.
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Contractor Safety Program - Pipelines & Distribution Edition
Work Control Procedures
Alcohol & Drug and Background Screening Guidance
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Contractor Safety Program – Pipelines and Distribution Edition
Work Control Procedures
Standards for Contractor Gas Testing
PURPOSE AND SCOPE
The intent of this procedure is to establish the minimum standards for gas detection
when contractors are working for Pipelines & Distribution. This document covers
minimum training requirements for individuals who perform gas detection while
working for P&D and also minimum requirements when using gas detection equipment
at P&D facilities.
REFERENCE
PDM 01-04-10: Safety: Work Permits (Link to PDM)
PDM 03-23-03: Safety & Environmental - Personal Safety: Air Testing and Monitoring
PDM 01-04-20: Safety: Area Classification Drawings
ASSOCIATED DOCUMENTS
P&D Gas Testing Log (0302F09)
DEFINITIONS
Bump Test
A bump test is defined as a brief exposure of the gas detector to a concentration of gas
(es) in excess of the lowest alarm set-point for each sensor for the purpose of verifying
sensors and alarm operation. It is not intended to be a measure of the accuracy of the
instrument. The test gas is only applied long enough to check the alarms and the sensor
heads are responding.
Calibration
Calibration is performed using a certified concentration(s) of calibration gas(es) to
ensure maximum accuracy.
Competent Gas Tester
A competent gas tester has documentation to show that they:
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1) have completed appropriate gas detection training,
2) have completed training on the particular device they are operating and,
3) understand the requirements of the Safe Work Permit.
ESD
Emergency Shutdown
Function Test
A function test is defined as an exposure of the gas detector to a concentration of
gas(es) to check sensor and alarm operation and the accuracy of the sensors against the
calibration gas. This takes longer than a bump test as the sensors are allowed to
stabilize before taking the readings.
Non-Electronic Sensor Equipment
Equipment that does not have electronic sensors and does not have audible or visual
alarms. This includes equipment such as detector tubes, etc.
LEL
Lower Explosive Limit
Zero (Fresh Air) Calibration
This determines the zero point of the sensor calibration. This test uses bottle "fresh air"
or clean ambient air.
PROCEDURE
General Requirements

Only a competent gas tester is qualified to perform gas testing.

Gas detectors must be calibrated:
o At a frequency more often than or equal to manufacturer’s specifications but
in no case longer than one month and,
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Work Control Procedures
Standards for Contractor Gas Testing
o Upon failure of a bump or function test
o Using the correct test gas for work on Owner sites:

Gasoline vapor LEL will not be read properly by a detector
calibrated with an incorrect test gas.

Calibration gases used for checking the LEL testing equipment must
be Hexane or Pentane. Alternatively, a “pentane equivalent” using
methane calibration gas with concentration levels equivalent to
pentane can be used where specified by the manufacturer. Refer to
manufacturer instructions for selection of one of these calibration
gases and how to change settings, if required.

Follow manufacturer instructions for the selection and use of all
other calibration gases required.

H2S detectors cannot be used for LEL detection and vice versa.

Gas detectors must be inspected and bump tested daily when in use.

Gas detectors are to be zeroed in a fresh air environment prior to each use.

Personal monitors, e.g., H2S monitor, must be bump tested at least once per month.
Minimum Gas Testing Equipment Set Points
Contractors must be aware that P&D may have more stringent gas testing set points
than provincial regulations call for. Link to PDM 03-23-03 Air Testing & Monitoring
for the current set points for portable gas-detection equipment used on P&D work sites.
Minimum Training Requirements
Individuals are qualified to do air quality testing or personal monitoring on specific gas
detection equipment if they have received training through either:
 An industry-recognized gas testing course or,
 Internal training on gas detection principles and,
 follow-up refresher training every 5 years.
Internal training where a specific course is not available must cover the following
areas:
 Understanding characteristics of hydrocarbons, toxic gases including explosive
mixtures, terminology such as Lower Explosive and Upper Explosive Limits,
Occupational Exposure Limits, etc.;
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SUBJECT 18:






Able to select the appropriate test equipment for the job or type of gas being
measured;
Understanding operations and limitations of gas detection equipment;
Understand and able to perform bump and function testing using calibration gas
and must be able to zero the detector;
Understanding and be able to determine when the gas detector requires
calibration;
Understand responsibilities of a gas tester, and;
Individuals performing testing on Owner sites should also be familiar with
PDM 03-23-03 – Air Testing and Monitoring.
Competent Gas Tester
A Contractor deems the competency of their worker(s) who perform gas testing and
must be able to demonstrate the worker has been trained and deemed competent.
Where gas or air-quality tests are required for a Work Permit, a competent gas tester
will include the type of test, frequency, time and result of each test on the Safe Work
Agreement. Further test results must be kept on a form similar to the P&D Gas Testing
Log 0302F09 P&D Gas Testing Log (0302F09).
A competent gas tester must be able to perform gas tests when:
 Oxygen content might be less than 19.5 % (percent) or more than 23%;
 Work involves an ignition source in a classified area;
 Toxic gases or materials might be present; and/or,
 Work involves entering a confined space.
Competent gas testers must effectively monitor air quality for all gases and toxic
materials to lower risk during critical work. Effective monitoring includes making sure
that the air quality remains the same during the job as when the initial gas test was
done.
Continuous Sampling Detectors
Continuous sampling detectors draw a sample into the detector and are most useful for
the following work:
 Pipeline maintenance work (e.g. checking open piping for LEL's, working
with excavations where there is suspected hydrocarbons);
 Confined space entry work (e.g. an excavation with hydrocarbons present);
 Checking out an area prior to utilizing potential ignition sources that are not
controllable (e.g. arcs and sparks while welding in a classified area).
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Standards for Contractor Gas Testing
When using sample pump units with sample hoses, allow at least 1 second per foot of
hose for sampling time
Monitors
Monitors are passive devices that must be located where the air quality needs to be
checked. They will not detect gas vapours that are not in the area that is being tested.
Monitors are acceptable for the following uses:
 Personal monitoring for oxygen, LEL's, H2S and CO2 toxic gases,
 Ambient air monitoring,
 After an area has been checked with a continuous sample draw detector,
 During critical work that requires continuous gas monitoring,
 Monitoring for gas while utilizing a non-explosive proof device (e.g.
camera, cell phone) in a classified area where the ignition source is
controllable.


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Contractor Safety Program – Pipelines and Distribution Edition
Work Control Procedures
Short Service Workers
PURPOSE AND SCOPE
The proper identification and management of:

new or inexperienced workers,

new-to-task workers,

new-to-site workers;
is a key component of an effective contractor safety management program. Two of the most
important factors in preventing new worker injuries are training and supervision. The purpose of this
document is to outline minimum program requirements for Short Service Workers (SSWs).
The visibility of SSWs in the field is an important element of the procedure. Other workers must be
able to easily recognize SSWs and provide quality support and guidance.
Contractors must have a program in place that meets the intent of this Work Safety Procedure.
ASSOCIATED DOCUMENTS
App 35: SSW Day 1 Checklist template (Part A)
App 36: SSW Graduation Checklists template (Part B, C & D)
DEFINITIONS
Short Service Worker (SSW):
A worker who meets the following requirements must enter the Short Service Worker
program:

less than 6 months of relevant work experience;

is not competent in the tasks they have been hired to perform;

has not worked on Imperial Oil operations/field site within the past 24 months.
A worker is no longer a SSW when they have demonstrated to their supervisor their
knowledge and skills with regards to safe working practices, the tasks they have been hired
to perform and personal, task and site hazards.
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Short Service Workers
The SSW has up to 6 months to achieve competency in all the areas.
The SSW program does not apply to accompanied personnel that are observing only, or to
low risk (Level 4) classified work, such as clerical, delivery, engineering support, office
equipment repair, technical consultants.
Mentor/Coach:
A designated person(s) who is responsible and accountable for guiding and monitoring the
performance of the SSW in the field. The Mentor/Coach:

is an employee of the Contractor company for which the SSW is working unless
documented otherwise at the work-site,

is a member of the same working team and providing direct supervision,

can be the SSWs Supervisor or Foreperson but does not have to be,

has demonstrated knowledge and skills with regard to site and task related hazards,
hazard management, and safe working practices and is able to communicate with
the SSW,

demonstrates Safety Leadership skills at all times,

receives appropriate training and is approved for the role by their management.
Direct Supervision:
As defined by Alberta law, direct supervision means that a competent worker:

is personally and visually supervising the worker who is not competent and,

is able to communicate readily and clearly with the worker who is not competent.
Competent Worker:
Contractors must have a means to document that their supervisors, mentors and workers are
competent. Competency as defined by Ontario & Alberta law:

COMPETENT PERSON means a person who is qualified because of knowledge,
training and experience to organize the work and its performance; is familiar with
the Occupational Health and Safety Act and the regulations that apply to the work;
and has knowledge of any potential or actual danger to health or safety in the
workplace.
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Short Service Workers

COMPETENT WORKER in relation to specific work, means a worker who is
qualified because of knowledge, training and experience to perform the work; is
familiar with the Occupational Health and Safety Act and with the provisions of the
regulations that apply to the work; and has knowledge of all potential or actual
danger to health and safety in the work.

Skilled trades may have slightly different or additional requirements that may need
to be addressed (4 years of apprenticeship).
IDENTIFYING SHORT SERVICE WORKERS
SSWs must be identifiable in the field by clear visual means. P&D recommends the use of the
color green in the form of a hard hat, an armband, or a hard hat sticker.
BASE KNOWLEDGE AND SKILLS OF SSW
SSW programs are intended to assist young and/or new workers in a manner similar to
apprenticeship programs. SSWs cannot work without direct supervision until:

they are competent to do the work they have been assigned, and

they have the site-specific safety training and safety tools required to ensure they
are able to recognize hazards to themselves and others.
ROLE OF CONTRACTOR COMPANY
Contractors are responsible for their workers by ensuring their competency and safety. The
Contractor must have a documented means of evaluating SSWs' comprehension of both
aspects. While working for the Owner the Contractor shall have a Short Service Worker (SSW)
program that addresses management of their SSWs consistent with the information in the
Associated Document templates listed. The intent of the program is that:

The Supervisor of the SSW shall be responsible for each SSWs competency, safety
behaviour, and performance.

The Contractor shall provide appropriately trained Mentor/Coach personnel to guide
the SSWs safety behaviour throughout the work shift. They shall be responsible for a
maximum number of SSWs depending on the potential hazards and nature of the task,
for example:
 Some civil work, such as hand-digging a ditch, may have one Mentor/Coach for
10 SSWs,
 For some higher risk trade tasks it may not be appropriate to have any SSWs,
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Contractor Safety Program – Pipelines and Distribution Edition
Work Control Procedures
Short Service Workers
TITLE
SECTION 04:
SUBJECT 19:

Major projects will typically have higher numbers of SSWs. Extra resources and
activities may be needed to provide adequate supervision, coaching, and
counselling. These considerations shall be included in the project safety plan.

A list of SSWs shall be maintained by the contractor. Program entry date, assigned
mentor, training plans, Graduation criteria and Supervisor sign-off shall be clear and
documented.

The Contractor shall limit the number of SSWs on site as much as practical:
 Special measures shall be implemented by the Contractor company and
endorsed by the Owner when the ratio of SSWs exceeds 50% of the workforce.
Examples of such special measures may include:
o Documented SSW risk mitigation plan;
o Deploying extra trained resources (both Contractor and/or Imperial Oil)
to provide the degree of supervision required;
o Providing more comprehensive orientation/training for a "core group" of
Contractor personnel. This "core group" can be graduated in a timely
manner prior to the mobilization of the workforce on the site;
o Intensive interaction with SSWs, such as through frequent safety
observations and interventions.
ROLE OF OWNER BUSINESS UNIT AND SITE MANAGEMENT
Project Managers and Site Managers (or designates):

Consider special measures to guide contractors without SSW programs or with a short
presence on site, such as providing full time supervision or an approved General
Service Provider supervisor.

Verify that contractor's work planning and scheduling process includes:
 A Mentor/Coach for each SSW and in a ratio that makes sense for the work,
 If the crew ratio is more than 50% SSWs, endorse the contractors SSW risk
mitigation plan:
o Managers will gain a better grasp of the situation by asking to review the
contractors graduation requirement checklist for each SSW. This will
help them to be better able to put a proper SSW RMP solution in place;
o Managers discovering work crews in the field that do not have the
proper ratio and accompanying SSW RMP in place, should:
 stop the work
 notify the contractor
 request a Near Loss Investigation for first time infraction
(nonconformance for further infractions) and forward for
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TITLE
SECTION 04:
SUBJECT 19:
Contractor Safety Program – Pipelines and Distribution Edition
Work Control Procedures
Short Service Workers
IMPACT entry. The solutions should reflect what must be done
to continue the work.

Provide an occasional spot check/review of SSWs working on site. Managers can use
the above Associated Document: SSW Day 1 Checklist as a guide to what kind of
questions should be asked of SSW's. It is not an expectation that the checklist is
completed, just used for reference. Contractors must use the Associated Documents or
similar to document their worker requirements.

Provide an occasional spot check/review of graduated SSWs, that they understand and
can discuss the requirements listed in the SSW Graduation Checklists (same as above:
use the checklist as a guide, it is not required as site documentation).

Request contractor remove a worker that does not have appropriate SSW training
documentation or is not meeting safe working intentions; request a Near Loss
Investigation for first time infraction; forward for IMPACT entry.
The BU / CSA shall:

Utilize Contractor Management System meeting processes and associated
scorecard/stewardship tools to monitor and steward performance in the field, with
particular focus on:
 Endorsing Contractor companies' Short Service Worker (SSW) program and
plans,
 Contractor SSW program documentation.
SPECIAL SITUATIONS/WAIVERS/DEVIATIONS
Temporary waivers from the elements in this SSW practice can be granted by Imperial Oil
BU/Site management if compensating measures are taken such that SSW risks are
appropriately managed. This includes when Short Term Contractors, are on site for short
durations such that the SSW program cannot be fully implemented.
Plans to permanently deviate from the elements in this practice require approval of the IOL
Pipelines and Distribution Manager.


RETURN TO INDEX
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TITLE
SECTION 05:
SUBJECT 01:
Contractor Safety Program – Pipelines and Distribution Edition
Continuous Improvement and Performance Review
Contractor Evaluation
PURPOSE AND SCOPE
The Contractor Evaluation process is described in the PDM (Pipeline & Distribution
Manual) via the following link:
Contractor Evaluation (Link to PDM)

RETURN TO INDEX
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P&D 05.01 Contractor Evaluation
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Pipelines and Distribution
Safety, Security, Health and Environment
Contractor Safety
Program
For Imperial Use Only
Copyright  by Imperial Oil Limited
All rights reserved. No part of this document may be reproduced, stored in a retrieval system, or
transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or
otherwise, without the prior written permission of Imperial Oil.
This document is the sole and exclusive property of Imperial Oil.
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